WORLD TRADE
ORGANIZATIONG/ADP/Q1/CHN/32
G/SCM/Q1/CHN/32
23 October 2003
(03-5590)
Committee on Anti-Dumping Practices
Committee on Subsidies and Countervailing MeasuresOriginal:  English
NOTIFICATIONS OF LAWS AND REGULATIONS UNDER
ARTICLE 18.5 AND ARTICLE 32.6 OF THE AGREEMENTS
Replies to Questions posed by the UNITED STATES1
Regarding the Notification of CHINA2
The following communication, dated 21 October 2003, has been received from the Permanent
Mission of the People's Republic of China.
_______________
Questions on Anti-Dumping
Q1. Article 3 of the Rules states that anti-dumping injury investigations involving
agricultural products shall be conducted by the State Economic and Trade Commission
(“SETC”) in conjunction with the Ministry of Agriculture.3  Could China please clarify the role
of the Ministry of Agriculture in an anti-dumping investigation?
Reply
The Ministry of Agriculture is responsible for assisting investigations conducted by the
Ministry of Commerce as well as collecting related evidence.
Q2. Article 5 of the Rules defines “material injury” as “injury that has been caused to a
domestic industry and is not negligible.”  For purposes of this definition, does the concept of“negligible” injury refer to the concept of negl igible import volume addressed by Article 16?  If
not, could China explain its understanding of the concept of “negligible” injury?
Reply
Yes, it does refer to the concept of negligible import volume addressed by Article 16.
Q3. Under Article 5 of the Rules, “threat of ma terial injury” occurs when “material injury
has not been caused to [a] domestic industry. . . ”.  However, in its response to United States
question 11(c) in G/ADP/Q1/CHN/19 (7 May 2003), China stated that, under current Chineselaw, “[a]n applicant [for anti-dumping duties] can not file an application based on theories of
                                                     
1 G/ADP/Q1/CHN/26-G/SCM/Q1/CHN/26
2 G/ADP/N/1/CHN/2/Suppl.2 (14 April 2003)
3 The United States is aware of reports that, since the time these regulations were notified, the injury
function has been transferred to the Ministry of Commerce.  However, we have continued to refer to the SETC
throughout these questions for consistency with the notified regulations.G/ADP/Q1/CHN/32
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both material injury and threat”. In light of this, how would the SETC have occasion in an
investigation where threat of material injury is alleged to make a finding whether or not
material injury has been caused to a domestic industry?
Reply
China’s investigating authorities will investigate into and determine “threat of material
injury” or “material injury” in accordance with China’s anti-dumping regulations, especially the
Rules, as well as related regulations of WTO anti-dumping agreements.
Q4. Article 3.7 of the Anti-Dumping Agreement (“ADA” or “AD Agreement”) defines the
analysis for threat of material injury and stat es that "no one of these factors by itself can
necessarily give decisive guidance, but the totali ty of the factors considered must lead to the
conclusion that further dumped exports are imminent and that, unless protective action is
taken, material injury would occur".  ADA Article 3.7 also states that "the change in
circumstances which would create a situation in which the dumping would cause injury must beclearly foreseen and imminent”.  Article 7 of the Rules does not contain language implementing
these provisions of ADA Article 3.7.  How does China intend to ensure that these requirements
are met?
Reply
First of all, China’s investigating authorities ha ve always been acting in strict accordance with
Chinese laws and regulations, citing related WTO regulations as our direct references.  The definition
of “threat of material injury” will not go agai nst Article 3.7 of the WTO Anti-Dumping Agreement;
Secondly, the anti-dumping regulations of the Chinese Government will be improved from actual
practices, and the spirit of WTO Anti-Dumping Agreement (ADA) will be clearly manifested.
Q5. ADA Article 3.7 specifies that an authority must examine whether there is a “significant
rate of increase of dumped imports into the domestic market..”.   Article 7 of the Rules does not
contain any provision stating that the examinatio n should include wheth er the rate of increase
of dumped imports is “significant”.  How will Chin a ensure that its analysis of an alleged threat
of material injury will be consistent with ADA Article 3.7 in these respects?
Reply
Article 7.1 of the Rules has specified related regulations.
Q6. Are the factors that SETC examines in as certaining impact for threat analysis under
Article 7.5 of the Rules the same as the ones SETC examines for analysis of material injury
under Article 6.3 of the Rules?  If not, how does the examination of impact for threat analysis
differ from that for analysis of material injury?
Reply
Basically they are the same.  These factors and indexes are established in strict accordance
with WTO Anti-Dumping Agreement.
Q7. Article 8 of the Rules identifies the fact ors examined in the determination of whether
material retardation of the establishment of a domestic industry has been caused by dumping.G/ADP/Q1/CHN/32
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Are these factors considered in relation to one an other?  Is any single factor considered to be
determinative?
Reply
These factors will be considered in relation to one another, and no single factor shall be
considered determinative.
Q8. Article 11 of the Rules refers to factors which may be examined in the determination of
like product and specifically mentions “comments from consumers and producers..”.  Does
China also intend to permit other potentially int erested parties to comment on this issue?  How
will such comments be solicited?
Reply
Related anti-dumping rules of China have not prohibited other potentially interested parties to
comment on this issue.  As for the question of how such comments will be solicited, we think thereare various channels:  notifying interested parties already known to participate in the comment;
Publicizing notifications for their suggestions;  Or issuing questionnaires to collect their viewpoints.
All these are based upon the premises of necessity.
Q9. The first sentence of Article 13 of the Rules states that “[i]n the determination of injury
to [the] domestic industry, SETC may exclude the product under investigation or part thereof
that did not cause injury to the domestic industry”.  The meaning of this provision, which does
not appear to implement any portion of the AD Agreement, is unclear.  Could China provide an
example of a factual situation in which SETC would apply this provision?  How can SETC
determine that a portion of the product under investigation did not cause injury before it hasconcluded its investigation of injury?
Reply
China’s investigating authorities may exclude the product under investigation or part thereof
that did not cause injury to domestic industry in the determination of injury to the domestic industry,
the meaning of this sentence is quite clear, which is to refrain from taking anti-dumping measures topart of the product under investigation that did not cause material injury to our domestic industry.
This article has in effect fulfilled the regulation that anti-dumping measures shall not be taken against
imported product without one of the three prerequisites in WTO Anti-Dumping Agreement:
dumping, injury and a cause-effect relation.
For example:  during the anti-dumping verdict by the Chinese Government in 1999 against
imported stainless steel sheets, we have excluded 4 categories of products which have not caused any
material injury to our domestic industry, and decided not to take anti-dumping measures against such.
The 4 categories are:  stainless steel strip for the cathode of an electron gun on TV, stainless steel
sheet for the razor, stainless steel sheet for a car’ s vent-pipe, and stainless steel sheet for a washing
machine.
The determination that part of the product under investigation did not cause material injury
will be made after the conclusion of the investigation, rather than before it.  One of the major tasks of
injury investigation is to determine whether or not the investigated product has caused material injuryto China’s domestic industry, or the investigated pr oduct as a whole or part has caused such injury.G/ADP/Q1/CHN/32
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Q10. Article 15 of the Rules appears to indica te when SETC may perform a regional industry
analysis pursuant to Article 4.1(ii) of the AD Agreement.  Article 4.1(ii) of the AD Agreement
states that, in order for the authority to base  an injury determination on a regional industry
there must be “a concentration of dumped import s into such an isolated market and . . . the
dumped imports [must be] causing injury to the producers of all or almost all of the production
within such market”.  How does China intend to implement these requirements of Article 4.1(ii),
which are not articulated in Article 15 of the Rules?
Reply   
As for the determination of regional isolated industry, Article 15 of the Rules has already had
clear regulations.  During investigations, the investigating authorities will act in accordance with
regulation of the Rules, citing Article 4.1 (ii) of the AD Agreement as our reference.  The regulations
will be gradually improved during future amendments.
Q11. Article 16 of the Rules states that “[ t]he volume of the dumped imports shall normally
[emphasis added] be regarded as negligible…”  Under what circumstances, other than those
listed in Article 16, would China consider imports accounting for less than three percent of total
imports to be non-negligible?
Reply
China’s investigating authorities will act in a ccordance with the stated regulations of the
state’s anti-dumping laws.
Q12. Article 18 of the Rules states that SETC shal l take account of public interest in making a
determination of injury to the domestic industry.  Will China also allow interested parties an
opportunity to present evidence in this respect?  Will interested parties be allowed to view the
information submitted by users and consumers of the allegedly dumped imports, or adequate
non-confidential summaries thereof?
Reply
China’s investigating authorities will allow interested parties to present related evidence, and
interested parties will be allowed to view information and non-confidential summaries according to
regulation of the Rules.
Q13.  Article 19 of the Rules states “[t]he period under anti-dumping investigations of injury
to industry is normally the 3 years immediately prior to the initiation of an investigation”.
Under what circumstances would China us e a different period of investigation?
Reply
Basically, China would use a different period of investigation under the following
4 circumstances:  1. Operation of domestic industry applicant is shorter than 3 years;  2. In view of
China’s investigating authorities, 3 years is not enough for domestic industry applicant to carry out
investigation;  3. Necessary readjustments are made in consideration of fiscal year or accounting
needs, which do not affect the final conclusion;  4. Other circumstances as regulated by Chinese Law.
Q14. According to ADA Article 5.3,  "[t]he au thorities shall examine the accuracy and
adequacy of the evidence provid ed in the application to determ ine whether there is sufficient
evidence to justify the initiation of an investig ation". Article 20 of the Rules does not containG/ADP/Q1/CHN/32
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any reference to the “accuracy and adequacy of evidence.”  How will China ensure that its
authorities examine the accuracy and adequacy of  the evidence prior to initiation, as required
by ADA Article 5.3?
Reply
China’s investigating authorities have the capability to ensure the examination of the accuracy
and adequacy of the evidence before initiation of an investigation, which have also been proved in
practice.  Not only do we request the applicant to provide all evidence as regulated by law, but also
request these evidence should be from either official statistics, officially authorized sector statistics or
lawful publications and lawful state bills.
Q15. Article 21 of the Rules describes the information that must be included in the
application for initiation of an anti-dumping investigation.  Although this Article lists
information required on injury, considerations for cumulative assessment, and other factors
that caused injury to the domestic industry, it does not contain any provision that theapplication must contain information related to causal link between the dumped imports and
the alleged injury, as required by ADA Article 5.2.  Does China require petitions to contain
information concerning causation?
Reply
China does require petitions to contain information concerning causation, which is explicitly
stated in Article 15 of China’s Anti-Dumping Regulations.
Q16. ADA Article 6.1 states “[a]ll interested part ies in an anti-dumping investigation shall be
given notice of the information which the authorities require and ample opportunity to present
in writing all evidence which they consider relevant in respect of the investigation in question.”
When considering Article 23 of the Rules, wi ll China allow respondents the opportunity to
revise information included with the notice of appearance after it is submitted?  What is the
status of interested parties if they do not register as respondents?  Additionally, will an
interested party be considered registered if it responds to the best of its ability, but does not
submit all of the information requested?
Reply
China’s investigating authorities will allow respondents the opportunity to revise information.
As for the notice of appearance that has been submitted, revisions can be allowed if time permits.
The Rules are quite explicit in determining the status of an unregistered interested party, i.e.
they will be considered as automatically give up opportunity to make an appeal and plea if they do not
respond in the stated time frame.
If an interested party responds to the best of its ability, but still fails to submit all the
requested information, so long as it has raised a responding appeal, the investigating authorities will
consider its qualification as a respondent, while at the same time continue to request the needed
information. If it fails to provide requested information during a specified time frame, its qualification
as a respondent will be held in question. The information requested by the Rules is rather basic, whichshall not pose much difficulty for the respondent. Provision of the requested information is a
prerequisite for a respondent’s participation.G/ADP/Q1/CHN/32
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Q17. Please specify the entities that may be treated as interested parties pursuant to
Article 24.4 of the Rules, which states that “others” may be granted interested party status.  In
its response to United States question 17 in G/ ADP/Q1/CHN/19, China did not indicate that it
considers any entity other than th ose specified in subsections (1), (2), and (3) of Article 24 (i.e.
domestic producers of the like product, impo rters and foreign producers of the merchandise
under investigation, associations of these groups, and governments of the country or region
producing the merchandise under investigation) eligible for status as an interested party.
Reply
Entities that may be treated as interested parties are: attorney agents or agencies hired by
interested parties, accountant or accounting agencies, experts and supervising sectors of the interested
parties.
Q18. In circumstances where SETC engages ex perts in an anti-dum ping investigation
pursuant to Article 27 of the Rules, how will China ensure that these experts maintain the
confidentiality of the data examined, as provided for in Article 6.5 of the ADA?
Reply
There are at least three ways to ensure confid entiality:  1. China’s investigating authorities
will only hire experts with lawful qualifications;  2. China’s investigating authorities will sign a
confidentiality agreement with hired experts;  and 3. The experts will be abide by law and the
agreement to meet confidentiality requirements.
In general, time limit for the return of questionnaire shall be 37 days. The investigating
authorities shall not grant an extension without occurrence of special circumstances, irresistible forces
or reasonable explanations.
Q19 . Article 30 of the Rules states that the questionnaires shall be returned "within the time
limit specified in the questionnaire."  Specifically, what is the time limit for questionnaire
responses?  Are these calendar days or working days?  Additionally, under what circumstances
will SETC not grant an extension?
Reply
Article 25 of China’s Anti-Dumping Regulations has related regulations.  China’s
investigating authorities have always acted in accordance with this regulation, citing ADA Article 6.7and Annex I as our reference. We have always guaranteed that Article 32 of the Rules will not go
against ADA Article 6.7 and Annex I, and fall in line with such stipulations. In practice, we have as
well tried to make results of verifications available to related firms, ensuring the availability of such
results to related parties.
Q20. Article 32 of the Rules does not provide for making results of verifications available to
the firm which was verified or for protecting th e confidentiality of information received during
the investigation as required in ADA Article 6.7 and Annex I.  How will China ensure that
Article 32 is implemented consistent with ADA Article 6.7 and Annex I?
Reply
There are 4 common situations:  1. the request of an interested party is raised too late. With
final verdict pressing near, the investigating authorities do not have time to conduct verifications. InG/ADP/Q1/CHN/32
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such case, we can find some other ways to compensate, without infecting the accuracy of the verdict;
2.  the request from an interested party bears no further significant evidence. A verdict can be made
from the possessed evidence, and there is no necessity for further verifications;  3. the internal
technical factors of the investigator have prevented the verification, but we will find ways tocompensate without infecting the accuracy of the verdict; 4. other situations as regulated by law.
Q21. Article 32 of the Rules states that, when requested by an interested party, the
administering authority will conduct a verifi cation.  Under what circumstances would a
requested verification not be conducted?  What provisions will SETC make for a situation in
which it cannot conduct all requested verifications?
Reply
Investigating authorities will come up with a ju stified verdict in accordance with all premium
evidences, and there will be no unjust regulations against the unverified interested party.
Q22.  Article 34 of the Rules states that hearings may be held upon request.  Under what
circumstances would requests for hearings not be honoured?
Reply
Requests for hearings will not be honoured due to irresistible forces or unlawful requests.
Article 23 of the Rules on Public Hearings on Injury to Industry has further provisions.
Q23. With regard to Articles 35 through 37 of the Rules, which address price undertakings:
(a) Will China be issuing further rules for price undertakings?  If so, when?
(b) Will China entertain requests for price undertakings prior to making a
preliminary determination of dumping and injury?  If so, please explain how
such a practice would be consistent with ADA Article 8.2, which states, “[p]rice
undertakings shall not be sought or accepted from exporters unless the
authorities of the importing Member have made a preliminary affirmativedetermination of dumping and injury caused by such dumping”?
Reply
1. The Ministry of Commerce has already had regulations on price undertakings.
2. China’s Anti-Dumping Regulations stipulate that price undertakings shall only be sought after
a preliminary determination of dumping and injury, which is strictly in line with the ADA Article 8.2.
Q24. The second sentence of Article 36 of the Rules states that, if exporters refuse or do not
offer a proposal for price undertaking, “SETC is free to determine that a threat of injury is
more likely to be realized if the exporters continue dumping the import[ed] products.”
(a) Is this a factor SETC will consider in addition to the factors pertinent to threat
analysis listed in Article 7 of the Rules?
(b) How is SETC’s consideration of this fa ctor consistent with Article 3.7 of the AD
Agreement.G/ADP/Q1/CHN/32
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Reply
1. The investigating authorities will act in strict  accordance with related regulations in chapter 4,
section 2 of China’s Anti-Dumping Regulations as well as the Rules.
2. China’s investigating authorities will act in strict accordance with related regulations of
China’s Anti-Dumping Regulations as well as the Rules, which are in exact consistence with Article 3
of the AD Agreement. It has already been proven th at investigation and judgment of such authorities
are in line with Article 3 of the AD Agreement.
Q25. How does Article 37 of the Rules conform to ADA Article 8.4, which states that “if a
negative determination of dumping or injury is made, the undertaking shall automatically
lapse”?
Reply
Different issues have been addressed in Article 37 of the Rules and Article 8.4 of ADA. The
same spirits are manifested in the regulations of the Rules and Anti-Dumping Agreement, and China’s
investigating authorities will give adequate consid eration to related stipulations in the Agreement,
which will fully guarantee ADA effectiveness.
Q26. If a respondent’s request for confidential information is denied, will the respondent be
given an opportunity to revise the non-confidential summary or withdraw any confidential
information prior to its disclosure?  How will China treat confidential information submitted by
the respondents once the investigation is completed?
Reply
If the request does not go against China’s related regulations and the set time limits, the
respondent will be given an opportunity to revise  the non-confidential su mmary or withdraw any
confidential information prior to its disclosure. On ce the investigation is completed, the confidential
information will be appropriately dealt with in accordance with China’s current regulations in file
keeping.
Q27. Article 42 of the Rules does not contain an y provision making allowances for difficulties
experienced by interested parties, in particular small companies, in supplying information
requested, nor does it require authorities to provide assistance, as required by ADA
Article 6.13.  How does China intend to implement this ADA requirement?
Reply
Any un-addressed issues in China’s anti-dumping regulations will be implemented in line
with the regulations of WTO Anti-Dumping Agreement under the precondition of not going againstthe spirits of related Chinese regulations.
Q28. Article 43 of the Rules states that interested parties shall have access to non-confidential
information after the initiation of the case, prior to the publication of the final determination
and within a reasonable period after publication of the final determination.
(a) Are there any circumstances in which interested parties would be denied access
to non-confidential information?  If so, please explain.  Additionally, how would
such circumstances be consistent with ADA Article 6.4?G/ADP/Q1/CHN/32
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(b) How does China define a "reasonable period” for purposes of this provision?
(c) Will records of investigations be avai lable indefinitely for reference in future
investigations and for judicial review?
Reply
1. They will not be any circumstances and regulations in which interested parties would be
denied to access to non-confidential information.
2. In case this does not go against China’s related regulations and specific preconditions, a
“reasonable period” here can be interpreted as during implementation period of the anti-dumping
measures.
3. In case this does not go against China’s related regulations and specific preconditions, records
of investigations that can be lawfully publicized will be available for reference in future investigations
and for judicial review.
Q29. How is Article 44 of the Rules consistent with Article 23 of the Regulations of the
People’s Republic of China on Anti-Dumping4, which states “the investigating authorities shall
allow the applicant and interested parties to have access to the information relevant to the
investigation, provided that the information has not been treated as confidential”?  In addition:
(a) What is the "relevant certificate" required by Article 44 of the Rules?  How do
interested parties obtain this certificate?
(b) What are the procedural formalities refe rred in Article 44 of the Rules?  Where
can respondent parties obtain information on these procedural formalities?
Reply
Article 44 of the Rules is consistent with Article 23 of the Regulations of the People’s
Republic of China on Anti-Dumping. The former is to better carry out the spirit of the latter, to protect
and guarantee the legal rights and interests of people who want to consult these documents, as well as
to protect the security of the documents.
The “relevant certificate” in Article 44 of the Rules refers to documents which can certify the
identity of the person who wants to look at the documents, the person’s working unit, and reasons for
consulting the documents.
The procedural formalities in Article 44 of the Rules refer to registration and contract
formalities before the access to the non-confidential information.
Q30. While Articles 43, 44, and 45 of the Rules contain provisions permitting interested
parties to inspect non-confidential information,  they do not expressly address whether parties
are entitled to prepare presentations based on such  information that they inspect.  Do interested
parties have such rights?  If not, how does China implement the requirements of Articles 6.4and 6.9 of the AD Agreement?
                                                     
4 G/ADP/N/1/CHN/2 (11 September 2002)G/ADP/Q1/CHN/32
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Reply
The rights of interested parties have been well clarified in the above-mentioned provisions. In
practice, China’s investigating authorities have w on good acclaims by interested parties for their
implementation of Article 6.4 and 6.9.
Q31. Will the SETC provide facilities such as a public reading room in order for interested
parties to review and copy non-confidential information?
Reply
These facilities have already been provided by the investigating authorities.
Q32. Article 48 of the Rules lists circumstances which would lead to termination of the injury
investigation.  This list does not include termination based on de minimis margins, although
these grounds are included in Article 27 of the  Regulations of the People’s Republic of Chinaon Anti-Dumping.  How is Article 48 of the Rules consistent with Article 5.8 of the ADA which
explicitly calls for termination of anti-dumping investigations when the authorities determine
the margin is de minimis (i.e., less than 2 pe rcent, expressed as a percentage of the export
price)?
Reply
China’s investigating authorities carry out the investigation and determination strictly in
accordance with the Regulations of the People’s Republic of China on Anti-Dumping and the Rules.
The Regulation is consistent with ADA in terms of the wording and the implementation.
Q33. With regard to Article 49 of the Rules, which contains provisions concerning interim
and expiration reviews:
(a) Does China intend to issue implementing rules for interim reviews and
expiration reviews?  If so, when?  Additionally, will these rules also be notified to
the WTO?
(b) Will five-year expiration reviews be conducted in all cases either at the request
of interested parties or based on self-initiation by SETC?
(c) Under what circumstances will SETC self-initiate a review?(d) What is the time line for completi on of interim and expiration reviews?
(i) Will the determination be issued publicly?  If so, in what format (e.g.,
where will it be published)?
(ii) What organization now conducts interim and expiration reviews?
(iii) What procedural rights will intere sted parties have with respect to the
injury determination?G/ADP/Q1/CHN/32
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Reply
(a) China is improving the regulations concerning interim and expiration reviews. Some
regulations have been issued, and some are still being made. Chinese government willnotify the WTO about these regulations.
(b) According to the related regulations, five-year expiration reviews will be conducted
either at the request of interested parties or based on self-initiation by China’s
investigating authorities.
(c) According to the law, SETC will self-initiate a review when China’s investigating
authorities consider that dumping, the side effects of dumping or the injury on
Chinese industry still exist, or when there are solid reasons for a review.
(d) The time line for completion of interim and expiration reviews is: the interim review
comes first, and later the expiration review. An interim review is conducted from the
second year after anti-dumping measures are taken into effect until the end of the
implementation period. An expiration review is made in the last year of the
implementation of anti-dumping measures. The procedural formalities for the reviews
are implemented in the light of the regulations concerning anti-dumping
investigations.
(i) The determination will be issued publicly in the form on an announcement
(e.g. on the Chinese media such as International Business).
(ii) Now the Ministry of Commerce of the People’s Republic of China conducts
interim and expiration reviews.
(iii) The procedural rights of interested parties are the same as the related rights in
application and investigation procedures.
Q34. With regard to Articles 53 through 56 of the Rules, which address circumvention:
(a) Will China develop and publish procedures for investigations into circumvention
of anti-dumping measures?
(b) With regard to Article 55 of the Rules, during what length of time prior to
initiation  of an investigation would alleged practices of circumvention be
considered a factor in evaluating whet her there has been circumvention of an
anti-dumping measure?
(c) How can actions prior to the initiati on of an anti-dumping investigation
constitute circumvention of a measure, if the measure does not exist at thattime?
(d) What are the appropriate measures China may take in situations where
circumvention of anti-dumping measures causes injury to the domestic industry
pursuant to Article 56 of the Rules?  What process will China follow indetermining what measures to take to address circumvention?G/ADP/Q1/CHN/32
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Reply
(a) Yes, China will develop and publish procedures for investigations into circumvention
of antidumping measures.
(b) Before the anti-circumvention investigation and during anti-dumping implementation
period.
(c) Under usual circumstances, only after anti-dumping measures have been taken,
circumvention can be identified. If price undertakings are involved, they should be
confirmed and investigated in accordance with law.
(d) When circumvention causes injury to the domestic industry, China’s investigating
authorities will take appropriate measures to stop such circumvention according to
measures set in China’s Foreign Trade regulations, China’s anti-dumping regulations,
China’s custom regulations, China’s quality monitoring regulations, etc.
China’s investigating authorities will take anti-circumvention measures according to
the above-mentioned laws and anti-dumping investigating procedures.
China’s investigating authorities clearly define the circumvention in Article 54 and 55
of the Rules.
Q35. When parties provide requested information in Chinese, as required by Article 57 of the
Rules, and a relevant document is lengthy, may a party submit a translation of only the
pertinent portions of the lengthy document, or mu st the party provide a translation of the entire
document, no matter how lengthy?
Reply
The translation of the entire document should be submitted, no matter how lengthy it is.
According to regulations, the evidence is only valid when it is translated into Chinese.
Q36. Will SETC interpretations of the Rules, re ferenced in Article 59 of the Rules, be subject
to judicial review?
Reply
The Rules is subject to national judicial review.
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