Comments on Methodology for Respondent Selection in AD Proceedings

SSA submitted comments to the U.S. Department of Commerce on its Proposed Methodology for Respondent Selection in Antidumping Proceedings in response to a Federal Register notice.

SSA fully supports the use of sampling to select mandatory respondents in administrative reviews of antidumping duty orders. Because the use of sampling facilitates the calculation of accurate dumping margins and enhances the remedial effect of the antidumping duty laws, the Department should begin to select mandatory respondents through a sampling methodology as a matter of course as soon as possible. Further, the Department should not permit the exceptions to employing sampling to swallow the general rule. The Department should also recognize and take steps to address the limitations inherent in data regarding “type 3” imports obtained from U.S. Customs and Border Protection (“CBP”).

SSA concurs with the proposals set forth in the submission of the Committee to Support U.S. Trade Laws in support of the use of sampling to select mandatory respondents.