Comments on Criteria for Establishing Non-Market Economy AD Rates

SSA submitted comments to the U.S. Department of Commerce on the de facto criteria for establishing a separate rate in antidumping proceedings involving non-market economy (“NME”) countries in response to a Federal Register notice.

SSA supports the agency’s efforts to improve the de facto criteria employed to determine whether separate rate status is appropriately granted and concurs with the submission of the Committee to Support U.S. Trade Laws (“CSUSTL”) in response to the Request for Comments. CSUSTL’s submission accurately identifies fundamental
problems with the entirety of the separate rate test currently employed by the Department.