Republic Steel Corp. v. United States

591 F. Supp. 640, 8 Ct. Int'l Trade 29, 8 C.I.T. 29, 1984 Ct. Intl. Trade LEXIS 1916
CourtUnited States Court of International Trade
DecidedJuly 11, 1984
DocketConsolidated Court 82-03-00372
StatusPublished
Cited by32 cases

This text of 591 F. Supp. 640 (Republic Steel Corp. 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
Republic Steel Corp. v. United States, 591 F. Supp. 640, 8 Ct. Int'l Trade 29, 8 C.I.T. 29, 1984 Ct. Intl. Trade LEXIS 1916 (cit 1984).

Opinion

WATSON, Judge:

This consolidated judicial review involves seven instances in which countervailing duty investigations of imported steel products came to an end because the International Trade Commission (ITC) found that there was no reasonable indication of mate *642 rial injury or threat of material injury from importations of those products. 1

The ITC made these preliminary determinations in February and June of 1982 pursuant to section 703(a) of the Trade Agreements Act of 1979 (the Act) (19 U.S.C. § 1671b(a)). 2

These seven determinations affected seven kinds of steel products, coming from three countries, Brazil, Spain and Korea. 3

It is important to add that in February of 1982, the ITC had found that, in the case of five of these products, imported from other countries, there was a reasonable indication of material injury. 4

In support of its determinations that there were no reasonable indications of material injury or threats of injury in the seven cases under review here, the ITC relied on one or more of the following reasons:

(a) low volume of importations
(b) declining volume of importations
(c) low penetration (low percentage of domestic consumption)
(d) declining penetration
(e) no evidence of underselling
(f) no evidence of price suppression or depression
(g) no confirmed lost sales
(h) healthy condition or relatively healthy condition of the domestic industry

In this review the Court finds that the ITC erred in three respects.

*643 First, with respect to those five products whose importations could possibly contribute to material injury by adding to the effects of importations of those products from other countries, the ITC erred by considering each of those products separately from each country. This error affected the preliminary determinations listed in footnote 1, except for Nos. 5 and 6. For those five products the criterion for finding a reasonable indication of material injury should have been simply whether all subsidized or allegedly subsidized products of the same type could exert a combined effect on the domestic industry. The ITC should have considered only the cumulated sum of importations of a particular product. In these preliminary determinations, the factors listed above could be relevant only for the cumulated amount as a whole. 5 For importations from a single country they were irrelevant.

Second, with respect to products which were not initially subject to the necessity of cumulated consideration, the ITC erred by applying too stringent a standard to the information before it and by weighing conflicting evidence concerning the listed factors. This error affected the preliminary determinations numbered 5 and 6 in footnote 1. For those products, the presence of any information from which the possibility of material injury could be reasonably inferred, was sufficient to present a reasonable indication of injury.

Third, with respect to the possibility of the existence of threats of material injury, the ITC also applied too stringent a standard and did not direct its preliminary inquiries to the proper factors.

These three errors will be discussed separately.

I

On the subject of cumulation the parties have presented a three-sided argument. In essence, plaintiffs argue that the cumulation of importations of a product from different countries is mandatory and permanent. The intervenors argue that it is unlawful. The ITC argues that it is discretionary.

Plaintiffs claim that for the purposes of a countervailing duty investigation all contemporary, subsidized or allegedly subsidized, competitive importations of a product, must be cumulated and considered as a unit for purposes of determining whether the domestic industry is being materially injured.

Plaintiffs urge that had the ITC done so, it would have been obvious that, given an indication of injury from one or more of those other sources, the allegedly subsidized imports involved here, in any amount, must be added to the same finding. Plaintiffs further argue that if importations from any of those other sources were finally found to be the cause of material injury, any other contemporary importations must also be subject to the same finding.

The defendant intervenors, representing Brazilian producers and Korean producers, argue that cumulation, as envisioned by plaintiffs, is not required by the countervailing duty law and would, in fact, violate the law and the international agreements that the law was intended to implement. They assert that this violation would occur if the ITC was to find injury from a country’s products without proof of causation.

The ITC argues that it properly exercized its discretion to consider the effect of importations of these products individually, as importations from separate countries. It further contends that, in each determination, its evaluation of the information gave a rational and lawful basis to the determinations that there were no reasonable indications of injury from importations of these products.

More specifically, on the issue of cumulation, the ITC maintained that these importations “could not conceivably have contributed to material injury.” 47 Fed.Reg. at 9091. It further stated that “the factors and conditions of trade” must show the relevance of cumulation to the determina *644 tion of injury. These factors were stated to include the following:

—volume of subject imports
—trend of import volume
—fungibility of imports
—competition in markets for the same end users
—common channels of distribution
—pricing similarity
—simultaneous impact
—any coordinated action by importers 6

In this judicial review the Court finds that the contributing effect standard is incorrect for the preliminary determination of whether there is a reasonable indication of material injury from importations originating from more than one country. The Court finds that when there is alleged to be material injury caused by importations from more than one country, the contributing effect standard is proper only for a final

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Bluebook (online)
591 F. Supp. 640, 8 Ct. Int'l Trade 29, 8 C.I.T. 29, 1984 Ct. Intl. Trade LEXIS 1916, Counsel Stack Legal Research, https://law.counselstack.com/opinion/republic-steel-corp-v-united-states-cit-1984.