66 FR 64950, December 17, 2001 A-580-834 ARP: 01/04/99 - 06/30/2000 Public Document IA/III/IX: LRL/CB/SS December 6, 2001 MEMORANDUM TO: Bernard T. Carreau Acting Assistant Secretary for Import Administration FROM: Joseph A. Spetrini Deputy Assistant Secretary for Import Administration, Group III SUBJECT: Issues and Decision Memorandum for the Administrative Review of Stainless Steel Sheet and Strip in Coils From the Republic of Korea for the Period of Review ("POR") January 4, 1999 through June 30, 2000 ------------------------------------------------------------------------ SUMMARY: We have analyzed the case and rebuttal briefs of interested parties in the 1999-2000 administrative review of the antidumping duty order of stainless steel sheet and strip in coils from the Republic of Korea. As a result of our analysis, we have made changes from the Notice of Preliminary Results and Partial Recission of Antidumping Duty Administrative Review for Stainless Steel Sheet and Strip in Coils From the Republic of Korea, 66 FR 41530 (August 8, 2001) ("Preliminary Results"). The specific calculation changes for Pohang Iron & Steel Co., Ltd. ("POSCO") can be found in Analysis for the Final Results of Review of Stainless Steel Sheet and Strip from the Republic of Korea: Pohang Iron & Steel Co., Ltd. ("POSCO Final Analysis Memorandum"), December 6, 2001. The specific calculation changes for Daiyang Metal Co., Ltd. ("DMC") can be found in Analysis for the Final Results of Review of Stainless Steel Sheet and Strip from the Republic of Korea: Daiyang Metal Co., Ltd. ("DMC Final Analysis Memorandum"), December 6, 2001. The specific calculation changes for Samwon Precision Metals Co., Ltd. ("Samwon") can be found in Analysis for the Final Results of Review of Stainless Steel Sheet and Strip from the Republic of Korea: Samwon Precision Metals Co., Ltd. ("Samwon Final Analysis Memorandum"), December 6, 2001. We recommend that you approve the positions we have developed in the "Discussion of the Issues" section of this memorandum. Below is the complete list of the issues in this administrative review for which we received comment and rebuttal briefs by interested parties. A. Issues with Respect to POSCO Comment 1: Indirect Selling Expenses for Pohang Steel America Corporation ("POSAM") Comment 2: Unrecognized Bad Debt Comment 3: Duty Drawback Comment 4: Export Warranty Expenses Comment 5: General and Administrative ("G&A") Expense Calculation Comment 6: Scrap Costs Comment 7: Affiliated-Supplied Inputs Comment 8: L-Grade Adjustment Comment 9: Energy Costs Comment 10: Financial Expenses Comment 11: Home Market Credit Comment 12: Programming Error with Respect to U.S. Indirect Selling Expenses Comment 13: Imputed Credit Expenses in the Calculation of Indirect Selling Expenses Comment 14: Deferred Foreign Exchange Losses in the Calculation of G&A B. Issues with Respect to DMC Comment 15: Indirect Selling Expenses Comment 16: G&A Expenses Comment 17: Marine Insurance and U.S. Inland Freight Comment 18: Commission Offset for DMC Comment 19: Ocean Metal Corporation's ("OMC") Indirect Selling Expense Ratio Comment 20: Short-Term Borrowing Rate in the Home Market Comment 21: Ministerial Errors C. Issues with Respect to Samwon Comment 22: Use of Partial Facts Available Comment 23: Use of a Single Weighted-Average COP Changes Since the Preliminary Results Based on our analysis of comments received, we made changes in the margin calculation for POSCO. The changes, which were made to POSCO's programs alone, are listed below: •We adjusted POSCO's reported costs to include an amortized portion of its deferred foreign exchange losses. • We adjusted POSCO's reported foreign exchange ratio to include gains and losses associated with cash, accounts payable, "other" accounts, and loans payable in the numerator. • We reversed our position on affiliated party inputs from the preliminary results and, for these final results, we are not making an adjustment to POSCO's costs for affiliated party inputs. • We revised the calculation of POSCO's per-unit G&A expense to apply POSCO's G&A ratio to the sum of the revised cost of manufacturing plus packing. • We calculated an adjustment for warranty expense and included it as an adjustment to U.S. price. • We have recalculated home market credit for POSCO's U.S. dollar home market sales using POSAM's U.S. dollar interest rate instead of POSCO's Korean won interest rate. • We have recalculated POSAM's indirect selling expenses to adjust the amount of interest expense applicable to U.S. sales of subject merchandise and to take into account an offset for imputed credit. • We have revised our calculations to deduct U.S. indirect selling expenses from U.S. starting price rather than add them. • We have revised the total cost of production included in both our cost and constructed value calculations to include interest expenses ("INTEX"), which were erroneously omitted from the calculation in our preliminary results of review. We made no changes to Daiyang's or Samwon's calculations for the final results of review. II. DISCUSSION OF THE ISSUES A. ISSUES WITH RESPECT TO POSCO Comment 1: Indirect Selling Expenses for POSAM Petitioners claim that POSCO significantly understated the indirect selling expenses incurred in the United States by POSAM, its wholly-owned selling arm in the United States. Petitioners claim that, although the denominator in the indirect selling expense ratio calculation reflects the total value of sales reported on POSAM's consolidated financial statements, the numerator reflects the expenses listed on POSAM's unconsolidated financial statements and thus, omits certain selling, general and administrative ("SG&A"), interest, and other expenses attributable to sales of the subject merchandise in the U.S. market. Furthermore, petitioners contend that the expenses reported in the questionnaire response significantly understate the selling expense ratio reported on POSAM's audited financial statements for fiscal year 1999. Consequently, petitioners propose that the Department adjust POSAM's indirect selling expenses upward to account for the expenses omitted in POSCO's calculation. POSCO contends that POSAM provided both the total value of indirect selling expenses and the total value of sales in the United States on the basis of its unconsolidated financial statements, and did not mix information from the consolidated and unconsolidated balance sheets to determine the numerator and denominator of the indirect selling expense ratio, as claimed by petitioners. POSCO argues that the adjustment for selling expenses is governed by section 772 of the Act, which, according to POSCO, defines indirect selling expenses as the general expenses of the company involved in selling the subject merchandise during the period of review. POSCO argues that this definition demands that indirect selling expenses must be reasonably attributed to sales of the subject merchandise in order to be included in the reported deductions for antidumping duty purposes. As a result, POSCO argues that the indirect selling expense ratio should be based on the expenses and sales of the party actually selling the merchandise during the period of review. POSCO contends that in this review, POSAM was the entity responsible for sales of subject merchandise in the United States and that neither of its two consolidated subsidiaries have had any involvement in the sale of the subject merchandise. As a result, POSCO argues that all of the expenses incurred for selling the subject merchandise in the United States are recorded in the unconsolidated financial statements. Therefore, POSCO contends that it properly reported its indirect selling expenses based on POSAM's unconsolidated financial statements, as it did in the original investigation. POSCO argues that petitioners' proposed indirect selling expense ratio is unreasonable because the Section A response and verification report document that only one person at POSAM is involved in the sale of subject merchandise. Consequently, according to POSCO, it is not plausible that POSAM's indirect selling expenses could be higher than POSCO's indirect selling expense ratio in the home market. Accordingly, POSCO argues that the Department has no basis for changing the methodology used to calculate U.S. indirect selling expenses in the preliminary results of review. Department's Position: We agree with POSCO. We note that POSCO derived its reported U.S. indirect selling expenses entirely from POSAM's unconsolidated financial statements. Petitioners' contention that POSCO mixed the information used to derive the numerator and denominator in its calculation of the indirect selling expense ratio from the consolidated and unconsolidated financial statements is not supported by information on the record. Although the total value of sales reported in exhibit 21 of POSCO's November 6, 2000 Section C response, and exhibit 24 of POSCO's January 16, 2001 supplemental section C response ties to the consolidated financial statements reported in exhibit 15 of POSCO's October 3, 2000 section A response, it also ties to POSAM's detailed profit and loss statement provided in sales verification exhibits ("SVE") 9A and 9B. These exhibits show that all of POSAM's sales income reported on the consolidated financial statements was derived from the sale of steel products and not from the income produced by either of POSAM's subsidiaries which do not sell steel products. Furthermore, there is no other evidence on the record showing that the total reported value of sales is inflated. We disagree that POSCO omitted any selling expenses applicable to sales of the subject merchandise during the POR, simply by calculating its indirect selling expenses on the basis of its unconsolidated financial statements. Neither of POSAM's two wholly-owned subsidiaries in the United States sold the subject merchandise during the POR. All of POSAM's reported selling expenses reconcile to POSAM's audited financial statements provided in exhibit 24 of POSCO's January 16, 2001 supplemental section C response. Finally, we disagree that POSCO was remiss by not reporting any of the specific proprietary expenses identified in petitioners' September 17, 2001 case brief, simply because they were lower than the expenses reported on the consolidated financial statements. As POSCO noted in its case brief, POSAM is the entity exclusively charged with selling POSCO's steel in the United States, and neither of its two other subsidiaries sold subject merchandise during the period of review. Consequently, we are making no changes to our calculation of POSCO's U.S. indirect selling expenses for the final results of review. Comment 2: Unrecognized Bad Debt Petitioners argue that the Department inappropriately failed to account for POSAM's unrecognized bad debt expenses derived from sales that were made in 1997 during the period of the original investigation. Petitioners note that, in response to instructions from the World Trade Organization ("WTO") dispute settlement panel, the Department issued an amendment to the final determination of sales at less than fair value in the original investigation without revising its calculations to account for bad debt attributed to sales that were made during the period of investigation. Petitioners allege that these sales have never been paid for, and that POSCO has not acknowledged bad debt attributed to them in any of POSAM's audited financial statements issued since the original investigation. Furthermore, petitioners allege that, in 1999, in the final results of the original investigation of stainless steel plate in coils from Korea, POSCO stated that it still expected to be paid for these sales, despite the fact that it had reversed the sales (thus acknowledging a loss) in its books and records by issuing negative invoices to the customer for the unpaid merchandise, effectively classifying the sales as a type of bad debt. Petitioners contend that since POSCO still expected payment in 1999, the loss should be recognized in this review as an expense incurred in 1999 and expressed as a percentage of total sales of subject merchandise in the United States during 1999. Alternatively, petitioners propose that the Department allocate the total amount of the bad debt incurred in 1997 to POSCO's sales of subject merchandise during the period of review ("POR"). Petitioners claim that this would be conservative in that it allocates the bad debt expense attributed to fiscal year 1999 to stainless steel flat product sales during the entire 18-month POR - a period which is longer than the fiscal year. However, if this outcome is not acceptable to the Department, petitioners allow that the most conservative and absolute minimum alternative adjustment would be to add the stainless flat product-related bad debt expense to POSAM's overall general expenses. POSCO contends that the Department verified (and the WTO Panel confirmed), that the bankrupt sales referenced by petitioners were written off within the period of the original investigation, at year-end 1997, and that there was no bad debt recorded on POSCO's financial statements for the POR. Consequently, POSCO argues that these sales bear no relationship to the current administrative review period of January 4, 1999 through June 30, 2000. Furthermore, POSCO contends that all of POSAM's indirect selling expenses were reported in this review, and bad debt was not among them. Consequently, POSCO maintains that the Department has no basis to attribute any alleged costs associated with the bankrupt sales written off in 1997 to the current administrative review. Department's Position: We agree with POSCO's assertion that the bankrupt sales at issue were written off within the period of the original investigation, at year-end 1997, and that there was no bad debt recorded in POSAM's audited financial statements during the period of review. Therefore, because these expenses were incurred prior to the period of review, we have no basis for including bad debt arising from 1997 sales in our margin calculation. Therefore, we made no changes to our calculation for the final results of review. Comment 3: Duty Drawback Petitioners contend that POSCO did not demonstrate that it met the Department's two-pronged test to determine whether an upward adjustment to export price for duty drawback would be warranted. Petitioners explain that this test specifies that: first, the import duty and rebate be directly linked to, and dependent on, one another; second, POSCO must demonstrate that there were sufficient imports of the imported material to account for the duty drawback received for the export of the manufactured product. Petitioners claim that POSCO did not demonstrate that the import duty and rebate are directly linked to, and dependent on, one another, but simply allocated a particular duty refund amount to a particular U.S. sale. In addition, petitioners contend that POSCO failed to demonstrate that the reported duty drawback amount was supported by sufficient imports of the imported material, and instead assigned specific refunds to U.S. sales. Petitioners contend that the amounts reported in POSCO's questionnaire response do not indicate that there were sufficient import duties paid to account for all of the rebates granted upon export of the subject merchandise. Finally, petitioners contend that POSCO failed to demonstrate that reported drawback amounts represent a proper allocation of all drawback amounts received for all exports of products that used the imported materials. Therefore, petitioners contend that the Department should deny POSCO's claimed duty drawback adjustment. POSCO claims that it received duty drawback on all exports of the subject merchandise to the United States during the POR. POSCO explains that it filed applications with the Korean Customs authority, which predicate the drawback amount on direct links between specific exports and the import licenses evidencing importation of duty-paid raw materials suitable for the manufacture of the exported good. POSCO notes that companies are required to provide supporting documents which demonstrate the amount of duty paid for the quantity of imported raw material used to manufacture the exported finished product. POSCO then calculated the total amount of drawback applicable to each sale on a contract-by-contract basis. POSCO claims that the Department has verified in numerous proceedings, including this one, that the Korean duty drawback system effectively limits the amount of drawback to the amount of duties actually paid on raw material imports. Thus, POSCO claims that the Korean duty drawback system meets the requirements for an adjustment to U.S. price pursuant to 19 U.S.C. § 1677b and the Department's traditional two-part test. POSCO further argues that neither Korean Customs law nor the Department's practice requires POSCO to demonstrate that a particular import of raw material was physically linked to a specific, exported finished product in order to obtain the duty drawback adjustment. POSCO contends that the duty drawback application provides a demonstrated link between imports of raw materials and finished exports. Finally, POSCO argues that the Department verified POSCO's reported duty drawback amounts in detail at verification and found no discrepancies. Consequently, POSCO claims that petitioners have failed to establish a basis upon which years of precedent should be discarded. As a result, POSCO argues that the Department has no basis to disallow POSCO's duty drawback adjustment in this review. Department's Position: We agree with POSCO. The Department has verified duty drawback in Korea numerous times, and has confirmed that the Korean duty drawback program satisfies both requirements of the Department's two pronged test. (For the Department's two-pronged test, see Investigation of Steel Wire Rope from India, Issues and Decision Memorandum from Notice of Final Determinations of Sales at Less Than Fair Value: Steel Wire Rope From India and the People's Republic of China; Notice of Final Determination of Sales at Not Less Than Fair Value: Steel Wire Rope From Malaysia, 66 FR 12759 (February 28, 2001).) The Korean government requires companies to demonstrate the quantity of imported inputs used in the production of subject merchandise, the applicable duties assessed upon those imports, and the total quantity of exported merchandise to obtain a duty drawback. In addition, the Korean government determines for each exported product, the allowable usage rate of each input subject to duties. The government then requires companies to demonstrate that they have imported a sufficient quantity of the inputs to account for the amount of duty drawback applied for and no additional duty drawback. During the verification of this review, we tested the duty drawback applicable to both export sales and local letter of credit ("local l/c") sales. See pp. 24, 30 and 31 of the SVR. We examined the full range of documents which demonstrate both the requirements of Korea's duty drawback program and POSCO's application. We traced the drawback amounts to proof of payment, and found no discrepancies. Consequently, we have accepted POSCO's duty drawback claim and made no changes to our calculation for the final results of review based on duty drawback. Comment 4: Export Warranty Expenses Petitioners contend that the Department's SVR demonstrates that POSCO could not tie its warranty expense worksheet to its financial statements, and could not resolve discrepancies with respect to its claim that it incurred no warranty expenses during the POR. Petitioners argue that the Department should allocate the amount paid and the "unresolved discrepancy" amount to U.S. sales during the POR even if the payments originated from claims on sales made prior to the POR. Petitioners claim that, since warranties, by definition, are incurred after a sale takes place, such expenses are properly attributed to the sales in the period in which the warranty expenses are acknowledged on the company's books and records. POSCO claims that it did not incur any warranty expenses on U.S. sales of subject merchandise during the POR. POSCO contends that petitioners misconstrue the Department's verification report when they request that the Department should allocate an amount that had been paid to a U.S. customer during the POR to U.S. sales in the POR. POSCO contends that the Department's verification report clearly states that the above-referenced warranty claim was "acknowledged during 1999 for a U.S. sale that occurred prior to the POR in sheet." Therefore, POSCO argues that since the warranty claim was not associated with sales of subject merchandise during the POR, the Department should dismiss petitioners' arguments. POSCO further claims that the expenses which petitioners claimed represented an "unresolved discrepancy" had no relationship to U.S. sales of subject merchandise during the POR. POSCO claims that the Department reviewed detailed documentation regarding POSCO's warranty claims at verification and determined that "no warranty expenses were recorded at all for the sheet case." Finally, POSCO contends that the alleged discrepancy amount, expressed as a percentage of POSCO's total export sales of stainless steel products was negligible. POSCO argues that the expenses were acknowledged during the POR for sales that occurred prior to the POR, and should be attributed to the period in which the sales were made, and therefore, no adjustment is warranted. Department's Position: We disagree with POSCO. As documented in the sales verification report, we found that POSCO paid substantial warranty claims for stainless steel products sold in the United States during the two year period prior to the POR. We determine that the actual POR warranty expenses, which were reported as zero in POSCO's response, are unrepresentative of the actual warranty expenses POSCO is likely to pay for sales during the period of review, based on its historical record of warranty claims. Therefore, in accordance with section 772(d) of the Act and section 351.402(b) of the regulations, we made an adjustment for warranty claims for the POR by dividing the total stainless steel warranty claims reported in SVE 41, which was for fiscal years 1997, 1998, and 1999, by the total U.S. stainless steel sales value reported for the corresponding time period. Since this amount includes the "unresolved discrepancy" above, we made no further adjustments for that discrepancy. This methodology is reasonable because it is based on POSCO's historical experience for warranty expenses for its stainless steel products. See NSK Ltd., v. Koyo Seiko, 190 F. 3d. 1321, 1332 (Fed. Cir. 1999). The amount of the warranty expense adjustment is reported in the POSCO Final Analysis Memorandum. Comment 5: G&A Calculation Petitioners argue that the Department should: (1) include the inventory valuation loss discovered at verification in POSCO's G&A expense; (2) recalculate the G&A ratio on a packing-inclusive basis in order to neutralize the packing-inclusive denominator used to calculate the ratio; and (3) disregard the miscellaneous income as unrelated to production of the merchandise under investigation. POSCO argues that the inventory loss was included in the G&A expense ratio and the Department's cost verification report mistakenly indicated that POSCO did not include the inventory valuation loss in its reported G&A ratio. POSCO points out that including the loss again would be double- counting an expense. In regard to the petitioner's request to recalculate the G&A ratio based on the packing-inclusive basis, POSCO did not dispute this suggestion. However, POSCO noted that the impact of this adjustment is negligible and that the ratio remains the same. Regarding the petitioner's comment on POSCO's miscellaneous income, POSCO argues that the Department obtained and examined the details of the miscellaneous income reported on POSCO's audited financial statements, noted no unusual items, and established that this income was associated with production, and was therefore, correctly included in the reported G&A. Department's Position: We agree with POSCO that the inventory loss was included in the G&A expense applied to the reported COPs and constructive values ("CVs"). See Cost Verification Exhibit 32. We further agree with POSCO that the miscellaneous income that it included in the G&A expense should continue to be allowed, because, contrary to petitioners' assertion that miscellaneous income must relate to the production of the merchandise under investigation, the Department includes miscellaneous income even if it relates to the general operations of the entity. As long as the miscellaneous income or expense item represents a general business expense item, and is not a separate line of business, then it is appropriately classified as a G&A item. See U.S. Steel v. U.S., 998 F. Supp. 1151 (CIT 1998). Finally, we agree with petitioners that because the denominator in the G&A expense ratio includes packing, the G&A rate should be applied to the COP with packing included. Therefore, for the final results of review, we have applied the G&A rate from the Preliminary Results to the COP, plus packing. Comment 6: Valuation of Re-Introduced Scrap Petitioners point out that POSCO's reported costs should be adjusted to reflect the variances from standard scrap costs as POSCO's valuation of re- introduced scrap is understated. POSCO argues that the Department confirmed that the variances between the standard and actual costs were included in the reported costs through the numerous reconciliations and cost build-ups performed during the course of the verification, and that the Cost Verification Report ("CVR") indicated that there were no disparities between the standard and actual cost valuation. POSCO continues that petitioners are incorrect that "re- introduced scrap value was understated". POSCO points out that the Cost Verification Exhibit ("CVE") 16 illustrates that re-introduced scrap was properly valued. POSCO adds that it applied the same value for recovered and re-introduced scrap. As evidence, POSCO notes that the credit for recovered scrap is the same as the cost of the reintroduced scrap. Therefore, POSCO contends that no adjustment should be made. Department's Position: We agree with POSCO that the variances were included properly in the reported costs. Furthermore, we note that the Department reconciled the reported costs to POSCO's books and records and found no unaccounted items. We also agree with POSCO that petitioners are incorrect as to the re-introduced scrap issue. When POSCO recovers scrap metals from its production process, it credits the cost of production for the recovered amount, using a conservative estimate of the market price of the scrap. This, in turn, slightly overstates production costs since more value could have been credited. However, the slight overstatement of production costs is offset when the recovered scrap is re-introduced into the production process because POSCO uses the same conservative estimate of market value to value the re-introduced scrap. Therefore, we have not made the adjustment suggested by petitioners for the final results of review. Comment 7: Cost for Affiliate-Supplied inputs In the Preliminary Results, the Department increased the transfer price of POSCO's purchases of a (proprietary) raw material input from an affiliated party on the basis that the "market price was higher than both the reported transfer price and the affiliate's cost of production." POSCO contends that the Department's adjustment to the reported cost for affiliate-supplied inputs in the preliminary results of review was unjustified as POSCO's transfer costs for affiliate-supplied inputs were identical to its prices from unaffiliated parties. POSCO states that it has emphasized the importance of making accurate, i.e., monthly, comparisons between the per-unit market and transfer prices, as the prices and quantities purchased varied throughout the POR. POSCO asserts that the Department's comparison between the market prices and the transfer prices was faulty since the Department compared the prices based on a total weighted average rather than the month-by-month unit prices. POSCO contends that the Department ignored variation in price and quantity throughout the comparison period and thereby distorted the conclusion. POSCO further questions that the Department's decision to adjust the transfer price was based on a comparison between a weighted- average transfer price from the affiliate to POSCO and a weighted-average price from an unaffiliated supplier. POSCO claims that the unit prices paid by POSCO to the unaffiliated and the affiliated supplier were identical. The only reason the average price used by the Department for comparison varies by supplier is that POSCO purchased different quantities from those suppliers at different times during the POR and when these prices and quantities are weight-averaged together, it appeared that the prices were different. Therefore, POSCO urges that the reported transfer prices must be used in the final results for purposes of calculating material costs. Petitioners argue that the Department properly disregarded POSCO's reported transfer prices. The petitioners state that the Department's comparison methodology is proper because costs in this proceeding have been reported for a specific period of review. Therefore, the analysis of POR weighted average input prices and costs is consistent with the Department's use of POR weighted averages in determining POSCO's costs. Petitioners contend that POSCO should not be permitted to pick the calculation of prices based on what generates the most preferable results in the Department's analysis. Petitioners state that the Department appropriately adjusted POSCO's transfer price to reflect the purchase price more accurately. Petitioners further contend that POSCO's reported transfer and "market" prices are unreliable and the Department should further adjust reported costs to correct for POSCO's improper reliance on transfer prices from affiliates and the "market" price in reporting costs. Department's Position: We agree with POSCO. The verification exhibits show that prices between POSCO and its affiliated supplier were identical to those between POSCO and its unaffiliated supplier for each month. Therefore, these prices offer a better comparison than POR weighted-average input prices and costs due to contemporaneity and identical pricing. See Cost Verification Exhibit 25. We find that only the quantities varied, thus causing the difference in the POR weighted-average price. Therefore, we find that the transfer prices were made at arm's length prices and accordingly have not made an adjustment to the transfer prices for the final results of review. Comment 8: POSCO's L-Grade Adjustment Petitioners argue that POSCO's allocation of costs among "L" and "non-L" grades is inappropriate. Petitioners contend that state that the "L" grade allocation of costs are too high compared to the "non-L" grade considering the differences between them represent an insignificant amount of only one input. Therefore, petitioners urge the Department to recalculate reported costs to eliminate POSCO's "L" grade adjustments. POSCO defends its allocation methodology stating that POSCO made the L- grade adjustment consistent with the methodology in the investigation to comply with the Department's instructions to account for the physical characteristics of the merchandise. POSCO argues that the petitioners' analysis of the differences between the standard products and the L-grade products addresses only the alleged differences in the cost of this input and not the customer requirements which were examined at the sales verification. Therefore, POSCO contends that the L-grade adjustment is necessary to reflect the differences in the merchandise. Department's Position: We agree with POSCO. First, we note that there are significant differences between L and non-L grades of stainless steel. For example, 304L can have as much as 5 percent more of a costly input than the non-L 304. In addition, because steel grades are defined in part by a range of acceptable quantities of the elements included in the grade, the producer can meet a customer's order based on the requested grade specifications, albeit with lower levels of certain elements or may fill an order with a product that has higher than the minimum requirements specified by the customer. When several similar products can be used to fill a customer's order, because all of the products meet the limited set of customer specified characteristics, then it is appropriate for POSCO to report, as POSCO did, the cost of the product actually used to fill the order. The Department's normal practice is to have respondents report unique product costs for each matching control number ("CONNUM") produced (as defined by the product characteristics used for the case). The reported cost of the CONNUM, to which the actual product used to fill the order belonged, is applied in the cost test and CV, not the costs of the theoretical products that could have been used to fill the order. Therefore, we have not made the adjustment suggested by petitioners for the final results of review. Comment 9: Energy Cost Petitioners argue that the Department should ensure that variances between energy costs have been reflected in the submitted costs. POSCO contends that the Department verified that POSCO accounted for all variances in its reported energy costs. Department's Position: We agree with POSCO that the appropriate energy costs were included in the standard cost build-ups and, furthermore, that any difference between standard and actual costs was captured through POSCO's applied variances. See Cost Verification Exhibits 14 and 28-31. Comment 10: Financial Expenses Petitioners argue that the Department should recalculate POSCO's reported financial ratio to omit offsets for estimated short-term income and gains from foreign-denominated debt to the extent the reported gains constitute estimates. Petitioners state that only actual short-term income and eligible foreign exchange gains should serve as an offset. POSCO argues that its adjustments for short-term interest income and foreign exchange gains are the actual amounts. POSCO states that its consolidated financial statements do not segregate interest income between short and long term, nor do they split exchange gains and losses into different categories. So, in accordance with the methodology applied and accepted in all other cases in which POSCO has participated, POSCO used the actual experience on an unconsolidated basis to split the actual amounts on the consolidated statements into the relevant categories. For above reason, POSCO contends that no additional adjustments need be made to POSCO's financial expenses. Department's Position: We agree with POSCO. Because of the difficulties in obtaining the details of short-term interest income across all its consolidated companies, we find it reasonable in POSCO's case to use the unconsolidated financial statements and records of POSCO (i.e., the respondent/producer) to estimate the amount of short-term interest income. We note that POSCO is by far the largest of the consolidated companies and can reasonably be presumed to represent the bulk of any short-term interest income in the consolidated entity. Therefore, for the final results of review we have continued to include POSCO's off-set for short-term interest income. Comment 11: Home Market Credit Petitioners contend that the Department should recalculate home market credit on dollar- denominated sales to reflect POSCO's dollar, rather than won, interest rate. POSCO contends that it did not have any U.S.-dollar borrowings during the POR, and that it does not object to the Department's use of POSAM's U.S.-dollar rate for local l/c sales in dollars in the final results of review. Department's Position: We agree with petitioners and POSCO. Policy Bulletin 98.2 states that "for the purposes of calculating imputed credit expenses, we will use a short-term interest rate tied to the currency in which the sales are denominated. We will base this interest rate on the respondent's weighted- average short-term borrowing experience in the currency of the transaction." Therefore, we will use the interest rate for POSCO's dollar- denominated borrowings to calculate imputed credit for dollar-denominated sales in the home market. Since POSCO did not have any U.S.-dollar borrowings during the POR, we will use POSAM's U.S.-dollar rate to calculate interest for POSCO's dollar-denominated sales in the home market in the final results of review, consistent with the Department's practice. See Final Determination of Sales at Less Than Fair Value; Oil Country Tubular Goods from Austria, 60 FR 33551, 33555 (June 28, 1995). Comment 12: Programming Error with Respect to U.S. Indirect Selling Expenses Petitioners contend that the Department should correct its margin calculation program, which incorrectly added indirect selling expenses to U.S. price rather than deducting them. POSCO agrees with the petitioners' correction. Department's Position: We agree with both petitioners and POSCO and have deducted U.S. indirect selling expenses from U.S. price in our computer program for the final results of review. Comment 13: Imputed Credit Expenses in the Calculation of Indirect Selling Expenses POSCO contends that the Department overstated the amount of interest expenses included in the calculation of U.S. indirect selling expenses by limiting the imputed-credit offset to the amount of imputed credit attributed to sales of subject merchandise as reported on the computer sales listing. Rather, POSCO argues that the imputed-credit offset should represent the amount of imputed credit expenses attributed to financing accounts receivable which includes imputed credit attributable to sales of non-subject merchandise. In addition, POSCO contends that the Department double counts the imputed credit expenses listed on the sales tape by deducting them from U.S. price twice: once in the circumstance of sale adjustment for imputed credit and once in the adjustment for indirect selling expense. POSCO explains that section 351.401(b)(2) of the Department's regulations explicitly prohibits the double counting of expenses. Therefore, POSCO argues that imputed credit expenses should be classified either as direct selling expenses in the imputed credit adjustment or as indirect selling expenses in the indirect selling expense adjustment, but not both in the same review. Furthermore, POSCO contends that we cannot classify them as direct expenses in one review and indirect in another. POSCO contends that the Department further erred in limiting its exclusion of imputed credit expenses to the value of credit expenses attributable to subject merchandise and not to sales of non-subject merchandise as well. POSCO points out that a number of the prior cases, including CIT Court decisions, affirmed POSCO's position that it is appropriate to exclude all of the interest expenses associated with financing accounts receivable from the calculation of indirect selling expenses in the United States. POSCO further maintains that the Department's decision in the final results of the sixth review of flat- rolled steel from Korea (Certain Cold-Rolled and Corrosion-Resistant Carbon Steel Flat Products From Korea: Final Results of Antidumping Duty Administrative Reviews, 64 FR 12927, 12932 (March 16, 1999) ("Flat Rolled - 5") ) and in the preliminary results of this review, to deduct only the imputed credit expenses reported on POSCO's databases, i.e., the direct credit expenses associated with the reported subject sales, is blatantly inconsistent with the requirements of the U.S. antidumping law and with the WTO Antidumping Agreement. Finally, POSCO contends that even indirect selling expenses must be "reasonably attributed" to the sales of subject merchandise in order to be included in an adjustment for antidumping duty purposes. POSCO argues that, even if the imputed credit expenses associated with the non-subject merchandise could be described as indirect selling expenses, POSCO maintains, they could not be reasonably attributed to the sales of the subject merchandise, since they bear no direct relationship to the sales of the subject merchandise. Consequently, POSCO maintains, the Department's decision to include these expenses in calculating indirect selling expenses for this review is distortive and must be corrected in the final results. Petitioners contend that POSCO erroneously claims that the Department's normal practice is to deduct all imputed credit expenses for both subject and non-subject merchandise from U.S. indirect selling expenses and that Departmental practice allows respondents to reduce actual financing costs for the opportunity costs associated with imputed credit expenses on all other non-subject products sold by U.S. affiliates. In contrast, petitioners claim that the Department's policy, set forth in Flat Rolled - 5 is that, under certain circumstances, the Department may consider making such adjustments in calculating indirect selling expenses incurred by U.S. affiliates. Although the Department found it appropriate to exclude interest expenses associated with non-subject merchandise in that review, petitioners claim that there is no policy of automatically reducing constructed export price ("CEP") selling expenses to account for imputed credit expenses. Petitioners note that in the subsequent administrative review of flat rolled, Final Results of Antidumping Duty Administrative Reviews: Certain Cold-Rolled and Corrosion-Resistant Carbon Steel Flat Products From Korea, 66 FR 3540, (January 16, 2001) ("Flat Rolled - 6), the Department found it appropriate to deduct only the imputed credit expenses for subject merchandise from the interest expenses included in POSCO's indirect selling expenses, and explained why it did not do so in previous reviews. Petitioners note that the Department relied on the basic principle that money is fungible and stated that financial indirect selling expenses, such as interest expenses, are allocated to all sales in a particular market "because, regardless of which unit incurred them, they relate to the general financing of the entire corporate entity." Petitioners claim that the Department made clear that "it is our practice to include interest expenses incurred by the U.S. affiliate in the total pool of U.S. indirect selling expenses under section 772(d)(1)(D) of the Act." Moreover, petitioners noted that the Department stated that "the fungibility of money is a basic principle applicable to our treatment of financing indirect selling expenses" and properly determined that "no portion of U.S. interest expenses should be segregated and attributed to non-subject merchandise sales." Petitioners argue that the Department's decision in Flat-Rolled - 6 to deduct only imputed credit expenses for subject merchandise from the total interest expense used to calculate indirect selling expenses is not sudden reversal of practice as claimed by POSCO. Rather, the Department clearly explained that it did not deduct the imputed credit attributable to sales of non-subject merchandise because "after taking into account potential double-counting, there were no or virtually no expenses remaining. Had there been an appreciable amount of U.S. interest expenses remaining, we would have included these expenses in the pool of U.S. indirect selling expenses." Flat-Rolled - 6, Issues and Decision Memorandum at Comment 1. Thus, petitioners argue, the Department's policy has always been not to allow offsets for hypothetical imputed credit expenses of non-subject merchandise in the pool of U.S. indirect selling expenses. Petitioners argue that POSCO's contention that the Department's adjustment constitutes double counting on the grounds that credit expenses are direct selling expenses and direct selling expenses cannot be included in calculating the indirect selling expense ("ISE") ratio is erroneous, since there is no basis for presuming that such imputed credit expenses are necessarily incurred. Petitioners argue, as the Department stated in Import Policy Bulletin 98.2, credit expenses derived from extended payment terms are usually built into the price of the sale. Therefore, petitioners argue that there is no presumptive link between the total value of interest expenses and extended credit policies: companies who grant extended credit terms may incur no borrowing costs, whereas companies that do not grant extended credit terms still incur significant borrowing costs. Petitioners argue that if the Department nevertheless makes an adjustment for imputed credit expenses, the absolute maximum that the Department should deduct is the imputed credit expenses reported in POSCO's U.S. sales database, consistent with the recent final results in Flat-Rolled-6. Petitioners contend that POSCO grossly overstated its imputed credit expenses attributed to sales of subject and non-subject merchandise and the Department should, at most, deduct no more than the actual imputed credit expenses reported in its U.S. sales database. Finally, petitioners contend that an examination of POSAM's proprietary sales information reveals that the basis of POSCO's accounts receivable calculation may not be appropriate as a determinant of accounts receivable financing, as indicated in the analysis memorandum for the preliminary results of review. See Analysis for the preliminary results of stainless steel strip in coils from Korea - Pohang Iron & Steel Company ("POSCO"), July 31, 2001 ("Prelim Analysis Memorandum"). Petitioners argue that POSCO may have overstated its adjustment for imputed credit attributed to accounts receivable financing. Consequently, petitioners argue the Department properly adjusted POSCO's imputed expense calculation and deducted only the actual imputed credit expenses reported in its sales listing. Department's Position: We agree with POSCO that the imputed credit calculation used to offset interest expenses included in indirect selling expenses is not correct. In Flat Rolled - 5, we explained that under appropriate circumstances, we may exclude some portion or all of a U.S. sales affiliate's interest expenses in its calculation of indirect selling expenses. Furthermore, we explained that we must determine the appropriate universe of CEP deductions on a case-by-case basis because the activities of U.S. sales affiliates differ considerably across cases. We agree with POSCO that our calculation of indirect selling expenses, which is done on a POSAM-wide basis, takes into account all of the indirect selling expenses of the company and allocates them over all of POSAM's sales in the United States. As a result, the offset for imputed credit is not calculated on the same basis as all of the other expenses included in indirect selling expenses, since the offset is limited to sales of subject merchandise, whereas all of the other expenses are reported on a company-wide basis. Therefore, we have adjusted POSCO's reported interest expenses to determine a net interest expense ratio applicable to U.S. sales of subject merchandise alone, thereby eliminating the double count attributed to imputed credit, and appropriately attributing the reported expenses to sales of subject merchandise. This method, by allocating a portion of the total interest expense to subject merchandise and disregarding the remainder, directly addresses POSCO's concern about including interest expenses associated with non-subject merchandise in the calculation of indirect selling expenses. This allocation is appropriate to ensure that the deduction for double counting is taken from a pool of expenses at the same level as the offset, e.g., subject merchandise. This more accurately ensures that no non- subject merchandise interest or imputed credit is applied to subject merchandise. To calculate indirect selling expense, we first eliminated interest expense from the calculation of indirect selling expenses, and then separately calculated an adjustment for net interest expense applicable to sales of subject merchandise and for the remaining indirect selling expenses. We then added the two separate adjustments to obtain the total indirect selling expenses applicable to sales of subject merchandise in the United States during the POR. We calculated the amount of interest expense applicable to sales of subject merchandise by multiplying the reported POSAM-wide interest expenses by the ratio of total U.S. sales of subject merchandise reported on the computer sales listing to the amount of total U.S. sales of all merchandise reported in exhibit 21 of POSCO's November 6, 200 section C response. We then deducted the total value of imputed credit expense reported on the computer sales listing from the amount of interest expense applicable to sales of subject merchandise. We divided the amount of net interest expense applicable to U.S. sales of subject merchandise by the total value of sales to the United States reported on the computer sales listing to obtain the interest expense ratio applicable to gross unit price as reported on the computer database. We then summed the amount of indirect selling expense and interest expense to obtain the total amount of indirect selling expense applicable to each U.S. sale of subject merchandise reported on the computer sales listing. Comment 14: Deferred Foreign Exchange Losses POSCO argues that the Department's adjustment to G&A for the full amount of deferred foreign exchange losses was inconsistent with precedent. POSCO argues that it recorded all of its deferred foreign exchange losses against retained earnings in 1999 in accordance with new Korean GAAP. POSCO states that in the original investigation, it initially capitalized these losses and these losses were to be amortized over time, which was consistent with Korean GAAP at that time. POSCO also claims that the Department included only the amortized portion of the loss booked during the POR in G&A in the original investigation. However, in this review, in spite of reporting the cost consistent with the new Korean GAAP, which requires POSCO to record the entire deferred foreign exchange losses against retained earnings, the Department adjusted POSCO's COP to include the entire balance of the losses. POSCO contends that in order to ensure consistency with precedent, the Department should amortize the losses over the life of the corresponding liabilities. POSCO further argues that there are several other cases addressing the change in Korean GAAP and gives as an example, Dynamic Random Access Memory Semiconductors of One Megabit or Above From the Republic of Korea: Final Results of Antidumping Duty Administrative Review, 65 Fed. Reg. 68,976 (November 15, 2000) ("DRAMS from Korea"), where the Department continues to include only the amortized portion of the cost in respondents' COP. POSCO strongly urges that the deferred losses must be amortized over the remaining life of the amortization period in the final results. Petitioners argue that the Department's adjustment to G&A for the full amount of deferred foreign exchange losses was proper. Petitioners contend that POSCO booked the full amount of its deferred losses in accordance with Korean GAAP which had changed from the original investigation and since POSCO wrote off the entire balance of its deferred losses in 1999, the Department properly adjusted POSCO's COP to include the entire balance of these losses rather than just the amortized portion of the loss. Petitioners contend that the Department's methodology is consistent with section 773(f)(1)(A). According to the statute, costs are normally calculated based on the records of the producer of the merchandise if the records are in accordance with the exporting counties' generally accepted accounting principles; and if the costs associated with the production of the merchandise are reasonably reflected. Petitioners argue that since the Department normally uses a company's GAAP-consistent, normal books and records and expressly rejects alternative cost methodologies that respondents prepare expressly for responding to the questionnaire in the antidumping inquiry, the Department's decision was proper in all respects. Petitioners also countered that POSCO only argues the Department should have amortized the losses because it did so in the original investigation, and that it did not provide any evidence regarding whether the inclusion of the entire balance of the unamortized deferred losses "reasonably reflect the cost" associated with its COP. Petitioners contend that if the Department accepts POSCO's argument, it will distort the costs in subsequent administrative reviews since the remaining balance of deferred losses would never be recognized in subsequent income statements. In such a case, the Department would have to determine the hypothetical unamortized foreign exchange loss balance for assets from prior periods for use in subsequent reviews, despite this loss already having been recognized in its full amount in prior years. Petitioners contend that the proper accounting would be extremely difficult. Therefore, petitioners urge the Department to continue to include the full amount of deferred foreign exchange losses in the G&A. Department's Position: We disagree with petitioners that the full amount of deferred foreign exchange losses should be included in the G&A. Prior to 1999, POSCO capitalized its foreign exchange losses to be amortized over time. In 1999, the unamortized losses still remained on the company's books, and POSCO, according to changes in Korean GAAP, moved these losses directly to retained earnings, without affecting the profit and loss statement. We note that, while this may be appropriate for Korean accounting purposes, for antidumping purposes this new practice fails to reasonably reflect the cost of producing the subject merchandise, as the respondent's new accounting treatment of these losses does not change the fact that these losses represent an additional cost of financing to the company. Therefore, for the final results of review, we have included an amortized portion of the losses in the respondent's COP, which is consistent with our decision in DRAMS from Korea. B. ISSUES WITH RESPECT TO DMC Comment 15: Indirect Selling Expenses Petitioners claim that DMC's allocation of indirect selling expenses between domestic and export sales based on the relative amount of paperwork for processing those sales is inappropriate. Petitioners argue that the Department should reject DMC's allocation methodology for the purposes of calculating the antidumping duty margin. Petitioners claim that DMC's allocation scheme hinges on the supposed direct identification of the salaries and bonuses of its administrative personnel and an allocation of the number of administrative employees. Petitioners claim that DMC never demonstrates how it "directly identified" either the salaries, bonuses or number of employees that account for each portion of the indirect selling expense allocation. Petitioners contend, that since DMC's allocation methodology hinges on the number of employees devoted to export and home market sales, the total number of employees should have been reconciled. Petitioners further argue that DMC's allocation ratio is skewed because its attribution of expenses to export sales is based solely on DMC's U.S. sales and does not take into account DMC's third-country sales. Petitioners argue that the only data used for the indirect selling expense calculations that have been reconciled are the total indirect selling expenses to the financial statements. Petitioners argue that since DMC had ample opportunity to provide a complete reconciliation of these data and failed to do so, the Department should reject DMC's indirect selling expense allocations. Petitioners further claim that DMC's allocation of indirect selling expenses between domestic and export sales fails to take into consideration one division of its sales unit, i.e., the sales management team, which collects accounts receivable, evaluates customer's credit, planning and reconciling delivery and production as well as organizing material logistics. Consequently, petitioners contend, DMC discredited its allocation of indirect selling expenses by failing to attribute a portion of its selling expenses to the sales management team. DMC asserts that its indirect selling expenses and G&A expenses have been fully accounted for and reconciled directly to the financial statements. DMC points out that in Exhibit B-23 of its April 27, 2001 response, under Part IV, all of DMC's actual SG&A expenses are listed for the year. DMC states that it further provided a detailed explanation of its allocation methodology. DMC states that from the total expenses, it allocated the expenses between export sales, domestic sales, and G&A. DMC claims that its allocation of expenses by domestic, export and other accounts for the third team of its sales unit and G&A. DMC states that when it split those expenses between export, domestic, and other, it took all of the expenses into account. DMC states that it allocated salary-based expenses directly to the department in which they were incurred. DMC asserts that the remaining expenses were allocated by the number of employees in each department. DMC maintains that it has demonstrated that all of the expenses were accounted for and that petitioners have established no basis for manipulation of this data. DMC explains that its obligation is to report its actual indirect selling expenses in the home and U.S. markets and it has no obligation to explain why expenses in one market may be higher or lower than another market. Department's Position: We agree that DMC's allocation reasonably divides expenses between domestic selling, export selling and G&A expenses. DMC explained its allocation methodology on page 12 of its February 16, 2001 supplemental questionnaire response. It tied its total SG&A expenses to its audited financial statements, then eliminated expenses such as packing and transportation that are otherwise included in the antidumping duty calculation. It then determined its allocation between domestic sales, export sales and G&A expenses based on either the number of employees performing a given function, or the level of salaries and bonuses (for salary type expenses). Certain salaries and bonuses were attributed directly to the department which incurred them. There is no information on the record to indicate that information from the sales management team was either inappropriately included in the G&A calculation rather than indirect selling expenses or omitted from the calculation of indirect selling expense altogether. Indirect selling expenses include salaries, bonus and welfare expenses in both the domestic and export departments. Because DMC accounted for all of the SG&A expenses included on its income statement, and prepared its allocation using a standard methodology accepted by the Department, we are not making any changes for the final results of review regarding this calculation. Comment 16: G&A Expenses Petitioners claim that DMC's calculation of G&A is inaccurate. First, petitioners contend that the Department's questionnaire requires that the G&A ratio be based upon the financial statements from the most recently completed fiscal year. They point out that DMC claimed to base its G&A ratio on expenses incurred during April 1, 1999 to June 30, 2000, the cost reporting period agreed to by the Department, which represents only a portion of the POR, when in fact the indirect selling expenses and G&A expenses were based on the fiscal year which ended March 31, 2000. Since the Department's regulations require that G&A and net interest expense ratios be based upon the most recently completed fiscal year, petitioners contend that the Department should amend the G&A ratio calculation to reflect the information reflected in DMC's financial statements for the most recently completed fiscal year. Furthermore, petitioners argue that DMC has not provided the Department with complete and accurate translations of its audited financial statements, but rather provided selected portions of "direct translations from the Korean version financial statements." Accordingly, petitioners argue that the Department should reject DMC's G&A calculation, which reportedly relies solely on the Korean language financial statements and instead rely on the English language financial statements. Petitioners also contend that costs for items such as travel, entertainment, cable and education that DMC claimed as variable overhead directly related to the production process are in fact G&A expenses. Petitioners propose that the Department make the following changes to DMC's calculation: recalculate indirect selling expenses based on the allocations of export versus home market sales found in DMC's business report; base all calculations on DMC's 1999-2000 financial statements; attribute only those items obviously attributable to indirect selling expenses as such, and allocate rent, insurance and taxes to G&A; add the non-operating expenses reported in DMC's 1999-2000 financial statement to the G&A expenses from the financial statement; include DMC's non-operating income which DMC failed to associate with the production or sale of the merchandise subject to review. Petitioners note that DMC classified this income as non-operating income for financial reporting purposes, furthering the argument that there is no basis to claim this income as a reduction to its G&A expenses. Finally petitioners propose that the Department include export expenses that DMC failed to confirm were reported in Section C of the questionnaire. DMC argues that its calculations are more precise than those required by the Department and that petitioners' efforts to inflate its G&A ratio are flawed. DMC does not dispute that the Department's questionnaire requests G&A for the most recently completed fiscal year. However, DMC notes that it derived its G&A ratio from expenses incurred during the 15-month cost reporting period, and reconciled the amount to its annual and semi-annual audited financial statements. DMC argues that this ratio corresponds to the time period for which it reported its cost of production information. Furthermore, for the purposes of this first administrative review, DMC contends that its ratio is more accurate than a ratio based on twelve- month fiscal data, which it claims is not acceptable to the Department for an administrative review covering an 18-month period. As a final point, DMC notes that the difference between its reported G&A and the G&A for the year ended March 31, 2000 is inconsequential, and will have no impact on the margin. DMC contends that petitioners' allegations that DMC's G&A expenses do not reconcile to the audited financial statements, and that DMC failed to translate its Korean language financial statements, are untrue. DMC asserts that it submitted both the English and Korean versions of its audited financial statements in its October 12, 2000 Section A questionnaire response. In addition, DMC claims that it provided a full translation of its Korean language income statements in its Section D questionnaire response and Section D supplemental response. DMC contends that it demonstrated in its July 27, 2001 letter that all of the reported G&A expenses tie directly to the income statements. DMC claims that the total SG&A figure on the English version of the financial statements matches directly the figure reported on the Korean financial statements. DMC claims that the travel, entertainment, cable, and education expenses which petitioners believe are G&A expenses were actually incurred in the factory and are included in DMC's cost of production. DMC argues that it is the Department's practice to include any costs incurred in the factory as factory overhead rather than to reclassify them to G&A, which by definition, does not include expenses related directly to production. DMC argues that petitioners have not explained why reclassification is necessary given that all of the costs have already been reported. DMC argues that reclassification would require revision not only to the G&A ratio, but also to the entire cost database, and the result would have absolutely no measurable impact on DMC's margin. DMC disagrees with petitioners' revised calculation for G&A. DMC notes that petitioners included transportation costs directly related to export sales in G&A expense. DMC contends that since these transportation expenses are directly associated with export sales, they were properly excluded from DMC's G&A calculation. DMC further argues that significantly reducing the salary-based expenses in G&A, petitioners' proposal is inappropriate because it includes certain non-operating expenses in G&A but excludes the associated income. Department's Position: We agree with DMC. In a memorandum from Amy Ryan to the file, Extension Request for DaiYang Metal Co., Ltd. (Dai Yang), dated April 16, 2001, the Department granted DMC permission to report costs for the fifteen-month period of April 1, 1999 to June 30, 2000, rather than report costs for the entire eighteen-month period of review. Since DMC reported its G&A expenses on the same basis and the reported expense ratio does not differ significantly from the fiscal year ratio, we did not recalculate G&A on the basis of DMC's financial statements for the year ended March 31, 2000. In addition, we have no basis for making any of the changes to the G&A expenses proposed by petitioners. We agree with DMC that its G&A calculations reconcile to its audited financial statements and that all of its expenses have been appropriately reported. In addition, we have examined DMC's allocation of expenses between the export and sales division and found that the allocations were made using reasonable methodologies for the purpose of calculating a dumping margin. We furthermore disagree with petitioners' proposal for revising DMC's calculation of G&A expense for the reasons put forth by DMC: Petitioners included transportation costs directly related to export sales in G&A expense; and DMC's allocation of salary expenses appropriately attributes salary based expenses to the divisions that incurred it. Comment 17: Marine Insurance and U.S. Inland Freight Petitioners contend that DMC failed to report marine insurance and U.S. inland freight from port to warehouse for certain U.S. sales. Petitioners claim that DMC's Section C response did not give any indication that there were instances in which these expenses were not incurred. Therefore, petitioners argue that the Department should use adverse inferences and apply the highest reported value from each field for U.S. sales for which no marine insurance or U.S. inland freight from port to warehouse were reported. DMC disagrees that adverse inferences should be applied to those transactions for which no marine insurance or foreign inland freight was reported, since these expenses were not incurred on those sales. DMC notes that these sales were shipped by an alternative means, and the actual expenses for those shipments were reported in the field for international freight (INTNFRU). DMC contends that the highest reported value for marine insurance is very small and would have absolutely no impact on the margin in this case if it were applied to those sales. Department's Position: The Department agrees with DMC that the company appropriately reported its inland freight and marine insurance. As DMC explained above, it did not incur marine insurance and foreign inland freight on certain sales which were shipped by alternate means. Consequently, no marine insurance or foreign inland freight expenses were reported on the computer sales listing and the actual freight expenses for those shipments were reported in the field for international freight. Since no information exists on the record demonstrating the such expenses were incurred, we have made no changes to this calculation for the final results of review. Comment 18: Commission Offset for DMC Petitioners claim that DMC provided no documentation in support of its reported commissions on U.S. sales. Consequently, the Department should deny DMC's claimed commission offset. Petitioners further contend that DMC's financial statements, unlike the financial statements of DMC's U.S. selling arm, OMC, do not substantiate the commissions reported by DMC. Consequently, petitioners argue that no information on the record specifies the conditions under which such commissions were paid. DMC did not provide a copy of the commission agreement as requested by the Department. Accordingly, petitioners argue that the Department should deny DMC's claimed commission offset. DMC replies that it that provided information concerning its selling agent in its original Section C questionnaire response and submitted sample documentation between that selling agent, and DMC. Consequently, DMC argues that no changes should be made for the final results of review with respect to commission offset. Department's Position: The Department agrees that DMC appropriately documented its commission practices and relationships, and provided sample documentation. DMC's computer sales listing indicates that DMC paid a commission on the net price for all sales in which OMC's selling agent was involved, and these commissions trace to the financial statements. Therefore, we have made no changes to the final results of review for commission offsets. Comment 19: OMC's Indirect Selling Expense Ratio Petitioners argue that OMC's indirect selling expense calculation inappropriately allocates costs to the cost of manufacturing when OMC's operations during the POR were reportedly devoted exclusively to the sale of the subject merchandise. Accordingly, petitioners contend that no costs should have been allocated to the cost of manufacturing. Rather, petitioners claim, the Department should rely on the revised ratio reported in proprietary Attachment 2 of petitioners' September 17, 2001 case brief for OMC's indirect selling expenses. DMC claims that petitioners are mistaken and that OMC did in fact incur further manufacturing costs during the POR. According to DMC, a review of OMC's financial statements demonstrates that while OMC did not sell any of the further manufactured pipe produced from subject merchandise during the POR, it did produce non-subject pipe during the POR. DMC, therefore, concludes that its allocation was appropriate. Department's Position: The Department agrees with DMC that further manufactured pipe was produced during the POR and that no sales of further manufactured pipe took place during the POR. Consequently, since the costs associated with this further manufacturing were incurred by OMC during the POR, we have determined that DMC's allocation is appropriate and we have made no changes for the final results of review. Comment 20: Short-Term Borrowing Rate in the Home Market Petitioners claim that DMC's short-term interest rate in the home market was not completely reconciled and differs from the figures reported in its financial statements. Petitioners further claim that DMC failed to reconcile its short-term interest rate calculation to its financial statements, despite the Department's repeated requests. Petitioners claim that the original questionnaire response provided figures only for the short-term interest paid during the year and the average balance of short- term borrowings on DMC's general loan. Petitioners note that in its first supplemental Sections B and C response, DMC illustrated its calculation of the average balance on short-term borrowings and the interest paid for the year, but failed to reconcile these figures to the financial statements. Petitioners further contend that, in its April 17 supplemental response, DMC reconciled its interest expenses to its financial statements, but that the summary of its interest expenses was merely stated and a reconciliation of the various interest expenses was not provided. Thus, petitioners contend, neither the denominator used to calculate the short- term interest rate (the average balance on short-term borrowings), nor the numerator (the short-term interest paid), were properly reconciled to the English language versions of the financial statements. Petitioners contend that DMC identified only its general loan as a short- term expense, but did not reconcile the general loan to the financial statements. Therefore, petitioners contend that the Department should instead rely on the company's published and audited financial statements. Consequently, petitioners argue that the Department should calculate DMC's short-term interest rate by dividing the sum of the interest expenses that appear to be associated with short-term borrowings on DMC's general loan and purchasing loan by the short-term borrowings at the end of the fiscal year and apply the result to the credit expense and inventory carrying cost calculations. DMC states that contrary to petitioners' allegations, it did reconcile its short-term interest rate to the financial statements. DMC notes Exhibit B-18 of its February 16, 2001 questionnaire response, provides a detailed worksheet listing all of its short-term borrowings during the POR, the name of the bank, the kind of loan, the principal amount, the interest rate, the period of the loan, the number of days, the accumulated principal, the interest payments, prepaid interest, accrued interest, and the interest amount for the year. In addition, DMC explains that the worksheet also provides details of the average daily balance and the interest for the year, used to calculate the short-term interest rate. DMC states that it tied the total interest expense from that worksheet, directly into its financial statements. DMC states that it further reconciled its interest expenses paid as part of its cost questionnaire response. DMC concludes that since it reconciled the information, petitioners have provided no basis upon which the Department can arbitrarily manipulate the short-term interest expenses in this case. Department's Position: We agree that DMC provided a detailed worksheet listing all of its short- term borrowings during the POR. As DMC noted, the worksheet provides a detailed listing of its short-term borrowings during the POR, including the name of the bank, the kind of loan, the principal amount, the interest rate, the period of the loan, the number of days, the accumulated principal, the interest payments, prepaid interest, accrued interest, and the interest amount for the year. DMC reconciled its short-term interest rate to the financial statements, and there is no information on the record indicating that its calculations are distortive. Therefore, we have used the information submitted by DMC and have made no changes for the final results of review. Comment 21: Ministerial Errors DMC argues that the minor ministerial error in the Department's preliminary results of review should be corrected in the final results of review. DMC asserts that the Department's calculation of DMC's overall weighted-average margin of 2.96% was slightly overstated. DMC states that the overall weighted-average margin is calculated by dividing "Total PUDD" by "Total Value," and this results in an overall weighted-average margin of 2.74%. Department's Position: The Department agrees with DMC that the Department inadvertently published the incorrect overall margin in the preliminary results of review. We have corrected this figure for the final results of review, and have made no other changes to our program for these final results of review. C. Issues with Respect to Samwon Comment 22: Use of Partial Facts Available Samwon argues that the COP data it submitted for raw material costs were accurate by discrete grade type, which it argues is the most significant and most relevant indicator of cost for all models. Samwon claims that the Department not only verified the accuracy of Samwon's reported material costs by grade, but it verified that Samwon did not have records allowing it the ability to calculate COP to a greater level of detail and accuracy other than grade. Samwon contends that, despite this lack of information, Samwon cooperated to the best of its ability in presenting the facts at its disposal. Samwon asserts that the Department's verification report finds that the reported total values for material, labor and overhead tied to the company's books and records with no discrepancies. Samwon contends that the Department's verification report continually makes statements such as "We noted no discrepancies," or "We arrived at . . . the figure reported," or "there were no discrepancies," such that Samwon claims that the only costs that did not "reconcile" to its books and records were certain conversion costs relating solely to differences in gauge, slitting and finish among the different products. Samwon claims that its production and accounting records do not track these types of cost differences. Therefore, Samwon argues, that given the accuracy level of its books and records, and its attempts to provide the information requested, the Department should use Samwon's reported per-unit CONNUM-specific costs for the final results of review. Furthermore, Samwon argues that the company never claimed that its CONNUM- specific costs tied directly to its books and records, which Samwon maintains are kept by grade. Samwon contends that, where a company has not willfully failed to comply with the Department's requests for information and has demonstrated that the information requested is not available, the Department may not simply ignore verified information in order to arrive at a "facts available" calculation, and that the reported CONNUM-specific costs are the most appropriate facts available, since Samwon believes that the facts it provided were accurate. Petitioners contend that the Department properly disregarded Samwon's CONNUM-specific costs as these costs were not accurate, not credible and not verifiable. Moreover, petitioners note that the Department afforded Samwon several opportunities to submit CONNUM-specific costs which reflect the company's actual cost experience, and therefore would be verifiable. Petitioners argue that acceptance of Samwon's reported costs would reward the company for failure to comply with the Department's request for accurate and verifiable COP data. Department's Position: Section 776(a)(2) of the Act provides that if any interested party: (A) withholds information that has been requested by the Department; (B) fails to provide such information in a timely manner or in the form or manner requested; (C) significantly impedes an antidumping investigation; or (D) provides such information but the information cannot be verified, the Department shall use facts otherwise available in making its results of review. The Department provided Samwon with three opportunities to submit a reasonable CONNUM-specific cost methodology based on its books and records during this review. Although Samwon claims that it never made an affirmative statement that its COP response tied to its books and records, it similarly never stated that its COP response didn't tie to its books and records. Rather, based on the information submitted in Samwon's responses, the Department had no reason to believe anything contrary to the idea that Samwon's reported methodology reconciled to its cost accounting records prior to verification. In fact, the Department's questionnaire specifically states: "The CONNUM specific per-unit COP and CV figures that you provide in response to this section of the questionnaire must reconcile to the actual costs reported in your company's normal cost accounting system and to the accounting records used by your company to prepare its financial statements... You should compute COP and CV based on your company's normal accounting records. If in preparing the COP and CV calculations you intend to depart from your company's normal accounting system and normal cost allocation methods, you must notify the Department in writing before preparing your response to this section of the questionnaire" (Emphasis added). See page D-9 of the Department's September 7, 2000 questionnaire issued in this review. Despite these concrete and specific instructions in the questionnaire, Samwon failed to inform the Department that it intended to depart from the books and records prior to verification. During verification, the Department found that Samwon's CONNUM-specific COPs were not based on and did not tie to the company's books and records. Additionally, the Department noted Samwon's statement that its books and records were not kept to the level of accuracy and detail that would enable it to accurately report CONNUM-specific production costs. See Antidumping Duty Review on Stainless Steel Sheet and Strip in Coils from Korea: Cost Verification Report of Samwon Precision Metals, dated July 24, 2001 ("verification report") at 5, 11 and 12. As noted in the Department's verification report, by its own admission, Samwon stated that the company was not able to quantify its own production experience. See the verification report at 12. Although the Department was not able to confirm Samwon's reported CONNUM-specific per-unit COPs, the Department did confirm the value of Samwon's aggregate company-wide cost of materials, labor and overhead as reported on its financial statements. However, the verified aggregate costs do not distinguish between material, grade, thickness, width, finish, etc., which the Department considers to be critical criteria for COP and model matching purposes. Moreover, we disagree with Samwon's claim that the Department's frequent use of such statements as "we noted no discrepancies" indicates that the Department accepted the accuracy of the totality of its cost response or that the statements are indicative that Samwon's COP response represents the most appropriate facts available. Rather, the statements referred to by Samwon in its brief represent tests of individual elements of the submitted data and do not indicate that Samwon correctly reported all of its cost data in a manner usable by the Department for the purposes of the antidumping duty calculation. Furthermore, the verification report documents that numerous attempts to test the reasonableness of Samwon's COP response failed due to insufficient records or yielded a wide range of results which cast doubt on the accuracy of the data reported in the COP response. See Verification Report at 1, 5, 13, and 15. For example, with regard to shift reports which could have served as a basis to allocate costs, the Department noted Samwon's statements that these reports are "completely unreliable." The Department also noted in its verification report that the Department was unable to trace and record critical production data like time, input mass, output mass, and scrap produced in Samwon's production records as numerous attempts to trace and record production times of specific coil failed due to the lack of information kept in the shift reports for various lines. See Id at 13. The Department's specific tests of the reasonableness of Samwon's COP response yielded results which indicated that its CONNUM-specific costs did not accurately reflect Samwon's production experience, and therefore, was not accurate. See the verification report at Attachment 3-5. For the above reasons, the Department determined that Samwon's reported CONNUM-specific costs are not verifiable and are not accurate. As a result, the CONNUM-specific costs of production reported in Samwon's response cannot serve as a reliable basis for reaching a final results of review. Therefore, pursuant to section 776(a) of the Act, we have determined that the use of facts available is appropriate for the final results. Although the reported CONNUM-specific costs are unusable, we found that the overall costs reported by Samwon were consistent with the data kept by the company in the normal course of business. Also, in the aggregate, we did not find any reason to suggest that the total reported costs did not accurately reflect the costs associated with all subject merchandise in its entirety. In this case, Samwon produced a limited range of subject merchandise composed primarily of only one grade. In addition, as noted in the preliminary results, a preponderance of Samwon's production consisted of a small number of models that share common characteristics (e.g., grade). In addition, material costs, which we were able to verify, constitute most significant element of cost. Under these circumstances, as Samwon's aggregate costs and production quantity were verified, the Department considers the aggregate costs to be the most appropriate facts available. Consequently, as partial facts available, we have calculated one weighted-average COP and compared all home-market prices to the single COP for the purposes of determining sales below cost. Comment 23: Use of a Single-Weighted Average COP Samwon contends that the Department's use of partial facts available in the preliminary decision regarding Samwon's cost of production was improper and unreasonable to the extent that the Department ignored verified components of product-specific costs. Additionally, Samwon claims that the Department's choice of partial facts available is adverse, non- neutral, and distortive. Samwon contends that although the Department claims that Samwon's COP methodology was unusable in its entirety, the Department verified its per- ton material costs and per-ton scrap values. Samwon further points out that throughout the course of revising its COP response at the Department's request, the reported per-ton material cost and per-ton scrap did not change. Samwon argues that at verification, the Department verified that Samwon's books and records were kept on a grade-specific basis with regards to material cost and a factory-wide basis for scrap, consistent with the company's response. Samwon further notes that the Department's verification report explicitly discusses problems related to the company's allocation of conversion costs and not the per-ton material costs. Additionally, Samwon argues under section 782(e) of the Act, the Department may not decline to use information which meets the following requirements: 1) the information is submitted by the established deadline; 2) the information can be verified: 3) the information is not so incomplete that it cannot serve as a reliable basis for reaching the applicable determination; 4) the interested party has demonstrated that it acted to the best of its ability; and 5) the information can be used without undue difficulties. Samwon argues that the per-ton material costs and per-ton scrap values satisfy each of these requirements, and as such, Samwon states that the Department must use the verified per-ton material cost and per-ton scrap and apply partial facts available to the conversion costs which were not verifiable. Moreover, by ignoring verified per-ton material costs and per-ton scrap value and using a single-weighted average COP, Samwon alleges that the Department is applying a partial facts available which is adverse, non- neutral, and distortive. Samwon argues that the Department's assertion in its preliminary decision that the single-weighted average COP approximates the production costs of Samwon is incorrect. Samwon contends that the Department's use of a single-weighted average COP in fact introduces distortions and inaccuracies into the calculation of an antidumping margin, and as such, the Department is prohibited from using a single- weighted average COP. Samwon specifically argues that an average combines products with significantly different per-ton material costs, and therefore, distorts the COP calculation. Samwon notes that the per-ton material costs vary widely across grades, and therefore, calculating a single weighted-average COP for all products across grades is distortive given that Samwon provided grade-specific per-ton material costs to the Department. Samwon also questions the Department's citation of the Notice of Final Determination of Sales at Less Than Fair Value: Hot-Rolled Carbon Quality Steel Products from the Russian Federation, 64 FR 38626 (July 19, 1999). Samwon contends that in that case, the respondent company's factor of production data was not allocated sufficiently to discrete grades or qualities, and therefore, did not accurately reflect the grades to which the products relate, whereas in the present case, the submitted per-ton material costs do distinguish between discrete grades. Like the per-ton material costs, Samwon also argues that scrap was verified and therefore should be used as reported. Samwon argues that the single-weighted average COP creates an average scrap offset without any consideration of differences in revenue on a per grade-type or product basis. Petitioners counter, stating that the Department's use of a single- weighted average single COP was appropriate in the absence of CONNUM- specific cost data. Petitioners argue that the Department used Samwon's verified data, which was on an aggregate level. Additionally, petitioners argue that Samwon misinterpreted the use of "We noted no discrepancies" in the Department's verification report. Petitioners contend that this phrase merely affirms the amounts reported in Samwon's response, but that, the phrase does not in any way endorse Samwon's cost methodology. Therefore, even if the per-ton material costs reported by Samwon are consistent with the amounts recorded in the company's own books, it does not mean that the reported costs are usable by the Department's standards. Moreover, petitioners contend that the per-ton material costs are not usable because the per-ton material cost is dependent upon the physical characteristics of the finished product - therefore, though finished products are of the same grade, the per-ton material costs may differ substantially because different models produce different amounts of scrap depending on various physical characteristics like gauge, width, and slitting. These differences, petitioners contend, would affect the per-ton material cost for each finished product coil. Since Samwon reported the same material cost for all products within each grade, regardless of the physical characteristics of the finished product, petitioners maintain that the Department cannot consider the per-ton material cost to be complete, verified, or usable. Petitioners also disagree with Samwon's characterization of the Department's use of a single weighted-average COP as distortive and inaccurate. While petitioners agree that some products' costs will be overstated, and therefore Samwon's sales will be more likely to fail the cost test, other products' costs will be understated, and therefore Samwon's sales will be more likely to pass the cost test. Additionally, petitioners support the Department's assertion that Samwon's limited product variation would not lead to a significantly distortive COP. Finally, petitioners seek to refute Samwon's argument that the Department refused to use information submitted on the record by Samwon. Petitioners argue that the Department used Samwon's submitted data, but only aggregate data because this is the only data which could be verified as accurate. Department's Position: Although Samwon's per-ton material costs on a grade-specific basis verified, these costs cannot be used to calculate per-unit costs on a grade-specific basis, or based upon the other criteria contained within the Department's model matching characteristics, because the per-ton material costs do not account for the physical characteristics of the finished product. Although the Department notes that Samwon provided grade- specific per- ton material cost which did verify, the Department also recognizes the difference between per-unit and per-ton material costs. The per-ton material cost represents the price of the raw material coil which Samwon purchased. The per-unit material cost is the cost of the raw materials used by Samwon to make a particular ton of a finished product. Hence, the per-unit material cost is a function of the per-ton material cost and the quantity used to make this unit. In order for the per-ton material cost to be considered usable, Samwon had to report the quantity of the raw material on a level which would allow the Department to distinguish between discrete products as established by any of the Department's model match criteria. In its verification report, the Department states that Samwon does not record scrap by grade, gauge, or more importantly by production line which would theoretically enable them to calculate product- specific scrap ratios. Although Samwon argues that the Department did not consider differences in scrap revenues per grade-type or product, Samwon's reported scrap treats all scrap from all products as the same. Because Samwon's scrap ratios and values are reported on a factory-wide basis and not on a product-specific basis, all products were reported as having the same usage rate, and therefore, Samwon's COP response represents that the company used the same amount of raw material coil within a grade to make one thin, narrow, and trimmed product as it did to make a thick, wide, and mill-edged product. Because the Department does not know the product- specific quantities of raw material needed to calculate a per-unit material cost, the Department cannot use Samwon's per-ton material costs. As such, Samwon's reliance on section 782(e) with regard to the per-ton material cost is not relevant because the material cost per-unit cannot be considered verified without product-specific scrap ratios which would enable the Department to use the per-ton material costs as submitted by Samwon. The per-ton material cost reported by Samwon represents the cost of the raw material coils used to make the various finished products. As noted by petitioners, scrap is produced in varying degrees based upon the physical characteristics of the finished product. A product which is rolled thin and trimmed will produce more scrap than a thicker mill-edged coil even if the two coils are of the same grade. Therefore, depending on the physical characteristics of a particular CONNUM/product, a company will need varying quantities of the raw material input coil to produce a ton of the product, irrespective of grade. While the raw material input coils could theoretically cost the same for all coils within a particular grade, the cost to produce a particular ton of a finished product will differ from another finished product of the same grade because one product requires a different quantity of input coil than another. However, in this instance, Samwon reported the same per-ton material cost within each grade and applied one scrap ratio to all grades which does not distinguish between products on any level, including grade, to arrive at a grade-specific per- unit material cost. This grade-specific per-unit material cost theoretically represents the cost of the raw material coil used to produce the finished product within a specific grade. Since the scrap ratio is constant, and therefore the same for all grades and products, the per-unit material cost is the same for all products within a given grade. Hence, a product which produces a considerable amount of scrap (a thin, narrow, and trimmed coil) incorrectly has the same per-unit material cost as a product within in the same grade which does not produce much scrap (a thick, wide, and mill-edged coil), which is not consistent with the production process for subject merchandise. In its verification report, the Department also noted problems with regard to tests of total per-unit CONNUM-specific costs reconciling to the company's own books. See the verification report at 14-15. The inability to reconcile the total per-unit CONNUM-specific costs to the company's books and records casts doubt upon the response in relation to CONNUM- specific costs, of which per-ton material costs, per-ton scrap, and conversion costs are parts. Because of the complexity involved in constructing a COP response and the unique nature of each company's production process, the Department, as noted in its preliminary decision, cannot adjust the CONNUM-specific costs due to the broad nature of the company's books and records. The Department noted in its verification report and its preliminary results of review that Samwon's allocation methodology possesses serious flaws which render the CONNUM-specific costs unusable. However, the Department additionally noted that in the aggregate, no evidence exists which suggests that the aggregate costs were inaccurate with respect to production of all models of subject merchandise. The overall costs were consistent with the books and records maintained in the ordinary course of business. Therefore, under the particular circumstances of this case, in the absence of CONNUM-specific costs, the Department as partial facts available has calculated a single- weighted average COP which takes into account the verified aggregate costs. The Department has then applied this figure to all CONNUMs for the cost test. The Department does recognize, as Samwon argues, that an average varies from individual observations and that in some instances, certain products may be assigned a cost higher than the actual cost of production. However, the Department also notes that the converse is true as well - other products may be assigned a cost lower than the actual cost of production. The example offered by Samwon in its comments indicates that the average of material costs hurts the company because the material cost of a less expensive grade is grouped with a grade with a more expensive material cost. Although sales of this one grade may fail the COP test, sales of the other more-expensive grade are just as likely to come out above the weighted-average cost of production precisely because of the weighted averaging. Moreover, as noted by the Department in its preliminary decision, a preponderance of Samwon's production is comprised of a small number of models which share common characteristics (e.g., grade), and as such, the Department agrees with petitioners that a single-weighted average COP is less likely to be distortive in this case. Under a weighted- average COP, specific costs are given more weight in the calculation of a COP based on the quantity produced. The Department notes in regard to per- ton material costs that Samwon primarily produces a preponderance of one grade, and as such, this grade figures heavily in the calculation of a single weighted-average COP. Therefore a weighted-average COP, of which a weighted-average per-ton material cost is a part, would not significantly or adversely misrepresent COP with respect to Samwon's primary grade. Since this grade comprises the majority of sales in the home market and the U.S. market, the weight-averaged COP is not adverse nor significantly distortive, and therefore we will continue to apply the weighted-average COP as facts available in this case. RECOMMENDATION: Based on our analysis of the comments received, we recommend adopting all of the above changes and positions, and adjusting the margin calculation programs accordingly. If accepted, we will publish the final results of the investigation and the final weighted-average dumping margins in the Federal Register. AGREE___________ DISAGREE___________ ______________________ Bernard T. Carreau Acting Assistant Secretary for Import Administration Date