Thai Pineapple Canning Industry Corp. v. United States

24 Ct. Int'l Trade 107, 2000 CIT 17
CourtUnited States Court of International Trade
DecidedFebruary 10, 2000
DocketCourt 98-03-00487
StatusPublished

This text of 24 Ct. Int'l Trade 107 (Thai Pineapple Canning Industry 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.

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Thai Pineapple Canning Industry Corp. v. United States, 24 Ct. Int'l Trade 107, 2000 CIT 17 (cit 2000).

Opinion

Opinion

Restani, Judge:

On May 5,1999, the court remanded the final results of the Department of Commerce, International Trade Administration (“Commerce” or “the Department”) in Canned Pineapple Fruit from Thailand, 63 Fed. Reg. 7,392 (Dep’t Commerce 1998) (final results of antidumping duty admin, rev.) [hereinafter “Final Results”]. See Thai Pineapple Canning Indus. Corp. v. United States, No. 98-03-00487, *108 1999 WL 288772 (Ct. Int’l Trade May 5,1999) [hereinafter “Thai Pine- applei”]. 1 The case concerned a challenge by Thai Pineapple Canning Industry Corp., Ltd. (“TPC”) and Mitsubishi International Corp. (“MIC”) (collectively “TPC”) to the Department’s Final Results. In its remand instructions, the court instructed Commerce to (1) reconsider the date of sale, (2) reconsider the matching of costs to sales on a fiscal year basis for cost of production (“COP”) and constructed value (“CV”) purposes, and (3) recalculate the constructed export price (“CEP”) profit calculation. Thai Pineapple, 1999 WL 288772, at *11. Because neither TPC nor Commerce had an adequate opportunity to address the assessment rate of entries made after the final determination in the original less-than-fair-value investigation, that issue was remanded to provide the parties a further opportunity to brief the issue. Thai Pineapple, 1999 WL 288772, at *2. The court upheld Commerce’s use of a single assessment rate for the period of review (“POR”). Id. at *10-11.

Commerce issued its remand determination on September 2, 1999. See Final Results of Redetermination Pursuant to Court Remand: Thai Pineapple Canning Industry Corp., Ltd., and Mitsubishi International Corp. v. United States, Court No. 98-03-00487 [hereinafter “Remand Results” or “RR”].

Jurisdiction and Standard of Review

The court has jurisdiction pursuant to 28 U.S.C. § 1581(c) (1994). In reviewing final determinations in antidumping duty investigations, the court will hold unlawful those agency determinations which are unsupported by substantial evidence on the record, or otherwise not in accordance with law. 19 U.S.C. § 1516a(b)(l)(B)(i) (1994).

I. Date of Sale

A. Background

In the Final Results, Commerce used the date of contract for purposes of determining the date of sale for export price (“EP”) sales and third country sales. Final Results, 63 Fed. Reg. at 7,394-95. The court found that Commerce’s policy as of the time of its review of TPC was to use invoice date for date of sale, absent a significant reason to do the contrary. See Thai Pineapple, 1999 WL 288772, at *5-6. The court therefore remanded for Commerce to state whether there was “another reason for rejecting invoice date” and to “square its reasoning with its other contemporaneous determinations.” Id. at *6. In the Remand Results, Commerce reconsidered the date of sale determination, and again concluded that “contract date remains the appropriate date of sale for TPC’s third country sales, based on the record in this case.” RR, at 13. The Department states that this decision is consistent with its date of sale methodology in contemporaneous determinations. Id.

*109 B. Discussion

TPC argues that Commerce has not provided an adequate explanation for not utilizing invoice date as date of sale in its remand determination.

The Department announced a new policy, applicable to this case, of using invoice date for date of sale unless there is information indicating that date of contract should be used because all material terms of the sale were firmly fixed at that time. See Thai Pineapple, 1999 WL 288772, at *5. This policy is now reflected in Commerce’s regulations. 2 19 C.F.R. § 351.401(i) (1999).

The announced policy was not applied to this matter although it was applied to other contemporaneous matters. See Thai Pineapple, 1999 WL 288772, at *6. The new rule establishes a presumption that invoice date will be the date of sale. See 19 C.F.R. § 351.401(i). If Commerce can establish “a different date [that] better reflects the date on which the exporter or producer establishes the material terms of sale,” Commerce may choose a different date. Id. Commerce has cited nothing of substance which indicates sales terms were fixed at an earlier date. Nor has it cited any other credible reason for disregarding its announced presumption. See Antidumping Duties; Countervailing Duties —Final Rule, 62 Fed. Reg. 27,296, 27,349 (Dep’t Commerce 1997) (invoice date presumption applies “absent satisfactory evidence that the terms of sale were finally established on a different date.”) Commerce does not cite industry practice or a lag between invoice and shipment, or any other unusual situation, indicating a date, other than invoice date should be used. There appears to be no other case in which “rare instances” of changes after contract date, RR, at 17, was considered substantial reason to abandon the invoice date presumption. Under the facts of this case, i.e., rising pineapple costs, the fact that few purchasers sought changes is meaningless. The question is could the terms be changed, or were they fixed at the time of the initial order. See Final Results, 63 Fed. Reg. at 7,394. The evidence is that the terms could be changed and were changed in some instances. See Thai Pineapple, 1999 WL 288772, at *4 & n.ll. There was no reason for Commerce to abandon its presumption in this matter. The court therefore reverses Commerce’s use of date of contract and directs the Department to use invoice date for date of sale purposes.

II. Use of Single Weighted-Average Cost of Production Covering Entire 18-Month Period of Review

In the Final Results, for COP and CV purposes, Commerce used a single weighted-average cost for the entire POR. Final Results, 63 Fed. *110 Reg. at 7,399. TPC argued that this single weighted-average cost failed to take into account the rising cost of fresh pineapple fruit from 1994 through the POR. Id. TPC alleged that this resulted in significant distortions in Commerce’s price-cost comparisons. Id.

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