Officine Tecnosider Srl v. United States

2024 CIT 102
CourtUnited States Court of International Trade
DecidedSeptember 17, 2024
Docket23-00001
StatusPublished

This text of 2024 CIT 102 (Officine Tecnosider Srl 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
Officine Tecnosider Srl v. United States, 2024 CIT 102 (cit 2024).

Opinion

Slip Op. No. 24-102

UNITED STATES COURT OF INTERNATIONAL TRADE

OFFICINE TECNOSIDER SRL,

Plaintiff,

v. Before: Stephen Alexander Vaden, UNITED STATES, Judge

Defendant, Court No. 1:23-cv-00001 (SAV)

and

NUCOR CORPORATION

Defendant-Intervenor.

OPINION

[Remanding Commerce’s Remand Determination.]

Dated: September 17, 2024

Pierce J. Lee, Crowell & Moring LLP, of Washington, DC, for Plaintiff Officine Technosider Srl. With him on the brief was Daniel J. Cannistra.

Augustus J. Golden, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, DC, for Defendant United States. With him on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, Commercial Litigation Branch, Tara K. Hogan, Assistant Director, Commercial Litigation Branch, and Ashlande Gelin, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce.

Stephanie M. Bell, Wiley Rein LLP, of Washington, DC, for Defendant-Intervenor Nucor Corporation. With her on the brief were Alan H. Price, Christopher B. Weld, and Jeffrey O. Frank. Court No. 1:23-cv-00001 (SAV) Page 2

Vaden, Judge: Before the Court is the U.S. Department of Commerce’s

(Commerce) remand determination for the 2020–21 administrative review of the

antidumping order for steel plate from Italy. At issue is whether Commerce should

depart from its normal annual average cost methodology and instead use an

alternative quarterly cost methodology for Plaintiff Officine Technosider SRL

(Officine). Commerce sought a voluntary remand to reconsider if it should apply the

alternative methodology. On remand, Commerce compared quarterly trends in sales

for the U.S. and home markets with the cost of manufacturing for certain control

numbers and determined that using the alternative methodology is warranted.

However, all U.S. sales took place in one quarter, making it difficult to decipher a

trend for U.S. sales prices. Only one control number shared between the U.S. and

home markets is also among the five highest-selling control numbers in both markets

— further complicating Commerce’s task. And a past Commerce decision points to

another potential way to analyze the data. Because Commerce failed to properly

respond to these shortcomings, its decision lacks substantial evidentiary support and

will be REMANDED for further explanation.

BACKGROUND

I. Procedural Background

This case concerns a challenge to Commerce’s Final Results in the

administrative review of the antidumping order on certain carbon and alloy steel cut-

to-length plate from Italy, covering entries from May 1, 2020, through April 30, 2021 Court No. 1:23-cv-00001 (SAV) Page 3

(the Period of Review). See Certain Carbon and Alloy Steel Cut-To-Length Plate from

Italy: Final Results of Antidumping Duty Administrative Review and Final

Determination of No Shipments; 2020-2021, 87 Fed. Reg. 75,219 (Dep’t of Com. Dec.

8, 2022) (Final Results), and accompanying Issues and Decisions Mem. (IDM), J.A. at

2,305, ECF No. 44. At issue is whether Commerce should use its normal annual

weighted-average cost methodology for the entire Period of Review or an alternative

methodology, which examines costs in shorter periods to minimize potential

distortions, known as the quarterly cost methodology.1 Officine is an Italian producer

and exporter of carbon and alloy steel cut-to-length plates. Pl.’s Mot. for J. on Agency

R. and Supp. Opening Br. (Pl.’s Mot.) at 6, ECF No. 24. Officine challenged

Commerce’s Final Results. See Compl., ECF No. 11. The Court granted Defendant-

Intervenor Nucor Corporation’s (Nucor) Consent Motion to Intervene to support

Commerce’s original determination. Order Granting Intervention, ECF No. 20.

Officine filed its Motion for Judgment on the Agency Record, focusing on

Commerce’s use of the annual weighted-average cost methodology instead of the

quarterly cost methodology. Pl.’s Mot. at 2, ECF No. 24 (identifying five issues, all

dealing with the quarterly cost methodology); see also Certain Carbon and Alloy Steel

Cut-To-Length Plate from Italy: Preliminary Results of Antidumping Duty

Administrative Review and Preliminary Determination of No Shipments; 2020-2021,

1A more detailed explanation of Commerce’s test for applying the quarterly cost methodology is found in the Discussion portion of this opinion. See infra § I (Legal Framework). Court No. 1:23-cv-00001 (SAV) Page 4

87 Fed. Reg. 34,246 (Dep’t of Com. June 6, 2022), and accompanying Prelim. Decision

Mem. at 19, J.A. at 2,289, ECF No. 44 (“[W]e determined that our quarterly cost

methodology is not warranted …. Therefore, we applied our standard methodology

of using annual average costs ….”); IDM at 31, J.A. at 2,335, ECF No. 44 (continuing

to reject requests to use the quarterly cost methodology). Officine contended that

Commerce established a “clear and predictable practice” for when it would employ

the quarterly cost methodology; Officine met both criteria for its use; and Commerce

failed to explain why it declined to use it. Pl.’s Mot. at 14, 18–20, 24–25, ECF No. 24.

It asked the Court to remand the case for Commerce to reconsider its decision. Id. at

34.

After reviewing Officine’s brief, Commerce requested a voluntary remand to

“reconsider … application of the quarterly cost methodology … and, if appropriate,

revise the dumping margin calculation.” Def.’s Mot. for Voluntary Remand at 2, ECF

No. 26 (Def.’s Mot.). Commerce explained that it examines costs averaged over the

entire Period of Review unless there are: (1) “significant cost variations” and (2)

“those variations are linked to changes in sales prices.” Id. at 2 (quoting Rebar Trade

Action Coal. v. United States (RTAC), 45 CIT __, 503 F. Supp. 3d. 1295, 1299 (2021)).

When these criteria are met, Commerce may apply a quarterly cost methodology. Id.

(citing RTAC, 45 CIT __, 503 F. Supp. 3d. at 1299). Commerce believed that an

important part of its required analysis was missing from the record and requested

the Court allow it to consider anew the information Officine submitted. Id. at 1. The Court No. 1:23-cv-00001 (SAV) Page 5

Court granted the unopposed Motion on May 15, 2023. Order Granting Def.’s Mot.

for Voluntary Remand (Remand Order), ECF No. 29.

II. Commerce’s Voluntary Remand and the Present Dispute

Commerce filed its Remand Results on September 12, 2023, and the Parties

submitted comments.2 Final Results of Redetermination Pursuant to Ct. Remand

Order (Remand Results), ECF No. 32; see Def.-Int.’s Comments in Opp’n to Remand

Results (Def.-Int.’s Br.), ECF No. 38; Def.’s Comments on Remand Results (Def.’s Br.),

ECF No. 47. On remand, Commerce reopened the record and requested that Officine

file additional information. Remand Results at 2, ECF No. 32. It requested this data

to determine if Officine’s foreign sales were made below that product’s cost of

production. Id. at 3. Commerce then applied the first part of its test, examining

whether Officine experienced significant changes in the cost of production over the

Period of Review. Id. at 4. It explained that the difference between the highest and

lowest cost of manufacturing during the Period of Review must be at least 25 percent

to be a “significant change.” Id.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
2024 CIT 102, Counsel Stack Legal Research, https://law.counselstack.com/opinion/officine-tecnosider-srl-v-united-states-cit-2024.