Jiangsu Senmao Bamboo & Wood Indus. Co. v. United States

2025 CIT 16
Procedural entryThis page is a short order in Jiangsu Senmao Bamboo & Wood Indus. Co. v. United States. Read the opinion of the Court — 698 F. Supp. 3d 1277
United States Court of International Trade·Decided February 18, 2025·No. 22-00190·Published

Opinion

Slip Op. 25-16

UNITED STATES COURT OF INTERNATIONAL TRADE

JIANGSU SENMAO BAMBOO AND WOOD INDUSTRY CO., LTD.,

Plaintiff, and

LUMBER LIQUIDATORS SERVICES, LLC,

Plaintiff-Intervenor, Before: Jennifer Choe-Groves, Judge v.

Court No. 22-00190

UNITED STATES,

Defendant, and

AMERICAN MANUFACTURERS OF MULTILAYERED WOOD FLOORING,

Defendant-Intervenor.

OPINION AND ORDER

[Sustaining in part and remanding in part the U.S. Department of Commerce’s Final Results of Redetermination Pursuant to the Second Remand Order in the antidumping duty review of multilayered wood flooring from the People’s Republic of China.]

Dated: February 18, 2025

Jeffrey S. Neeley and Stephen W. Brophy, Husch Blackwell LLP, of Washington, D.C., for Plaintiff Jiangsu Senmao Bamboo and Wood Industry Co., Ltd.

Mark R. Ludwikowski and Kelsey Christensen, Clark Hill PLC, of Washington, D.C., for Plaintiff-Intervenor Lumber Liquidators Services, LLC.

Kelly M. Geddes, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for Defendant United States. With them on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, and Tara K. Hogan, Assistant Director. Of counsel on brief was Christopher Kimura, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C.

Timothy C. Brightbill, Stephanie M. Bell, Maureen E. Thorson, and Theodore P. Brackemyre, Wiley Rein, LLP, of Washington, D.C., for Defendant-Intervenor American Manufacturers of Multilayered Wood Flooring.

Choe-Groves, Judge: The Court remands for a third time the determination of the U.S. Department of Commerce (“Commerce”).

In summary, the Brazilian plywood import data contains objectively incorrect information, which Commerce chose to address by deleting one month of import data, rather than reopening the record to obtain accurate data. Commerce’s deletion of the one month of import data resulted in a distortion that increased the Brazilian plywood surrogate value (“SV”) by 453%, thus leading one to question whether Commerce’s repeated insistence on using objectively incorrect Brazilian data is results-driven or cherry-picking.

For the reasons explained below, the Court remands Commerce’s adjustment of surrogate value data for plywood. The Court sustains Commerce’s selection of Brazil as the primary surrogate country and the use of Malaysian data for oak log inputs.

Before the Court is Commerce’s second remand redetermination in the administrative review of the antidumping duty order on multilayered wood flooring from the People’s Republic of China (“China”) for the period of December 1, 2019, through November 30, 2020, filed pursuant to the Court’s Opinion and Order in Jiangsu Senmao Bamboo & Wood Industry Co., v. United States (“Senmao II”), 48 CIT __, 698 F. Supp. 3d 1277 (2024). Final Results of Redetermination Pursuant to Court Remand Order (“Second Remand Redetermination”), ECF No. 66-1; see also Final Results of Redetermination Pursuant to Remand Order (“Remand Redetermination”), ECF No. 55-1; Multilayered Wood Flooring from the People’s Republic of China (“Final Results”), 87 Fed. Reg. 39,464 (Dep’t of Commerce July 1, 2022) (final results of antidumping duty administrative review; 2019–2020) and accompanying Issues and Decision Memorandum for the Final Results of Antidumping Duty

Administrative Review: Multilayered Wood Flooring from the People’s Republic of China; 2019–2020 (Dep’t of Commerce June 24, 2022) (“IDM”), PR 245.1 ISSUES PRESENTED

The Court reviews the following issues:

1. Whether Commerce’s determination to select Brazil as the primary surrogate country, while using Malaysian data for oak log inputs, is supported by substantial evidence and in accordance with law; and 2. Whether Commerce’s determination to adjust the Brazilian surrogate value data for plywood is supported by substantial evidence and in accordance with law.

BACKGROUND

Commerce initiated the underlying administrative review on February 2, 2021. Initiation of Antidumping and Countervailing Duty Admin. Review, Multilayered Wood Flooring from the People’s Republic of China, 86 Fed. Reg. 8166, 8169–71 (Dep’t of Commerce Feb. 4, 2021). Commerce conducted an administrative review of the antidumping duty order on multilayered wood flooring from China for the period from December 1, 2019, through November 30,

1 Citations to the administrative record reflect the public record (“PR”), remand public record (“RPR”), and second remand public record (“2RPR”) numbers filed in this case, ECF Nos. 48, 64, 72.

2020, and selected Jiangsu Senmao Bamboo and Wood Industry Co., Ltd. (“Plaintiff” or “Senmao”) as the mandatory respondent in the investigation. Id.; Commerce’s Antidumping Administrative Review of Multilayered Wood Flooring from the People’s Republic of China; 2019–2020: Respondent Selection Mem., PR 112.

In its Final Results, Commerce selected Brazil as the primary surrogate country, but it valued Senmao’s oak and non-oak logs with Malaysian surrogate values. IDM at 9, 22; Multilayered Wood Flooring from the People’s Republic of China (“Preliminary Results”), 86 Fed. Reg. 73,252 (Dep’t of Commerce Dec. 27, 2021) (preliminary results of the antidumping duty administrative review, preliminary determination of no shipments, and rescission of review, in part; 2019– 2020) and accompanying Decision Memorandum for the Preliminary Results of Antidumping Administrative Review (“PDM”) at 17, PR 213. Commerce used Malaysian surrogate values because it determined that Brazilian surrogate values were not usable for oak and non-oak log inputs. Jiangsu Senmao Bamboo & Wood Industry Co. v. United States (“Senmao I”), 47 CIT __, 651 F. Supp. 3d 1348, 1357 (2023) (citing PDM at 17).

Commerce also adjusted the Brazilian surrogate values for plywood by excluding data that it determined to be incorrect regarding the quantity of plywood. IDM at 9. Commerce determined that the Spanish import data for 2020 were

incorrect because the data reported the same quantity of plywood in cubic meters (“m3”) as it did in kilograms (“kg”). Id. Because the m3 unit measures volume and the kg unit measures mass, Commerce concluded that it was “illogical for the Spanish import data to report the same quantity in these two different units of measure.” Id. Commerce removed this line of data from its calculation. Id. at 910. Ultimately, Commerce calculated Senmao’s antidumping duty margin at 39.27%. Final Results, 87 Fed. Reg. at 39,465.

In Senmao I, the Court held that Commerce failed to provide a reasonable explanation to justify departing from its established practice of using one surrogate country and failed to support its determination with substantial evidence. Senmao I, 47 CIT at __, 651 F. Supp. 3d at 1357. The Court found that Commerce did not cite any record evidence to support its determination that Brazilian surrogate values regarding oak log inputs were highly questionable, inadequate, or unavailable. Id. Commerce lacked a sufficient basis to substitute input data from a second surrogate country. Id. at 135758. The Court found that Commerce relied on Exhibit 9 of Multilayered Wood Flooring from the People’s Republic of China: American Manufacturers of Multilayered Wood Flooring (“AMMWF”) Surrogate Value Comments (“AMMWF Surrogate Value Comments”) (“Exhibit 9”), when determining to strike Spanish import data but never placed the document on the

record. Id. at __, 651 F. Supp. 3d at 1361; AMMWF Surrogate Value Cmts., PR 17982.

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