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TRANSCRIPT
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CERTAIN BRASS SHEETS AND. STRl~S FROM. BRAZIL, . CANADA, FRANCE, ITALY, THE REPUBLIC OF KOREA, SWEDEN, AND -WEST GERMANY
. .
Determination& of the Commission .In . Investigations Noa. 701-TA-28& and 2·70(Prellmlnary) Under the
. Tariff Act of 1.930, Together · W~h the Information Obtained
In the Investigations W
Determinations of the Commission In Investigation• NOS.; 7 31-t A-311
USITC PUBLICATION 1837 through 317 (Preliminary) Under the Tariff Act of 1930,
MAY 1988 Together With the Information· · Obtained In· the Investigations
United States International Trade Commission I Washington, DC 20438 ..
UNITED STATES INTERNATIONAL TR1lDE COMMISSION
COMMISSIONERS
Paula Stern, Chairwoman
Susan W. Llebeler, Vice Chairman . Alfred E. Eckes
Seeley G. Lodwick
David B. Rohr Anne E. Brunsdale
Staff Assigned
Tedford Briggs, Office of Investigations Debbie VonBeulen, Office of Investigations
Stephanie Elsman, Off ice of Economics James Lukes, Office of Industries
Marcy Stras, Office of the General_ Counsel
Vera Libeau, Supervisory Investigator
Address all communications to
Kenneth R._ Mason, Secretary to the Commission Uq,ited. S~ates International Trade Commission
·w ashington, D.C 20436
C 0 N T E N T S
Determinations-----------------------------------------~-----------------Views of the Commission----------------------------..;.----------------------Information obtained in the investigations:
Introduction----------------------------------------------------------The product:
Description----~--------------------------------------------------Manufacturing pr9cess-------------------~-------------------------Uses--------------------------------------------------------~----
U.S. tariff treatment---------------------------------------------The U.S. market:
1 5
A-2 A-3 A-4 A-4
U.S. producers--------------------~------------------------------ A-5 u.s. importers----------~--------------------~-------------------- A-6 Channels of distribution-------------------------~---------------- A-6 U.S. consumption-----------------------~--------------------..:-~--- A-6
The nature and extent of alleged sales at LTFV and alleged s~bsidies: Alleged sales at LTFV------------------~-~--.:..--------------------- A-8 Alleged subsidies:
Brazil------------------~-------.:..--------------------~-------- A-8 France----------------------------------------------------·----
Cons idera t ion of alleged material injury to an industry in the United States:
U.S. production, capacity, and capacity utilization---------------u.s. producers' shipments-----------------------------------------U.S. producers' inventories--------------~---------~----~------~--Employment and wages-------------------~------------~-------------Financial experience of U.S. producers----------------------_: ____ _
Overall establishment operations-------~------~--------------Operations producing all grades oi brass sheet~ and strips---Operations producing C20000-series brass sheets and strips----Capital ·expenditures---------~----------------~---------------Value of plant, property, and equipment---------------~-~-'---..: Research and development expenses-~--------------~-~-..:--~----Capita l and investment------------------------------------~---
The question of the threat of material injury------------·_:_;, __________ _ U.S. importers' inventories--------------------------..: ___________ _ Capacity of foreign.producers to generate exports-----------..: ____ _
Consideration of the causal relationship between alleged material injury or the threat thereof and the alleged LTFV and/or. subsidized imports:
U.S. imports---------------------------~---~----------------------Market penetration by the alleged LTFV and subsidized imports-----Prices-----------------------------------..: _______ _: ____________ ~---
Sales practices-----------------------------------------:-----Spo t market sales-------·------------------------------------:--Con tract sales----..;. __ . ________ ..,: ____________ _: ________________ . __ _
Price trends: · : · · Domestic producers' price trends for spot ~ales-_: ____________ _
Importers' price trends for spot sales------------:------'------Price trends on contiact sales----------...: ____ _: _______________ _
Price comparisons:· . . Spot price comparisons----------------------~-----------------
B r az i 1------------------------------.:..-·-~-------~---------Ca nad·a --------------.:..----'-----------------'--'--------------Fr·a nc e -------------------:..:. ___ . __ _:_: __ ..:_: _____________________ .
Italy-----------------------------------------------------
A-9
A-9 A-10 A-12 A-12 A-14 A-14 A-15 A-15 A-16 A-16 A-18 A-18 A-18 A-19 A-19
A-20 A-23 A-23 A-24 A-24 A-25
A.:..26 A-28 A-29
A-33 A-33 A-36 A-36. A-36
ii
CONTENTS
Information obtained in the investigations--Continued Price comparisons--Continued
Spot price comparisons--Continued
The Republic of Korea (Korea)----------------------------- A-36 Sweden---------------------------------------------------- A-37 West Germany---------------------------------------------- A-37
Price comparisons on fixed-period contract sales-------------- A-37 Transportation costs---------------------------------------------- A-38 Exchange rates---------------------------------------------------- A-38 Lost sales and lost revenues----~--------------------------------- A-40
Purchaser 1--------------------------------------------------- A-41 Purchaser 2--------------------------------------------------- A-41
Purchaser 3--------------------------------------------------- A-42 Purcha~er 4--------------------------------------------------- A-42 Purchaser 5-----~-------------------------------~------------- A-42 Purchaser 6--------------------------------------------------- A-43
Appendix A. Appendix B. Appendix c.
Federal Register notices-------------------------------------List of witnesses appearing at the Commission's conference--Specifications for UNS C20000, UNS C30000, and
B-1 B-13
UNS C40000 series brasses----------------------------------------------- B-19
Tables
1. Brass sheets and strips: U.S~ rates of duty, as of Jan. 1, 1980, Jan. 1, 1986, and Jan. 1, 1987------------------------------~------- A-4
2. Brass sheets and strips: U.S. producers' shipments, imports for consumption, and apparent consumption, 1983-85------------------ A-7
3. Brass sheets and strips: U.S. production, practical capacity, and capacity utilization, by types, 1983-85----------------------------- A-10
4. Brass sheets and strips: U.S. producers' domestic shipments, intracompany shipments, toll shipments, and exports of domestically produced product, by types, 1983-85-------------------- A-11
5. Brass sheets and strips: U.S. producers' inventories, by types, as of Dec. 31, 1982-85------------------------------------------------- A-12
6. Average number of U.S. producers' employees (total and production and related workers) producing all products and those producing brass sheets and strips; hours worked by and wages, total compensation, and average hourly compensation paid to such workers; output per hour worked; and unit labor cost in producing brass sheets and strips, by types, 1983-85-------------------------- A-13
7. Income-and-loss experience of U.S. producers on the overall operations of their establishments within which C20000-series brass sheets and strips are produced, 1983-85----------------------- A-14
8. Income-and-loss experience of U.S. producers on their operations producing all grades of brass sheets and strips, 1983-85------------ A-15
9. Income-and-loss experience of U.S. producers on their operations producing C20000-series brass sheets and strips, 1983-85------------ A-16
10. Capital expenditures on U.S. producers' facilities within which C20000-series brass sheets and strips are produced, as of the end of 1983-85-------------------------------------------------- A-17
11. Value of plant, property, and equipment (investment in productive facilities) of U.S. producers' facilities within which C20000-series brass sheets and strips are produced, as of the end of 1983-85-------------------------------------------------- A-17
iii
CONTENTS
Tables--Continued
12. Brass sheets and strips: The Republic of Korea's capacity, production, capacity utilization, domestic shipments, and exports, 1983-85---------------------------------------------------- A-19
13. Brass sheets and strips: West Germany's capacity, production, capacity utilization, domestic shipments, and exports, 1983-85------ A-20
14. Brass sheets and strips: U.S. imports for consumption, by principal sources, 1983-85--------------------------------------- A-21
15. Brass sheets and strips: U.S. imports for consumption, by selected sources, 1983-85--------------------------------~------- A-22
16.· C20000-series brass sheets and strips: Shares of U.S. consumption supplied by Brazil, Canada, France, Italy, the Republic of Korea, Sweden, and West Germany, all other countries, and U.S. producers, 1983-85---------------------------------------~--------------------- A~23
17. Brass sheets and strips: Domestic producers' weighted-average delivered prices on their largest single quarterly spot sales, by products and by quarters, January 1983 to December 1985---------- A-27
18. Brass sheets and strips: Importers' weighted-average delivered prices on their largest single quarterly spot sales of builders' hardware, by countries and by quarters, January 1983 to December 1985---------------------------------------'---------------- A-29
19. Brass sheets and strips: Importers' .~eighted-average delivered prices on their largest single quarterly spot sales of slitting stock, by countries and by quarters~· January 1983 to December 1985---- A-30
20. Brass sheets and strips.--Weighted-average total negotiated price (fabrication plus metal value) on sales contracts reported by U.S. producers and importers of the subject products from West Germany and average margins of underselling (overselling) by the subject imports, by product and by quarters, January 1983-December 1985-------------------------------~---------------~-- A-31
21. Brass sheets and strips.--Weighted-average fabrication prices negotiated for sales contracts of U.S. producers and importers of the subject products from West Germany and average margins of underselling (over-selling) by the subject imports, by product and by quarters, January 1983-December 1985------------------------- A-32
22. Brass sheets and strips: The average margins (per pound) by which imports of builders' hardware undersold the u.s.produced product sold on a spot-sale basis, by countries of origin and by quarters, January 1983-December 1985----------~------- A-34
23. Brass sheets and strips: The average margins (per pound) by which imports of slitting stock undersold or (oversold) the U.S.-produced product sold on a spot sale basis,·by countries of origin and by quarters, January 1983-December 1985------------------ A-35
24. Nominal and real exchange rate indexes between the U.S. dollar .and the Brazilian cruzeiro, Canadian dollar, French franc, Italian lira, Korean won, Swedish krona, and the West German deutsche mark, by quarters, January 1983-Dec~mber 1985-------------- A-39
Note.--Informatio·n which would disclose confidential. operations of individual concerns may not be published and therefore has been deleted from this report. Deletions are indicated by asterisks.
UNITED STATES INTERNATIONAL TRADE COMMISSION Washington, DC
Investigations Nos. 701-TA-269-and 270 (Preliminary) and 731-TA-311 through 317 (Preliminary)
CERTAIN BRASS SHEETS AND STRIPS FROM BRAZIL, CANADA, FRANCE, ITALY, THE REPUBLIC OF KOREA, SWEDEN, AND WEST GERMANY
Determinations
·on the basis of the record l/ developed in the subject investigations,
the Commission determines, pursuant to section 703(a) of the Tariff Act of
1930 (19 u.s.c. § 16llb(a)), that there is a reasonable indication that an
industry in the United States is materially injured by reason of imports from
Brazil (in~estigation _No. 701-TA-269 (Preliminary)) and France (investigation
No. 701-TA-270 (Preliminary)) of certain brass sheets and strips,'!:._/ provided
for in item 612.39 of the Tariff Schedules of the United States, which are
alleged to be subsidized by the Governments of Brazil and France.
Further, the Commission determines, pursuant to section 733(a) of the
Tariff Act of 1930 (19 U.S.C. § 1673b(a)), that there is a reasonable
indication that an industry in the United States is materially injured by
reason of imports from Brazil (investigation No. 731-TA-311 (Preliminary)),
Canada (investigation No. 731-T_A-312 (Preliminary)), France (investigation No.
731-TA-313 (Preliminary)), Italy (investigation No. 731-TA-314 (Preliminary)),
1/ The record is defined in sec. 207.2(i) of the Commission's Rules of Practice and Procedure (19 CFR § 207.2(i)).
2/ For purposes of these investigations, the term "certain br~ss sheets and st~ips" refers to brass sheets and strips of solid rectangular cross section, over 0.006 inch but not over 0.188 inch in thickness, in coils or cut to length, whether or not corrugated or crimped, but not cut, pressed, or stamped to nonrectangular shape, provided for in items 612.3960, 612.3982, and 612.3986 of the Tariff Scheduies of the United States Annotated (TSUSA). The petitions limit the scope of the investigations to sheets and strips of brass alloys designated as "C20000-series" under the nomenclature and numbering system of the Unified Numbering System (UNS) or the equivalent "200-series" under the Copper Development Association (CDA) numbering system.
2
the Republic of Korea (investigation No. 731-TA-315 (Preliminary)), Sweden
(investigation No. 731-TA-316 (Preliminary)), and West Germany (investigation
No. 731-TA-317 (Preliminary)) of certain brass sheets and strips,];_/ provided
for in item 612 .39 of the Tariff Schedules of _the United ·States, which are
alleged to be sold in the United States at less than fair value (LTFV).
Background
On March 10, 1986, petitions were filed with the U.S. International Trade
Commission and the U.S. Department of Commerce by counsel on behalf of
American Brass, Buffalo, NY; Bridgeport Brass Corp., Indianapolis, IN; Chase
Brass & Copper Co., Solon, OH; Hussey Copper Ltd., Leetsdale, PA; The Miller
Co., Meriden, CT; Olin Corp. (Brass Group), East Alton, IL; and Revere Copper
Products, Inc., Rome, NY. Tha following trade unions are also petitioners:
The International Association of Machinists and Aerospace Workers; the
International Union, Allied Industrial Workers of America (AFL-CIO); Mechanics
Educational Society of America, Local 56; and the United Steelworkers of
America (AFL-CIO/CLC).
The petitions allege that an industry in the United States is materially
injured and threatened with material injury by reason of imports from Brazil
and France of certain brass sheets and strips which are alleged to be
subsidized by the Governments of Brazil and France. In addition, the
petitions allege that an industry in the United States is materially injured
1/ For purposes of these investigations, the term "certain brass sheets and strips" refers to brass sheets and strips of solid rectangular cross section, over 0.006 inch but not over 0.188 inch in thickness, in coils or cut to length, whether or not corrugated or crimped, but not cut, pressed, or stamped to nonrectangular shape, provided for in items 612.3960, 612.3982, and 612.3986 of the Tariff Schedules of the United States Annotated (TSUSA). The petitions limit the scope of the investigations to sheets and strips of brass alloys designated as "C20000-series" under the nomenclature and numbering system of the Unified Numbering System (UNS) or the equivalent "200-series" under the Copper Development Association (CDA) numbering system.
3
and threatened with material injury by reason of im~orts from Brazil, Canada,
France, Italy, the Republic of Korea, Sweden, and West Germany of certain
brass sheets and strips which are allegedly being sold in the United States at
LTFV.
Accordingly, the Commission instituted, effective March 10, 1986,
preliminary countervailing duty investigations Nos. 701-TA-269 (Preliminary)
(Brazil) and 701-TA-270 (Preliminary) (France), under section 703(a) of the
Tariff Act of 1930 and, further, the Commission instituted, under section
733(a) of the Tariff Act of. 193.0, preliminary antidumping inv~.stigations Nos.
731-TA-311 (Preliminary) (Brazil), 731-TA-312 (Preliminary) (Canada),
731-TA-313 (Preliminary) (France), 731-TA-314 .(Preliminary) (Italy),
731-TA-315 (Preliminary) (the Republic of Korea), 731-TA-316 (Preliminary)
(Sweden), and 731-TA-317 (Preliminary) (West Germany).
Notice of the institution of the Commission's investigations and of a
public conference to be held in connection therewith was given by posting
copies of the notice in the Office ox the Secretary, U.S. International Trade . ' Commission, Washington, DC, and by publishing the notice in the Federal
Register of March 19, 1986, (53 F.R. 9536). The conference was held in
Washington, DC, on April 4, 1986, and all persons who requested the
opportunity were permitted to appear in person or by counsel.
5
VIEWS OF THE COMMISSION
We unanimously determine that there is a reasonable indication that an
industry in the United_ States is materially injured !I by reason of imports of
brass sheets and strips from Brazil, Canada, France, Italy, the Republic of
Korea (South Korea), Sweden, and the Federal Republic of Germany (West
Germany) that are allegedly being sold at less than fair value (LTFV) or upon
which bounties or grants are alleged to be paid.
These determinations are based primarily on the deteriorating conditions
of the domestic industry in 1984-85, the significant market penetration
ratios, and adverse impact of imports on prices for the domestic product
during the period of these investigations.
Like proauct and the domestic industry
The statute instructs the Commission to identify the domestic industry to !
be examined in order to determine whether material injury j>r the threat of
material injury exists. The statute defines the "domestic industry" 21 in
terms of producers of the "like product", which is, in turn, defined in terms
of the "article subject to an investigation."~/
1/ Material retardation is not an issue in these investigations and will not be discussed further. 'l:_I Section 771(4)(A) defines that term "industry" as "the domestic producers as a whole of a like product, or those producers whose collective output of tho 1iko product conatitutea a major proportion of the total domestic production of that product. 19 u.s.c. § 1677(4)(A). In turn, "like product" is defined as a "product which is like, or in the absence of like, most similar in characteristics and uses with, the article subject to an investigation." 19 U.S.C. § 1677(10). ;!/ The "article subject to an investigation" is defined by the scope of the investigations initiated by the Department of Commerce, which in this case covers "brass sheet and strip, other than leaded brass and tin brass sheet and strip, currently provided for under items 612.3960, 612.3982, and 612.3986 of the Tariff Schedules of the United States Annotated (TSUSA)." 51 Fed. Reg. 11771-11778. (April 17, 1986).
6
Brass sheets and strips are products of a solid rectangular cross section
that is over 0.006 inch but not over 0.188 inch thick, in coils or cut to
length, whether or not corrugated or crimped. Sheets are over 20 inches wide,
and strips are over 1.25 inches but not over 20 inches wide. !I The articles
under investigation are brass sheets and strips known as the C.D.A. 200 or
U.N.S. C20000-series. ~/ ~I They are manufactured in three basic stages:
casting, rolling, and finishing. l/ Some of the unfinished brass material is
purchased by firms commonly referred to as reroll~rs which have processing
equipment for rolling brass sheet and strip to a final thickness but do not
have casting facilities or break-down mills. ~/
The chief characteristics of the products under investigation are ease of
manufacture, electrical cond~ctivity, excellent forming and drawing .
properties, and good strength. The uses to which they can be put are
virtually unlimited and include automotive radiators, electrical connectors,
terminals, electrical sockets, locksets, jewelry, coins and medallions, lamp,
bases, hinges, ornaments, and cartridge cases. ii . There is no distinction between the imported and the domestic product.
However, at the conference several opponents of the petition urged the
Commission to find two separate and distinct like products: reroll (brass
!I ~eport of the Commission ("Report") at A-3. 51 Brass is an alloy of copper in which zinc is the principal alloying element, with or without small quantities of other elements. Among the various numbering systems that have been devised to categorize the different alloys within the family of brasses is the three-digit numbering system of the Copper Development Association ("C.D.A.") and the five-digit Unified Numbering System ("U.N.S."). ~I In 1985 the UNS C20000-series represented approximately 90 percent of the U.S. consumption of brass sheets and strips. Report at A-2. 71 Report at A-3-4. ~I Id. at A-4, A-6. ii Id. at A-5.
7
material to be rerolled) and finished brass sheet and strip products. We have
declined to do so and note that our decision is based on factors established
in previous cases 10/ that have addressed the issue of whether semi-finished
(reroll in this case) and finished products constitute one like product.
Amon~ the factors that we have considered are physical characteristics,
interchangeability, market, costs of processing, complexity of processing,
labor, price, and independent uses. In making our decision, we note the
following factors: metallurgically reroll and the finished products are
identical; they are produced in the samemanner; they can be interchanged; and
reroll may need little or no further processing.
In light of the above factors, the Commission finds, for the purposes of
these preliminary investigations, that there is one like product, brass sheets
and strips, which includes reroll and finished products and that the domestic
industry consists of the producers of these products. 11/ Furthermore, we
determine that ·the domestic industry includes primary mills with casting
10/ !.:_&.,Nylon Impression Fabric from Japan, Inv. No. 731-TA-269 (Preliminary), USITC Pub. 1726 at 5 (1985); Oil Country Tubular Goods from Argentina and Spain, Invs. Nos. 731-TA-191, 731-TA-195 (Final), USITC Pub. 1555 at 4-5 (1984); Certain Flat-Rolled Carbon Steel Products from Brazil, Inv. No. 731-TA-123 (Final), USITC Pub. 1499 (1984); Low-Fuming Brazing Copper Wire and Rod from France, New Zealand, and South Africa, Inv. No. 701-TA-237 (Preliminary) and Invs. Nos. 731-TA-245-247 (Preliminary), USITC Pub. 1673 at 8 (1985); Certain Welded carbon Steel Pipes and Tubes from the Republic of Korea and Taiwan, Invs. Nos. 731-TA-131-132 (Final), USITC Pub. 1514 (1984); Choline Chloride from Canada, Inv. No. 731-TA-155 (Final), USITC Pub. 1595 at 4-5 (1984); Fireplace Mesh Panels from Taiwan, Inv. No. 731-TA-49 (Preliminary), USITC Pub. 1186 at 4 (1981); Sorbitol from France, Inv. No. 731-TA-44 (Final), USITC Pub. 1233 at 4 (1982). 11/ In the event that these investigations return to the Commission for final investigations, the Commission will further examine the issue of whether reroll and the finished products constitute a single like product or separate like products and whether rerollers should be included as members of the domestic industry.
8
capabilities and firms known as rerollers. 12/
Condition of the domestic industry
In assessing the ·condition of the domestic industry the Commission
considers, among other factors, wages, sales, financial.performance,
production, capacity, capacity utilization, employment, and consumption. 13/
The U.S. brass sheet and strip industry showed improvement from 1983 to
1984, followed by a sharp reversal in 1985. The industry's net sales rose
from $320 million in 1983 to $356 million in 1984, an increase of 11.4
percent, and then declined to $296 million in 1985, a decrease of 16.8
percent. Operating income increased from $11.2 million in 1983 to $18.7
million in 1984, an increase of 66.4 percent, and then in 1985 dropped to only
$2.1 million, a decline of 88.7 percent from 1984. 14/
other economic indicators reveal similar trends. Production of C20000
brass sheets and strips increased by 12.3 percent from 1983 to 1984 and
declined 17.4 percent from 1984 to 1985. 15/ The industry's overall
12/ Petitioners contend that the commission should invoke the related parties provision to exclude the operations of domestic rerollers that import brass material from its analysis of the domestic industry. 19 U.S.C. § 1677(4)(B). They argue that the inclusion of the rerollers might distort the injury data. Application of the related parties provision is within the sound discretion of the Commission after analyzing the facts of each case. !.:A·• Rock Salt from Canada, Inv. No. 731-TA-239 (Final), USITC Pub. 1798 (1986) (Vice Chairman Liebeler concurred in the result on the related party issue). For these preliminary investigations, the Commission has only received questionnaire responses from two rerollers, neither of whom imports or is related to a foreign producer. Thus, there is no factual information to substantiate petitioners' allegations that the related parties provision is applicable. 13/ 19 U.S.C. § 1677(7)(C)(iii). 14/ Report at A-15-16. Moreover, in 1983 only one out of seven firms reported losses on their C20000-series brass sheet and strip production, in 1984 no firms reported losses, and in 1985 four firms reported losses. 15/ Id. at A-9.
9
capacity increased from 1983 to 1985. 16/ Capacity utilization rose from 69.8
percent in 1983 to 77.6 percent in 1984, but declined to 61.0 percent in
1985. 17/ Industry shipments of brass sheets and strips rose about 60 million
pounds from 1983 to 1984, from 410 million pounds to 470 million pounds, but
dropped about 85 million pounds from 1984 to 1985. 18/ Employment, hours
worked, wages paid, and total compensation rose from 1983 to 1984 and then
declined sharply from 1984 to 1985; the number of workers producing C20000
series brass sheets and strips declined 15.8 percent, hours worked declined
20.2 _percent, and wages paid declined 18.9 percent. 19/ Likewise, apparent
consumption of C20000-series brass sheets and strips in the United States rose
from 533.6 million pounds in 1983 to 654.4 million pounds in 1984, and then
dropped to 529.2 million pounds in 1985. U.S. producers' shipments accounted
for 76. 7 pe_rcent of consumption in 1983, 71. 9 percent in 1984, and 72. 7
percent in 1985. 20/ .
Based on the foregoing information, we find that there is a reasonable.
t
indication that the domestic brass sheets and strips industry is experiencing •
• material injury. 21/ 22/
16/ Kuch of the equipment used to produce C20000-series brass sheets and strips can also be used to produce other types of brass sheets and strips. Kost lirms that responded to the.Commission's questionnaire did not or could not separate- these data. Thus, the most meaningful statistic is total capacity. Hence, presented figures for capacity utilization are representative of all series of brass sheets and strips. 17/ Report at A-9. 18/ Id. at A-11-12. We note that while export shipments by domestic firms rose sharply during the course of these investigations, exports accounted'for a very small fraction of total shipments. 19/ Id. at A-12-14. 20/ Id. at A-7. 21/ Chairwoman Stern does not believe it necessary or desirable to make a determination on the question of material injury separate from the consideration of causality. She joins her colleagues by concluding that the domestic industry is experiencing economic problems. 221 Commissioner Eckes believes that the Commission is to make a finding regarding the question of material injury in each investigation. See, American Spring Wire Corp. v. United States, 590 F. Supp. 1273, 1276 (Ct. Int'! Trade 1984), aff'd sub nom., Armco Inc. v. United States, 760 F.2d 249 (Fed. Cir. 1985). · ·
10
Cumulation
Under the Trade and Tariff Act of 1984 (the 1984 Act), the cumulative
impact of imports from several countries shall be assessed if the imports
(1) compete with both other imports and the domestic like product, (2) are
marketed within a reasonably coincidental period; and (3) are subject to
investigation. 23/ 24/
The respondents have raised several arguments against cumulation.
Metallverken, Inc. maintains that imports of brass sheets and .. strips from
Sweden do not compete nationally with other imports and domestic products. '~
However, the Commission has no information supporting that allegation.
Moreover, we have serious reservations about the legal sufficiency of this
argument.
Trefimetaux asserts that imports from France should not be cumulated
with the finished product imports, because the great bulk of the French
imports are reroll. Conversely, Elunia urges the Commission not to cumulate
the Brazilian finished brass sheets and strips imports with reroll imports . . We believe that like products that compete with each other should be
cumulated. As is discussed above, f.or these preliminary investigations we •
have determined that there is only one like product and that they compete.
Lastly, Poongsan Metal Corp. and Pan Metal Corp. argue that the statute
and the legislative history make it clear that Congress intended cumulation of
small sources with each other, but not of small sources with very large
sources. They al~ege that South Korea is a small source. We believe that the !
23/ Commisioner Eckes cross-cumulated the effects of prices and volume of the allegedly LTFV imports from Canada, Italy, South Korea, Sweden, and West Germany with the allegedly subsidized imports form Brazil and France. In these particular investigations, however, Commissioner Eckes would have found affirmatively without cross-cumulating. 24/ 19 U.S.C. Sec. 1677(7)(E); H.R. Rep. No. 725, 98th Cong., 2d Sess. 37 (1984).
11
legislative history should not be read as narrowly as proposed by the
respondents.· The criteria that are established in the legislative.history for
cumulation require the Commission to consider and evaluate the facts and
realities regarding the interactions of the producers in the market. Nothing
suggests:that Congress did not intend this type of analysis when one of the
importers is much larger than another. 25/
Accordingly, we have cumulated the volume and price effect of LTFV
imports from Brazil, Canada, France, Italy, South Korea, Sweden and West
Germany. We have also cumulated the volume and price effect of al.legedly
subsidized imports from Brazil and France. 26/ 27/ 28/
251 In Certain.carbon. steel Pipes and Tubes from the PRC, the Philippines and Singapore, Invs. Nos. 731-TA-292 to 296 (Preliminary), USITC Pub. 1796 at 15 (1985), the Commission found that~ small producer may very.well be the price leader. · . 26/ commissioner Rohr and Commissioner Lodwick find that ~hey do not need to reach the issue of whether cross-cumulation is necessary at this time because they reached an affirmative determination. · · 271 Chairwoman Stern does not.believe cross-cumulation is appropriate. 28/ Vice Chairman Liebeler and Commissioner Brunsdale also do not believe cross-cumulation is appropriate. They note that the commission has voted to appeal Bingham and Taylor, Division Virginia Industries, Inc. v. United States, Slip Op. 86-14 (Feb. 14, 1986) to the Court of Appeals for the Federal Circuit and believe that the statute is clear on this matter. First, the Commission's treatment of foreign government subsidization of imports and sale.s by private firms at LTFV are governed by different sections of title VII. This raises a presumption that Congress intended to treat the two activities separately. Second, not cross-cumulating is historical commission practice, existing prior to the statutory enactment of the existing statutory cumulation provisions. Obviously, Congress couid have chosen to alter this practice but did not do so. Third, the wording of the operative sections of title VII precludes cross-cumulation. For example, the language of the countervailing duty section clearly requires that the .injury be by reason of the subsidized imports, not subsidized and dumped imports. If the commission were to cross-cumulate, it would be acting outside its statutory mandate. The Commission simply cannot make an affirmative determi.nation in, !h&· a countervailing duty case based on dumped imports. For a detailed explanation ~Certain Carbon Steel Products from Austria, et. al., Invs. Nos. 701-TA-225-234 and 731-TA-213-217, 219, 221-226, and 228-235, (Preliminary), USITC Pub. No. 1642, at 43-48 (Views of Vice Chairman Liebeler).
12
Reasonable indication of material injury or threat by reason of allegedly LTFV imports from Brazil, Canada, France, Italy, South Korea, Sweden; and West Germany 29/
To ascertain whether there is a reasonable indication of material injury
by reason of allegedly LTFV imports, the Commission is directed to consider,
among other factors:
i) the volume of imports of the merchandise which· is the subject of the investigation,
ii) the effect of imports of that merchandise on · prices in the United States for like products, and ·
iii) the impact of imports of such merchandise on domestic producers of like products. 30/ 31/
29/ We did not reach the issue of threat. In a final investigation in considering whether the domestic industry is threatened with material injury, the Commission needs additional data regarding foreign capaci~ies, U.S. and foreign inventories, the potential for product-shifting and prices of the various products of the countries.under investigation. 30/ 19 U.S.C. § 1677(7)(B). 31/ Vice Chairman Liebeler finds five factors.to be particularly helpful on the issue of causation. An affirmative vote is more likely when the following conditions are present: (1) a large and increasing market share; (2) a high margin of dumping or subsidization; (3) homogeneous products; (4) declining domestic prices; and (5) barriers to entry (or low elasticity of supply of other imports). ~Certain Red Raspberries from Canada, Inv. No. 731-TA-196 (Final), USITC Pub. 1680 at 11-19 (1985). As to (1), she notes that in the LTFV investigations, market share is moderate, and declined from 1984 to 1985. Although import market share increased between 1983 and 1984, there is some evidence that there were periods of demand that could not be met by domestic producers. In the subsidy investigations, market penetration.is low, but absent information on other factors is not determinative. As to (2), the data on margins is too tentative from which to draw firm conclusions. As to (3), physical characteristics of the products appear to be the same but delivery conditions and minimum quantity requirements for sales are markedly different. As to (4), the Commission needs to investigate the pricing data in more detail, especially the effect of declining metal prices on brass sheet and strip prices. See footnote 39, infra. As to (5), we have very little information on foreign supply elasticity but we do know that other foreign countries supplied about 8.6 percent of U.S. consumption in 1985. The data gathered in preliminary investigations are often incomplete and data gathered during the final investigations should enable a more precise causation analysis.
13
In determining whether imports of brass sheets and strips are causing
material injury to a domestic industry, we have cons.idered the. -cumulative . ~
volume and effect of LTFV imports from Brazil, Canad~, France, Italy, South
Korea, Sweden and West G~rmany. We note that imports 01
f brass sheets and ·
strips from these seven countries increased 61. 2 percent from 85. 7 million·.
pounds in 1983 to 138.1 million pounds in l984, and then dropped by 28.2
percent to 99.2 million pounds in l985. 32( The import penetration ratio also
increased from 16.l percent in 1983 to-21.1 percent in 1984 ·and dropped to
18.7 percent in 1985. 33/
The Commission requested producers and importers to provide quarterly
price data during 1983-85 on spot market sales and on fixed-period contracts
negotiated for four common brass sheet and strip products. The price data for
domestic producer spot sales indicate that the weighted-average prices
fluctuated considerably but showed a downward trend .. 34/. The·price data for
imports from France, West Germany; ·South Korea and ·sweden suggest that
importers', p·rices generally fell during the period of investigation, while the·
data for Braziiian imports show·prices trending upward in two out of three.
product categorie~. 35/
Usabie price ·data on domestic fixed-period, non-toll contracts show a .. decline in the weighted-ave~age total selling prices- during the period of
investigation. 36/ Importers' data indicate that the total selling prices and ·
32/ Report at A-20. 331 Id. at A-23. 34/ Id. at A-26-28. 351 Id. at A-28. 36/ Id. In analyzing these prices it should be noted how changing metal values affect the total price of brass sheets and strips and that fabrication prices of the products for which data were collected either remained steady· or .. increased in the United States.
14
fabrication prices of the material also declined. 37/ The margins of
underselling associated with the products.for all· the countries reveal . .
that there was consistent underselling throughout the period of
investigation. 38/ 39/
we conclude that the rising volume of brass sheets and strips from
Brazil, Canada, France, Italy, South Korea, Sweden, and West Germany, and the
significant import penetration during the period of investigation, together
with underselling and generally declining prices, establish a reasonable
37/ Id. at A-33. 38/ Id. at A-33-38. 39/ Vice Chairman Liebeler and Commissioner Brunsdale generally do not find evidence of. underselling probative of· the issues of prfce undercutting or causation. See Certain Welded Carbon Steel Pipes and Tubes from Turkey and Thailand-, Invs. Nos. ,701-TA-253 (Final), and 731-:rA-252 (Final) (Views of vice Chairman Liebeler and Commissioner Brunsdale at 44-45)~ Office of Economics Memorandum EC-J-010. Moreover, they have serious reservations about t~e data collected in these investigations allegedly supporting a conclusion that imports consistently undersell the domestic product. Price comparisons in the spot market, where most import sales but comparatively few domestic sales occur, do not account fully for the larger quantities involved in import sales. Quantity discounts, differences in lead times, or other terms of sale were either not available ·or were not fully accounted for when making price comparisons. Should a final investigation occur, more complete and directly comparable data would be needed' in order to draw any reasonable conclusions about the relationship between foreign and domestic prices. Similarly, the available data on fabrication prices, which indicate that foreign prices are higher than domestic prices, are limited. The data are for contract sales only and do not include imports from all countries subject to investigation.
In addition, Vice Chairman Liebeler and Commissioner Brunsdale note that metal value accounts for a large proportion of the selling price of brass sheet and strip and the available data indicate that metal values have declined between 5 and 13 percent during the period of investigation. Thus, it is hardly surprising that total selling prices for the domestic and the imported product have declined during this same period. It is surprising, however, that total selling prices may have declined by less than could be expected given the drop in metal valu·e and that fabrication prices have apparently remained steady or increased. In a final investiga~ion, they would seek to receive an explanation for these differing trends, especially in light of the drastic drop in demand for brass sheet and strip in 1985.
15
indication of a causal connection between the material injury to the domestic
industry and the alleged LTFV imports from the seven countries.
Reasonable Indication of Material Injury by Reason of Allegedly Subsidized Imports.from Brazil and France
In determining whether there is a reasonable indication that allegedly
subsidized imports are causing material injury to a domestic industry, we have
considered the cumulative volume and effect of imports from Brazil and France.
We note that the volume of imports from these countries is significant.
Imports of brass sheets and strips from Brazil -and France increased by 117 . .
percent from 17.9 million pounds in 1983 to 38.8 million· pounds in 1984.
Imports declined by 50 percent to 19.4 million pounds in 1985, but remained
above the 1983 level .. 40/ The import penetratio~ ratio rose from 3.3 percent
in 1983 to 5.9 percent in 1984 and then dropped to 3.6 percent in 1985. 411
The margins of underselling associated with the products for Brazil and
France reveal the same trends discussed in the LTFV section of this
determination. There was consistent underselling throughout the period of
inve~tigation. 42/ 43/ Moreover, overall prices for domestically produced
brass sheets and strips declined, 44/ while the French import prices generally
declined and the Brazilian import prices generally followed an upward trend
during the period under investigation. 45/
We conclude that the rising volume of brass sheets and strips from Brazil
and France, and the significant import penetration, together with underselling
40/ Report at A-22. 41/ Id. at A-23. 42/ Id. at A-33, A-36. 43/ For views of Vice Chairman Liebeler and Conunissioner Brunsdale regarding underselling, see footnote 39, supra. 44/ Id. at A-26-28, A-29-31. 45/ Id. at A-28.
16
and generally declining prices, establish a reasonable indication of a causal
connection between the material injury to the domestic industry and the
allegedly subsidized imports from Brazil and France.
A-1.
INFORMATION oBrAINED IN THE INVESTIGATIONS
Introduction
On March. 10,. 1986, petitions were filed with the. U.S. International Trade Commission and the U.S •. Department of Commerce by counse 1 on behalf of American Brass, Buffalo, NY; Bridgeport Brass Corp., Indianapolis, IN; Chase Brass & Copper Co., Solon; OH; Hussey Copper Ltd.~ Leetsdale,·PA; The Miller Co., Meriden,. CT; Olin Cqrp. (Brass·Group) ,. East Alton; IL; and Revei:e Copper Products, Inc., Rome, NY. The following trade unions are also petitioners: The International Association of Machinists and Aerospace Work~rs;~the International Union, Allied Industrial Workers of America (AFL-CIO); Mechanics Educational Society of America, Local 56; and the United Steelworkers of America (AFL-CIO/CLC).
The petitions allege that an industry in the United States is materially injured and threatened with material injury by reason of imports from Brazil and France of ~ertain brass sheets and strips 1/ that are alleged to be subsidized by the Governments of Brazil and France.' In addition, th~ petitions allege that an industry in the United States is materially injtired and threatened with material injury by reason of imports from Brazil, Canada, France, Italy, the Republic of Korea (Korea), Sweden, and West Germany of certain brass sheets and strips.that are allegedly being sold in the United States at less than fair value (LTFV}. ·
Accordingly, the Commission .ins"tituted, effective March 10, 1986, preliminary countervailing duty investigati6ns Nos. 701-TA-269 (Preliminary) (Brazil) and 701-TA-270 (Preliminary) (France), under section 703.(a)' of the Tariff Act of 1930 and, further, the Commission instituted, under section 733(a) of the Tariff Act of 1930, preliminary antidumping investigations Nos. 731-TA-311 (Preliminary) (Bra_z·il), 731-TA•312 (Preliminary) (Canada),· 731-TA-313 (Preliminary) (France),- 731-TA-314 (Preliminary) (Italy)·, 731-TA-315 (Preliminary) (Republic of Korea), 731-TA-316 (Preliminary) (Sweden), and 731-TA-317 (Preliminary) (West Germany), to determine whether there is a reasonable indication that an industry in the United States is materially injured, or is threatened with material injury, or the establishment of an industry in the United States is materially retarded, by reason of imports of such merchandise into the Unit~d Stat~s.
!/ For purposes of these investigations, the term "certain brass sheets and strips" refers to brass sheets and strips of solid rectangular cross ~ection, over 0.006 inch but not over 0.188 inch in thickness, in coils or cut ·to length, whether or not corrugated or crimped, but not cut, pressed, or starope.d to nonrectangular shape, provided for in items 612.3960, 612.3982, arid 612.3986 of the Tariff Schedules of the United States Annotated (TSUSA). The. ~. petitions limit the scope of the investigations to sheets and. ~trips of brass alloys designated as. "C20000-series" under the nomenclature· and· numbering system of.the Unified Ntimbering System {tiNS) or the equivalent "200-series" under the Copper Development Association (CDA) numbering system.
A-2
Notice of the institqtion of the Commission's investigations and of a conference to be held in connection therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International Trade Commission, Washington,.DC, and by publishing the notice in the Federal Register of March 19, 1986 (51 F.R. 9536). ];./ The conference was held on April 4, 1986, 2/ and the briefing and vote was held on April 18, 1986. The statute directs-that the Commission make its determinations within 45 days after receipt of the pet~tions or, in these cases, by April 24, 1986.
These are the first Commission investigations with respect to brass sheets and strips.
The Product
Description
Wrought 1./ brass sheets and strips meeting the composition specifications o"f the Unified Numbering System for Metals and Alloys (UNS) C20000-series, 4/ other than clad sheets, no~ cut, pressed, or stamped to nonrectangular.shap;, are the subject of these investigations. Brass is an alloy of copper (not including nickel silver) in which zinc is the principal alloying element, with or without small quantities of other elements. There are three g~neral· categories of brasses: copper-zinc alloys (brasses) covered by the UNS, C20000-series, copper-zinc-lead alloys (lead~d brasses) covered by the UNS CJOOOO-series, and copper-zinc-tin alloys (tin brasses) covered by the UNS C40000-series. 5/
UNS C20000-series represents the major portion (approximately 90 percent in 1985) of U.S. consumption of brass sheets and strips. Petitioners state that leaded and tin brasses are essentially not competitive with UNS C20000-series brasses. 2_/
1/ Copies of the Commission's and Commerce's notices are shown in app. A. Z/ A list of witnesses· appearing at the conference is presented in app. B. 3/ The term "wrought" refers to products that have been rolled, forged,
drawn, or extruded, and also refers to cast or sintered products that have been machined or processed otherwise than by simple trimming, scalping, or descaling.
4/ The Unified Numbering System for Metals and Alloys is managed jointly by th; American Society for Testing and Materials and the Society of Automotive Engineers.
5/ Specifications for each of these UNS series are presented in app. C. 6! Petitions of the instant investigations, pp. 8-9. Petitioners state that
the high-machining abilities of leaded brasses and extremely high strength and spring characteristics of tin brasses cause these alloys frequently to be incompatible with normal UNS C20000-series uses. The additional processing expenses required for lead and tin brasses and the higher metal cost for the tin braGses make substitution of these brasses for the UNS C20000-series brasses unusual.
A-3
For the purposes of these investigations, sheets and strips are prociu::~ of solid rectangular cross section over 0.006 inch but not over 0.188 inch in -thickness, in co.ils or cut to length, whether or not corrugated or crimped. 1/. Sheets are over 20 inches in width; strips are over 1.25 inches but not over-20 inches in width.
Manufacturing process
At integrated producers, firms that cast, roll, and finish brass sheets and strips, the.manufacturing process begins with the production of brass at casting facilities. Casting operations produce brass ingots that are roughly 5 to 7 inches thick, 30 inches wide, and 25 feet long.· These ingots are produced by the direct chill technique. Brass production begins with the acquisition ~f raw materials. Producers utilize refined products, such as ~opper and zinc •nd, also, scrap materials, scrap purchased and that ~enerated by .their own manufacturing operations. Producers do hot always bciy all the raw materials they use in the production of brass sheets and strips. Some customers believe they can obtain copper at lower prices than can the brass producers. Such customers provide brass·producers with copper and pay brass producers a fee to have that copper converted into brass sheets and strips. Such arrangements are termed "tollin_g" in the industry.
Raw materials are ~easured and placed in a melting furnace. When the raw materials are properly melted, they are pou~ed from the melting furnace into a holding furnace. Several melting furnaces typically service each holding furnace. When a holding furnace is sufficiently filled, casting operations· begin. Molten brass is then directed from the holding furnace into single or multiple molds. These molds function as dies; they are approximately 1 foot thick and bottomless. The molds rest on a piston device that is enclosed in a water-filled cylinder. As the mold fills with molten brass, the piston is gradually lowered, and the brass coolS and hardens as it is exposed. to ·the. water. Once the entire ingot"is cast, the ingot is removed from the casting equipment. Before further processing, the rough ends of the ingots are cut off.
At this point, rolling operations begin with hot-breakdown rolling. The ingots are heated, rolled (reducing them in thickness from approximately 5 to 7 inches in thickness to less than 0.5 inch), and coiled. This material is milled for surface irregularities and then further reduced in thickness to · 0.188-inch or less through cold-breakdown rolling. The extent of further processing is entirely dependent on customer requirements. Material purchased by firms that have processing equipment of their own, rerollers, might require little or no further processing. The larger portion of the material would typically undergo a variety of additional operations, such as bell annealing,
l/ The domestic industry considers brass strips to be brass that is coiled or-wound on reels of whatever gauge and width, and brass sheets to be brass that is no longer coiled or wound but ha~ been cut to length and is identified by gauge, width, and length. Petitions of these investigations, p~ 4.
A-4
strip annealing, cleaning, rolling, tension leveling, ~litting (to achieve a desir~d width), and cutting to length to meet customer specifications. Once all operations are completed, the material is packed and shipped.
Uses ,.
The chief characteristics of the UNS C20000-series of brasses are ease of manufacture, fair electrical conductivity, excellent forming and drawing properties, and good strength. They are used in automotive radiators, electrical hardware, locksets, jewelry, coins, lamp bases, hinges, ornaments, and cartridge cases. ];_/
U.S, tariff treatment
Imports of wrought brass sheets and strips meeting the specifications for br~sses of the UNS C20000-series, other than clad sheets, not cut, pressed, or stafuped to nonrectangular shapes, are classified and r~ported for tariff and st•tistical purposes under items 612.3960 (sheets), 612.3982 (strips under l/t6 inch in thickness), and 612.3986 (strips 1/16 inch or more in thi~kness) of the Tariff Schedules of the United States Annotated (TSUSA). The current coiumn I or most-favored-nation (MFN) rate of duty, 2/ final concession rate gra,rited under the Tokyo Round of the Multilateral Tr:;-de Negotiations (MTN), and column 2 duty rate are shown in table 1.
TSUS item
Table 1.--Brass sheets and strips: U.S. rates of duty 1/ as of Jan. 1, 1980, Jan. 1, 1986, and Jan. 1, 1987
(Pe~cent ad valorem)
Description Col. l Col. 2
;Jan. 1, 1980~Jan. 1, 1986~Jan. 1, 1987~
~/ 612.39 Brass sheets and strips.
3/ 2% 3/ 1.9% 3/ 1.9% :9%.
1/ Rates of duty for Tariff Schedules of the United States (TSUS) item 612.39 are divided into col. 1-a and col. 1-b rates of duty. Col. 1-a rates apply when the market price of copper is 24 cents or more per pound. Col. 1-b
c rates apply when the market price of copper is under 24 cents per pound, but copper prices have averaged well above that level in the 1980's.
2/ Includes TSUSA item~ 612.3960, 612.3982, and 612.3986. J/ Col. 1-a rate. Col. 1-b rate, applicable if the market price of copper
drops below 24 cents per pound, is 0.9t per pound on copper content+ 0.9t per pound.
1/ Petitions of these investigations, p. 6. l/ The col. l rates are applicable to imported products from all countries
except those Communist countries and areas enumerated in general headnote 3(f) of the TSUSA.
A-5
Imports of the subject product are eligible for duty-free treatment if from designated beneficiary countries under the Generalized System of Preferences (GSP); imports from.Brazil and Korea' are eligible for GSP treatment. ·
... The U.S. Market
U.S. producers
The petitioners define the U.S. industry as firms that cast, roll, and finish brass sheets and strips. !I There are nine known U.S. firms that meet that definition, the seven petitioning firms and MRM Industries and Plume & Atwood Brass Mill. A 10th firm, Volco Brass & Copper Co., is currently in liquidation. The nine active firms, the locations of their facilities, and their share of producers' shipments .of C20000-series brass sheets and strips in 1985 are presented in the following tabulation:
Firm and plant locations
American Brass------~~----------------~--~ Buffalo, NY; Kenosha, WI
Bridgeport Brass.Corporation-----~-------Brian, OH; Indianapolis, IN
Chase Brass & Copper Company--~--~-------Solon, OH
Hussey Metals----------------------------Leetsdale, PA
MRM Industries---~----~--------------~---Meriden, CT.
Olin Corporation--~-----~--~-------------E. Alton, IL; Waterbury, CT
Plume & Atwood Brass Mill----------------Revere Copper Products, Inc.-------------
Rome, NY The Miller Company------------------~-----
Keriden, CT; Thomaston, CT . Total-------~--------~-~----~---------
Share of U.S. producers' shipments
in 1985 (Percent)
***'
. ***
. ***
***
***
***
*** ***
***
100.0
Petitioners accounted for *** percent of shipments of C20000-series brass sheets and strips, on the basis of quantity, in 1985. · Producers of brass sheets and strips tend to be'either subsidiaries of large rnultiproduct corporations or relatively smail firms that primarily produce brass in various forms. In certain cases, part of a firm's output is captively consumed in brass fabrication operations.
l/ Petitions of these investigations, p. ~·
A-6
Questionnaires were also sent to all firms that were identified as possible rerollers, which roll brass sheets and strips to final thicknesses, but do not operate casting facilities or break-down mills. Of those firms, eight were identified in. the petitions, but only two responded to the Commission's questionnaires. At the Commission's conference for these investigations, petitioners presented a chart indicating that rerollers accounted for 13.9 percent of the U.S. product distribution for brass sheets and strips. 1/ Counsel for French interests stated at the conference that approximately 75 percent of French imports is for reroll; 2/ however, they were unable to quantify the total U.S. reroll market for brass sheets and strips.
U.S. importers
Foreign-produced brass sheets and strips are pr~marily imported by distributors, some of which are subsidiaries of foreign producers of brass sheets and strips, or by agents of foreign producers.
Channels of distribution
U.S. producers with casting facilities market their products to rerollers, distributors, and end users. Rerollers, which may purchase either U.S.- or foreign-produced brass sheets and strips, further process the material and may sell either to distributors or end users. The distributors, which also may purchase u~s.- or foreign-produced material, primarily provide a warehouse service for end users, but they can and do slit the material to width and cut it to length.
Importers use the same channels of distribution, selling to rerollers, distributors, and end users. In some cases, imports are shipped directly to a customer, with the importer of record never physically receiving the merchandise.
U.S. consumption
U.S. apparent consumption is computed as shipments plus imports less exports. Publication of export data could disclose the operations of individual firms; therefore, export quantities are included in producers' shipments. * * *· Export shipments were small, a maximum of *** percent in ***, and their inclusion with other shipments did not result in large errors in consumption data. The quantities of export shipments were *** pounds in 1983, ***pounds in 1984, and ***pounds in 1985. Thus, domestic consumption was overstated by these amounts, and the import to consumption ratio was slightly understated.
1/ Conference exhibit No. 2. 21 Transcript of conference, p. 89.
A-7
Aggregate data compiled from responses to the Commission's importers questionnaires indicate that for Brazil, Canada, France, Italy, Korea, ·Sweden~ and West Germany combined, imports of C20000-series brass sheets and strips accounted for approximately 98 percent of total imports. Therefore~ official statistics·of the U.S. Department of Commerce are· believed to be the best available information"for imports from all countries and are used for imports of C20000-series brass sheets and strips. Thus~ imports of C20000-series brass sheets and strips, as reported here, are overstated by about 2 percent~ and the import to consumption ·ratio is also slightly overstated because of this. The assumptions concerning imports ana exp9rts lead to small errors that tend to off set one another~ ·
Based upon these data, as presented in table 2, apparent consumption of C20000-series brass sheets and strips increased from 1983 to 1984, then dropped back to about the 1983 level in 1985. · J.'he ratio of imports to consumption increased from 23.3 percent in 1983' 'fo 28.l percent in 1984 and then declined slightly, to 27.3 percent, in 1985.
Table 2.--Brass sheets and strips: U.S. producers' shipments, imports for consumption, and apparent consumption, 1983~85
• Ratio to
Item and period u.s.
producers' :Imports 2/ Apparent · . . . : consumption of--consump- :Producers':
· =shipments l/: -: - : tion hi · ·t Imports : s pmen s:
-----------1,000 pounds---------- ------Percent------C20000-series brass
sheets and . . . strips:
1983---------------: 409,525 124,083 533~608 76.7 23~3 1984---------------: 470,306 184,082 654,388 71.9 . 28.1 1985----------------: 384,637 :3/ 144,538 529,175 . 72.7 . 27.3 .
Other brass sheets and strips: ..
1983--------~------: 37 ,378 2/ ,. 37 ,378 100.0 o~o 1984---------------: 43,476 21 43,476 100.0 o.o 1985---------------: 44,573 21. 44,573 100.0 o.o
Total brass sheets: 19 83---------:-----:. 446,903 124,083 . 570,986 . 78.3 21. 7 . . . 1984----------~----: 513, 782 184,082 697,864 73.6 26. 4 : 19 8 5-------·--------: 429,210 :~/ 144,538 573~748 74.8 25~2
l/ Total U.S. producers' shipments include small quantities of export shipments and, therefore, are overstated. These exports are included with total shipments to .av~id disclosing the operations of individual· firms.
Jj Official U.S. Department .of Commerce import data f.or all brass sheets and strips include small quantities of brass sheets and strips other than the C20000-series and, therefore, are overstated. ll Corrected data received from the U.S. Department of Commerce.
Source: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission and official statistics of the U.S. Department of Commerce.
A-8
The Nature and Extent of Alleged Sales at LTFV and Alleged Subsidies
Alleged sales at LTFV
In general, petitioners used the average unit values of brass sheets and strips as reported in official statistics of the U.S. Department of Commerce, to estimate LTFV margins. Unit values were first.-netted back to an ex-factory level by deducting the cost of packing and handling as well as foreign inland freight. This ex-factory U.S. price was then subtracted from the netted-back foreign home market price. Where the netted-back foreign home market price exceeded the ex-factory U.S. price, the difference was divided by the ex-factory U.S. price to derive the estimated percentage ad valorem dumping margins.
Petitioners made several price comparisons for each foreign country and alleged LTFV sales as shown in the following tabulation: ];_/
Country of origin
Brazil Canada France Italy Republic of Korea Sweden West Germany
Alleged subsidies
Low value High value ----Percent ad valorem-----
11.0 9.1 1.8 2.8 2.0 5.5 2.7
55.9 24.9 60.8 22.0 37.1 35.7 62.4
Brazil.--Petitioners allege that the Brazilian producers of brass sheets and strips, primarily the Brazilian producer Eluma, have numerous export and domestic subsidies available to them from the National and State Governments of Brazil. Among these alleged subsidies, petitioners list the following: 2/ working capital for export financing, which petitioners estimate to be 3.3 -percent ad valorem; export financing by the Banco do Brasil, which petitioners estimate to be 2.4 percent ad valorem; export financing by the Foreign Trade Department of the Banco do Brasil, which petitioners estimate to be 2.9 percent ad valorem; and an income tax exemption for export earnings, which petitioners estimate to be 0.8 percent ad valorem. The total alleged subsidies under these programs is 9.4 percent ad valorem. In addition,
1/ Transcript of conference, p. 35. 21 Countervailing duty petition, Brazil, pp. 14-27.
A-9
petitioners allege that there. are several other Brazilian programs that may confer subsidies on producers ··of brass sheets and strips. Included in the other programs are loans· to exporte.rs and imp.orters to finance the purchase by an importer or production by an exporter of Brazilian goods for export; financing for merchandise placed in a bonded warehouse and destined for export; short-term credits for exports, incentives for trading companies, reduction of Brazilian import duties with respect to machinery· and equipment necessary for export programs; export credit premiums; and a number of alleged domestic subsidies. According to petitioners, the aggregate subsidies amount to about 10 percent ad valorem .• !/
France.--Peiiti¢ners allege: that subsidization of the French brass industry is mostly related to subsidization of the French producer, Trefimetaux, and (to a lesser extent) the French firm, Pechiney., which (according to the petitioners) are unprofitable and have been able to exist only through various subsidies.!/!:_/
Consideration of Alleged Material Injury to an Industry in the United States.
U.S. production, capacity, and capacity.utilization
U.S. production of C20000-series brass sh~ets and strips increased by 12.3 percent from 1983 to 1984 and then decreased 17.4. percent •from 1984 to 1985 (table 3). Domestic production of C20000-series brass sheets and strips was less in 1985 than in 1983. U.S. production of all.other series of brass sheets and strips increased 17.7 perc~nt from 1983 to 1984 and 3.8 percent from 1984 to 1985. C20000-series brass sheets and strips accounted for 92.0 percent of total production in 1983, 91.7 percent in 1984, and 89.7 percent in 1985.
Much of the equipment used to produce C20000-series brass sheets and strips can also be used to produce other. types of brass sheets and strips, and most of the firms that reported data in response to the Commission's questionnaires reported the. same capacity figure for both C20000-series brass sheets and strips and other brass sheets and strips •.. Thus, the total capacity seems to be the most meaningful statistic and total capacity is reported .in table 3. Total U.S. capacity to produce all series of brass sheets and strips increased 1.4 percent from 1983 to 1984 and 7.2 percent from 1984 to 1985.
Utilization rates for the total capacity increased 11~2 percent from 1983 to 1984 and then dropped 21.4 p~rc'ent from 1984 to 1985. The capacity utilization rate in 1985 wai iower than that of 1983.
1/ Petitioners estimate that the aggregate subsidies in ~razil and in France amount to about 10 per~ent ad valorem.for each of the countries~ transcript of conference, p. 69. · ·
!:_/ Cou~tervailing duty petition, France, pp. 10-21~
A-10
Table 3.--Brass sheets and strips: U.S. production, practical capacity, and capacity utilization, by types, 1983-85 ·
Item 1983 1984 1985
Production: C20000-series brass sheets
and strips--------------1,000 pounds--: 415,337 466,310 384~946 Other brass sheets and strips-----do----:
----=-=-=~,..,,-,.------==--=-'=""-=--------.,...,=-=-=-=-~ ~otal--------------~------------do----:
36~087 42~481 44~102 451,424 508,791 429,048
Practical capacity: 1/ All series of brass sheets
and strips----------------------do----: 646,670 655~699 703,228 Ratio of production to capacity:
All series of brass sheets and strips-----------~~------percent--: 69.8 77.6 6LO
I/ Practical capacity was defined as the greatest level of output a plant can achieve within the framework of a realistic work pattern. Producers were asked to consider, among other factors, a normal product mix and an expansion of operations that coul4 b~ reasonably attained in their industry and locality in setting capacity in terms of the number of shifts and hours of plant operations. For the mos~ part, firms responding to the Commission's questionnaires reported total capacity to produce brass sheets and strips; therefore, the total is presented above as the best available information.
Source: Compiled frollJ data submitted in response to questionnaires of the U.S. International Trade Commission.
U.S. producers' shipments
·Domestic shipments of C20000-series brass sheets and strips increased*** percent by quantity from 1983 to 1984, then dropped *** percent from 1984 to 1985 (table 4). U.S. producers were requested to provide their shipment data for C20000-series brass sheets and strips, C20000-series brass sheets, C20000-series brass strips, other brass sheets and strips~ other brass sheets~ and other brass strips.
The producers were unable to separate data for sheets from that for strips and, therefore, reported combined data for sheets and strips. Shipments reported in table 4 are shipments of each domestic firm's own production and do not include shipments of brass sheets and strips purchased from another firm or an importer~ or shipments of imported merchandise. Intracompany transfers of C20000-series brass sheets and strips increased *** percent from 1983 to 1984 and then decreased slightly, *** percent, from 1984 to 1985. Toll shipments increased *** percent from 1983 to 1984 and then dropped sharply, *** percent, from 1984 to 1985. Export shipments increaseu * * * during 1983-85, by *** percent from 1983 to 1984 and *** percent from 1984 to 1985. Nevertheless, export shipments were a small fraction of total shipments of C20000-series brass sheets and strips and reached a maximum of *** percent in ***
A-11
Table 4.--Brass sheets and strips: U.S. producers' domestic shipments, intracompany shipments, toll shipments, and exports of domestically produced product, by types, 1983-85
Item 1983 1984 1985
Quantity (l,000 pounds)
Domestic shipments: C20000-series brass sheets and strips-----: *** *** ***
*** *** *** Other brass sheets and strips-------------: ~----------------------------------~ *** *** *** Total-----------------------------------: ____________ ..;.... ______________________ ~
Inttacompany shipments: • C20000-series brass sheets and strips-----: *** *** ***
*** *** *** Other brass sheets and str1ps-----------~-: Total-----------------------------------:~------,....,...,,_---------------------.... ......... *** *** ***
Toll shipments: . C20000-series brass she~ts and strips-----: *** *** ***
*** *** *** Other brass sheets and strips-------------: Total-----------------------------~-----!.._ __ __. __ ,....,...,._,;._ ______ ...,_ __ ....;_ ________ __ *** *** ***
Export shipments: C20000-series brass sheets and strips-----: *** *** ***
*** *** *** Other hr.ass sheets and strips-------------:· Total----------------------~------------=--------,.....,....,.-..;._ ______ ...,..,_,_...:...----------*** *** ***
All shipments: C20000-series brass sheets and strips-----: 409,525 4 70 ,306 384 ,637 Other brass sheets and strips-----------~-:.
Total-----------------------~-----------:----:,-;--:~=-:=------=-=-~="-,:------,.....;..,,...:.;;..;..;;._ 3 7 ,3 78 43,476 44,573
446,903 513,782 429,210
Value (l,000 dollars)
Domestic shipments:· C20000-series brass sheets and strips---~-: *** *** *** Other brass sheets and strips-------------: *** *** ***
*** *** *** Total---------~---~---------------------:~------,.....,....,.---------~-,----------.,.....,....,..
Intracompany shipments: C20000-series brass sheets and strips-----: *** *** ***
*** *** *** *** *** ***
Other brass sheets and strips-------------: Total-----------------------------------:~------,....,....,.-..;._ ______ ~-,----------.,.....,....,...
Toll shipments: .. ·. C20000-series brass sheets and strips-----: *** *** ***
*** *** *** *** *** ***
Other brass· sheets and strips-------------: Total-----~-----------------------------:~---------,.------'----..,.~--------------
Export shipments: C20000-series brass sheets and strips-----: *** *** ***
*** *** *** *** *** ***
Other brass sheets and strips-------------: Total-----------------------------------:~------,,....,,_----------------------~
All shipmerits: C20000-series brass sheets and strips-----: 345,858 384'138 311,458 Other brass sheets and strips-------------: 39,903 45,990 46,468 ~----.....;. ____________ .;.... __________ ..;_ __ __
Total-----------------------------------: 385,761 430,128 357,926
Sourc~: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
A-12
Total shipments of C20000-series brass sheets and strips increased 14.3 percent from 1983 to 1984 and then dropped 18.2 percent froc 1984 to 1985. Total shipments of brass sheets and strips, other than those of the C20000-series, increased 16.3 percent from 1983 to 1984 and 2.5 percent from 1984 to 1985.
One integrated producer, * * *, purchased some doraestic and imported brass sheets and strips for rerolling, and that firm's questionnaire data were adjusted (upon consultation with a representative of the firm) to exclude such purchC;lses so as to avoid double counting production or imports."
U.S. producers' inventories
U.S. producers' inventories of C20000-series brass sheets and strips increased *** percent from the end of 1982 to the end of 1983 arid then were stable during 1983-85 (table. 5).
Table 5.--Brass sheets and strips: U.S. producers' inventories, by types, as of Dec. 31, 1982-85
December 31--Item
.. 1982 1983 1934 1985
Inventories of firms' productionr C20000-series brass . : ..
sheets and strips---1,000 pounds--: *** 65,352 66,915 66,907 Other brass sheets and
strips---------------------do--~-: *** 4,993 4,.977 5,753 --~~~~~....,,,......:.-,---,_--~-=-,...:;-~..--~~--:--:-"-.,...,...,..
Total-----------------------do----: 59,219 70,350 71,892 72,660 ~~..:-.~~~~..:-.-'-~~~---~~~~~------
Ratio of inventories to all shipments during the preceding period of--
c20000·-series brass sheets and strips--------percent--:
Other brass sheets and 16.0 14.2 17.4
strips---------------------40----: 13.4 11.4 12.9 Average----------------~----do----:~~--~--~-...1~5-.~7--~--.1~4~.~0,..-------,1~6~.-=9 . . .
Source: Compiled from data submitted in response to questionnaires of the U.S. International rrade Commission.
Inventories ranged from 14.2 to 17.4 ~ercent of total shipments.of C20000-series brass sheets and strips during 1983-85. Inventories of other brass sheets and strips showed similar trends.
Employment and wages
In general, employment, hours worked, wages paid, and· total compensation paid incrcaseu fro~ l98J to 1984 and then dropped from 1984 to 1985 to levels below those of 1983 (table 6). For example, total employi;ient in those
A-13
Table 6.--Average number. of U.S •. Producers' employees (total and production and related workers) produdng'all products and 't~ose producing brass sheets and strips; hours worked by and· wages, total compensation, .and average hourly compensation paid to· ·such workers; output per hour worked; and unit labor cost in producing brass she-ets and strips, bY:, types, l,983"'."85
Item
Average employment: All.persons-------.;..-----------.----------------: Production and related workers producing--
All products--------------------------------: Brass sheets and strips--------------------: · C20000-series brass sheets and strips-------:
Hours worked by production and related workers producing--
All products.:..--------------------i~ooo hours--: Brass sheets and strips--.:..--------------do----: C20000-series brass sheets and strips---do----:
Wages paid to production and related workers producing-
All products-------------------1,000 dollars--:: Brass sheets and strips--------:..--------do---~: C20000-series brass sheets and strips---do----:
Total compensation paid to production and related workers producing-
1983.·
6,859
4,949 2,03.0 1,750
. 9,487 .. 4,197 3~614.
108,176 47 ,328 41,416
All products---------.:.. ____ :__•_1,000 dollars--:· 143, 792 Brass sheets· and strips-----------------do----: · 63,498. C20000-series brass sheets and strips---do----: 54,844
Average hourly compensation paid- to production .: and related workers producing.:..-
All products-------------!._. ____ ;;.. _____________ : $15.16 Brass sheets and strips------------------~----: 15.13 C20000-series brass sheets and strips---------:
Output per hour worked: · ; · Brass sheets and strips---.;.. ____ .:_:_ _____ pounds--:
15.l,8
107.6 C20000-series brass sheets and strips---do----: 114. 9 .:
Labor cost of producing--Brass sheets and. s_trips-----:"'.':Cents ·per pound--: C20000-series brass sheet~ and E!tr~ps-~-do----:
10.5 : 10.0 -:
1984
7 ,041
5,158 2,127 1~802
9,924 4,535 3,867
115,847 . 52,451 45,3,10
150,306 68,366. 59,175
$15.15 ·15.08 15.30
112.2 120.6
10.3 9.7
:
·• .
1985.
6~187
4~418 1~814 1~518
8,026 3~687 3,087
94,899 43,324 36,724
123,955. . 57,665.
5,1,659
$15.44 15.64' 16.73·-.
116.4 124.7
10.l 9.5
Source: Compiled from data submitted in response to qu.estionnaires of tbe U.S. International Trade Commission.
establishments in which C20000-series brass sheets and strips are pro<luced increased 2. 7 percent from 1983 to. 1984 arid then dropped 12.1 percent frora 1984 to 1985.
A-14
The number of workers producing all types of brass sheets and strips increased 4.8 percent from 1983 to 1984 and then dropped 14:7 percent from 1984 to 198.5. Likewise, th¢ number of worker.s pr,oducing C20000-series brass sheets and.strips increased 3~b p~rcent fr~m 198~ to 1984 and then dropped 15.8 percent from 1984 to 1985. Hours worked by· workers producing C20000~series brass sheets and strips increased 7.0 percent from 1983 to 1984
·and then fell by 20.2 percent from 1984 to 1985. Wages paid to such workers increased by 9.4 percent from 1983 to 1984 and then fell by 18~9 percent from 1984 to 1985. ·Total compensation showed similar trends. Productivity, as measured by output per hour worked, increased during 1983-85.
Financial experience of U.S. producers
Seven producers of brass sheets and strips provided usable income and loss data on overall establishment op~rat~ons, on operations producing all grades of brass sheets and strips, and on C20000-series brass sheets and strips. All· seven producers are basic producers of brass sheets and strips. One firm·,***, imports and.rerolls between*** to*** percent of their brass.
Overall establishment. operations.--Aggregate income and loss data on overall establishment operations are presented in table 7. Overall establishment sales of the seven producers increased from $880 million in 1983 to $979 million in 1984, or by 11.2 percent, t~en fell to $773 million in 1985 for a decrease of 21 percent.
Table 7.--Income-and-loss experience of u.s~ producers.on the overall operations of their establishments within which C20000-series brass sheets and strips are produced, 1983-85
: Item 1983 1984 1985
Net sales---------------------~--1,000 dollars--: 773,170 880,266 979,169 Cost of goods sold------------------------do----: 673,048
-... ....... -"":="!::-----,:-=-,,..:.~.,;-~~..,..,,,-,:-"''""='""~ 765,957 827~680
Gross profit--------------~---------------do----: 100,122 114 ,309 151,489 General, selling, and administrative
expenses--------------------------------do----: 78,375 ----,,...;..,,--~~~.....:..,..-~~~~...,..::...---
77 ,352 81,304 0 per at in g income or (loss)---~------------do----: 21,747 36,957 70'185 Depreciation and amortization----------~--do----: 23,327 . 17 ,350 21 ,531 Ratio to net sales:
Cost of goods sold------~------------percent--i 87 .o Gross profit----------------------------do----: 13.0 General, selling, and administrative
expenses------------------------------do----: 8.8 Operating income or loss----------------do----: 4.2
Number of firms reporting operating losses----~-: 0 Number of firms reporting-----------------------: 7
84.5 15.5
~-3 7.2
0 7
87.1 12.9
10.l 2.8
1 7
Source: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
A-15
Op.erating income increased significantly from $37 million in 1983 to $70 million in 1984, an incr.ease of 90 percent. During 1985, however, operating income fell sharply to $21.7 million, or a decline of ~9 p•rcent from the 1984 level. The operating margins during 1983-85 were 4.2 percen~, 7.2 percent, and 2.8 percent, respectively. None of the producers incurred operating losses in 1983 or 1984, but one producer reported an operating loss in 1985.
Operations producing all grades of brass sheets and ~trips.--Aggregate income and loss data are.presented in table 8 .for these operations. Net sal~s of all grades of brass sheets and strips increased to'$*** million during · 1984, up*** percent from $***million reported in 1983. Sales declined, however, during 1985 to$*** million, down ***-percent. from 1984 levels.
· Operating income almost doubled from $*** million in 1983 to $*** million in 1984. During 1985, however, operating income.dr~matically fell to S*** million, a decline of *** percent from the 1984 level. Operating margins during 1983-85 were ***percent, ***percent, and ***percent respectively. ***firms reported op~rating·losses iti 1983, ***.reported losses in 1984, and *** firms reported losses in 1985.
Table 8.--Income-and·-loss. experience· of u •. s. 'producers on their operations producing all grades of biass sheets and strips, 1983-85
·Item 1983 1984 1985 :
:_,
Net sales--~-~-------------------1,000 dollars--: *** *** Cost of goods sold--------------... ;..; __ ..;. ___ _:_do----: *** ***
*** ***
*** ·*** *** .. Gross profit---------------------~--------do-~--:~~--:~:--~~~-:-:--:-~~~~..,..,,...-General, selling, and administrative
*** . *** *** *** *** ***
expenses-~------------------------------do----:. ~~..,.--.,.....~;.._~~-,.~..:.....~~~~~
Operating income. or -{loss)----------------do----: . . *** : *** Depreciati_on and amort'izatfon ... ~-----------do-..:--:
Ratio to net sales: · *** *** . . . Cost of goods sold-------------------percent--:
Gross profit--~---------------------~---do----: '*** *** General, selling~ and administrative · expenses~--~--------------;..;-----------do----: *** ***
Operating income or loss-------~--------do----: *** *** Number of firms reporting operating losses------: *** *** Number of firms reporting-:..-----~---------------: *** ***
Source: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
' .
***
*** ***
*** *** *** ***
OperatiOns producing C20000-series brass sheets and strips.--Aggregate income and loss data are presented in table 9 for these operations. Net sales of the C20000-series brass sheets and strips increased fro.m $320 million in 1983 to $356 million in 1984, an increase of 11.4 percent, then fell to $296 million in 1985 for a decrease of 16.8 percent.
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Table 9.--Income-and-loss experience of U.S. producers on their opera~ions producing c2oooo~series brass sheets and strips, 1983-85
Item 1983 1984 1985
Net sales------~-----------------1,000 dollars--: 319,873 356 ,2 77 296 ,332 Cost of goods sold'----,.-------.. ·'--..:---------do----: 287 ,058 316,601 2 72 ,826 Gross profit-----------------'--~--~-------do----: 32,815 39,676 23 ,506 General, selling, and administrative
expenses-----------------~----~-------~-do----: 21,567 ·20 ,959 21,398 Operating income or (loss)------~---------do----: 11,248 18, 717 2, 108 Depreciation and amortization-------------do----: 6 ,358 7,990 9 ,341 Ratio to net sales:
Cost of goods ~old-------~--~--------percent--: 89.7 88.9 92.l Gross profit--------~~-----~---~--------do--~-: 10.3 11.1 7.9 General, selling, and administrative
expenses------------------------------do----: 6.7 5.9 7.2 Operating income or loss----------------do----: 3.5 5.3
Number of firms reporting operating losses------: 1 0 Number of firms reporting------------:-~--------.--: 7 7
Source: Compiled from data submitted in response to questionnaires of the U.S. International Tra'de Commission·.
Operating income increased significantly fr·om $11.2 million in 1983 to $18.7 million in 1984, an increase of 66.4 percent. During 1985, however, operating income dropped to only $2.l mill~on, ~~ a decline of 88.7 percent from 1984 levels.
The operating margins during the 1983-85 period were 3.5 percent, 5.3 percent, and 0. 7 percent, respectively. One of the firms reported an operating loss during 1983, none of the producers reported operating losses during 1984, and four reported losses during 1985.
Capital expenditures.--The data provided by s~ven firms on their-capital expenditures for land, buildings, and machinery and equipment used in the manufacture of all brass sheets and strips are shown in table 10. Capital expenditures relating to all brass sheets and strips decre~sed from $*** million in 1983 to$*** million during 1984, and further declined to.$*** million in 1985. Capital expenditures for C20000 series.brass sheets and strips followed a similar downward trend during 1983-85.
Value of plant, property, and equipment.--The data. provided by seven producers on their investment in productive facilities in which brass sheets and strips sre produced are shown in table 11. The aggregate investment in productive facilities for all brass she_ets and strips,.valued at cost, increased from $*** million in 1983 to $*** million in 1984 and rose further to $***million as of December 31, 1985.
.7 4 7
A-17
Table 10.--Capital ~xpenditures on U.S. producers' facilities within which···. C20000-series brass sheets and strips are produced, as of the end of 1983-85
(In thousands of ~olla~s)
Item · 1983 1984 1985
All products of the establishment(s): .. Land and land improvements---------~--: *** *** *** Building or leasehold improvements----: *** *** ***
*** *** *** Machinery, equipment, and fixtures----: -----------------------------------------Tot al - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - : *** *** *** All types of brass sheets and strips:
Land and land improvements------------: *** *** *** *** •· . Building or leasehold improvements----: *** *** *** *** *** *** *** ***
Machinery, equipment, and fixtures----: ----------,."'"'""'-----------...,...,...,,.--------------
Tot al - - - - - -~------------------~-----: C20000-series brass sheets and strips:
Land and land improvements------------: ·*** *** *** Building or leasehold improvements----: *** *** ***
·*** *** *** *** *** ***
Machinery, equipment, and fixtures----: Total-------------------------------=--------~,....,..----------...,...,....,...----------......,...,_.
Source: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
Table 11.--Value of plant, property, and equipment (investment in productive ;f,ciliti~s) of U.S. producers' facilitie~ within which C20000-series.brass sheets and strips are produced, as of the end of 1983-85
(Ifi thousands of dollars)
Item
All products.a~ the establishment(s):
Original cost----------------~---: Book value-----------------------:
All types of brass sheets and; strips:
Original cost--------------------: Book value-----~-----------------:
C20000-series brass sheets and strips:
Original cost------~-------------: Book value-----------------------:
.1983
*** ***
*** .. . ***
*** ***
1984 1985
*** . . . ***
*** ***
*** ***
Source: Compiled from data submitt_ed in respons_e to questionnaires of the U.S. International Trade Commission.
*** ***
*** ***
*** ***"
A-18
The book value of such assets increased from $*** million in 1983 to $*** million in 1984; however, the book value declined to $***million.during 1985. Total reported investment in productive facilities for C20000-series brass sheets and strips, valued at cost, increased from$*** million in 1983 to $*** million in 1984 and rose further to $*** million during 1985. The book value of such assets increased from $*** million in 1983 to $*** million in 1984, then declined to $***million in 1985.
Research and development expenses.--Reported expenses on research and development for the seven reporting firms are shown in the following tabulation for 1983 to 1985 (in thousands of dollars):
All types of brass sheets and strips--C20000-series brass sheets and strips--
1983
*** ***
1984
*** ***
1985
*** ***
Capital and investment.--u.s. producers were asked to describe any actual or potential negative effects of imports of C20000-series brass sheets and strips from Brazil, Canada, France, Italy, Korea, Sweden, or West Germany on their firm's growth, investment, and ability to raise capital. Six firms, including all of the majo~ producers, responded to these questions.· In essence, their replies were that imports have prevented the firms from obtaining a sufficient return on investment to sustain the capital investments required to meet changing customer requirements and to finance plant expansions. The low profitability from brass sheets and strips operations have made it difficult to obtain outside financing or to justify expansions of these operations within multiproduct corporations. With the continuation of the importinj of the allegedly unfairly traded products, some producer§ expect plant closings and further reductions in employment.
The Question of the Threat of Material Injury
In its examination of the question of the.threat of material injury to an industry in the United States, the Commission considers among other relevant factors, any increase in production capacity or existing unused capacity in the exporting country like~y to result in an increase in imports of the subject merchandise to the United States, any rapid increase in U.S. market penetration and the likelihood that the penetration will increase to an injurious level, the probability that the price of the subject imported product will have a depressing or suppressing effect on the domestic prices of the merchandise, any substantial increase in inventories of the merchandise in the United States, any other demonstrable trends that indicate that the importation (or sale for importation) of the merchandise will be t~e cause of actual injury, and the potential for product-shifting.
Information on the market penetration of the subject product is presented in the market penetration section of this report. Available information on the depressing or suppressing effect on domestic prices of the imported product is presented in the pricing section of this report. Available information on the other factors listed above is discussed in this section of the report.
A-19
U.S. importers.'. inventories
U.S. importers' inventories are not very meaningful in these investigation·s because many, if not most~ shipments are made directly from the foreign producers' plants to U.S. customer~ through orders placed with U.S. agents or the foreign manufacturers. Further, some of the U.S. importers that do maintain inventories combine inventories of foreign and.domestic brass sheets and strips and were unable to determine inventories by country of origin.
C~pacity of foreign producers to generate exports
· Counsels for Brazilian, Canadian, French, Italian, Korea~, Swedish, and West German interests were requested to provide information on the foreign industries in each of these countries, but'complet~ d•ta for ~11 c~untries have not been received. ·
Korean data are presented in table 12 and West German data.are presented in table 13. Data for West Germany should be·viewed with caotion. West German firms typically provided data for sheets and strips of all brass compositions, b~t certain ~~b~issions for capacity, productiori, and capacity utilization data included copper.and bronze compositions and for exports were limited to C20000-series brasses.
Table 12.--Brass sheets and strips:· The Republic of Korea's capacity, production, capacity utilization, domestic shipments, and exports, 1983-85
Item 1983 1984 1985
::
All brass sheets and strips: Capacity---~-----1,000 pounds--: *** *** •,*** Production--------------~do----: *** *** .. . *** Capacity u~ili~ation~-percent--: *** *** *** Domestic shipments
1,000 pounds--: *** *** *** .. . C20000 _brass sheeta and strips: Capacity---------1,000 pounds--: *** *** *** Production------------~--do----: *** *** ... *** . Capacity utilizat~on--percent--: *** *** *** Domestic shipments
1,000 pounds--: *** *** *** Exports to-
United States----------do----: *** *** *** Japan------------------do----: *** *** *** Taiwan-----------------do----: *** *** *** All other countries----do----: *** *** ***
*** *** *** Total----------------do----:~~~~...,.--,-.,....,...--------~--~----~~~----~--~
Source: Compiled from data provided by counsel for Korean interests.
A-20
ta.ble 13.--Brass sheets and strips: West Germany's capacity, production, capacity utilization, domestic shipments, and exports, 1983-85
Item
All brass sheets and strips: Capacity---------1,000 pounds--: Production---------------do•---: Capacity utilization--percent-~: Domestic shipments
1,000 p~unds--: Exports to--
1983
*** *** ***
***
1984
*** *** *'**
***
1985
*** *** ***
***
United States----------do~---: *** *** *** All other countries----do----: *** *** ***
Total----------------do----=------------=*~*~*:--------------*~*~*.,......---------------*-*~*
Source: . Compiled from data pt,qvided by counsel for West German interests.
Note.--West German firms typically provided data for sheets and strips of al 1 brass compositions. but certain submissions for capacity,; production. and .· capa~ity utilization data included copper and bronze compositions and for exports, were limited to C20000-series brasses.
Consideration of the Causal Relationship Between Alleged Material Injury or the Threat Thereof and the Alleged LTFV and/or Subsidize~ Imports
U.S. imports
According to official statistics of the U.S. Department of Commerce, impo~ts of brass sheets and strips increased 48.4 percent by quantity from 1983 to 1984, then dropped 21.5 percent from 1984 to 1985 (table 14). Imports of brass sheets and strips from the seven countries included in thes~ investigations increased 61.2 percent from 1983 to 1984, then dropped"28.2 percent from 1984 to 1985 (table 15). Imports from these countries in 1985 were above 1983 l~vels.
Responses to the Commission's importers questionnaires covered about 90 percent of the quantity of brass sheets and strips imported in 1983 ahd 1984 and about 80 percent of 1985 imports. These questionnaire responses-indicate that imports of brass sheets and strips were predominately of the C20000-series, ***percent in 1983, ***percent in 1984, and*** percent in 1985.
A-21
Table 14.--Brass sheets and strips: U.S. imports for cbnsumption·, by principal sources, 1983-85
Source , 1983 1984 1985
Quantity (1,000 pounds)
West Germany--------------: 51,850 69 ;525 1/ 48,913 Japan---------------------: 21 ,233 17,934 .. 19,194 . Netherlands---------------: . 9 ,633 15,630 . 15,406 France--------------------: 7,990 22,992 1/ 11, 774 Italy---------------------: 3 ,749 8,444 l/ 10,502 Republic of Korea---------: 1,793 6,286 Tl 7 ;712 Brazil--------------------: 9,867 15,793 7,590 Canada--------------------: 9,656 13 ,354 : 7,502 Sweden--------------------: 754 1 ,670 .. 5,176 . Switzerland---------------: 1,675 2'170 3,208 All other-----------------: 5 ,883 10 ,284 7 ,561
Total----------------~: 124 ,083 184 ,082 1/ 144 ,538
Value ( 1 ,000 dollars)
West Germany--------------: 46,629 62,742 45 ,313 Japan---------------------: 19 ,217 17,231 18,132 Ne~herlands---------------: 9,834 16,209 15,785 France--------------------: 6'121 17,522 9'14 7 Italy---------------------: 3'163 7·,401 1/ 9 ,463
1,679 6 ,314 .. l/ 6,590 . Republic of Korea---------: Brazil--------------------: 7,986 12 '797 6,204 Canada--------------------: 9 ,821 13 ,365 7 ,403 Sweden--------------------: 886 1,669 4 ,792 Switzerland---------------: 1 ,360 2,084 2 ,5 79 All other-----------------: 5,226 8,907 6,579
111,922 166 ,241 1/ 131,987 Total-----------------:,..._,__,__,___,...,,..,...~,....,...,__,__,__,__~~~..,,..,....,._,..._,..._,__~"T'""",..._,.....:..;.~
•· . West Germany~-------------: Japan---------------------:. Netherlands---------------: France--------------------: Italy---------------------: Republic of Korea---------: Brazil--------------------: Canada--------------------: Sweden-------~------------:
Switzerland---------------: All other-----------------:
Unit
89.9 90.5
102 .1 76.6 84.4 93.6 80.9
101. 7 117 .5 81.2 88.8
value (cents per pound)
90•2 92.6 96.1 94.5
103. 7 102 .5 76.2 77.7 87 .6 90 .1
100.4 85.5 81.0 81. 7
100. l 98.7 99.9 92.6 96.0 80.4 86.6 87.0
Aver age - - - - - - - - - - - - - - - : 90.2 90.3 91.3 ,..._,..._~,..._,..._---:~--::-~~~~~,..._-.......,.......,._~,..._~,..._,..._,..._...,,,...,....-..-
1/ Corrected data received from the U.S. Department of Comuierce.
Source: Compiled from official statistics of the U.S. Department of Commerce.
A-22
Table 15.--Brass sh~ets and strips: U.S. import.s for consumption, by selected sources, 1983-85
Source . . .
West Germany--------------: France--------------------: Italy---------------------: Republic of Korea---------: Brazil-------------------~: Canada--------------------:
1983
Quantity
51,850 7,990 3,749 1,793 9,867 9,656
1984 1985
(l,000 pounds)
69,525 1/ 48,913 22,992 l/ 11,774 8,444 Tl 10,502 6,286 l/ 7,712
15,793 7,590 13,354 7,502
Sweden--------------------: ______________ ,........ ______________ .....:;.. ______________ __;.....:;.. ___ Seven country total---:
754 1,670 5,176 85,659 138,064 99,169
All other countries---~-----------=-=~'"='""------------..,....,,..-,,-:--:,..-----------..,....,,...:..,~ 38,424 46,018 45,369 Grand total-----------: ____________ ...:..;._;_;; ____________ _;;;_;..:..;;..;;_;;._;__ ____ ...::..: __ ;;...;_.:...!.:~ 124,083 184,082 l/ 144,538
Value (l,000 dollars)
West Germany--------------; 46,629 62,742 45,313 France--------------~----~: 6,121 17,522 9,147 Italy-------------------~-: 3,163 : 7,401 1/ 9,46'3 Republic of Korea---------: 1,679 6,314 l/ 6,590 Brazil--------------------: 7,986 12,797 6,204 Canada--------------------: 9,821 13,365 7,403 Sweden------------------~-=----------~-8~8~6~-----------...,,....,,l~,~6~6~9------------~4~,7~9=-=-2
Seven country total---:· 76,285 121,810 88,912 __________ __;...:.......;...; ______________ ,....:.. ________________ ,....:.. ___ All other countries---: 35,637 44,431 43,075 ============::!:::::===============================;:========= Grand total-----------: 111,922 166,241 l/ 131,987
------------...:....-----------------"-------------"-----"'-~ Unit value (cents per pound)
West Germany--------------: 89.9 90.2 92.6 France--------------------: 76.6 76.2 77.7 Italy---------------------: 84.4 87.6 90.l Republic of Korea---------: 93.6 100.5 85.5 Brazil--------------------: 80.9 81.0 81.7 Canada--------------------: 101.7 100.l 98.7 Sweden--------------------: 117.5 99.9 92.6 -------------------------------------------------'--'--Seven country
average-------------: ____________ 8~9;;...;;...1 ______________ ~8_8_._2 ____________ __;8~9~.;_;_7 All other country
average-------------=------------~9~2_.~7 ____________ -'-9~6~·~6 ______________ 9~4.;...;...;.....9 Average---------------: 90.2 90.3 91.3
1/ Corrected data received from the U.S. Department of Commerce.
Source: Compiled from official statistics of the U.S. Department of Commerce.
A-23
Market penetration by the alleged LTFV and subsidized imports
The share of the U.S. market for C20000-series brass sheets and strips supplied by U.S. producers decreased from 1983 to 1984, then increased slightly from 1984 to 1985 (table 16). Imports from the countries subject to these investigations increased from 1983 to 1984, then declined from 1984 to 1~85 but, for four of seven subject countries, r~main~d at levels higher than that in 1983·. The import penetration ratio increased from 1983 to 1984 and then dropped fre>m 1984 to 1985.
Table 16.--C20000-series brass sheets' and strips: Shares of U.S. consumption supplied by Brazil, Canada, France, Italy, the Republic of Korea,·sweden, and West Germany, all other countries·, and U.S. producers, 1/ 1983-85
Item
C20000 brass.sheets and strips: u.s.consumption----1,000 pounds--:
Share of U.S. consumption: supplied by--
1983
533,609
1984 1985
654,388 529,175
Braz i 1------~-------------percen t--: 1.8 2.4 1.4 Canada----~-----------------do----: 1.9 2.0 1.4 France-----~----------------do----: 1.5 3.5 2.2 Italy-------~---~------~----do----: .7 1.3 2.0 Republic of Korea---------~-do----: .3 · : 1.0 .1.5 Sweden---:.---~-"'.'------------do----: · .1 .3 : 1.0 West Germany----------------do--~: 9.8 10.6 9.2
Sub to tal------.--'----------do---- =-----:l:-:6:-.-=1------=2,...1:-.-=1,..-------...,l,..,8,...;.~7
All other countries----------do----: 7.2 7.0 8.6 U.S. producers--------------do----: 76.7 71.9 72.7
To ta 1---..'.-----------------<lo-"'.'-- :=-=====1~0~0==.~0========10~0===.~0~======1~0:3'0==.o:;::
1/ Shares suppli~d by import$ and shares supplied by U.S. producers are s lTgh t ly overstated. · · ··
S~urce: Compiled from data submitted in response to questionnaires of the U.S. Internationa.l Trade Commission and official statistics of the U.S. Department of Commerce.
Prices
Brass sheets ·and strips are sold on a per pound basis. There are two major components to the final selling price: a fabrication price and the metal value of th~ product. The fabrication price generally varies with the
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gauge, or thickness, and width of the brass sheets and. strips. 1/ The thinner the gauge, the more costly the item is to produce and the highe-; the price·. A width resulting in lower yield from a coil will also have a higher price. The metal value-of brass sheets and strips generally accounts for at least half of the total selling price. '!:._/
Preliminary information suggests that the metal value of brass sheets and strips declined during the period under investigation. Six domestic producers and ~wo importers of brass sheets and strips from Germany provided quarterly data on th~ metal value portion of brass sheets and strips prices. These data indicate that average metal values declined by from 5 to 13 percent during 1983-85. Because metal value accounts for such a large proportion of the total selling price of brass sheets a'nd strip·s, _the decline in th.e metal value may have affected price trends during the period under investigation~
Sales practices~--Domesti.c producers and importers sell br·ass sheets and strip~ to distributors, rerollers and also to many end-user markets. Industry sources report that price varjes among market segments becaus~ historical pricing traditions somewhat ~istort a cost-based approach to pricing. Brass sheets and strips are sold to:each of these different market segments 6n both a spot basis and a contract basis.
Producers and importers wer~ asked to estimate the share of their total 1985 sales of brass sheets and strips that were sold on a spot-sale ba~is and the share sold by different types of fixed-period contractual arrangements •. A substantial proportion of U.S.-produced brass sheeis and strips is sold on a. contractual basis. For example,*** of their total 1985 sales.of brass sheets and strips on a contractual basis. For U.S. importers of brass sheets a'nd strips, the majority of° sales are on a spot basis. Of *** importers · responding to the Commissions' questionnaire,*** reported that they sold exclusively on a spot sales basis. * * *· These firms sold ~** to *** percent of their bras~ sheets and strips on a contract basis.·
Spot market sales.--For.spot sales, suppliers may quote a. single s~lling price for both fabrication and metal, or may.quote th~ fabrication price and metal value separately. Unlike most importer$, domestic producers publish price lists to which adjustments are made depending on·market conditions •. These producers' price lists also generally have a list price for.metal value. This list price for metal value is changed only as conditions in the metal markets warrant, perhaps as frequently as once a week but usually less often.
Producers and importers generally quote prices on a delivered basis, although some quote on an "f.o.b." basis but absorb freight costs for the majority of their sales. The minimum quantity requirements for U.S.-produced brass sheets and strips generally range from 2,000 to 5,000 pounds. Because specifications desired for brass sheets and strips frequently vary with the
ll In addition, certain special finishes or tempers may affect fabrication prices.
'!:_/ Cartridge brass contains 70 percent copper and 30 percent zinc.
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purchaser and the individual order, it is difficult to inventory "standard• items. The lead time for U.S.-produced brass sheets and strips is generally 4 to 6 weeks for an order.· Importers also generally do not maintain large · inventories in the United States. For purchases of brass sheets and strips imported from the subject countries, minimum quantity requirements are generally higher, and the lead times are typically much longer. The minimum quantity requirement for purchases of imports can be as high as 8,000 pounds per individual item ordered, with a minimum total shipment of 40,000 pounds, a full truckload. The ranges of average lead times reported by importers of brass sheets and strips are presented by country of origin in the tabulation below: 1/
Country
Brazil------------France------------Germany----------I ta ly--------~----Korea-------------Sweden------------
Weeks
*** *** *** *** *** ***
Contract sales.--For fixed-period contract sales, the price for fabrication and metal value are normally quoted separately. A fixed-period . ' contract generally establishes a firm fabrication price and sets guidelines on purchase quantities. U.S. inland freight costs to the purchaser are also implicitly included in the fabrication price. The ~econd price component, the metal value of the brass sheets and strips, may flu'ctuate with the market price of the metal on the date of shipment, or it may be fixed (hedged) for a specified period of time. Alternatively, in a toll arrangement or metal . conversion contract, the purchaser of the brass sheets and strips supplies the· input metal: Toll-sales contracts accounted for at least *** percent of total sales for·***· Imported brass sheets and strips would not normally-be sold on a toll-account basis because of the substantial transportation costs that would be involved in shipping metal to the foreign producer and returning the finished product.
, The Commission requested producers and importers to provide quarterly
price data during 1983-85 on spot-market sales and on fixed-period contracts 'negotiated for four common brass sheets and strips products listed· below:
Product 1.--Builders' hardware, CDA end-use classification 110, CDA alloy 260, 0.016 inch to 0.032 inch thick by 2 inches to 12 inches in width.
Product 2.--Slitting stock, CDA end-use classification 920, CDA alloy 260, 0.020 inch to 0.025 inch thick by maximum yield width (MYW).
1/ Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
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Product 3.--Communications and electronics, CDA end-use. classification 430, CDA alloy 260, 0.010 inch to 0.013 inch thick by 0.75 inch to 2 inches in width.
Product 4.--Communications and electronics, CDA end-use classification 430, CDA alloy 260, 0.016 inch to 0.020 inch.thick by 0.75 inch tp 2 .inches in width, traverse wound (TRW).
The above listed product specifications used to collect price data were define·d to specify the four major price factors identified--alloy, gauge, width, and end use. For spot sales, producers and importers were asked to report the total selling price, i.e. fabrication plus metal value for their largest single quarterly sale (by volume). ***producers, * * *, reported spot-price data as requested, although not necessarily for all products and periods under investigation. Usable price data were received from *** importers covering all countries subject to these investigations except Canada, although not necessarily for all periods or products requested. No Canadian importer responded to the Commission's questionnaires in time to include their data in this report.
For fixed-period, nori-toll contracts negotiated, producers and importers 'were asked to report the base fabrication price for the largest volume contrac~.negotiated in e~ch quarter. In response to suggestions of Petitioner's counsel, Commission staff subsequently requested producers and importers .to provide the metal vaiues corresponding to the contract sales data reported. *** U.S. produ~ers and *** importers of brass sheets and strips from * * * provided usable cont'ract price data.
Several producers, including*** petitioners, did not report price data for single. spot sales and contracts negotiated but reported quarterly average unit values for each specification. Importers were-generally able to report price data as requested.
Price trends
Domestic producers' price trends for spot sales.--Price data from domestic producers on their largest single quarterly spot sale provided complete price series only for the builders' hardware and slitting stock specifications. These price data are shown in table 17 and indicate that producers' weighted-average prices fluctuated considerably but fell from January-March 1983 to October-December 1985 by from *** to *** percent. Weighted-average prices for the U.S.-produced builders' hardware specification fell from $*** per pound in January-March 1983 to $*** per pound in October-December 1985, or by ***percent. During the same period, producers' prices for the slitting stock specification fell from $*** per pound to $*** per pound or by *** percent.
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Table 17 • ...:-Brass sheets and strips: Domestic producers.' weighted-a.verage delive~~d prices on their largest single quarterly spot sales~ by products and by qua~ters, January 1983 to December 1985
. O'
Period Builders' Slitting Communications hardware ]J stock J;J and electronics
-----------Per pound----------1983:
3/
$**-Ir . $*** $*** . January-March------~----------: April-June---~------~---------: *** *** *** July-September-~--------------: *** *** *** October-December--------------: *** *** '4/
1984: : January-March•----------------: *** *** *** April-June--------------------: *** *** 4/
*** . *** 4/ . *** . *** 4/ . July-September--------------~-:
October-December--------------: 1985:
January-March-----------------: *** *** 4/ *** *** . ' 4/ . *** *** . ' 4/ . Ap ri 1-J une-----------------·.:., __ :
July-September~-.-;;.,------------: October-December--------~-----.: *** *** 4/
1,/ Builders' hardware, CDA end-use classification 110, CDA alloy 260, 0.016 inch to· 0~032 ·inch thick by 2 inche~ to 12 inches in width.
]J Sli'tting ·stock, CDA end:..use classification 920, CDA alloy 260, O .020 inch to 0.025 inch ~hick by maximum yield 'width (MYW).
1/ Communications and electronics, CDA end-use classification 430, CDA alloy 260, 0.010 inch to 0.013 inch thick by 0,75 inch to 2 inches in width.
!!_/ No data reported.
' Source: Compiled from da~-?- 'submitted in response to questionnaires of the
u.s. International Trade Commission.
Average quarterly unit revenue data submitted by the remaining U.S. producers for sales of the builders' hardware and slitting stock specifications ~u~port the ~onclusion of • do~nward trend in prices of these products. ]/
17 Average unit revenues for the U.S.-produced builders' hardware specification fluctuated downward during the period under investigation by *** percent since the-first quarter of 1983. Producers' average prices for the slitting stock 'speci'fication fluctuated ·consider~bly but ended 1985 at *** percent below the· firs~ quarter 1983 price )evei.·
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Insufficient price data·were provided by producers on their largest .. quarterly sales of the two communications and electronics products.. Quar·terly average unit value data for. the two communica.tion·s and electronics product.s suggest that, during the period under investigation, producers' prices for these·prpducts were, on average, approximately$*** per pound above prices for the U.S.-produced builders' hardware and slitting stock products. Average unit values for the two U.S. produced communications and electronics products declined during 1983-85. U.S. producers' average unit values for the 0.010 inch to 0.013 inch gauge specification rose from $*** per pound during January-March 1983 to a high of $***per pound during July-September 1983, before declining erratically to $*** pe~ pound in October-December 1984, or by *** percent. Unit revenues for this product then recovered through October-December 1985 to $***per pound, or to*** percen~ below the January-March 1983 average price level.
Producers' quarterly average ~nit values for the 0.016 inch to 0.020 inch gauge specification followed a different trend, rising erratically from$*** per pound in January-March l983 to $*** per pound in Ja.nuary-March 1985, or by ***percent, and declining steadily during the remaind~r of 1985 to $***per pound, or by *** percent since the first quarter of 1983.
Importers' price trends for spot sales.--Although price data reported by importers on their largest quarterly s_pot sales of brass sh.eets and strips produced in the subject countries does not allow a thorough analysis-of importers' price trends, price data available for imports from France, Germany, Korea, and Sweden .sriggest ·that importers' prices gener~lly'fell during the period under investiga'tfon. Importers·• price data for Brazil.ian brass sheets and strips products, however, show prices following an upward trend during the period under investigation in 2 out of 3 product ~ategories~ Importers I prices for the builders·• hardware and slitting stock product categories are shown in tables 18 and i9. · .
Importers' prices for Brazilian brass sheets and strips products rose by ***percent, from mid-1983 to mid-1985, for the builders~ hardware specification and by*** percent,· o~er roughly the'same perio4, for the 0.016 inch to 0.020 inch gauge communications and electronics specification. Importers' prices of Brazilian slitting stock fell by*** percent from January-March 1983 to October-Dec~mber 1985. 1 .
Prices of French brass sheets and strips were relativ~ly steady for the builders' hardware ind slitting stotk products, ·falling by*** percent for the builders' hardware product from mid-1983 to mid-1985 and by*** percent for the slitting stock product from January-March 1984 to October-December 1985. Importers' prices for the 0.016 inch to 0.020 inch gauge communications and electronics product fell by *** percent during 1984 and rose by *** percent during 1985.
'·
Importers of· German brass sh_e.et& and strips reported co.mplete quarterly price series for spot sales of the ~uild~rs' hardware ~nd ~litting stpck products during January 1983-Decemb.er 1985. These price data show weighted-average importers' prices fluctuating within ·an ***-cents range but declining by ***percent for the builders' hardware product, with a continuous decline during 1985 of *** percent. Prices of the slitting stock product imported from Germany fell by *** percent during the period under investigation.
.A-29
Table 18.--Brass sheets and strips: ·Importers' weighted-average delivered prices on their largest ~ingle·quarterly spot s•les of builijers' hardware, 1/ by countries and by quarters, January 1983.to December 1985
Period Brazil France Germany Italy Republic of Korea
1983: January-March--------------: 2/ 2/ $*** 2/ 2/ April-June-----------------: -$*** 21 *** 21 21 Juiy-September-----~--~----: *** l*** *** 21 21 October-December-----------: *** 2/ *** . 21 "IJ .
1984: . : . January-March--------------: *** *** *** . $*** $*** •. April-June-----------------: *** *** *** *** *** July-September-------------: *** *** . *** 2/ 2/ . October-December-----------: *** *** *** 21 21
1985: January-March--------------: *** *** . ***": 2/ *** April-June-----------------: *** *** *** *** *** July-September-------------: 2/ 2/ *** 2/ : . '!:_/ October-December-----------: IJ IJ *** 2/ ***
1/ Builders' hardware, CDA end-use classification 110, CDA alloy 260, 0.016 inch to 0 .032 inch thick by 2 inches to 12 inches in wid"th.
2/ No data reported.
Source: Compiled from data submitted .in response to questionrtaires ~f the U.S. International Trade Commission.
Price data for brass sheets and strlps imported from * * * are primarily available for 1985 and generally show prices of these imports falling during 1985 by*** to ***percent for the build~rs' hardwar~ ~peci!ication and the communications and electronics products.
From the last quarter of 1984 to-the third quarter of 1985, prices of the slitting stock product imported from * * * fluctuated within a ***-cents range, falling by around ***percent during April-June 1985 and recovering substantially during July-September 1985. ·
Price trends on contract sales.--Usable price data on fixed-period, nontoll contracts negotiated were provided by·*** U.S. producers and *** importers of * * * brass sheets and strips. Weighted-average price series were calculated for both negotiated fabrication prices and total selling prices, i.e., fabrication price plus the metal values corresponding to the contracts negotiated. Contract-price data for the builders' hardware and slitting stock specification are shown in tables 20 and 21. An analysis of these two types ·of price da.ta for contract sales is instructiv.e because it shows how changin~ metal value~ affect the total pric~ of brass she~ts a~d strips.
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Table 19.--Brass sheets and strips: Importers' weighted-average delivered prices on their largest single quarterly spot sales of slitting stock, l/ by countries and by quarters, January 1983 to December 1985
Period Brazil France Germany Italy Republic: of Korea~ Sweden
1983: January~March-----: April-June--~-----: July-September----: October-December--:
1984: January-March-----:
$*** *** *** ***
2/ 21 21 21
$*** *** *** ***
2/ 21
.. 21 21
2/ 21 21 21
2/ 21 21 2/
2/ April-June--------:
*** *** •
$*** 2/
*** *** *** ***
$*** 2/
$*** *** ***
- $*** July-September----: -*** 21 !:_/ October-December--:
*** *** *** 21 2/ ***
1985: January-March-----: April-June--------:
*** *** *** ***
*** *** ***
*** *** *** ***
2/ ***'
*** *** ***
*** ***
July-September----: October-December--: ***
2/ 21
*** ll *** 2/
1/ Slitting stock, CDA end-use classification 920, CDA alloy 260, 0.020 inch to-0.025 inch thick by m~ximum yield width (MYW).
2/ No data reported. 3/ An importer of Korean slitting stock reported selling *** pounds with a
special.mirror polish for $***per pound.
Source: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
While domestic producers' weighted-average total selling prices for three product categories for which price data were collected declined during the period under investigatiop, the fabrication prices of these products either remained steady or increased. Producers weighted-average total selling prices for contract sales of the builders' hardware product declined by*** percent from January-March 1983 to January-March 1985, and * * * total selling price of the slitting stock specification declined by *** percent from January-March 1983 to October-December 1985. l/ * * * total selling prices on contract sales of the 0.010 inch to O.OlJ inch communications and electronics specification (not shown) fell by *** percent from January-March 1983 to October-December 1985.
17 Producers' spot sales price data for the corresponding products and periods showed similar price declines of *** percent and *** percent for the builders' hardware and slitting stock product categories, respectively.
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Table 20~--Brass ·sheets ·and s'tript{.--Weigh'ti~d-average · tot~l n~g.otiated price (fabrication plus metal value) on sales contracts reported by U.S. producers and importers :pf· the· subject products from West Germany and average margins of underselling (overselling) by· the subject impor'ts, by product and by ·quarters, January 1983-December 1985
U.S. ' : Margin
Product and period producers' Importers' : · --~~~~~~~~~~-
. : price price Amount Percent
--------------------Per pound-----------------
Builders' hardware 1/ .. 1983: January-March---~---------: $*** $*** $*** *** April-June----~--------~--: *** *** *** *** July-September------------: *** *** *** ***
.October-December----------: 2/ *** '}_/ 3/ 1984:
January-March-------------: *** *** (***): (***). April-June---------------~: 2/ *** 3/ 3/ July-September------------: *** •· *** *** *** October-December----------: *** *** ': *** ***
1985: January-March-------------: *** *** *** *** April-June-------~--------: 2/ *** 3/ 3/ July-September------------: 21 *** J/ J/ October-December-~--------: I! '!-_/ J/ 3!
Slitting stock 4/ 1983: .. . ..
January-March"-------------: *** *** (***): (***) April-June-----------..:----: *** '!-_/ 3/ l! July~September-----~:~----: *** *** <***): (***) October-December----------: *** *** (***): (***)
1984: January-March-------------: *** *** (***): (***) April~June-----"-~---------: *** ~/ 3/ 3/ July-September------------: *** *** (***): (***) October-December----------: *** *** (***): (***)
1985: .. . January-March~------------: *** 2/ 3/ 3/ Apr.i 1-June-----------"."---- :· *** 21 J/ J/ July-September------------: *** 21 J/ J/ Oc to be r-Decembe r--"-------- :· *** 2t 3! 3!
17 Bu1lde.rs 1 hardware; CDA ehd'-us·e classification 110, CDA alloy 260, 0.016 inch to 0.032 inch thick· by 2 inches to· i2· inches in width. ~/ No data reported. 3/ Cannot be calculated. !./ Slitting stock, CDA'end-"use classification 920·, CDA alloy 260, 0.020 inch
to 0 .025 inch thick by maximum yield width (MYW). ·
Source: Compiled from data submitted in response to questionna~res of the U.S. International Trade Commission.
Note: Margins were calculated from unro~nd~d weighted-average prices. the margins shqwn in these tables cannot always be duplicated from.the weigh ted~average pr ices' shtiwn above.·
Thus, rounded
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Table 21.--Brass sheets and strips.--Weighted-average fabrication prices negotiated for sales contracts of U.S. producers and importers ~f the subject produC:.s from West Germany and average margins of. unde.rse.lling (over~elling) by th~ subject imports, by product and by quartets, January 1983-December 1985 . '
Product and period u.s.
producers·, price
Importers' price
. . . Margin
Amount Percent
--------~-----------Per pound-----------------
Builders' hardware 1/ 1983: -
.. . :
January-March-------------: April-June----------------: July-September------------: October-December-----·-----:
1984: January-March-------------: April-June----------------: July-September------------: October-December----------:
1985: January-March-------------: April-June----------------: July-September------------: Oc tober-De.cembe r----'"'.'-----:
Slittin~ stock 4/ 1983:
January-March-------------: April-June----------------: July-September------------: October-December----------:
1984: January-March--------~----:
April-June----------------: July-September------------: October-December----------:
1985: January-March-------------: April-June------------~---: July-September------------: October-December----------:
$*** *** ***
2/
*** 2/
*** ***
*** 2/ 21 21·
*** *** *!'* ***
*** *** *** ***
*** *** *** ***
$*** *** ***
·***
*** *** *** ***·
: . *** *** .. . *** ***
. *** 2/
*·** . ***
*** :: *** . *** . ***
*** . l:./ .. *** . ·*** A . . .
$*** . *** *** *** •••• ***
3/ 3/
.(*~*):. (***) 3/ ,. 3/
*** .. . *** .. ~. (***)': (***)
*** *** 3/ 3/ ·3l. 3! 3! .. 3! .
(***): (***) 3/ 3/
.. ::-c ***) : ( ***) (***): (***)
. (***)·: (***) (***): ( ***) (***'}: (***) (***) :· (***)
(***): (***) 3/ : 3/
*·** : *** ·. (***): (***)
17 Bu1lders 1 hardware, CDA end-use classificatiori 110~ CDA allof·260~ 0.016 inch to 0.032 inch thick by 2 inches to 12 inches in width.
2/ No data reported. 3! Cannot be calculated. 4/ Slitting stock, CDA end-use .classification 920, CDA alloy· 260, .0.020 inch
to 0.025 inch thick by maximum yield width (MYW).
Source: Compiled from data submitted in response to questionnaires of the U.S. International Trade Commission.
Note: Margins were calculated .from unrounded weighted-average prices. Thus, the mariins sh6~~ iri the~i tablei ci~~6i ~lways be duplicai~d f~6i ~hi i~~iid~d weighted-average prices shown above.
A-33
In contrast, producers' weighted-average negotiated· fabrication prices for the builders' hardware specification increased erratically from$*** per pound during January-March 1983 to $*** per pound during January~March 1985, or by *** percent. * * * fabrication prices for its contracts negotiated on sales of slitting stock were at $*** per pound during 9 quarters from January-March 1983 to October-December 1985. During the fourth quarter of 1984, and during the first and third quarters of 1985, * * * fabri~ation prices were slightly higher at $*** per pound. * * * negotiated fabrication price reported for the 0.010 inch to 0.013 inch gauge communications and electronics product (not shown) increased from $*** per pound during January-March 1983 to$*** per pound during October-December 1985, or by·*** percent. The negotiated fabrication price for this product increased by *** percent in the third quarter of 1984 and by *** percent in the fourt~ quarter of 1985.
Importers of * * * brass sheets and strips pr.ovided price data on their contract sales negotiated for the builders' hardware and slitting stock specifications. These data show the total· selling prices and the fabrication prices of the * * * m8terial declining during the period under investigation. From January-March 1983 to July-September 1985, importers' total selling price for builders'.hardware contracts negotiated fluctuated downward by*** percent, and the fabrication price component declined by *** percent. From January-March 1983 to October-December 1984, importers' total selling price for German slitting stock declined by *** percent and the fabrication price component declined by *~* percent.
Price comparisons
Spot price comparisons.--The·reported selling-price data for producers' and importers' largest quarterly ~pot sales during January-March 1983 to October-December 1985 resulted in 83 direct quarterly price comparisons between weighted-average delivered.prices.of domestic and imported brass sheets and strips from Brazil, France, Germany, Italy, Korea, and Sweden. Margins of underselling by.the subject imports were uniformly the highest for the 0.010 inch to 0.013 inch communications and electronics product, smaller fdr the builders' hardware product, and the smallest for ihe slitting stock product category. Margins of underselling (overselling) by country and product are reported in tables 22 and 23 and are discussed in detail below.
Brazil.--Underselling_ by importers of brass sh~ets and strips was generally * * * for imports from Brazil. Each of the *** price comparisons between domestic and imported Brazilian brass sheets and strips showed underselling by the imported products. There were *** price comparisons for the builders' hardware product category. Margins of underselling on importers' spot sales of builders' hardware from Brazil ranged from$*** to $***per pound, or from*** to*** percent of U.S. producers' weighted-average prices. For the slitting stock specification, importers undersold domestic producers in all 12 quarters during the period under investigation by from less than$*** to$*** per pound, or by*** to*** percent of domestic producers' prices. One price comparison involved the 0.010 inch to 0.013 inch gauge communications and electronics product sold during April-June 1983. In this instance, t~e price of the Brazilian material was $***per pound lower priced, or*** percent below the price of U.S.-produced material.
Table 22.--Brass sheets and strips: The average margins (per pound) by· which imports of builders' hardware undersold the u.s.-produced product sold on a spot-sale basis, by ~ountries of origin and by quarters, January 1983-December 1985 J;,_/ ·
Republic of Brazil : France : Germany : Italy : Korea
Period : Margin ; Percent ; Margin ; Percent ; Margin : Percent : Margin : Percent ' Margin · Percent
: : : : : 1983:
Jan. March--------: 2/ J:_I : 2/ : 2-/ : $*** : *** : 2/ : 2/ : 2/ ·: 2/ April-June--------: $***•: *** : . 2; : 21 : *** : *** : 21 : I.I : 2/ : 'II July-Sept.--------: *** : *** : $*** : *** : *** : *** : 21 : 2/ : 2/ : 2/ Oct.-Dec.---------: *** : *** : y : 2/ : *** : *** : 2/ : 3_1 : 2/ : !J
1984: : : : : : : : : -Jan.-March--------: *** : *** : *** : *** : *** : *** : $*** : *** : $*** : *** April-June--------: *** : *** : . *** : . *** : *** : *** : *** : *** : *** : *** July-Sept.--------: *** : *** : *** : *** : *** : *** : '!:_/ : '!:_/ : 2/ : 2/ Oct.-Dec.---------: *** : *** : *** : *** : *** : *** : 2/ : '!:_/ : 2/ : l)
1985: : : : : : : : : : : Jan.-March--------: *** : *** : *** : *** : *** : *** : 2/ : 2/ : *** : *** April-June--------: *** : *** : *** : *** : *** : *** : *** : *** : *** : *** July-Sept.--------: 2/ : 2/ : 2/ . 2/ : *** : *** : 2/ : 2/ : 2/ : 2/ Oct.-Dec.---------: 21 : 3_1 : It : 21 : *** : *** : 21 : I.I . *** . ***
; : : : : : : : !7 Builders' hardware, CDA end-use classification 110, CDA alloy 260, 0.016 inch to 0.032 inch thick by 2
inches to 12 inches in width. J: .. / Cannot be calculated.
Source: Compiled from data ·submitted in response to questionnaires of the U.~. International Trade Commission.
> 1 ~ .i::.
Table 23.--Brass sheets and strips: The.average margins (per pound) by which imports of slitting stock undersold or (oversold) the U.S.-produced product so~d on a spot sale basis, by cotintries of origin and by quarters, January 1983-~cember 1985 1/
. • ; ; RepubTic -of . : Brazil : France : Germany : Italy : Korea : Sweden 5 I
Period : Margin : Percent : Margin ; Percent ; Margin ; Percent ; Margin : Percent : Margin : Percent : Margin • Percent
: : : : : : : 1983: : : : : : :
Jan.-March--------: $*** : *** ·: 3/ : 3/ : $*** .: *** : 3/ : 3/ : 3t : 3/ : 3t : April-June--------: *** : *** : J/ : . 3; : '*** : *** : 31 : 3t .: 31 : 3/ : It : July-Sept.--------: *** : *** : J./ : 3/ : *** : *** .. 31 : 3t : 3; : J/ 3/ : Oct.-Dec.---------: *** : *** : I1 : . 31 : *** : *** : 11 : 3/ : 3! : 3/ : 31 :
1984: : : : .. : : : : : Jan.-March--------: *** : *** : $*** : *** : *** : *** : $*** : *** : $*** : *** : 3/ : April-June~-------: *** : *** : 11 : :~J : *** : *** : 3/ : 3/ : *** : *** : $*** : July-Sept.--------: 2t : *** : *** : *** : (***): (***): 31 : 3/ : *** : *** : 3/ :
*** : ll J/ Oct.-Dec.---------: *** : *** : *** : *** : *** : : : 1.1 : ]J : *** : 1985: : : : : : : : : : : : :
Jan.-March--------: *** : *** : *** : *** : *** : *** : 3/ : 3/ : *** : *** : *** : April-June--------: *** : *** : *** : *** : **·* : . *** : <***): <***>: *** : *** : *** : July-Sept.--------: *** : *** : *** : *** : *** :. *** : 3/ : 3/ (***): (***): *** : Oct.-Dec.---------: *** : *** : *** : *** : *** : *** : 11 : 31 : 4/ : 4/ : 3/:
.. : : r/ST1tt1ng stoi:K-;CDA-eno-usecl8ssillcation 920, CDA alloy 260, 0.020 inch to 0.025 inch thick by maximum yield width (MYW). 2; This price comparison showed absolute underselling of less than $0.005 pe'r pound. J/ Cannot be calculated. °£_/An importer.of Korean· slitting stock reported selling*** pounds of slitting stock with a special mirror polish for.$*** per
pound {delivered) during October-December 1985. This .pric~ was $***per pound, or almost*** percent, higher than the weighted-average domestic price during this period.·
2/ Margins of underselling for Swedish slitting stock were calculated using rounded, weighted-average U.S. producers' prices •.
Source: Compiled from d~ta submitted in response to questionnaires of the U.S. International Trade Commission.
3t It 3/ 31
~I *** 3/ -***
*** *** *** 3/
> I
V'I VI
A-36
Canada.-- No questionnaire responses were received fro~ Canadiin importers in time for inclusion with the data in this report; therefore, rio price comparisons were made.
France.--* * *, were reported by importers of brass sheets and strips from France and Germany. Of the *** price comparisons between U.S.-produced and French brass sheets and strips, all showed underselling by the imported product. From July-September 1983 to April-June 1985, importers' selling prices of the French builders' hardware product were lower priced than domestic producers' prices in*** instances. Underselling for this product category ranged from$*** to $***per pound, or was *** to ***.'percent below domestic producers' prices. For.the slitting-stock.product category,*** instances of underselling by importers of French material occurred from January-March 1984 to October-December 1985. In these instances, importers' prices were $*** to *** per pound, or *** to *** percent below domestic producers' prices. During January-March 1985, the price for the imported French 0.010 inch to 0.013 inch communications and electronics product was lower priced than u.s.-produced material by $***per pound, or by*** percent of domestic producers' prices •.
Italy.--Relative to .u.S.-producers' prices for the brass sheets and strips products investigated, prices of Italian imports were***·, Of*** price comparisons involving Italian imports, ***showed underselling and*** showed overselling by importers. *** price comparisons on spot sale~ of the builders' hardware product in the first half of 1984 showed margins of underselling of $*** per pound, or*** percent, and $***per pound, or*** percent. In April-June i985, Italian builders' hardware was lower priced ·than domestic material by $*** per pound or *** percent below domest.ic prices. Limited price data are available on Italian imports of the slit~ing stock product. It should be noted, however, that the largest importer of Italian brass sheets and strips did not respond to the Commission's questionnaire. During January-March 1984, importer• uridersold,U.S. producers by $*** per . pound, or by ***percent. During April-June 1985, however, importers oversold domestic producers by $***per pound, or by ***percent:
The Republic of Korea (Korea) .-.-Imported Korean brass sheets and strips was generally priced at levels similar to those of imported * * * material. *** of *** price comparisons showed underselling by importers of the Korean brass sheets and strips. *** instances of underselling occurred for the builders' hardware product category. Margins of underselling ranged from$*** to$*** per pound and importers' prices were therefore between*** to*** percent below domestic producers' prices. In*** of*** slftting stock price comparisons, imported Korean material was lower priced by absolute margins of $*** to $*** per pound, or by percentage margins of·*** tB *** below domestic producers' prices. During July-September 1985, importers' prices of Korean slitting stock were sold for $*** per pound above domestic producers' prices. One January-March 1983 price comparison for the 0.01 inch to 0.013 inch communications and electronics product showed underselling by Korean imports of $*** per pound or *** percent below prices of U.S.-produced material.
A-37
Sweden.--In all *** price comparisons for imp~rts of brass sheets and strips from Sweden, involviri·g the slitting stock product ca_tegory, importers undersold. d·ome~i'tic· p·roducers. Margin_s o.f underselling on sale~ of. the Swedish' slitdng stotk· :tange·d from $.*** to $*** per pound and averaged *** percent of domestfc' ·producers' prices. ·
West Germany.--*** of the *** price comparisons involving imports of West German brass sheets and strips sold on a. spot basis showed·underselling by the imported products. From January-March 1983 to October:-December 1985, importers' prices ot West.German builders' hardware were lower than U.S. producers I prices ~in•each Of the 12 quarJerS' With margins ranging from $*** to $*** per pound or *** to *** p~icent ~f domestic producers prices. Price comparisons on spot sales of the siitting st.ock .. product showed *** instances of underselling and *** of over'selling by importers of West German slit.ting stock. Underselling on the~e.·in~~ances r~nged from $*** to j*** per-pound~ or *** to ***percent below prices of 'u.s.-produc~d slitting stock~ During January-March 1985, the· 0.O10 inch· to 0 .013 inch ~ommunications and electronics prod.uct imported from _West Germany was sold for $*** per pound less _than domestfc material or ?.Y ·*** percent below domestic prices.
Price compari~on• on fixed-period c~~tract sales~--Price data rep~rted.by · U.S. producers and ·importers of brass sheets and strips from Germany-on-the · largest quarterly contr~6~• riegotiated.by them r~sult~d in*** price. · comparisons of fabrication pricei and.*** price cQmparisons of total negotiated prices~ the negotiated price of th~ fabrication plus that of the · metal being used. 'Because the repo~ting prod~6ers and importers absorbed the· freight costs for these contract sales, th~ fabricaiion prices are effectively. delivered pri~es. Th~se 'c6ntrac~ price comparisons generally show less . . . underselling by importers of 'Ger·man brass sheet·s and strips· th.an was observed for price comparisons on spot sales, and most' price' comparisons for the slitting stock specification showed importers' piic~s hjgher than producers' prices.
.' With respect to fabrication prices negotiated, importers of the b~ilders'
hardware and slitting stock products undersold domestic p~oducers in *** of ***quarterly price comparisons. Underselli~~ occurred in*** of*** qu~rters for the builders' hardware specification, with margins of underselling ranging from*** to*** percent of domestic producers' prices. In*** of*** price comparisons for slitting stock sales contracts negotiated, importers'. fabrication prices were higher than U.S. producers' prices by*** to*** percent. The one instance of underselling by importers~for the slitting stock product category occurr~d-dur{ri~ July-~eptember 1985 •. In this quarter, importers' fabricati6~ prices weie ~ow~r than those .of domestic producers by $*** per ·pound or *** percent. . · · . . . · .
Adding the ~etal values correspondl°ng to the periods in which the contracts were negotiated t'C) the fabrication prices. r_eported by producers and importers generally reduced th~ margin~ between th~ prices of domestic and German brass sheets and str:ips. Price comparisons ·of the total prices for contracts· negotiated· 'showed underselling by importers of * * * material in *** otlt of *** instancei, ail involving sales ~ontr~cts for th~ builders' hardware product category. Impor·ters· total pr1ces o·f b.uilders' hardware were lower
A-38
than· those of domestic producers in*** of*** quarters, by margins ranging from *** to *** percent. In each of *** total price comparisons for sales contracts of slitting stock, importers' prices were higher than those of U.S. producers, with margins ranging from*** to*** percent of producers' prices.
Transportation costs
Domestic producers of brass sheets and strips are located primarily in the Northeastern and Midwestern United States. All domestic producers and most· importers reported that they market brass sheets and strips nationally, and several reported sales outside the continental United States. * * *, an importer of the subject products from* * *, reported that its geographic market area was primarily limited to the Northeast and Midwest. U.S. inland transportation costs were absorbed by producers and importers on the majority of their sales, and transpottation costs repre~ented a small percentage of the final delivered price. Thus, while transportation costs might affect suppliers' "netback," they would probably not be an important factor affecting purchasers' sourcing decisions. Producers and importers were asked to report their average U.S. inland transportation costs in 1985 as a percentage of the final delivered selling price. u.s. producers generally reported that these costs ranged fr'om *** to *** percent of the final delivered price. Importers estimated average U.S. i~land transportation costs were a smaller proportion of the final delivered price and generally ranged from *** percent to *** percent. Average transportation costs of producers and importers, calculated from the actual costs reported for spot-sales price data, generally support these estimates. The average actual U.S. inland transportation costs per pound, as a percentage of the final delivered Melling price, are shown in the tabulation below by country of origin:
Exchange rates
Brazil----------France----------Germany----~----
I taly----------Korea-----------United States--~
***
*** ***
*** *** ***
· Table 24 presents nominal and real exchange rate indexes between the U.S. dollar and the Brazilian cruzeiro, Canadian dollar, French franc, Italian lira, Korean won, Swedish krona, and West German deutsche mark, by quarters, from January-March 1983 (the base period) to October-December 1985. Relative to the dollar, the currencies of the seven countries covered in this investigation all depreciated, in nominal terms, during this period. Nominal depreciation ranged from 5 to 20 percent for all subject currencies except the Brazilian cruzeiro. In nominal terms, the cruzeiro depreciated by 96 percent against the dollar since the base period. As a result of varying rates of inflation in the countries covered in this investigation and in the United States, the nominal exchange rate indexes do not explain changes in the real values of the subject currencies.
Table 24.--Nominal and real exchange rate indexes be.tween the u.s._.dollar an·d the Brazilian cruzeiro, Canadian dollar, French franc',. Italian lira, Korean won, Swedish krona, and the West German deutsche mark, by quarters, January 1983-D~cember 1985 ]._/ ]_/ . . .
(January-March 1983=100)
Period
irrazilian --=- -c-anadian cruzeiro : dollar French franc ; Italian lira Korean won Sweaish
krona German
deutsche mark
~Nominal: Real :Nominal: Real ~Nominal: Real :Nominal:. Real ~Nominal: Real :Nominal~ Real ~Nominal~ Real
1983: Jan.-Mar.: Apr.-June: July-Sep.: Oct. -D"ec.:
1984: Jan.-Mar.: Apr.-June: July-Sep.: Oct.-Dec.:
1985: Jan.-Mar.: Apr.-June:
· July-se·p.: Oct .-Dec.:
100.0 68.6
. 51. l 37.6
28.6 21.6 16.3 12.0
8.7 6.2 4.8 3.6
100.0: 90 .4: 95.6: 98. 7:
97.9: 97 .3: 98.3:
101.1:
101.3: 93.1: 94.8:
100. 7:
100.0 99~7 99.6 99.1
97.8 95.0 93.4 93 .1
90. 7 89.6 90.2 89.0
. 100.0: 100.9: 100 .6: 100 .1:
99.3: 96.9: 96.2: 96.3:
95.1: 94.4: 95.9: 94.6:
100.0 . 92 .2 •. 86.5 84.3
82.9 82. 7 76.9 73.6
69.2 73.2 79.3 87.3
100.0: 95.6: 92.2: 92.6:
93 .2: 95.0: 90.5: 88.2:
84.4: 90.0: 96.9:
103. 7:
100.0 94.7 88.9 86.l :
84.2 83.5 77.8 74 .o
69.2 71.0 73.8 80.0
100 .o: 96.0: 91.3: 90.9:
90.7: 91.4: 86 .4: 84.0:
.80. 9: 84.7: 88.6:
100 .o:
100.0 97.9 • 96.0 94.8
94.7 94.4 93.0 91.9
89.8 86.9 85.3 84.5
100 .o: 96.9: 93. 7: 92.1:
91.4: 90.8: 90.4: 89.7:
87.8: 84.9: 84 .2: 83.3:
100.0 98.3 94.9 • 93.6
92.9 92 .6 88.l 85.1
80.0 82.9 88.3 94 .8
100 .o: 98.8: 97 .2: 96.7:
97.6: 97.9: 94.7: 93 .6:
90.3: 93.5:
100.3: 107. l:
100.0 96.9 91.1 89.9
89.l 88.9 82.5 78.9
73 .9 78.0 84 .5 93.2
100.0 97.0 91.0 89.9
89.0 88.8 83.0 80. l
76.0 80.4 87.8 . 96.0
17 Exchllnge rates are-expressed in u.s. dollars· per unit of foreign currency. 2/ The real exchange rate indexes are derived from nominal exchange rates adjusted by the producer price indexes
of-each country. These indexes are presented in line 63 of the International Financial.Statistics.
Source: International Monetary Fund, International Financial Statistics.
> I
CA ID
A-40
The real value of the Brazilian cruzeiro and the Canadian dollar, relative to the U.S. dollar, did not change markedly during the.period under investigation. Adjusted for the high rate of inflation in Brazil, the real value of the cruzeiro at its lowest point was 10 percent lower, in real terms, than during January-March 1983. During October-December 1985, the real value of the cruzeiro was the· same as in the base period. The real value of the Canadian dollar had fallen by 5 percent since the base period as of October-December 1985.
The real values of the European Community currencies--the French franc, the deutsche mark, and the lira--followed similar, rapidly-shift~ng trends during January 1983-December: 1985. Relative to the U.S. dollar, the real values of these currencies all declined considerably during the second and third quarters of 1983 and again from the second quarter of 1984 through the first ·quarter of .1985. As of_ .January-March 1985, the real value of these· currencies had declined by 16 percent for the franc, 24 percent for the deutsche mark, and 19 percent for the lira. The real value of these currencies then reversed their downward trend and increased sharply against the dollar during the remainder of 1985. As of October-December 1985, the reai value of the franc had risen to 4 percent above its base period value. The real value of the deutsche mark was 4 percent below its base period value during October-December 1985. In the last quarter of 1985~ the ~eal ~alue of the lira was approximately at the same level as during January-March 1983.
·The Swedish krona followed the same trend as the ~uropean countrie~' currencies. At its lowest level during January-March 1985, th• real value of the Swedish krona was 10 perce?t below its base period value. As-~f October-December 1985, however, tne real value of the krona had· risen to 7 percent above its base period value •
• The real value of the Korean won fell steadily against the dollar every
quarter during January 1983-December 1985. As of the fourth quarter of 1985, the Korean won was 17 percent lower," in real terms, than in the base period.
Lost sales and lost revenues
Six domestic producers provided lost sales and lost revenue allegations for these investigations. Twenty-nine purchasers were cited in 45 allegations of sales revenues lost to avoid losing sales to imports from "the subject countries. Forty-four purchasers were cited in 75 allegations of sales lost because of price competition from the subject imports. Most of the lost revenues and lost sales allegations were for 1985~ but there wer~ alle~ations for the entire period of 1983 through early 1986. Alleged sales los~ from 1983 through early 1986 totaled approximately 9 .3 million pound·f!.• While the vast majority of these allegations involved import competition fo CDA Alloy 260 products (cartridge brass), other alloys, such as yellow brass, guilding brass, ·commercial bronze, and red brass were cited in a few instances. The number and type of allegations cited for each country subject to these, investigations is shown in ·the following tabulation:
A-41
Country of origi.,rt· Alleged lost sales· Alleged lost revenues
Brazil *** *** Canada *** *** France ·'• :*** *** Germa'ny ·*** *** Italy *** *** Korea *** ***
·sweden *** ***
Information obtained from purchasers contacted is summarized below.
· Purchaser 1.--* * * was cited by' both * * * in a total of *** allegations,. *' * *'cited * * * in *** lost rev'enue allegations on price reductions made in * * * to avoid losing sales of * * *·alloy inaterial to importers of. Bra'zili~n, German·, and Swedish ·material. Total revenues allegedly lost by*'** were$*** on sales of***· ·***cited the purchaser in·*** lost· safes allegatiort's involving *** pounds of German and Brazilian material Yepo~tedli ~urchase~ iri * * *~ * * *· * * *· The purchaser's' domestic suppliers include.* * *· The company used to purchase from * * * but hai not d~ne so recently because they "don't ~nock on our door." * * *hi~ purchased impoited br~ss sheets and strips from Brazil, Germany, and Sweden.
In *' * '*, this purchaser "pressured·* * * to reduce its ·prices of * * * alloy 6rass she~ts ana ~trips. '* * *· *. * *· Asked about import prices at th~-time, the ~urchaser reported' that Brazilian imports were selling for $*** per pound,· and ***·initial price was $***per pound. In***, the purchase~ bought German material· foi $***-~er ~ound. ·
The purchaser volunteered· price quotes he received in***, the ·peri~d of * * * allegation. * * * price' for a certain specification was $*** per pound and * · * * offered to sell German· material meetin·g these s.pecifications for $*** per pound. During the same month, * * *quoted a price for u.s.-produced ***brass strip of$*** per pound, and ***quoted price for Swedish material meeting these specifications was $*** per pound. . . ., . :
The major factors in this purchaser's sourcing decisions were cited as price, availability,· vendor· loyalty, and service. the manufacturer purchases imported bras~ sheets and strips piincipally to lower its average raw materiai costs. The spok~sman"couimented.that ''foreigners sell only on price," adding that current lead times·f~r·sp~t purchases ~ere about 6 weeks for U.S.-produced btass sheets and strips and 8 to 12 weeks, at the minimum, for foreign brass~ ·
Purchaser 2.--* * * cited * * *, a manufacturer of * * *, in a losi sales allegation involving *** pounds Qf * * * gauge by *'* * in width strip allegedly purchased from importers of Italian material in * * *· The purchaser reported that it· purchases domestically from * * *~ It has also purchased bras·s sheets and strips from Italy, Japan, Korea, Britain, and Germany. The Italian and Korean material currently 'being'purchased is reportedly lower priced than domestic material. In * * *, the manufacturer had initially agreed to purchase *** pounds of * * * brass material but canceled the order because of depressed demand in the * * * market.
A-42
The current prices for brass-sheets and strips purc~ases are approximately $*** per pound for Italian materi~l and $*** per pound for comparable domestic products. A price difference of this magnitude is reportedly small enough to purchase domestically because a buyer can sell the U.S.-produced brass scrap back to its domestic suppliers for approximately $*** per pound. Domestic producers will not repurchase brass scrap if they know it was from imported brass sheets and strips products. The major factor in this purchaser's sourcing decisions is currently price. Before the purchaser's industry (hardware) faced import competition, vendor reliability and quality were the most important determinants.
Purchaser j.--* * *, was cited by * * * in an allegation ~f rev~nues lost to avoid losing * * * sale to this purchaser because of price competition from Canadian imports. * * * is a manufacture.r of * * *. The c~pany purchases domestic brass sheets and strips from * * * and also purchases material imported from Brazil and Germany. The purchaser reported that imports from Brazil and Germany are approximately *** to *** percent lower priced than U.S.-produced brass sheets a~d strips. De~ying that any of its domestic suppliers had reduced pricei to * * * in * * * because of price competition from any imports, the spokesman explained that price competition from domestic firms was the reason * * * reduced its prices at that time. Reportedly, * * * initiated a price cut in * * *, and * * * followed with pr~ce reductions of their own.
***spokesman added ~hat imports have .. to.be lower priced by ***t per pound before he will buy them over domestic material because of .the longer lead times involved. Lead times for U.S.-produced brass sheets and strips can be as short as 2 weeks. For purchases of BrazJlian or Germ.an imports, it takes at least 3 to 4 months for delivery,.a~d sometimes supplies of these products arrive a month late. Purchasing solely imported products would only be possible if * * * increased its raw material inventories substantially, according to the spokesman. The purchaser reported that the quality of Brazilian and German brass sheets and strips is equal ~o that produced domestically.
Purchaser 4.--* * * named * * *, in a lost sales allegation involving a * * * purchase of Italian brass sheets and strips •. * * * is a manufacturer of * * * that purchases brass sheets and strips from ~ * * and a few other U.S •
. producers. The purchaser had a difficult ti~e recalling the * * * brass sheets and strips pricing situation but reported his belief that Italian material he was purchasing in * * * was ***t lower priced than Brazilian material and ***t to ***t lower priced than ~.S.-produced material. The quality of the imported brass sheets and strips from Brazil and Italy was equivalent to that of U.S. producers. Currently, the price differentials between U.S.-produced and imported brass sheets and .strips from Brazil and Italy are reportedly much smaller than in * * *· This purchaser added that he considered domestic and imported material price-competitive at that time.
Purchaser 5.--* * * alleged that * * *, a manufacturer of * * *, rejected its * * * price quote for *** pounds of * * * gauge materials in favor of lower priced French and German brass sheets and strips.
A-43
A spokesman for the company's legal department refused to answer specific allegations over the telephone. However, general information offered suggests that such a price quote from* * *, if offered, would have been rejected for reasons other than price. This purchaser currently buys U.S.-produced brass · sheets and strips from * * *· * * *· At that time, however, this manufacturer experienced quality problems with* **products and discontinued· purchasing them. The tolerances of * * * brass sheets and strips reportedly were inconsistent and performed poorly in the purchaser's manufacturing operations. The purchaser is satisfied with the quality of U.S.-produced material from * * *· Most of * * * experience with brass sheets and strips produced in foreign mills involves material purchased by * * *· To the best of the spokesman's knowledge, his company purchases domestic material almost exclusively for use in the United States, with the exception of spe~ial material purchased from* * * that is not available from U.S. producers. This product is a * * *·
Purchaser 6.--* * * also named * * *, a distributor of brass sheets and strips in a lost sales allegation involving *** pounds of * * * width brass strip allegedly purchased from~ * *, an importer of Brazilian material during * * *· * * * is a large scale distributor with * * *· * * * are among this purchaser's suppliers of domestic brass sheet and strip. It also purchases brass sheets and strips produced in Brazil, Canada, Sweden, and Germany. Asked about the specific allegation, the spokesman for the ~irm denied purchasing *** pounds from any supplier in one order, saying "that would be a~ awful lot." From foreign mills, the distributor typically purchases container loads (40,000 pounds) containing several different specifications of brass sheets and strips. ·
All of the distributor's purchases are on a spot basis, following their own price quote inquiries. The major factors in this purchaser's sourcing decisions were cited in order of importance as qu~lity, financial strength of· the vendor, product availability, the range of a supplier's product line, and price. The primary quality characteristics are cosmetic appearance, chemical composition, gauge control, and a coil size that a customer's equipment can handle. The accepted price quote does not necessarily have to be the lowest as long as it is within a certain range. Pric~ becomes a primary determinant when specifications required are not critical. The purchaser stated that German material is generally the highest priced among imports the distributor purchases.
The distributor acknowledged that, for 260 alloy brass, lower priced imports are a problem for U.S. producers because some importers do not charge for extra rolling or other special arrangements. Imports gained in their market share a couple of years ago when U.S. mills could not meet heavy demand in the automotive and electronics industries. The spokesmen commented that they could not understand why Canadian products were under investigation because they have played a positive role in the !U.S. brass market for years,. especially in periods of high demand. Canadian suppliers reportedly have sales practices similar to those of domestic producers and even use the U.S. producers' list prices for metal value, unlike importers of brass sheets and_ strips from other countries. Historically, the spread between U.S. producers' prices for metal value and the LME prices used by importers has ranged from ***i to ***i per pound.
B-1
APPENDIX A
FEDERAL REGISTER NOTICES
9536
B"'2
fcc.Jcral Register I Vol_. 51. No. 53 I Wcuncslfoy. ~lurch HI. 1U86 I Notices
(Investigations Noa. 701-TA-269 and 270 (Preliminary) and 731-TA-311-317 (Preliminary) J
Import Investigation; Certain Brass Sheets and Strips From Brazil, Canada, France, Italy, South Korea, Sweden, and West German1 AGENCY: U.S. lnternuliom.11 Trude Commission. ACTION: Jnslitutiop of prelimimtry countervailing duty and antidumping investig4tion11 and scheduling of a conference to be held in connection with the investigations.
SUMMARY: The Commission hereby gives notice of the institution of preliminury countervailing duty investigations Nos. 701-TA-269 and 270 (Preliminury) under section 703(a) of the Tariff Act of 1930
, (19 U.S.C. 161lb(a)) lo determine whether there ia a reasonable indkatiun
· tha-t an industry in the United Stutes ia materh1lly injured, or is threatened with malerial'injury, or the establishment of an Industry in the United Slates is materially retarded, by reason ol import!' from Brazil (investigation Nu. 701-TA-269 (Preliminary)) 1md France (investigation No. 701-TA-270 · (Preliminary)) of certain brass sheets arid strips (UNS C20000-series). the foregoing not cut. pressed, or stamped to nonreclangular ~hape, provided for in item 612.39 of the Tariff Schedules ol the United States. which ar~ alleged to be subsidized by the Governments of Brazil and france. ·
The Commission also gives notil:e of the instilulion of preliminary antidumping investigations Nus. 731-TA-~11-317 (Preliminary) under section 733(ct) of the Tariff Act ol 1930 (19 U.S.C. 1673b(a)) to determine whether there is a reasonuble indication that an industry In the United States Is materially Injured, or la threatened with material inju,.Y, or the establishment of an Industry in the United States is materially retarded, by reason ol imports from Brazil (investigation No. 731-TA-311 (Preliminary)); Canada. (investigation No. 731-TA-312 · (Preliminary)); France (lnvestlgutlun No. 731-TA-313 (Preliminary)): Italy (investigation No. 731-TA-314 (Preliminary)); South Korea (investigation No. 731-TA-315 (Prellminury)); Sweden (investigation No. 731-TA-316 (Preliminary)); and West Germany (investigation No. 731-TA-317 (Preliminary)) of certain brass sheets and strips (UNS C2QOOO.series), the f oregolng not cut, pressed, or stamped lo nonrectangular shape, provided for In Item 612.39 of the Tariff Schedules of the United Stales, which
. : .
' 11re ullcged lo be sold in the United Slales at less than fair value.
As provided in sectiuns 703(a) and 733(a), the Commission must complete preliminary countervailing duly and anliduf!lping investigations in 45 days. or in these cases by.April 24, 1986.
For further information concerning the conduct of these investigations and rules or general application, consult the Commission's Rules of Practice and Procedure. part 207, subparts A and B (19 CFR part 207), and part 201. sul.iparti; A though E (19 Cl-'R part 201). EFFECTIVE DATE: March 10. 19ll6. FOR FURTHER INFORMATION CONTACT: Ti!dford Briggs (202-523-4612). Orric:e or Investigations, U.S. lnternatiOnal Trad1: Commission, 701 E Street NW .. Washington, DC 20436. Hearing· impaired individuals are advised lh••I information on these matters can he obtuined by contacting the Commission's TDD tenninal on 211~-724-0002. $UPPLEM£NT ARY INFORMATION: Background.-These investigations aw being instituted In response to petitions filed on March 10; 1966, by counsel on behalf of American Brass, Buffalo. NY: Bridgeport Brass Corp .• Indianapolis. IN: Chase Brass Br Copper Co., Solon, OH: Hussey Metals Div. (Copper Range Co.). Leetsdale, PA; The Miller Co;, Meriden. CT; Olin Corp. (Brass Croup), East _ Allon, IL; and Revere Copper Products. Inc., Rome, NY.
Parlicipatio(I in Ille i111•estigaliu11:;.Persons wishing lo participate in th~se investigations as parties giusl file un entry of appeurance with the Secretn1·y to the Commission, as provided in I 201.11 of the Commission's rules (19 CFR 201.11). not later than seven (7) · days after publicalion"of this notic:e in the Federal Register. -"ny· entry of appearance filed after this date will be referred to the Chairwoman, who will determine whether to accept the late entry for good cause shown by the person desiring to file the entry.
Servicelist . ...;_Pursaunl to I 201.tl(dJ of the· Commission's rules (19 CFR 201.ll(d)), the Secretary will prepare a service list containing the.names and addresses of all persons, or thdr representatives. who are parties to the these invesligutioris upon the expiration of the period for filing entries of uppearance. In accordance with § § 201.16(c) a11d 207.3 of the rules ( rn Cf'R 201.16(c) and 207.3), each docum1:nt fil~d by a party lo the Investigations must be served on all other parties to the investigations [as identified by the service list),' and a certificate of service musl acc~mpany the document. The
B-3
federal R.igisler / Vol. 51, No. 53 / Wi:JncsJay. l\l:1rd1 1U. l!lllU / Notic.:es
Sccrct<1ry will nut ~cccpt a 'duc:ument for filing without a certificate of service.
ConfcJrence.-The Commis:iiun's . Director ~fOperations has schcduleJ a · conference in.connection with these invesiigalions for 9:30 a.m .. on April 4. 1966, at the U.S. lnternationi.tl Trade Commission Building. 701 E Street NW., Washin~ton, DC. Partie:i wishing to participate in the confori:nce sho.uld contact Tedford Brigg:1 (202-523-!612) nut later than March 31. 19&6. to arrange for their 11ppearance. Parties in support of the in1po11i\ion u( countcrvailin11 and antiJumping duties in these· investigations and partfes in opposition lo the imposition of such duties will each be cullectivdy allocakd one hour within which to muke an oral presentation ut .the conference.
Writ/en gubn1i:1sion11.-Any person may submit to the Comn1ission on or before April 8, 1{!86, a written statement of informatiu~ pertine~t to the subject of the investigations, as provided Jn . I 201.1s·orthe Commisi1iun'.s rules (19 CFR 207.1~)· A signed.original and · fourtee.n (i-1) copies of eac.h :iuh~ission must be filed with the Secretary to the Commission in 'accordance with I 201.8 of the rules (19 CFR 201.8).All written submissions except for confid1mliul . businei1s data will be available for public in:ipection during re11ular · business hours (8:45 a.in. tu 5:15 p.ui~) in the Office of the Secretary to tho Commission.
Any bui1iness information for which confidnntial treatment 111 desired must be submitted sepill'.ately •. The ~!lvelope and all pages of ;uch.subm.i,911lons must be clearly lubeled "Confidt?nlial Business Information." Confidential submissions and request for confidentiut· treatment must conform with the· requirements of I 201:6 of the · Commission's rules (19 Ct'R 201.6).
Authorily:.Thcse lnvesl_igalionq ,ure Lein11" cunJucled under uuthurlty uf thil Turirf Act uf. 1930, litle VII. Thi• nolice ia puLlished · · pursuant of I 207.12 of the Cummisaion'il ·· niles (19 CFR 207.121 . .
Dy order of lhe Commi11:1ion. lasued: March 13, 1986.
1'04Delh IL Mason. Sucrelary. (FR Doc. 86-4ill07 fitlld 3-t!H!u; 11:-15 amJ llWNG COOi 71120-02-M
B'"4
Federal Register / Vol. 51, No. 66 / Monday, April 7, 1986 / Notices 11771
lA-351-6031
Brass Sheet and Strip From Brazil; Initiation of Antldumplng Duty Investigation
AGENCY: International Trade . . Administration. Import Administration, Department of Commerce. ACTION: Notice. .
SUM~ARY: On the basis of e petition filed in proper form with the United Stoles Department of Commerce, we are Initialing an anlidumplng du,ly • . Investigation lo determine whether brass sheet and strip from Brazil are being, or ere likely lo be, sold In the United Stales at less than fair value. We are notifying the United Stales International Trade Commission (ITC) of this acflon so that II may determine whether Imports of these products materially Injure, or lhreuten material injury to, a United Stales industry. If this Investigation proceeds nomllllly, the ITC will make Its preliminary determination on or before April Z4, 1986, end we will make ours on or before August 18, 1986. EFFECTIVE DATE: April 7, 1986. . FOR FURTHER INFORMATION CONTACT:
· Mary S. Clapp, Office of Investigations, Import Administration, International Trade Administration. U.S. Department of Commerce, 14th Sireet and · Constitution Avenue, NW., Washington, D.C. 20230: telephone: (202) 377-1769 .. SUPPLEMENTARY INFORMATION:
The Pelillon
On March 10, 1980, we received a petition In proper form filed by American Brass; Bridgeport Brass Corporation, Chase Brass and Copper Company. Htissey Copper Ltd., the Miller Company, Olin CorporalionBross Group, and Revere Copper . Products, Inc., dpmeslic manufactu1·ers of brass sheet and strip, and by the International Association of Machinists ond Aerospace Workers, International Union-Allied Industrial Workers of · America (AFL-CIO), Mechanics Educational Society of America (Local 56), and Uniled Steelworkers of America (AFL-CIO/CLC). ·The petition was filed on behalf of the United States Industry lhal casts, rolls, and finishes brass sheet end strip. In compliance wilh the filing requirements of I 353.36 of the · Commerce Regulations (19'CFR 353.36), lhe pelilion alleged lhal imporls of lhe
subject merchandise from Brazil are being, or are likely to be, sold In the Uniled States at less than fair value within the meaning of section 731 of the Tariff Act of 1930, as amended (the Act), and that these Imports materially Injure, or lhr~alen materiel injury lo, a United .stale, industry.
Initiation of Investigation
Under section 732(c) of the Act, we must ~etermlne, within 20 days after a petition Is filed, whether It sets forth the allegations necessary for the Initiation of an !lnlidumping duty Investigation and, further, whether it contains Information reasonably available to the petitioner supporting the allege Ilona.
We:examined the petition on braes sheet and strip from Brazil and have found:that lt meets the requirements of section 732(b) of the Act. Therefore, In accordance with section 732 of the Act, we are Initiating an anlldumping duty Investigation to determine whether brass sheet and strip ate being, or are
, likely to be. sold in the United States at less than fair value.
Scope of Investigation.
The products covered by this Investigation are bra BB sheet and strip,· other than leaded brass and tin brass sheet and strip, currently classified under the Tariff Schedules of the United States, Annotated (TSUSA) Item numbers 812.3960, 612.3982, and 612.3980. The chemlc"l compositions of • the products under Investigation are currently defined In the Copper Development Association (C.D.A.) 200 series or the Unified Numbering System (U.N.S.) C20000 series. Products whose chemical compositions are defined by other C.D.A. or U.N.S. series are not covered by this Investigation.
United States Price and Foreign Market Value·
The petitioners based United States price on actual sales or offers made by a Brazilian proifucer to U.S. purchasers and from monthly average unit values of Brazilian brass sheet and strip Imports as derived from the Bureau of Census lmport:statlstics. Using actual sales prices end price. offers from lhe Brazilian produter, petitioners arrived at ex-factory prices by subtracting estimated charges for ocean freight, Insurance, customs duties, and U.S. · Inland freight. '.
Pelil!oners based foreign market value on lhe Brazilian producer's home market prices.·
Petilloners adjusted for differences in packing and credit costs.
Based on the comparison of these estimated values, pelitioners alleged
dumping margins ranging from 11.03 · percent to 55.93 percent.
NotifitaUon of ITC
· · Section 732(d) of the Act requires us to notify the ITC of this action and lo provide ll with the Information we used lo arrive at this determination. We will notify the ITG and make available to ll all nonprtvileged and nonconfidential . Information. We will also allow the ITC acceBS to all privileged and confidential Information in our files, provided It confirms that it will not disclose such Information either publicly or under an administrative protective order without the written consent to the Deputy Assistant Secretary for Import Administration. .
Preliminary Detennlnation by ITC
The ITC will determine by April Z4, 1986, whether there ls a reasonable Indication that Imports of braa11 sheet and strip from Brazil are causing material Injury, or threaten material
. Injury, to a United States Industry. If Its determination Is negatlve;the , Investigation will termjnate: otherwise, It will proceed accordln.r to •he statutory procedures. · Sohn L. Evaii1," · Actina Deputy Assistant Secretary for /111p11rt Administration. March 31, 1988. · · (FR Doc. ~76U filed.4-4-86: R:45 um) . BILLING COOE 3'1fMS-ll
(A-122-6011 .
Brass She~t and Strip From Canada; Initiation of Antldumplng Duty Investigation · · · ·
' . . AGENCY: lntemallonal Trade Administration, Import Administration, Department of Commerce. ACTION: Notice. . . .
SUMMARY: On the basis of a petition filed In proper: form with the United States Depa.rtment of Commerce, we are initiating an anlldumping duty lnvesllgatlon to determine whether brass sheet and strip from Canada are . being, or are likely to be, sold In the United Stales at less than fair value. We are notifying the United S~ates . . Jntemallonal Trade Commission (ITC) of this action so. that It may determine whether Imports of these products . materially Injure, or threaten material Injury to, a United States Industry. If this investigation proceeds normally, the ITC· will milk~ Its preliminary determination on or before April 24, 1986, and we will muke ours on or before August 18, 11180.
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11772 Federal Register / Vol. 51, No. 66 / Monday, April 7, 1986 I Notices j .••
EFFECTIVE DATE! April 7, 1986. FOR FURTHER INFORMATION CONTACT: Mary S. Clapp, Office of Investigations, Import Administration, lntematiomsl Trade Administration, U.S. Departmenl of Commerce, 14th Street and Constitulion Avenue. NW., Washington, D.C. 20230: telephone: (202) 377-1769. SUPPLEMENTARY INFORMATION:
. Tbe Pelilion
On March 10, 1986, we received a petition i~ proper fonn filed by · American Brass. Bridgeport Brass Corporaliun, Chase Brass and Copper Company, Hussey Copper Ltd., Miller Company, Olin Corporation-Brass Group, and Revere Copper Products, Inc., domestic manufacturers of brass sheE:t and 1trip, and by the International Association of MachinistS and · . Aerospace Workers, International Union-Allied Industrial Workers of America (AFL-clO), and the Mechanics F.ducational Society of America (Local 56). The petition was filed on behalf of the United S•ates industry that casts, rolls, and finishes brass sheet and strip. In compliance with the filing requirements of I 353.36 of the Commerce Regulations (19 CFR 353.36), the petition alleged that imports of the subject merchandise from Canada are being, or are likely to be, sold in the United Slates at less than fair value within lhe meaning of se.:lion 731 of the Tariff Act of 1930, as amended (the Act), amt that these import11 materially injure, or threaten material injury to, a United States industry.
Initiation of lnves'tigatioo
Under section 732(c) of the Act, we must determine, within 20 days after a petition is filed, whether it sets forth the ullegations necessary for the initiation of an antidumping duty investigation and, further, whether it contains information reasonably available to the petitioner supporting the allegations.
We examined the petition on brass sheet and strip from Canada and have found that it meets the requirements of · section 732(b) of the Act. Therefore, in accordance with section 73Z of the Act, we are initiating ao antidumping duty investigation to determine whether brass sheet and strip are being, or are likely to be. sold in the United States at . lesa than fair va!Ue. ·
Scope of Investigation
The products covereJ by this investigation are brass sheet and slip, other than leaded brass and tin brass sheet and strip, currently classified
under the Tariff Schedules of the United States. Annotated (I'SUSAJ item numbers 612.3960, 612.3982, and 612.3986. nle chemical compositions of the products under investigation are currently defined in the Copper Developmenl Association (C.D.A.) 200 series or the Unified Numbering System (U.N.S.) C~ aeries. Products whose chemical compostions are defined by other C.D.A. or U.N.S. series are not co~red by this investigation.
Uniled States Price and Foreign Market Value ·
' The petitioners based United States
price a on actuaf sales or off era made by Canadian producers to U.S. purchasera and from monthly average unit values of Canadian brass sheet and strip imports as derived from the Bureau of Census import statistics. Using actual sales · prices a.nd price offers from Canadian producers, petitioners arrived at exfactory prices by subtracting estimated charges for customs duties and U.S. inland freight.
Petitioners based foreign market value on home market prices of the Canadian producers. · ·
Petitioners adjusted for differences in p<1cking and credit costs.
Based on the comparison of these estimated values, petitioners alleged dumping margins ranging from 9.15 percent to 24.94 percent.
Notification of ITC
Section 732(d) of the Act requires us to notify the ITC of this action and to provide it with the information we used to arrive at this determination. We will notify the ITC and make availuble to ii all nonprivileged and nonconfidenlial infonnation. We will also allow the ITC access to all privileged and confidential information in our files, provided it confirms that it will not disclose such lnfonnalion either publicly or under an administrative protective order without the written consent of the Deputy Assistant Secretary for Import Administration ..
Prelimi.Dary D~tennioatloo by ITC
·The ITC will determine by April 24, 1986, whether there is a reasonable . indication that iinports of brass sheet and strip from Canada are causing material injury, or threaten material ilijury, to a United Stales industry. If its determination is negative. the investigation will terminate; otherwise,
it will proceed according to the statutory procedures; · Johll L Evans, Ac~ion Deputy As~":.tun/ Sec:relary /vr lmpurl Administration. March 31.1986. (FR Doc. 116-:7612 Filed~; 6:45 amf BILLING CODE UIO-OS-U
(A-428-602)
Brass Sheet and Strip From the Federal Republic of Germany; Initiation of Antldumplng Duty Investigation
AGENCY: International Trade Administration, Import Admi.nii;trJlion. Department of Commerce.. ACTION: Notice.
SUMMARY: On the basis of a petition filed·io proper form wilh the United States Deparbnent of Commerce, we are Initiating aantidumping duty investigation to determine wbetht=r brass sheet and strip from the Federal Republic of Germaoy (FRG) are being, or are likely to be, sold in the United States aHess than fair value. We are notifying the United States International Trade Commission (ITC) of this action so that it may determine whether imports of these producbl ma lerially injure, °'threaten material injury to, a United States industry. If this investigation proceeds normally, the ITC will make its preliminary determiDlllion on or before April 24, 1986, and we will make ours on or before August 18. 1986. EFFECTIVE DATE: April 7, 1986. FOR FURTHER INFORMATION CONTACT: Mary S. Clapp, Office of Investigations, Import Administration, International Trade Administration, U:S. Department of Commerce, 14th Street and Constitution Avenue, NW., Wa11hingtoo, D.C. 20230; telephone: (202) 317-1769. · SUPPLEMENTARY INFORMATION:
The Petition On March 10, 1986, we received a
petition in proper form filed by American Brass, Bridgeport Brass Corporation, Chase Brass and Copper Company, Hussey Copper Ltd., the Miller Company, Olin Corporation- · Brass Group, and Revere Copper· Products, Inc., domestic manufacturers of brass sheet and strip, and by the International Association of Machinists and Aerospace Workers, International Union-Allied Industrial Workers of America (AFL-CIO), Mechanics Educational Society of America (Local 56), and United Steelworkers of America (AFL-CIO/CLC). The petition was filed
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Federal Register I Vol. 51, No. 66 I MQnd1;1y. Aprir7,."1986 I Notices 1177~
on behalf of the United States industry .. · that casts. rolls, and finishes brass sheet · and strip. lit compliance with tJte filing requirements or t 353.36 of the Commerce Regulations {19 CFR 353.36), the petition alleged that imports of tha subject merchandise from the FRG are being, or are likely to he, sold in the United States at less than fair value within the meaning of section 731 of the Tariff Act of 1930, as amended (the Act), and that these imports materially injure, or threaten material injury to, a United States ind~stry.
Initiation of Investigation Under section 732(c) of the Act, we
must determine, within 20 days after a · petition is filed, whether it sets forth the
allegations necessary for the initiation of an antidumping duty inyestigation and, further, whether it contains · information reasonably available to the petitioner supporting the allegations. , • We examined the petition on brass sheet and strip from the FRG and have found that it meets the requirel)lents of section 732(b) of the Act. Therefore, in accordance with section 732 of the Act, we are initiating an antidumping duty investigation to determine whether brass sheet and strip are being, or are likely to be, sold iJ) the United States at less than fair value.
Scope of Investigation The products covered by this
investigation are brass sheet .and strip, other than leaded brass and tin brass . sheet and strip, currently classified under the Tariff Schedules of the United States, Annotated (TSUSAJ item numbers 612.3960, 612.3982, and 612.3~_86. The chemical compositions of the products under investigation are currently defined in the Cooper . Development Association (C.D.A.) 200 series or the Unified Numbering System (U.N.S.) C20000 series. Products whose chemical compositions are defined by other C.D.A. or U.N.S. series are not covered by this investigation.
United States Price and Foreign Market Value
The petitioners based United States price on actual sales or offers made by FRG companies to U.S. purchasers and from monthly average unit values of FRG brass sheet and strip imports as derived from the Bureau of Census import 11tatistics. Using actual sales prices and price offers fro~ FRG . companies. petitioners arrived at exfactory prices by subtracting estimated charges for ocean freight, insurance, customs duties, and U.S. inland freight.
Using an FRG producer's home market prices, petitioners arrived a-t ex-factory
prices by deducting insurance 'and discounts. . ._ , .
Petitioners also adjusted fo,r . · differences in packing an4_credit costs.
Based on the comparison of these · estimated values, petitioners allege ·
· average dumping margins ranging from 2.71 percent lo 62.43 percent. · ·
Notification of ITC ..
Section 732{d) of the Act requires us to notify the ITC of this action and to provide it with the information we used to arrive at this determination. We will notfiy the ITC and make available to it all nonprivileged and nonconfidential informatiop. We will also allow the ITC access lo all privileged and confidential information in our files, provided it confirms that it will not disclose such information either publicly or under an administrative protective order without the written. consent of the Deputy Assistant Secretary for Import Administration. ·
Preliminary Dete~Uon by ITC
The ITC will determine'by April 24, 1986, whether there is a reasonable indication that imports of brass sheet and strip from the FRG materially injure, or threaten material injury to, a United States industry. If its determination is negative, the investigation-will · terminate: otherwise, it will proceed according to the statutory procedures. John L. Evans, · · .
Acting Deputy Assistant Secretary for Import Admjnistration. March 31, 1986. [FR Doc. 86-7617 ,Filed 4-4-00; 6:34 am) BIWNG CODE S51o-oS-ll
[A-427-602) ;
Brass Sheet and Strip From France; Initiation of Antldumplng Duty · Investigation
AGENCY: International Trade Administration, Import Administration,
· pepartment of Commerce. ACTION: Notice.
SUMMARY: On the bar.is of a petition filed in proper form with the United. States Department of Commerce, we are initiating an antidumping duty. · investigation to determine whether brass sheet and strip from France are · · being, or are likely to be, sold in the United States at less than fair value. We are notifying the United States Intemati~nal Trade Commission (ITC) of this action so that it may determine whe~her imports of these products materially injure, or threaten material injury to, a United.States industry. If this
.. investigation proceeds normally, the ITC will inake its preliminary determination on or before April 24, 1986, and we will
· make ours on or before August 18, 1986.
EFFECTIVE DATE: April 7, 1986 ..
FOR FURTHER INFORMATION CONTACT: Mary S. Clapp, Office _of Investigations, Import Administration,· International Trade AdniinistratiQn, u·.s: Depa.rtment of Commerce, 14th Street and Constitution Avenue, NW., Washington, D.C. i0230; telephone: (202) 377-1769.
SUPP~MENTAi:IY INFORMATION;
The Petition
On Marcli 10, 1986, we receiyed a petition in proper form filed by American Brass, Bridgeport Brass Corporation, Chase Brass and Copper Company, Hussey Copper Ltd., the Miller Company, Olin CorporationBrass Group. and Revere Copper · Products, Inc., domestic manufacturers of brass sheet and strip, and by the International Association of Machinists and Aerospace Workers, International Union-Allied Industrial Workers of America {AFL-CIO), Mechanics Educational Society of Ame*a (Local 56), and United Steelworkers of Americu (AFL-CIO/CLC). The petition was filed · on behalf of the United Slates industry that casts, rolls, and finishes brass sheet
1
and strip. In compliance witti the filin8 requirements of § 353.36 of the : · ·
. Comµierce Regulations (19 CFR 353.36), the petitioµ alleged that imports of the subject merchandise from Franc:e are being, or are likely to be, sold _in th~ United States at Jess than fair value within the meaning of section 731 of the Tariff Act of 1930, as amended (the Act), and thql these imports materi_ally injure; or threaten material injury lo, a United States industry.. ·
lnitiat~on of Investigation ·
·Under section 732(c) of the Act, we must determine, within 20 days after a petition is filed, whether it sets forth the allegatfons necessary for the initiation of an.antidumping 41uty investigation and, further, whether it contains information reasonably available to the petitioner supporting the allegations.
We examined the petition on brass sheet and strip from France and have found that it meets the requirements of section 732(b) of the Act. Therefore, in accordance with section 732 of the Act. we are initiating an antidumping duty investigation to determine whether brass sheet and strip are being, or are likely to be, sold in the United States at less than fair value.
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11774 Federal Register I Vol. 51, No. 66 I Mond<ty, April 7, 1986 I Notices
. Scope of hivestigation
· The pro~ucts covered by this investigation are brasa sheet and strip, other than leaded brass and tin brass
· .sheet and strip, currently classified undi:r the Tariff Schedules of the United · States. Annotated (TS USA) item numbers 612.3960, 612.3982, and 612.3986. The chemical compositions of the products under investigation are currently defined in the Cooper Development AssociatiOn (CD.A.) 200 series or the Unified Numbering System (U.N.S.) C20000 series. Products wtlose chemical compositions are defined by other C.D.A. or u.N.S. series are not cQvered by this investigation.
United Statea Price and.Foreign Market Value · ·
The petitioners based United States . price on actual sales or 'offers made by a French producer to U.S. pW'cbaseri and from monthly average unit values of 1-'rcnch brau sheet and strip imports are derived from the BW'eau of Census import'statistica. Using actual sales prices and price offers from the French producer, petitioners arrived at exfactory prices by aubtractin8 estimate~ charges for oc'ean freight, 'insurance, customs duties. and U.S Inland frelghL
. Using the French producer'a IKJme . market prices, petitioners arrived at exfactory pricea by deduetfug' disco'unts.
Petitioners also adjusted for differences in packing arid credit costs.
Based on . .the ·comparison of these estimated valueli, pelitioriers alleged dumping margins ranging from t.76 percent to 60.85 percenL
Notific:alioo of ITC . Section 732f d) of the Act requites us
to notify the ITC of this action and lo provide.it with ~e information we used to arrive et this determination. We Will notify the ITC and make available to it
. ell nonprivileged end nonconfidential informatioo.-We will also' allow the ITC access to all privileged and confidential information in our files. provided it confirms that il will not disclose such information either publicly or under an administrative protecth;e order without the written consent of the Deputy . · Assistant Secretary for Import Administration
Preliminary Determination ·by ITC
The ITC will detennine by April 24, 1986, 'whether there is a reasoaable indicati'on that imports of brass sheet and 1trip from France are causing material injury, or threaten.material . injury, to a United States industry. If its determination is negative, the investigation will terminate; otherwise,
it will proceed according to the statutory procedures. John L. Evans, · . Acti11g.Deputy Assistant Secrotaryfor Import AdministratiorL · . · · · · · March St, 1988. • ·
(FR Doc. 00-7613 Filed 4-4-66; 8:45 amJ BIWNG CODE a51o-os-tl
(A-475101)
Brasa Sh-et and Strip From Italy; Initiation of Antidumplng Duty ln~stlgatlon · · ·
AGENCY: International Trade Administration. Imp~rt Adminllilration, ·. Department of Commerce. ACTIOtc Notice.
and.strip. lil compllarice\vith the filing requirements I 353.36 ofthe Commerce Regulations (19 CFR 353.36), the petition alleged· that lmP.orts of the subject · merchandise from Italy ere being, or are likely to be, sold in the United States at less than fair value within the meaning of section 731 of the Tariff Act of 1930, as amended (the Act), and that these imports materially Injure, or threaten material injury to, a United States Industry. · · ·
Initiation of Investigation
Under section 732[c) of the Act, we must determine, within 20 days after a petition is filed, whether it set& forth the allegations necess.ary for the biitiation of an antldumping duty investigation and, further, whether it contains ·
SUMMARY: On the basis of a petition information reasonably avaUable to the · filed in proper form with the United petitioner supporting the allegations . States Department of Commerce, we are We examined the petition on brass
· Initiating an anti<Jumping dµty sheet and s~p from Italy and have Investigation to defermjne whether found that It meets·the requirements of brass sheet and strip from Italy ere section 732(b) of the Act. Therefore, in being. or are likely to be, sold in the · accordance with section 732 of the Act, United States at less then fair value. We we an: initiating 8n entidumpting duty are notifying the United States . investigation to determim[I whether
. ln(emational Trade Commission (ITC) · brass sheet and strip are being, or are ·of this action 10 that It may determine. likely to be, sold in the United States at . whether imports of these produ(:ts less ~an fair value. · materially ~jure, or threah;n materi11l Scope of Investigation injury to, a United States industry. If this investigation proceeds no~y. the ITC will make its preliminary determination on or before April 24, 1986 .. and we will make ours on or before August 18, 1986. EFFECTIVE DATE: April 7, 1986.. FOR FUllTHER INFORMATION CoNTACT: Mary s: Clapp, Office of Investigations, bnport Administration, International Trade Administration, U.S. Department of Commerce, 14th Street and Constitution Avenue, NW., Washington, D.C. 20230; telephone: (2Q2) 3~7-1769. SUPPLEMENTARY INFORMATION: •
The Petition
. On March 10, 1986, we received e petition in proper fonn filed by American Brass, Bridgeport Brass · Corporation. Chase Brass and Copper Company, Hussey Copper Ud .. the Miller Company, Olin CorporalionBrass Group, and Revere Copper · Products. Inc., domestic manufacturers of braH sheet and strip, end by the . International Association of Machinists end Aerospace Workers, Int~mational Union-Allied Industrial Workers of America (~10), Mechanics. Educational Socie~y of America (Local 56), and United Steelworkers of America (APL-CIO/CLC). The petition was filed on behalf of the United States Industry that casts, rolls, end finishes brass sheet
The products covered by this . investigation are brass sheet and strip, other than leaded brass and tin brass sheet and strip, Cun"ently classified under the Tariff Schedules of the United States. Annotated (TSUSA)4tem numbers 612.3960, 612.3982, and 612.3986. The chemical compositions of the products under investigation are currently defined in the Copper Development Association (C.D.A.) 200 series or the Unified Numbering System (U.N.S.) C20000 series. Products whose chemical eompoaitions ere defined by other C.D.A. or U.N.S. serie!J ere not covered by this invesUgation.
Uni~ed States Price and Foreign Market Value ·
The.petitioners based United States price on actual sales or·offers made by en lt~lian producer-to U.S. purchasers and from monthly average unit values of
. Italian brass sheet and strip imports as · derived from the Bureau gf. Census import statistica. Using actual sales
· prices and price offers from the Italian producer, petitioners arrived at exfactory prices by subtracting estimated charges for ocean freight, insurance, customs duties, and U.S. inland freight. · Using the Italian producer's home ', market prices, petitioners anived at ex.factory prices by deducting discounts.
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Federal Register / Vol. 51, No. 66 / Monday, April 7, 1986 / Notices 11715
Petitioners also adjusted for . differences in packing and credit costs.
Based on the comparison of these · estimated values, petitioners alleged dumping margins· ranging from 2.78 percent lo 22.00 percent. ·
Notification of ITC
Sectic;m 732(d) of the Act requires us to notify the ITC of this action and to provide it with the information we used to aJTive at this determination. We will notify the ITC and make available to it all nonprivileged and nonconfi<lential information. We wip also allow the ITC access to all privileged and confidential in~ormation in our files. provided it confirms that it will not disclose such information either publicly or under an administrative protective order without the written consent of the Deputy Assistant Secretary for Import Administration.
Preliminary ~etermination by ITC · The ITC will determine by April 24,
1986, whether there is a reasonable indication that imports of brass sheet and strip from Italy are causing material injury, or threaten material iniury. to a
· United States industry. If its determination is negative, the . investigation will terminate: otherwise, it will proceed according to the statutory procedures. John L Evans, Actii1g Deputy Ai;sista11t Secretary fur Import Adminislratio11. · Ma·rch.31.1986.
·[FR Doc, ~7614 Filed H-116; 11:4S ~ml BIWHG CODE 3510-0S-U
(A5So-603J
Brass Sheet and Strip From the Republic of Korea; Initiation of'. Antldumplng Duty Investigation
AGENCY: International Trade . Administration, Import Administration, · Departm~nt of Commerce. ·
ACTION: Notice.
SUMMARY: On the basis of a petition filed in proper form with the United States Department of Commerce. we are initiating en antidumping duty investigation to determine whether .bra115 sheet and strip from the Republic o_f Korea are being. or are likely to be, sold in the United States at less than fair value. We are notifying the United · Stateslntemational Trade Commission (ITC) of thia action so that it may determine whether imports of these products materially injure, or threaten material injury to, a United Stales industry. If this investjgalion·proceeds
-normally, the ITC will make its preliminary determination on or before April 24, 1986, end we will make ours on or before August 18. 1986. EFFECTIVE DATE: April 7, 1986. FOR FURTHER INFORMATION CONTACT: . Mary S. Clapp, Office of Investigations,
· Import Administration, International Trade Administration, U.S. Department -of Commerce, 14th Street and Constitution Avenue, NW., Washington, D.C. ~0230; telephone: (202) 377-1769.
·&UPP~MENTAAY INFORMATION:
The.Petition
On March 10, 1986, we received Ii · 'petition in proper form fil!ld by ~me~ican Brass. Bridgeport Brass
. Cor~ration, Chase Brass and Copper .. Company, Hussy Copper Ltd., Miller ; Company, Olin Corporation-Brass · Group. and Revere Copper Products, Inc.; domestic manufacturers of brass sheet and strip, and by the International Association of Machinists and · . Aerospace Workers, International · Unioit; Allied Industrial Workers of America {AFL-CIO), Mechanics Educational Society of America (Local 56), and United Stales Steelworkers of • America (AFL-CIO/CLC).'The pe~ition was filed on behalf of the United States industry that casts, rolls, a'nd finishes bras$ sheet and strip. In compliance . with the filing requirements of§ 353.36 of the Commerce Regulations (19 CFR 353.36), the petition alleged that imports. of the subject merchandise from the · Republic of Korea are being, or are likely to be, sold in' the United States at less than fair value within the meaning of section 731 of the Tariff Act of 1930,
· as amended (the Act), and that these imports materially injure, or threaten material iniury to, a United States industry. ·· · · ·
lniti .. tion of Investigation
Under section 732(c} of the Act, we must determine, within 20 days after a petition is filed, whether it sets forth the allegations necessary for the initiation of an antidwnping duty investigation and, further, whether it contains infonnation reasonably available to the · petitioner supporting the allegations.
We examined the petiion on brass sheet and strip from the Republic of Korea ·and have found that it meets the requireme~ts of seciion 732(b) of the Act. Therefore, in accordance with seE:tion 732 of the Act, we are initiating an anUdumping duty investigation to determine whether brass sheet end strip are being, or are likely to be, sold in the . United States at less than fair value.
Scope of Investigation
The products covered are bra1111 sheet end strip, other than leaded brass und· tin bra~s sheet und strip, currently classified under the· Tariff SchedultJs of tl1e United States,. Annotated (TSUSA] item numbers 612.3960, 612.3982, and 612.3986. J'he chemic~! compositions of the products under investigation are currently defined in the Copper Development Association (C.D.A.) zoo series or the Unified .Numbering S)·stem (U.N.S.) C20000 series. Products whose chemi.ca! compos~ticins are defined by other C.D.A. or U.N.S. series are not covered. by this ipvestigation.
United Siatesi>rlce !lad f'.oreign Market Value · · ·' ·
· ·The petitioners based United States price on actual sales or offers made by 8
.Korean producer to U.S. purchasers and fro.m monthly average unit values of the Repul!lic of Korea's brass sheet and strip imports as derived from the Bureau
. of Cens.us import statistics. Using actual sales prices and price offers from the Korean producer, petitioners arrived at ex-factory prices by subtracting estimated charges for foreign inlund freight, ocean freight, insurance, customs duties and U.S. in land freight.
Petitioners b!lsed foreign market value ·on hor,ne market prices of the korean producer ... · . .
Petitiqners ac;ljustec;I for differences in · pa~ing and Q~dit costs. ·
Based on th.e comparisorl-of these · estimuted .. vBlues; petitioners. lillegcd · dumping rpargins ranging from 2.97 percent to 37.1.5 perc_ent.
Notification of ITC " ·'
Section 732(d) of the Act requires us to notify the ITC of this action and to provide it with the information we used
:·to arrive.at th.is;determination~ We will notify the ITC and make available to It
. al.I nonprivOeged and rionconfidcntial . information .. We will also allow the ITC acce11s .to all. privileged and confidential inform_ation in our files, provided it confirms that it will not disclose such information either publicly or wider an administrative protective order without the written consent of the Deputy Assistant Secretary for Import· Administration. ·
PrelinJinary Determination by ITC
The ITC will determine by. April 24. . 198~ •. wllether there is a reasonable
indication that imports of brass sheet and strip from the Republic of Koren uru causing material injury, or threaltm material injury, to a United States ipdusiry. If its ~etermination is negative, the investigation will terminate:
B-9
11776 Federal Register / Vol. 51, No. 66 '/ Monday, April 7, 1986 I Notices
otherwise, it will proceed according to the statutory procedures. · John L Evans, . Acting Deputy Assistimt Secr.etary for Import Admi11islralion. · March 31, 1986. . . ,. . (FR Doc. 86-7615 Filed 4-4-86; 8:45 am) BIWNG COO£ 1510-05-M
lA-401-6011
Brass Sheet and Strip From Sweeten; Initiation of Antldumplng Duty lnvestlgaUon · · . · ·
AGENCY: International Trade Administration, Import Administration, Department of Commerce. · · ACTION: Notice.
SUMMARY: On the basis \Jf a'.petition filed in proper form with the United States Department of Commerce, we are initialing an antidumping duty investigation to determine whether · brass sheet and strip from Sweden are being. or are likely to be. sold in the .. United States at less than fair value. We are notifying the United States International Trade Commission (ITC) of this action so that.it may determine whether imports of these products materially injure. or threaten material ' injury to, a United States industry, If this investigation proceeds normally, the ITC will make its preliminary determination on or before April 24, 1986, and we will make ours on or before· August, 18, 1~86. EFFECTIVE DATE: April 7, 198~: . . FOR FURTHER INFORMATION CONTACT:· Mary S. Clapp. Office of Investigations, Jmport Administration, International
· Trade Administration, U.S. Department. of Commerce, 14th Street and , Constitution Avenue, NW.; Washington, D.C. 20230; tel.ephone: (~2) 371-1769. SUPPLEMENTAflV INFORMAT.ION:. .. ,
The Petition On March 10. 1986, we 'received a
petition in proper form filed by · American Brass, Bridgeport Brass Corporation, Chase Brass and Copper Company, Hussey Copper Ltd ..• the · · Miller Company, Olin Corporation~ Brass Group, and Revere Copper · Products, Jnc., domestic manufacturers of brass sheet and strip, and by the · •· · International Association of M11chinists and Aerospace Workers, International. Union-Allied Industrial Workers of America (AF~IOJ, Mecha11ics Educational Society of America (Local 56). and United Steelworkers of America (AFL-CIO/CLC). The .petition was filed;. on behalf of the United States industry that casts. rolls, and finishes brass sheet
.. and strip. In compliance with the filing requirements of § 353.36 of the .. Commerce Regulations (t9 CFR 353.36), the petition alleged ~hat imports of the subject merchandise from Sweden are being, or are likely to be, sold in th!) · United States at less than fair value · within the meaning of section 731 of the T~riff Ac~ of 19~0, as amepded (the Act), and tJia~ ~ese impor's materialJy injure, or t.hrea.ten matetjal injury to, a United. St11tesJn~ustry._ ·
Jnltiation of Investigation
- Under ·5~Ction .732(c) of the Act, we must determine, within 20 days after a petition is.filed, whethe~ it sets forth the allegations necessary for the initiation of a11·anti~umping duty investigation and, further, whether it contains . information reasonably available to the petitfoner supporting t~e allegations. , ·
We examiiied the petition on brass sheet and strip from· Sweden and have found that it meets the requirements of section 732(b) of the Act. Therefore, in accordance with section 732 of the Act, w.! are initiating an antidumping duty Investigation to determine whether brass sheet .and strip are being, or are likely'tobe, sold in the United States at li!SS _th~n (air ~alue., ·
Scope of Investigation . !:· '. . ·i• . The products covered by this
investigation are brass.sheet and strip, other than.leaded brass and tiri brass sheet and strip, currently classified under the Tariff Schedules of the United States,,,Annotated (TS USA) item · · · numbers 612.3960, 612.3982, and· · · 612.3986 .. The chemical compositions of th11 products under investigation ar~ · currently defined in the Copper . Development AssoCiation-(C.D.A.) 200 series or the Unified Numbering System (U.N.S.) C20000 series. Products whose
·chemical compositioill! -are defined by other C.D.A. or U.N;S. series are not covered by this investigation.-
united States Price ~d Fon,ig~ Ma.rkel Value · · · .· __ · , · _
I
The petitioners. based United States prj!=e on actual sal~s or offers made by a S~edish producer to u:s. purchasers .. and from ~ontly averag~. unit values of Swedi~h brass sheet ~nd strip Imports . , as derived from the Bureau of Ce_nsus impprt statistics. Usiiig ac,ual sales .. prJces .and price off era from the Swe.dish producer, petitioners.arrived a' ex- .. factory prices by subtracti_ng estimated, changes for ocean freight.and insurance, c:-ustoms·duties, and u.s:·inland freight.
Usiilg ~he $\\'.,edish pro~ucer~s home · market.pric.es, pqtitioners arrived-at exfactory prices by deducting discounts.
Petitioners also ·adjusted for differences in packing and credit.
Based on· the comparison of these estimated va.lues, petitioners allege dumping margins· ranging from 5.47 percent to 35.72 percent. ·
Notification of ITC
Section 732(d) of the Act requires us to notify the ITC of this action and to provide it with the information we used to arrive at this determination. We will notify the ITC and make available to it all'nonprivileged and nonconfidential information. We will also allow the ITC access to all privileged and confidential infonnation in our files; provid.ed ii _ confirms that it will not disclose such information either publicly or under an adminstr.ative protective order without the wrilt!)n consent of the Deputy Assistant Secret~ry for I.mport Administration.
Preliminary Determination by ITC
The ITC will det~rmine by April 24, 19~f(whether there is a reasonable indication that imports of brass sheet and strip from Sweden materially Injure,
. or threaten material Injury to, a United States industry. If its determination is · negative, the investigation will · terminate; otherwise,,it will proceed according io the statutory procedures .
. John ~ Evans, Acting Deputy Assista11l Secl'elury 6/ Import Administration. March 31, 1986.
(FR_D~c. 86-7616 Filed 4-4-86; 8:45 11m] BIWNO CODE 351~05-M
r • ,·. .
[C-351~04)
Initiation of'Countervalllng Duty Investigation: Brass Sheet and Strip From Brazll · ·
AGENCY: Import Administration. IriternationalTrade Administration, Commerce. ACTION: {'lotice.
SUMMARY: On the basis of a peti.tion filed in proper form with the U.S. Departnient of Commerce, we are initiating a countervai1ing duty investigation to determine whether manufacturers, producers, or exporters in Brazil of brass sheet tlnd strip, as .described In the "Scope' of the ·1nvestigatioil" section of this notice, : · receive benefits which constitute subsidies within the meaning of the countervailing duty law. we· are notifying the U.S. International Trade Commission (ITC) of this action, so that it may determine whether imports of
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Federal Register / Vol. 51, No. 66 / Monday, April· 7, WU6 / Not'ices 11777
these products materially injure, or threaten material injµry to, a United States industry. If this investigation proceeds normally, the ITC will make its preliminary determination on or before April 24, 1986, and we will make our preliminary determination on or before June 3. 1986. · ·
EFFECTIVE DATE: April 7, 1906.
FOR FURTHER INFORMATION CONTACT: Mary Martin, Office of Investigations, Import Administration. International Trade Administration, U.S. Departmcn' of Commerce, 14th Street and Constitution· Avenue NW .. Washington·, DC 20230; telephone: 202/377-2830• SUPPLEMENTARY INFORMATION:
Petition On March 10, 1906, we rcc.eiv!Jd a
petition in proper form filed by American Brass, Bridgeport Brass Corporation. Chase Brass Br Copper Company, Hussey Copper Ltd., the Miller Company, Olin Corporation-Brass Group, Revere Copper Products, Inc., domestic 111anufacturers of brass sheet and strip, and by the International Association of Machinists and Aerospace Workers. the lntemalional Union, Allied Industrial Workers of America (AFL-CIO), the Mechanics Educational Society of America (Local 56). and the l,Jniled Steelworkers of America (AFL-CJO/CLC). In compliance . wilb the filing requirements of I 355.26 · of the Commerce Regulations (19 CFR 355.26). the petition alleges that manufacturers, producers, or exporte~ in Brazil of brau sheet and strip receive subsidies within the meaning of sectiOIJ 701 of the Tariff Act of 1930, as amended (the Act). Since Brazil is a "country · under the Agreement" within the meaning of section 701(b) of the Act, Title VII of the Act applies to this investigation; and the ITC is required to determine whether imports of the subject merchandise from Brazil materially injure. or threaten material injury lo, a U.S. industry.
Initiation of Investigation Under section 702(c) of the Act, we
must determine, within 20 days after a petition Is filed, whether it sets forth the allegations necessary for the initiation of a ·countervailing duty investigation, and, further. whether it contains. Information reasonably available to the petitioner supporting the allegations. We examined the petition on brass sheet and strip from Brazil, and we have found that it meets these requirements. Therefore, we are Initiating a · countervailing duty investigation to determine whether the manufacturers,
producers. or exporters in Brazil of brass sheet and strip. as described in the "Scope of Investigation" section of this notice, receive subsidies.
Scope of lnves,igation•
The products covered by this investigation are brass sheet and strip. other than leaded brass and tie brass sheet and strip, currently classified under the Tariff Schedules of tl1e U11itt:d
. States Annotated (TSUSA) under item numbers 612.3960, 612.3982. and 612.3986. The chemical compositions of the pr9ducts under investigation are .. currently defined.in the· Copper Development Assochttion (C.D.A.) 200 series 1or the Unified Numbering.System (U.N~.) C20000 series. Products whose . chemij:al compositions are defmed by other C.D.A. or U.N.S. series are not covered by this investigation:·
Allegations of Subsidies I
The' petition alleges that . manu(acturers, producers, or exporters in Brazil of brass she~t and strip receive ·benefi'ts under the following programs which constitute subsidies:
•·Working Capital Financing for Exporters;
• P~eferential Fin.ancing for Trading Companies; · ,
• Export Fimmcing Under the CIC-CREGE 14-11 Circular; .
• Finiancing for Storage of Exports; • P~OEX Export Financing: • Rj!solution 68 Financing; '• Accelerated Depreciation for
Brazilian-made Capital Equipment; • BEFIEX; • Income Tax Exemptions for Export
Eumings; • CIEX; • Resolution 509; • Exemption on IPI Tax and Customs
Duties on Imported Machinery; · • FINEP/ADTEN ~ng-Term Loans:
. • Pieferential Electricity Rates; and· • BANDES Financln(J and Other
Regional Subsidies. · · We are not initiating an investigation
on the following allegations: • Subsldization of Copper and Zinc Petitioners allege that brass sheet and
strip is subsidized through price controls on the input product, copper, and · perhaps on zinc. However, absent an allegation and evidence of preferential pricing, purchase price controls do not consUtute countervailable subsidization. Petitioners further allege that brass· sheet and strip benefit from upstream subsidies through the purch11se of inputs from the state-owned copper project Caraiba Metals, S.A. However. there has been no proper.allegation of a
counteravailable subsidy. bestowed by the Government of Brazil on copper and zinc, which con,fers a competitive benefit to brass sheet and strip production, within the meaning of section 7'1A of the Act.
• BNDES Loans The Department has previously
investigated BNDES loans and has found that these loans are not limitclJ tu u specific enterprise or industry or group of enterprises or industries. See, Final' Affirmative Cow1tervailing Duty Determination: Certain Carbon Steel Products from Brazil. ~9 FR 17988. Because petitioners have not submitted any new evidence or alleged changed circumstances with respect to BNDES loans we are not initiating on the program.
• IPI Export Cr~dit Premium The Department has previously
investigated this program and has . determined that the program ha~ bt!l:ll terminated by the Brazilian ; Government. See, Final Affirmu,im CQuntervailing Duty Detennmatio11: Certain Heavy iron Construction Castings from Brazil, 51 FR 9491.
Notification of ITC
Section 702(d} of the Act requires us to notify the ITC of this action, and to provide it with the information we used to arrive at this determination. We will notify the ITC and make available to it all nonprivileged and nonconfidential information in our files. We will also allow the ITC access to all privileged o and confidential information in our files, provided it confirms that it will not disclose such information, either publicly or under an administrative protective order, without the written consent of the Deputy Assistant Secretary for Import Administration.
Preliminary Deterininatioo by ITC
The ITC will determine by April 24, 1986, whether there is a reasonable indication that imports of brass sheet and strip from Brazil materially injure, or threaten material injury to, a United Stutes industry. If its detennination is negative, the investigation will . terminate; otherwise, It will proceed according to statutory procedures. Jotm I.. Evans, · · Acting Deputy Assistant Secretary fur Import Ac/ministration. March 31. 1986. IJ'"R Ooc. IJ&.:7620 Fili:d 4-4--00: 8:45 aml
81WHG C00£ UID-OS-11
Federal ·Register l 'Vol. 51,. No. 66 I Monday, April 7, l9S6 I Notices
[C-427-603)
lni~latlon of Countervailing Duty Investigation: Brass Sheet and ~trip From France ·
AGENCY: Import Administration, , International Trade Administration, Commerce. · · ACTION: Notice.
SUMMARY: On the basis of a petition filed in proper form with the U.S. Department of Commerce, we are initiating a countervailing duty
' investigation to determine whether manufacturers, producers, or exporters in France of brass sheet and strip, as described in the "Scope of Investigation" section of this notice, receive benefits which constitute subsidies within the meaning of the countervailing duty Jaw. We are
. notifying !he U.S. International Trade Commission (ITC) of this action, so that it may determine whether imports of these products materially injure, or threaten material injury to, a United Slat86 industry. If this investigation proceeds normally, the ITC will make Its preliminary determination on.or before April 24, 1986, and we will make our · preliminary determination on or before June 3, 1986. EFFECTIVE DATE: April 7, 1986. FOR FURTHER INFORMATION CONTACT: Mar}' Martin, Office of Investigations, Import AdministJ:ation, International Trade Administration, U.S. Departnient of Commerce, 14th Street and Constitution Avenue, NW., Washington, DC 20230; telephone: 202/377-2830. SUPPLEMENTARY INFORMATION:
Petition. On March 10, 1986, we received a
petition in proper form filed by American Brass, Bridgeport Brass Corporation, Chase Brass Bi Copper Company, Hussey Copper Ltd., the Miller Company, Olin Corporation-Brass Group, Revere Copper Products, Inc., domestic manufacturers of brass sheet and strip, and by the International
· Association of Machinists and Aerospace Workers, International . Union, Allied Industrial Workers of America (AFL-CIO), Mechanics Educational Society of America (Local 56), and the United Steelworkers of America (AFL-CIO/CLC). In compliance with the filing requirements of I 355.26 of the Commerce Regulations (19 CFR 355.26), the petition alleges that manufacturers, producers. or exporters in France of brass sheet and strip receive subsidies within the meaning of section 701 of the Tariff Act of 1930, as amended (the Act). Since France Is a
"country under the Agreement" within the meaning of section 701(b) of the Act, Title VII of the Act applies to this investigation, and the ITC is required to determine wnether imports of the. subject merchandise from France . materially injure, or threaten material injury to, a U.S. industry.
IDitiati~n of Investigation
: Under section 702(c) of the Act, we must determine, within 20 days after a petition is filed, whether it sets forth the allegations necessary for the initiation of a countervailing duty investigation, and, further, whether it contains information 1'4!asonably available to the petitioner supporting the allegations. We examined the petition on brass sheet and strip from France, and we have. found that it meets these requirements. Therefore, we are initiating a countervailing duty investigation to determine whether the manufacturers, producers, or exporters in France of · brass sheet and strip, as descri~ed in ·the "Scope of the Investigation" section of this notice, receive subsidies.
Scope of Investigation
• The products covered by this investigatio~ are brass sheet and strip, other than leaded brass and tin brass sheet and strip, currently classified under the Tariff Schedules of the United States Annotated {TSUSAJ item numbers 612.3960, 612.3982, and 612.3986. The chemical compositions of the products under investigation are currently defined in the Cooper Development Association (C.D.A.) 200 series or the Unified Numbering System (U.N.S.) C20000 series. Products whose chemical compositions are defined by other C.D.A. or U.N.S. series are not ' covered by this investigation.
;
Allegations of Subsidies
'.The petition alleges that manufacturers. producers. or exporters in France of brass sheet and strip r~ceive benefits under the following programs which constitute subsidies:
\ • Government Equity Infusions into Trefimetaux Since 1981; ·
i • Government Subordinated Shareholder Loans to Trefimetaux; '• Benefits from Fonds National
L'Emploi to Trefimetaux; ·•.Preferential Electricity Rates for
Trefimetaux; · • Other Government Financing; • Regional Development Incentives: • Export Credit Insurance for
Political, Exchange Rate; Fluctuation and Inflation Risks;
• Export Financing.
We have determined not to initiate on the following allegations:
• .Modernization Grants to Trefimetaux ·
Petitioners note several expensive moderniZation projects undertaken by Trefimetaux during the last six years. Pet.itioners allege that such.expenditvr1::s would have been impossible without ~irei:t government grants, but they have failed to show any evidence that · Trefimetaux could not fina·nce these projects through other means and have provided no evidence that any such ·
. grant program for·modemization exists. · • Pechiney Divestitures . Petitioners note that Pechiney. the
parent company of Trefimetaux, sold two unprofitable subsidiaries to French nationalized companies in 1981 and 1983, and allege that these divestitures bestowed benefits on Trefimetaux . Petitioners have provided no evidence that these divestitures were inconsistenl with commercial considerations or thaf they bestowed a counterva\lable ben~fit on Trefimetaux. ·
• Research and Development Incentives
Petitioners believe that . manufacturers. producers, or exporters in France of brass· sheet and strip may· receive research and development incentives from Direction General a la Recherche et a la Technologie (DGRT). an agency in the Ministry of Research and Technology. Benefits from this agency were found not countervailabl!;! · inlndustrial Nitrocellulose from France, 48 FR 28521, because they are not limited to a specific industry or enterprise or group of industries or enterprises and because research results are pu~licly available.
Notification of ITC
Section 702(d) of the Act requires us to notify the ITC of this action, and to provide it with the information we used to arrive at this determination. We will notify the ITC ~nd make available to it
. all nonprivileged and nonconfidential information in our files. We will also allow the ITC access to all privileged and confidential information in our files, provided it confirms that it will not . disclose such information, either publicly or under an administrative protective order, without the written consent of the Deputy Assistant
' Secretary for Import Administration.
Preliminary Determination by ITC The ITC will determine by April 24,
1986, whether there is a reasonable indication that imports of brass sheet and strip from France materially injure,
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Federal Register / Vol. 51, No. 66 I Monday, April 7, 1986 / Notices
or threaten material injury to, a United States Industry. If Its determination Is negative, the investigation will terminate: otherwise, ii will proceed .according to the statutory procedures. John L Evans, Acting Deputy Assistant Secretary for Import Administration. March 3, 1988.
f FR Doc. ll&-7621 filed~; 8:45 om) BIWNO CODE :1510-DS-lll
11779
.B-13
APPENDIX B
LIST OF WITNESSES APPEARING AT THE COMMISSION'S CONFERENCE
B-14
CALENDAR OF PUBLIC CONFERENCE
Investigations Nos. 701-TA-269 and 270 (Preliminary) and Investigations Nos. 731-TA-311-317 (Preliminary)
CERTAIN BRASS S~EETS AND STRIPS FROM BRAZIL, CANADA, FRANCE, ITALY, THE REPUBLIC OF KOREA, SWEDEN, AND WEST GERMANY
Those listed below appeared at the United States International Trade Commission's conference held in connection with the subject investigations on April 4, 1986, in the Hearing Room of the USITC Building, 701 E Street, NW., Washington, DC.
In support of the imposition of antidumping and/or countervailiµg duties
Collier, Shannon, Rill & Scott--Counsel ·Washington, DC
on behalf of--
Olin Corp., Brass Group East Alton, IL
Patrick J. Davey, Vice President, Marketing
American Brass Buffalo, NY
Bruno H. Eisner, Vice President, Marketing and Sales
Georgetown Economi~ Services Washington, DC
Nicholas D. Giordano, Vice President
David A. Hartquist ) 0 Jeffrey S. Beckington)-- F COUNSEL
B-15
In oppos1t1on to the imposition of antidumping and/or countervailing duties
Arnold & Porter--Counsel Washington, DC
on behalf of--
Langenberg Kupfer-und Messingwerke GmbH KG Langenberg, West Germany
Metallwerke Schwarzwald GmbH -Schwenningen, West Germany
William Prym-Werke KG, Metal Div. Stolberg Rhld., West Germany
R and G Schmole Metallwerke GmbH and Co. KG Menden, West Germany
Schwermetall Halbzeugwerk GmbH and Co. KG Stolberg Rhld., West Germany
Stolberger Metallwerke GmbH and Co. KG Stolberg Rhld., West Germany
Wieland-Werke AG Ulm/Donau, West Germany
Abco Metals Corp. Needham, MA
Mark Abraham, President
·Wieland-America, Inc. Wheeling, IL
Klaus J. Schlunk, Vice President
Richard A. Johnso~--bF COUNSEL
B-16
In opposition to the imposition of antidumping and/or countervailing duties--Continued
Busby, Rehm and Leonard--Counsel Washington, DC
on behalf of--
Trefimetaux Paris, France
Christian Bauchet, Assistant Export Manager
Pechiney World Trade (USA), Inc. New York, NY
Cornelius L. Hudak, Trefimetaux Representative Copp,er Products Division
Guggenheim International Corporation Jersey City, NJ
Edward Felding, President
Will E. Leonard ) Philippe M. Bruno)--OF COUNSEL
Cleary, Gottlieb, Steen & Hamilton--Counsel Washington, DC
on behalf of--
La Metalli Industriale S.p.A. Firenze, Italy
Giovanni P. Prezioso) --OF COUNSEL James W. Conrad )
Finley, Kumble, Wagner, Heine, Underberg, Manley & Casey--Counsel Washington, DC
on behalf of--
Poongsan Metal Corp. Seoul, the Republic of Korea
Pan Metal Corp. Los Angeles, CA
Alexander Haig--OF COUNSEL
B-17
In opposition to the imposition of antidumping and/or countervailing duties--Continued
Davis Polk & Wardwell--Counsel Washington, DC
O'Melveny & Myers--Counsel Washington, DC
on behalf of--
Eluma S.A. Industria E Comercio (Eluma) Sao Paulo, Brazil
Richard Rosenmayer, Sales Manager Eluma International (U.S.A.), Inc.
Scott W. Muller) __ 0F COUNSEL Gary N. Horlick)
Sonnenberg, Anderson & O'Donnell--Counsel Chicago, IL
on behalf of--
Metallverken, Inc. Elmhurst, IL
Johan Scheel, President
Paul S. Anderson--OF COUNSEL
. Taft, Stettinius & Hollister--Counsel Washington, DC
on behalf of--
Noranda Metal Industries, Ltd. Montreal, Canada
W.J. Moloughney, Executive Vice President
Ratcliffs Canada Ltd.
James D. Williams, Jr.--OF COUNSEL
William E. Wright, Trade Specialist
B-19
APPENDIX C
SPECIFICATIONS FOR UNS C20000, UNS C3000o,·and UNS C40000
SERIES BRASSES
B-20
HIGH COPPER Aq.ovs (continued)
COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
COPPER OTHER ALLOY PREVIOUS Cu NAMED
NO. TRADE NAME (inct. Ag) Fe Sn Ni Co Cr Si Be Pb ELEMENTS
C18700 ............ Rem. .8·1.5 C18900 ............ Rem. .6-.9 .15·.40 .02 .05P
.01AI .10·.30Mn
.10Zn
C18980 ............. 98.0 1.0 .so .02 .SOMn .15P
C19000 ............ Reni. .10 .9-1.3 .05 .8Zn .15·.35P
C19100 ............ Rem. .20 .9-1.3 .10 .SO Zn .35·.6Te
-· .ts-.3SP
COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
COPPER ALLOY PREVIOUS
NO. TRADENAME . Cu Fe Sn· Zn Al Pb p Co
C19200 ............ 98.7min. .8·1.2 .01·.04
C19210 ............ Rem. .05·.15 .025-.040
C19400 ............ 97.0min. 2.1·2.6 .05-.20 .03 _.015-.15
C19500 ............ 96.0min. 1.3·1.8 .40-.7 .20 .02 .02 .08-.12 .6-1.1
C19520 ............ 96.&min. .50·1.5 .50·1.5 .01-.35
C19600 ............ Rem, .9·1.2 .35 .25·.35
COPPER-ZINC ALLOYS (BRASSES)
COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
COPPER OTHER ALLOY PREVIOUS NAMED
NO. TRADE NAME Cu Pb Fe Zn ELEMENTS
C20500 . . . . . . ~ ........... . 97.0-98.0 .02 .05 Rem • C21000 Gilding, 95%: •••••••• 94.0-96.0 .03 .05 Rem. C22000 Commercial Bronze, 90% 89.0-91.0 .05 .05 Rem.·· C22600 Jewelry Bronze, 87%% •• 86.0-89.0 .05 .05 Rem. C23000 Red Brass, 85%. ; ••••• 84.0-86.0 .05 .05 Rem. C23030 .......... " ....... ' 83.5·85.5 .05 .05 Rem.· .20-.40Si C23400 . . . . .. . . . . . . . . . . . . 81.0-84.0 .05 .05 Rem • C24000 Low Bran, 80% .•••••• 78.5-81.5 .05 .05 Rem. -C24080 ................. 78.Q.82.0 .20 Rem. .10AI C25000 ................. 74.Q.76.0 .05 .05 Rem.
B-21
COPPER-ZINC ALLOYS (BRASSES) (con~inued)
(COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
COPPER OTHER ALLOY PREVIOUS NAMED
NO. TRADE NAME Cu Pb Fe Zn ELEMENTS
C26000 Cartridge Brass, 70% ••• 68.5·71.5 .07 .05 Rem • C26100 ................. 68.5·71.5 • 05 .05 ·Rem. .02·.05P C26130 ................. 68.5·71.5 .05 .05 Rem. .02-.08As C26200 . .. . . . . . . . . . . . . . . . 67.0.70.0 .07 .05 Rem • C26380 .. ................. 68.0.72.0 .30 Rem. .10AI C26800 Yellow Brass, 66% ••••• 64.0·68.5 .15 .05 Rem. C27000 Yellow Brass, 65% ...•• 63.0·68.5 .10 .07 Rem. C27200 . . . . . . . . . . . . . . . . . 62.Q.65.0 .07 .07 Rem • C27400 Yellow Brass, 63% .•... 61.0-64.0 .10 .05 Rem • C28000 Muntz Metal, 60% ••••• 59.0-63.0 • 30 .07 Rem. C28580 . . . . . . . . . . . . . . . . . 49.0-52.0 .50 .10 Rem •
COPPER-ZINC-LEAD ALLOYS (LEADED BRASSES)
(COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
COPPER OTHER ALLOY PREVIOUS NAMED
NO. TRADE NAME Cu 'Pb Fe Zn ELEMENTS
C31200 ................... 87.5-90.5 .7-1.2 .10 Rem •. .25Ni C31400 Leaded Commercial Bronze 87.5-90.5 1.3-2.5 .10 Rem.
\ .7Ni
C31600 Leaded Commercial Bronze (Nickel Bearing) •••••.• 87.5-90.5 1.3-2.5 .10 Rem. .7·1.2Ni
.04-.10P C32000 Leaded Red Brass ....•.• 83.5-86.5 1.5-2.2 .10 Rem. .25Ni C32510 ................... 69.0-72.0 .30.. 7 Rem. .02·.06As C33000 Low Leaded Brass (Tube) .• 65.0-68.0 .25·.7'21 1 .07 Rem. C33100 . . . . . . . . . . . . . . . . . . . 65.0-68.0 .8·1.5 .06 Rem • C33200 High Leaded Brass (Tube) •• 65.0-68.0 1.5-2.5 .07 ···Rem. C33500 Low Leaded Brass ••••••• 62.0-65.0 .25-.7 .10 Rem • C33530 .................... 62.5-66.5 • 30..8 .10 Rem. .02·.06As C34000 Medium Leaded Brass, 64%% 62.0-65.0 .8-1.5 .10 Rem. C34200 High Leaded Brass, 64%% •. 62.0·65.0 1.5-2.5 .10 Rem. C34500 . . . . . . . . . . . . . . . . . . . 62.Q.65.0 1.5·2.5 .10 Rem • C35000 Medium Leaded Brass, 62% 60.0·63.01221 .8·2.0 .10 Rem. C35300 High Leaded Brass, 62% ••• 60.0-63.01221 1.5-2.5 .10 Rem. C35330 ................... 60.5-64.0 1.s.3.51231 Rem. .02·.25As C35340 . . . . . . . . . . . . . . . . . . . 60.0-63.0 1.5-2.5 .10..30 Rem • C35600 Extra High Leaded Brass ••• 60.0-63.0 2.Q.3.0 .10 Rem. C36000 Free Cutting Brass ••••••• 60.0·63.0 2.5-3.7 .35 Rem. C36200 ................... 60.Q.63.0 3.5-4.5 .15 Rem.
B-22
COPPER-ZINC-LEAD ALLOYS (LEADED BRASSES) (continued)
COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM) COPPER OTHER ALLOY PREVIOUS NAMED
NO. TRADE NAME Cu Pb Fe Sn Zn ELEMENTS
C36500 Leaded Muntz Metal, Uninhibited .• 58.0-61.0 .25-.7 .15 .25 Rem. C36600 Leaded Muntz Metal, Arsenical .•• 58.0-61.0 .25-.7 .15 .25 Rem. .02·.10As C36700 Leaded Muntz Metal, Antimonial •. 58.0-61.0 ;25-.7 .15 .25 Rem. .02-.10Sb C36800 Leaded Muntz Metal, Phosphorized 58.0-61.0 .25·.7 .15. .25 Rem. .02·.10P C37000 Free Cutting Muntz Metal •. · •..•• · 59.0-62.0 .8·1.5 .15 Rem. C37100 ........................ 58.0-62.0 .6-1.2 .15 Rem. C37700 Forging Brass .•..••••••••... 58.0-61.0 1.5-2.5 .30 Rem. C37710 ........................ 56.5-60.0 1.0-3.0 .30 Rem. C37800 ........................ 56.0-59.0 1.5·2.5 .30 Rem. C38000 Architectural Bronze, Low Leaded . 55.0-60.0 1.5·2.5 . .. 35 .. .30 Rem. •. . .50AI C38010 ........................ 56.0-59.0 1.5-3.0 .30 Rem. .10-.6AI C38500 Architectural Bronze ••.•.•.•.. 55.0-59.0 2.5-3.5 .35 Rem. C38510 ........................ 56.0-60.0 2.5·4.5 Rem. C38590 ........................ 56.5-60.0 2.0·3.5 .35 Rem.
COPPER-ZINC-TIN ALLOYS (TIN BRASSES)
. COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM) COPPER OTHER ALLOY PREVIOUS NAMED
NO. TRADE NAME Cu Pb Fe Sn Zn p ELEMENTS \
C40400 ................... Rem. .35-.7 2.0-3.0 C40500 . . . . . . . . . . . . . . . . . . . 94.0-96.0 .o5 .05 .7-1.3 Rem • C40800 ................... 94.0-96.0 .05 .05 1.8-2.2 Rem. C41000 . . . . . . . . . . . . . . . . . . . 91.0-93.0 .05 .05 2.0-2.8 . Rem • C41100 . . . . . . . . . . . . . . . . . . . 89.0-92.0 .10 .05 .30-.7 Rem . C41300 . . . . . . . . . . . . . . . . . . . 89.0-93.0 .10 .05 .7-1.3 Rem • C41500 . . . . . . . . . . . . . . . . . . . 89.0-93.0 .10 .05 1.5-2.2 Rem . C42000 ................... 88.0-91.0 1.5-2.0 Rem. .25 C42100 ................... 87.5-89.0 .05 .05 2.2-3.0 Rem. .35 .15-.35Mn C42200 ................... 86.0-89.0 .05 .05 .8-1.4 Rem. .35 C42500 ................... 87.0-90.0 .05 .05 1.5-3.0 Rem. .35 C43000 . . . . . . . . . . . . . . . . . . . 84.0-87.0 .10 .05 1.7-2.7 Rem • C43200 ................... 85.0-88.0 .05 .05 .40-.6 Rem. .35 C43400 . . . . . . . . . . . . . . . . . . . 84.0-87.0 .05 .05 .40-1.0 Rem . C43500 . . . . . . . . . . . . . . . .. . . . 79.0-83.0 .10 .05 .6-1.2 Rem • C43600 . . . . . . . . . . . . . . . . · ... 80.0-83.0 .05 .05 .20-.50 Rem . C44300 Admiralty, Arsenical .•••. 70.0-73.0 .07 .06 .s-1.2(241 Rem •
,. .02·.10As
C44400 Admiralty, Antimonial ••.• 70.0-73.0 .07 .06 . 8·1.2(24) Rem. .02-.10Sb C44500 Admiralty, Phosphorized .. 70.0-73.0 .07 .06 .8•1•21241 Rem. .02-.10 C46200 Naval Brass, 63%% ...•... 62.0-65.0 .20 .10 .50-1.0 Rem.
. C46210 ................... 61.0-6,.0 .05 1.0 Rem. .03AI .50Si
C46400 Naval Brass, Uninhibited ..• 59.0-62.0 .20 .10 .50-1.0 Rem. C46420 .... - .............. 61.0-63.5 .20 .20 1.0-1.4 Rem. C46500 Naval Brass, Arsenical .••.• 59.0-62.0 .20 .10 .50-1.0 Rem. .02-.10As C46600 Naval Brass, Antimonial .•. 59.0-62.0 .20 .10 .50-1.0 Rem. .02·.10Sb C46700 Naval Brass, Phosphorized .. 59.0-62.0 .20 .10 .50-1.0 Rem. .02-.10
B-23
COPPER-ZINC-TIN ALLOYS (TIN BRASSES) (continued)
COPPER ALLOY
NO.
C47000
C47600 C47940
C48200 C48SOO C48600 C49080
PREVIOUS TRADE NAME
Naval Brass Welding and
COMPOSITION. PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
OTHER NAMED
Cu Pb Fe Sn Zn P ELEMENTS
Brazing Rod •••••••••• S7.0-61.0 .OS .25-1.0 Rem. .01AI ................... 86.0-88.0 1.8-2.2 .OS 1.8-2.2 Rem. .03-.07 .05·.15Mn ................... 63.0-66.0 1.0-2.0 .10-1.0 1.2-2.0 Rem. · .• 10..50Ni
.. (incl. Co) Naval Brass, Medium Leaded S9.0-62.0 • 40.1.0 .10 .50-1.0 . Rem. NavarBrass, High Leaded •• S9.0-62.0 1.3-2.2 .10 .S0-1.0 Rem. ................... S9.0-62.0 1.0-2.5 .8-1.5 Rem. .02·.25As ........ . -: . ........ 49.0·S2.0 .50 3.0-4.0 Rem. - ····.10AI
COPPER-TIN ALLOYS. (PHOSPHOR BRONZESI
COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM)
COPPER OTHER ALLOY PREVIOUS NAMED
NO. TRADE NAME Cu Pb Fe Sn Zn p ELEMENTS
CS0100 .................. Rem. .OS .OS .S0-.8 .01-.05 C50200 .................. Rem. .OS .10 1.0-1.S .04 csosoo Phosphor Bronze, 1.2S% E Rem. .OS .10 1.0-1.7 .30 .03-.35 CS0700 .................. Rem. .OS .10 1.S-2.0 \ .30 C50710 .................. Rem. 1.7-2.3 .1S .10-.40Ni csoaoo .................. Rem. .OS .10 2.6-3.4 .01-.07 C50900 ............ •.• .... Rem. .05 .10 2.S-3.S .30 .03-.30 CS1000 Phosphor Bronze, S% A •• Rem. .OS .10 4.2-S.S .30 .03-.35 CS1100 .................. Rem. .OS .10 3.5-4.9 .30 .03-.35 C51800 Phosphor Bronze .•..••• Rem. .02 4.0-6.0 .10-.35 .01AI C51900 .................. Rem. .05 .10 S.0-7.0 .30 .03-.35 CS2100 Phosphor Bronze. 8% C •• Rem. .OS ..10 .•... 7.0.9.0 . .• ..20 .03-.35 C52400 Phosphor Bronze, 10% D • Rem. .OS .10 9.0-11.0 .20 .03-.35
COPPER-TIN-LEAD ALLOYS (LEADED PHOSPHOR BRONZES)
COMPOSITION, PER CENT MAXIMUM (UNLESS SHOWN AS A RANGE OR MINIMUM) COPPER ALLOY PREVIOUS
NO. TRADE NAME Cu Pb Fe Sn Zn p
C53200 Phosphor Bronze B •• Rem. 2.S·4.0 .10 4.0-5.5 . .20 .03-.35 C53400 Phosphor Bronze B· 1 Rem. .8-1.2 ;10 3.S-5.8 .30 .03-.35 C54400 Phosphor Bronze B-2 Rem. 3.5-4.5 .10 3.S-4.5 1.5-4.5 .01-.50 C54800 ............... Rem. 4.0-6.0 .10 4.0-6.0 .30 .03-.35
UNITED STATES
INTERNATIONAL TRADE COMMISSION
WASHINCHON. O.C. 20436
OFF'ICIAL BUSINESS
ADDRESS CORA£CTION REQUESTtD
ADDRESS CHANGE O Rem~ve from Ult O Change as Shown
PluM debch address l•haf AIM'f ,....u ._ .,. .... __ _.
Postage And Fees Paid U.S. International Trade Commission ~ -......
ITC-853