Ditar, S.A. v. United States

2025 CIT 128
CourtUnited States Court of International Trade
DecidedOctober 1, 2025
Docket24-00130
StatusPublished

This text of 2025 CIT 128 (Ditar, S.A. v. United States) is published on Counsel Stack Legal Research, covering United States Court of International Trade primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ditar, S.A. v. United States, 2025 CIT 128 (cit 2025).

Opinion

Slip Op. 25-

UNITED STATES COURT OF INTERNATIONAL TRADE

Court No. 24-00130

DITAR, S.A., Plaintiff, v. UNITED STATES, Defendant, and COALITION FOR FAIR TRADE IN SHOPPING BAGS, Defendant-Intervenor.

Before: M. Miller Baker, Judge

OPINION

[Remanding for the Department of Commerce to re- consider its denial of a level-of-trade adjustment.]

Dated: October 1, 2025

Robert G. Gosselink, Jonathan M. Freed, Kenneth N. Hammer, and MacKensie R. Sugama, Trade Pacific PLLC, Washington, DC, on the briefs for Plaintiff.

Yaakov M. Roth, Acting Assistant Attorney General; Patricia M. McCarthy, Director; Franklin E. White, Jr., Assistant Director; and Daniel Bertoni, Trial Ct. No. 24-00130 Page 2

Attorney, Commercial Litigation Branch, Civil Divi- sion, U.S. Department of Justice, Washington, DC, on the brief for Defendant. Of counsel for Defendant was Ruslan Klafehn, Attorney, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Depart- ment of Commerce, Washington, DC.

J. Michael Taylor and Daniel L. Schneiderman, King & Spalding LLP, Washington, DC, on the brief for De- fendant-Intervenor.

Baker, Judge: In this case involving an antidump- ing investigation of paper bags exported from Colom- bia, a producer from that country challenges the De- partment of Commerce’s denial of a level-of-trade ad- justment to the company’s home-market pricing. For the reasons stated below, the court remands for recon- sideration.

I

Under the Tariff Act of 1930, as amended, anti- dumping duties must be “equal to the amount by which the normal value exceeds the export price . . . for the merchandise.” 19 U.S.C. § 1673. “Normal value” means “the price at which the foreign like prod- uct is first sold . . . for consumption in the exporting country, in the usual commercial quantities and in the ordinary course of trade and, to the extent practicable, at the same level of trade as the export price.” Id. § 1677b(a)(1)(B)(i) (emphasis added). Essentially, de- termining “normal value” requires Commerce to calcu- late the sales price to consumers in the producer’s home market. Giorgio Foods, Inc. v. United States, Slip Ct. No. 24-00130 Page 3

Op. 24-79, at 3, 2024 WL 3534491, at *1 (CIT 2024) (citing Smith-Corona Grp. v. United States, 713 F.2d 1568, 1573 (Fed. Cir. 1983)), appeal pending, No. 25-2090 (Fed. Cir.). But sometimes, the level-of- trade question can make that a fraught exercise.

As relevant here, the Department must adjust the home-market sales price “to make allowance for any difference” between export price and normal value “that is . . . due to a difference in level of trade.” 19 U.S.C. § 1677b(a)(7)(A). Such a “difference in level of trade” must both involve the performance of “differ- ent selling activities” and “affect price comparability, based on a pattern of consistent price differences be- tween sales at different levels of trade” in the pro- ducer’s home market. Id. § 1677b(a)(7)(A)(i), (ii).

A Commerce regulation implements this mandate. See 19 C.F.R. § 351.412. It says the agency will find different levels of trade if the sales “are made at differ- ent marketing stages (or their equivalent). Substantial differences in selling activities are a necessary, but not sufficient, condition for determining that there is a dif- ference in the stage of marketing.” Id. § 351.412(c)(2) (emphasis added).

When the Department promulgated the regulation in 1997, it observed that “the statute uses the term ‘level of trade’ as a concept distinct from selling activi- ties.” 62 Fed. Reg. 27,296, 27,371 (citing Statement of Administrative Action (SAA) accompanying the 1994 Ct. No. 24-00130 Page 4

Uruguay Round Agreements Act,1 H.R. Doc. 103–316, vol. 1, at 829, 1994 U.S.C.C.A.N. 4040, 4168, as “rein- forcing” the point). The statute allows a finding of one such level even if two sales have substantial differ- ences in selling activities. Id. On the other hand, some common selling activities will not preclude a finding of different levels of trade. Id. “Taken together, the two points establish that an analysis of selling activities alone is insufficient to establish the [level of trade].” Id. A level of trade, therefore, “is a marketing stage ‘or the equivalent’ (which means that the merchandise does not necessarily have to change hands twice in or- der to reach the more remote [level of trade]). It is suf- ficient that, at the more remote level, the seller takes on a role comparable to that of a reseller if the mer- chandise had changed hands twice.” Id.

By negative implication, then, “different marketing stages” exist when merchandise changes hands twice. Pasta Zara SpA v. United States, 703 F. Supp. 2d 1317, 1324–25 (CIT 2010) (Zara I). Thus, a company seeking an adjustment has two options to show different levels of trade—it can show that its products changed hands twice or it can show that in making sales, it took over the role normally performed by a reseller.2 Pasta Zara

1 The SAA is an “authoritative expression” of the statute’s

meaning. 19 U.S.C. § 3512(d). 2 The Federal Register notice provides two ways a producer

can attempt to show that it assumed the role of reseller. First, it can provide evidence that it performed “an addi- tional layer of selling activities, amounting in the aggre- gate to a substantially different selling function.” 62 Fed. Reg. at 27,371. That is, because demonstrating different (footnote continues on next page) Ct. No. 24-00130 Page 5

SpA v. United States, 781 F. Supp. 2d 1297, 1301 (CIT 2011) (Zara II) (“[T]he Department considers a differ- ent marketing stage to occur where merchandise changes hands twice to reach a more remote level of trade. . . . In identifying the possibility of the ‘equiva- lent’ of a separate marketing stage, [it] recognizes that a determination of multiple [levels] is not precluded solely by the fact that the merchandise did not change hands twice.”) (citing 62 Fed. Reg. at 27,371).

Although showing a difference in the level of trade is necessary to warrant an adjustment to the home- market sales price, it is not sufficient. An interested party seeking such a tweak must also demonstrate that the “difference has an effect on the comparability of prices.” 19 C.F.R. § 351.412(a); see also SAA at 829, 1994 U.S.C.C.A.N. at 4168. Commerce will find such an effect when “there is a pattern of consistent price differences between sales in the market in which nor- mal value is determined” both at the export price’s level of trade and at the level at which normal value is determined. 19 C.F.R. § 351.412(d)(1).

selling activities alone is “necessary, but not sufficient,” un- der 19 C.F.R. § 351.412(c)(2), the producer must show those activities’ cumulative effect. Second, it can point to “[s]ub- stantial differences in the amount of selling expenses asso- ciated with two groups of sales,” which “also may indicate that the two groups are at different levels of trade.” 62 Fed. Reg. at 27,371. Ct.

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