U.S. International Trade Commission

Publication 4155 June 2010

Washington, DC 20436

Ironing Tables and Certain Parts Thereof 

from China

Investigation No. 731-TA-1047 (Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Shara L. Aranoff, Chairman 

Daniel R. Pearson, Vice Chairman 

Deanna Tanner Okun 

Charlotte R. Lane 

Irving A. Williamson 

Dean A. Pinkert

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Acting Director of Operations

Jennifer Merrill, Investigator 

Ralph Watkins, Industry Analyst 

Gerald Benedick, Economist 

Mary Klir, Accountant 

Patrick Gallagher, Attorney 

Douglas Corkran, Supervisor Investigator

Special assistance from

Lemuel Shields, Statistician
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4155 June 2010

Ironing Tables and Certain Parts Thereof 

from China

Investigation No. 731-TA-1047 (Review)

CONTENTS

Page

Determination .................................................................. 1

Views of the Commission ......................................................... 3

Part I: Introduction and overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1

Background . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1

The original investigation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-2

Summary data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-2

Statutory criteria and organization of the report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

Statutory criteria . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-3

Organization of the report . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-4

Commerce’s reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-5

Administrative reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-5

Five-year reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-6

Distribution of Continued Dumping and Subsidy Offset Act funds . . . . . . . . . . . . . . . . . . . . . . . I-6

The subject merchandise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-7

Commerce’s scope . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-7

Tariff treatment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

The domestic like product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

Description and applications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-8

Manufacturing processes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-9

Domestic like product issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-11

U.S. market participants . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-11

U.S. producer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-11

U.S. importers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-12

U.S. purchasers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-14

Apparent U.S. consumption and market shares . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-14

Part II: Conditions of competition in the U.S. market ................................ II-1

U.S. channels of distribution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1

Regional sales . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-2

U.S. market characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3

Purchases of ironing tables before and after the order ............................... II-4

Information on suppliers of ironing tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-4

Supply and demand considerations ................................................ II-5

U.S. supply ............................................................... II-5

U.S. demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-9

Substitutability issues .......................................................... II-16

Factors affecting purchasing decisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-18

Comparisons of domestic products, subject imports, and nonsubject imports ............ II-19

Elasticity estimates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-23

U.S. supply elasticity ........................................................ II-23

U.S. demand elasticity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-23

Substitution elasticities ...................................................... II-23

i
CONTENTS

Page

Part III: Condition of the U.S. industry ............................................ III-1

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-1

U.S. producer’s capacity, production, and capacity utilization .......................... III-2

U.S. producer’s shipments . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2

U.S. producer’s inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2

U.S. producer’s imports and purchases ............................................. III-3

U.S. producer’s employment, wages, and productivity ................................ III-3

Financial experience of U.S. producer . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4

Background ............................................................... III-4

Operations on ironing tables . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-4

Variance analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-5

Capital expenditures research and development expenses ........................... III-5

Assets and return on investment ............................................... III-6

Part IV: U.S. imports and the foreign industry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

U.S. imports . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

Imports from subject and nonsubject sources . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-1

U.S. importers’ inventories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

U.S. importers’ imports subsequent to 31, 2009 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

The industry in China . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

Overview . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

Ironing tables operations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3

Global market . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-6

Demand . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-6

Supply . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-7

Prices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-9

Part V: Pricing and related information . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

Factors affecting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

Raw materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

U.S. inland transportation costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1

Pricing practices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-2

Line reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-3

Importance of product features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-4

Price data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-7

Price trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-12

Price comparisons . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-13

ii
CONTENTS

Page

Appendixes

A. Federal Register notices . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1

B. Hearing witnesses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . B-1

C. Summary table . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . C-1

D. Responses of U.S. producer, U.S. importers, U.S. purchasers, and foreign 

producers concerning the significance of the antidumping duty finding and the 

likely effects of revocation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . D-1

E. U.S. producer’s selling prices of products 1 and 3 combined, and U.S. importers’ 

selling prices of the Chinese products 3 and 4 combined . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1

Note.–Information that would reveal confidential operations of individual concerns may not be published

and therefore has been deleted from this report. Such deletions are indicated by asterisks.

iii

UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation No. 731-TA-1047 (Review)

IRONING TABLES AND CERTAIN PARTS THEREOF FROM CHINA

DETERMINATION

On the basis of the record1

 developed in the subject five-year review, the United States

International Trade Commission (Commission) determines, pursuant to section 751(c) of the Tariff Act of

1930 (19 U.S.C. § 1675(c)), that revocation of the antidumping duty on ironing tables and certain parts

thereof from China would be likely to lead to continuation or recurrence of material injury to an industry

in the United States within a reasonably foreseeable time.

BACKGROUND

The Commission instituted this review effective July 1, 2009 (74 F.R. 31755, July 2, 2009) and

determined on October 5, 2009 that it would conduct a full review (74 F.R. 54066, October 21, 2009). 

Notice of the scheduling of the Commission’s review and of a public hearing to be held in connection

therewith was given by posting copies of the notice in the Office of the Secretary, U.S. International

Trade Commission, Washington, DC, and by publishing the notice in the Federal Register on November

30, 2009 (74 F.R. 62593). The hearing was held in Washington, DC, on April 13, 2010, and all persons

who requested the opportunity were permitted to appear in person or by counsel.

 1 The record is defined in sec. 207.2(f) of the Commission’s Rules of Practice and Procedure (19 CFR § 207.2(f)).

VIEWS OF THE COMMISSION

Based on the record in this five-year review, we determine under section 751(c) of the Tariff Act

of 1930, as amended (“the Act”), that revocation of the antidumping duty order on ironing tables and

certain parts thereof from China would be likely to lead to continuation or recurrence of material injury to

an industry in the United States within a reasonably foreseeable time.

I. BACKGROUND

A. The Original Determination

On July 29, 2004, the Commission determined that an industry in the United States was being

materially injured by reason of imports of ironing tables from China that were being sold at less than fair

market value.1

 Subsequently, the U.S. Department of Commerce (“Commerce”) issued an antidumping

duty order covering these imports.2

B. The Current Review

The Commission instituted this five-year review effective July 1, 2009.3

 The Commission

received five responses to the notice of institution: from domestic producer Home Products International,

Inc. (“HPI”), from Chinese manufacturer and exporter Since Hardware (Guangzhou) Co., Ltd. (“Since

Hardware”), and from three U.S. importers of the subject merchandise - Whitney Design, Polder Inc.

(“Polder”), and Group SEB USA Inc. On October 5, 2009, the Commission determined that the

individual responses, the domestic interested party group response, and the respondent interested party

group response to the notice of institution were adequate. Accordingly, the Commission determined to

proceed to a full review.4

One U.S. producer, HPI, accounting for 100 percent of U.S. production of ironing tables in 2009,

provided a complete response to the Commission’s questionnaire.5

 The Commission received usable

 1 Ironing Tables and Certain Parts Thereof from China, Inv. No.731-TA-1047 (Final), USITC Pub. 3711 (July

2004) (“Original Investigation”). Commissioner Pearson found that the domestic industry was not materially injured

by reason of the subject imports, but, rather, was threatened with material injury by reason of subject imports sold at

less than fair value. Original Investigation at 31-45.

 2

 Notice of Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order: FloorStanding, Metal-Top Ironing Tables and Certain Parts Thereof from the People’s Republic of China, 69 Fed. Reg.

47868 (August 6, 2004).

 3

 74 Fed. Reg. 31755 (July 2, 2009).

 4

 74 Fed. Reg. 54066 (October 21, 2009); see also Explanation of Commission Determinations on Adequacy,

reprinted in Confidential Staff Report (“CR”), INV-HH-047 (May 7, 2010), as amended by INV-HH-052 (May 13,

2010), Public Report (“PR”) at App. A. 

 5

 CR at I-20, PR at I-11.

3
questionnaire responses from 10 importers and 13 U.S. purchasers of ironing tables,6

 and six responses to

foreign producer questionnaires from ironing tables producers in China.7

II. DOMESTIC LIKE PRODUCT

In making its determination under section 751(c) of the Act, the Commission defines “the

domestic like product” and the “industry.”8

 The Act defines “domestic like product” as “a product which

is like, or in the absence of like, most similar in characteristics and uses with, the article subject to an

investigation under this subtitle.”9

 The Commission’s practice in five-year reviews is to look to the like

product definition from the original determination and any completed reviews and consider whether the

record indicates any reason to revisit the prior findings.10

In its expedited five-year review determination, Commerce defined the subject merchandise as

ironing tables and certain parts thereof:

For the purposes of this order, the product covered consists of floor-standing,

metal-top ironing tables, assembled or unassembled, complete or incomplete, and certain

parts thereof. The subject tables are designed and used principally for the hand ironing or

pressing of garments or other articles of fabric. The subject tables have full-height leg

assemblies that support the ironing surface at an appropriate (often adjustable) height

above the floor. The subject tables are produced in a variety of leg finishes, such as

painted, plated, or matte, and they are available with various features, including iron

rests, linen racks, and others. The subject ironing tables may be sold with or without a

pad and/or cover. All types and configurations of floor-standing, metal-top ironing tables

are covered by this order.

Furthermore, the order specifically covers imports of ironing tables, assembled or

unassembled, complete or incomplete, and certain parts thereof.

* * *

Ironing tables without legs (such as models that mount on walls or over doors) are not

floor-standing and are specifically excluded. Additionally, tabletop or countertop models

 6 CR at I-21 to I-23, PR at I-12 to I-14, and CR/PR at Table I-6. We rely upon import data submitted in response

to the Commission’s importer questionnaires, rather than Customs data, as the latter appear to have discrepancies. 

Eleven of the 13 importers listed in the Customs data as having imported at least *** units from China or from other

countries reported to the Commission that they did not import any ironing tables during the period examined. CR at

IV-2 n.4, PR at IV-1 n.4.

 7

 CR at IV-5, PR at IV-3 to IV-4. The Commission sent foreign producer questionnaires to 31 known Chinese

producers of ironing tables and received usable data from the following six Chinese producers: Forever Holdings

Ltd. (“Forever Holdings”), Foshan Shunde Yongjian Housewares & Hardware Co., Ltd. (“Foshan Shunde”),

Greenwood Houseware (Zhuhai) Ltd. (“Greenwood”), Harvest International Housewares (“Harvest”), Heshan

Zhishan Hengfeng Metal Co., Ltd. (“Heshan”), and Since Hardware (Guangzhou) Co. Ltd. (“Since Hardware”). Id.

 8

 19 U.S.C. § 1677(4)(A).

 9

 19 U.S.C. § 1677(10); see, e.g., Cleo, Inc. v. United States, 501 F.3d 1291, 1299 (Fed. Cir. 2007); NEC Corp. v.

Department of Commerce, 36 F. Supp. 2d 380, 383 (Ct. Int’l Trade 1998); Nippon Steel Corp. v. United States, 19

CIT 450, 455 (1995); Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l Trade 1996); Torrington Co. v.

United States, 747 F. Supp. 744, 748-49 (Ct. Int’l Trade 1990), aff’d, 938 F.2d 1278 (Fed. Cir. 1991); see also S.

Rep. No. 249, 96th Cong., 1st Sess. 90-91 (1979). 

 10 See, e.g., Internal Combustion Industrial Forklift Trucks From Japan, Inv. No. 731-TA-377 (Second Review),

USITC Pub. 3831 at 8-9 (December 2005); Crawfish Tail Meat From China, Inv. No. 731-TA-752 (Review), USITC

Pub. 3614 at 4 (July 2003); Steel Concrete Reinforcing Bar From Turkey, Inv. No. 731-TA-745 (Review), USITC

Pub. 3577 at 4 (February 2003).

4
with short legs that do not exceed 12 inches in length (and which may or may not

collapse or retract) are specifically excluded.11

Ironing tables are used in households, hotel rooms, and workplaces for the purpose of pressing

apparel and other textile items. The standard size of an ironing table is 48 to 54 inches in length and 13 to

18 inches in width. The table may be equipped with special features such as an iron rest or linen racks. 

Ironing tables and their components are produced from flat-rolled steel and wire, as well as fasteners,

plastic fittings, foam, and textile fabric. The principal components of an ironing table are its metal

ironing surface, legs, feet, slide bar, handle, hangers, ribs, and foot cover. The ironing surface is either

mesh-top or perforated-top and is attached to a T-leg stand in the most popular configuration as well as

other leg configurations, such as the 4-leg stand. A T-leg ironing table is made of a single metal tube

inserted into a metal leg base that is shaped as an inverted “T.” A 4-leg ironing table has two legs, each

made of two metal tubes that run parallel to each other, which flare out to form a 4-footed base on the

floor, and typically have a cross brace at or near the flare or at the end of the tubes. In each system, users

press a lever that allows the legs to drop down and subsequently adjust the height of the table or fold the

unit flat for storage.12

The scope definition set out above is unchanged from Commerce’s original scope determination. 

In the Commission’s original investigation, it defined a single domestic like product as ironing tables and

certain parts thereof, commensurate with the scope of the investigation.13

No new facts have been presented to warrant a conclusion regarding the domestic like product

that is different from the domestic like product identified in the Commission’s original investigation. 

Moreover, HPI and the other interested parties have indicated that they agree with the Commission’s

definition of the domestic like product in the original investigation.14 Therefore, we find that the

appropriate definition of the domestic like product in this full five-year review is ironing tables and

certain parts thereof, the same as Commerce’s scope and unchanged from the Commission’s original

determination.

III. DOMESTIC INDUSTRY

Section 771(4)(A) of the Act defines the relevant industry as the domestic “producers as a whole

of a domestic like product, or those producers whose collective output of a domestic like product

 11 Floor-Standing Metal-Top Ironing Tables and Certain Parts Thereof from the People’s Republic from China: 

Final Results of Expedited Five-Year (Sunset) Review of Antidumping Duty Order, 74 Fed. Reg. 56794, 56794-95

(November 3, 2009). 

 12 CR at I-15 to I-16, PR at I-9.

 13 Original Investigation at 11. In the preliminary phase of the original investigation, the Commission determined

that there was one domestic like product consisting of floor-standing, metal-top ironing tables, coextensive with the

scope. Ironing Tables and Components Thereof from China, Inv. No. 731-TA-1047 (Preliminary), USITC Pub.

3623 (August 2003), at 5. In the final phase of the original investigation, Commission staff gathered data pertaining

to over-the-door, wall-mounted, and countertop boards. Original Investigation, USITC Pub. 3711, at 8. The

Respondents in the original investigation had argued that the Commission should expand the domestic like product

beyond the scope of the investigation to include over-the-door boards. In the final determination, however, the

Commission again found one domestic like product, co-extensive with the scope. Id. at 4-11.

 14 HPI’s Response to the Notice of Institution at 39 and Prehearing Brief at 9; Polder Response to the Notice of

Institution at 8; Whitney Design Response to the Notice of Institution at 9; and Since Hardware Response to the

Notice of Institution at 7.

5
constitutes a major proportion of the total domestic production of the product.”15 In defining the domestic

industry, the Commission’s general practice has been to include in the industry producers of all domestic

production of the like product, whether toll-produced, captively consumed, or sold in the domestic

merchant market. Section 771(4)(B) of the Act, the related parties provision, allows the Commission to

exclude certain domestic producers from the domestic industry that import subject merchandise or have a

corporate affiliation with importers or exporters of subject merchandise, if the Commission finds that

appropriate circumstances exist.16

In its original determination, the Commission defined the domestic industry as all domestic

producers of ironing tables.17 During the period examined in the current review, there is no new evidence

to warrant a change in the definition of the domestic industry, and no party has raised an objection to the

domestic industry definition from the original investigation.18 Therefore, based on our definition of the

domestic like product, we define the domestic industry to include all U.S. producers of the domestic like

product.19

IV. LIKELIHOOD OF CONTINUATION OR RECURRENCE OF MATERIAL INJURY IF

THE ANTIDUMPING DUTY ORDER IS REVOKED

A. Legal Standard

In a five-year review conducted under section 751(c) of the Act, Commerce will revoke an

antidumping or countervailing duty order unless (1) it makes a determination that dumping or

subsidization is likely to continue or recur and (2) the Commission makes a determination that revocation

of the antidumping or countervailing duty order “would be likely to lead to continuation or recurrence of

material injury within a reasonably foreseeable time.”20 The SAA states that “under the likelihood

standard, the Commission will engage in a counterfactual analysis; it must decide the likely impact in the

reasonably foreseeable future of an important change in the status quo – the revocation or termination of a

 15 19 U.S.C. § 1677(4)(A). The definitions in 19 U.S.C. § 1677 are applicable to the entire subtitle containing the

antidumping and countervailing duty laws, including 19 U.S.C. §§ 1675 and 1675a. See 19 U.S.C. § 1677.

 16 19 U.S.C. § 1677 (4)(B).

 17 Original Investigation at 12-13. In the original investigation, both domestic producers, HPI and Whitney

Design, were related parties, as defined in the statute, because they imported subject merchandise during the period

examined. The Commission found, however, that appropriate circumstances did not exist to exclude either producer

from the domestic industry. Id.

 18 19 U.S.C. § 1677(4)(B). The Respondents alleged, solely in their discussion of conditions of competition, that

HPI is either an importer of the subject merchandise or has facilitated the importation of subject merchandise as a

purchaser for a third party in the United States through an agreement with a Chinese producer. See, e.g.,

Respondents’ Prehearing Brief at 1-4 and Posthearing Brief at 3-5. Although there is a ***, there is no evidence on

the record that HPI imported subject merchandise or that HPI was the importer of record for subject merchandise

during the period examined other than the ***. Rather, HPI is sourcing nonsubject merchandise, such as ***, from

***. CR/PR at Table III-5; see also HPI Posthearing Brief at Exhibit 2 and Answers to Questions from the

Commission (Chairman Aranoff and Commissioners Lane, Okun, and Williamson) at A-13 to A-14.

 19 HPI imported a *** quantity of subject merchandise *** and, therefore, is a related party under the statute. We

find, however, that appropriate circumstances do not exist to exclude HPI from the domestic industry as a related

party. HPI imported *** quantities of the subject merchandise ***, representing only *** percent of its production

in that year, and has not imported any subject merchandise since that time. Thus, its interest appears to be in

domestic production rather than importation of the subject merchandise. In addition, HPI is the sole remaining

domestic producer and supports the continuation of the order. CR/PR at Table I-5.

 20 19 U.S.C. § 1675a(a).

6
proceeding and the elimination of its restraining effects on volumes and prices of imports.”21 Thus, the

likelihood standard is prospective in nature.22 The U.S. Court of International Trade has found that

“likely,” as used in the five-year review provisions of the Act, means “probable,” and the Commission

applies that standard in five-year reviews.23 24 25

The statute states that “the Commission shall consider that the effects of revocation or termination

may not be imminent, but may manifest themselves only over a longer period of time.”26 According to

the SAA, a “‘reasonably foreseeable time’ will vary from case-to-case, but normally will exceed the

‘imminent’ timeframe applicable in a threat of injury analysis in original investigations.”27

Although the standard in a five-year review is not the same as the standard applied in an original

antidumping duty investigation, it contains some of the same fundamental elements. The statute provides

that the Commission is to “consider the likely volume, price effect, and impact of imports of the subject

merchandise on the industry if the orders are revoked or the suspended investigation is terminated.”28 It

directs the Commission to take into account its prior injury determination, whether any improvement in

the state of the industry is related to the order or the suspension agreement under review, whether the

industry is vulnerable to material injury if the orders are revoked or the suspension agreement is

terminated, and any findings by Commerce regarding duty absorption pursuant to 19 U.S.C.§

 21 SAA at 883-84. The SAA states that “{t}he likelihood of injury standard applies regardless of the nature of the

Commission’s original determination (material injury, threat of material injury, or material retardation of an

industry). Likewise, the standard applies to suspended investigations that were never completed.” Id. at 883.

 22 Although the SAA states that “a separate determination regarding current material injury is not necessary,” it

indicates that “the Commission may consider relevant factors such as current and likely continued depressed

shipment levels and current and likely continued {sic} prices for the domestic like product in the U.S. market in

making its determination of the likelihood of continuation or recurrence of material injury if the order is revoked.” 

SAA at 884.

 23 See NMB Singapore Ltd. v. United States, 288 F. Supp. 2d 1306, 1352 (Ct. Int’l Trade 2003) (“‘likely’ means

probable within the context of 19 U.S.C. § 1675(c) and 19 U.S.C. § 1675a(a)”), aff’d mem., 140 Fed. Appx. 268

(Fed. Cir. 2005); Nippon Steel Corp. v. United States, 26 CIT 1416, 1419 (2002) (same); Usinor Industeel, S.A. v.

United States, 26 CIT 1402, 1404 nn.3, 6 (2002) (“more likely than not” standard is “consistent with the court’s

opinion”; “the court has not interpreted ‘likely’ to imply any particular degree of ‘certainty’”); Indorama Chemicals

(Thailand) Ltd. v. United States, Slip Op. 02-105 at 20 (Ct. Int’l Trade Sept. 4, 2002) (“standard is based on a

likelihood of continuation or recurrence of injury, not a certainty”); Usinor v. United States, 26 CIT 767, 794 (2002)

(“‘likely’ is tantamount to ‘probable,’ not merely ‘possible’”).

 24 For a complete statement of Commissioner Okun’s interpretation of the likely standard, see Additional Views

of Vice Chairman Deanna Tanner Okun Concerning the “Likely” Standard in Certain Seamless Carbon and Alloy

Steel Standard, Line and Pressure Pipe From Argentina, Brazil, Germany, and Italy, Invs. Nos. 701-TA-362

(Review) and 731-TA-707 to 710 (Review)(Remand), USITC Pub. 3754 (Feb. 2005).

 25 Commissioner Lane notes that, consistent with her views in Pressure Sensitive Plastic Tape From Italy, Inv.

No. AA1921-167 (Second Review), USITC Pub. 3698 (June 2004), she does not concur with the U.S. Court of

International Trade’s interpretation of “likely,” but she will apply the Court’s standard in these reviews and all

subsequent reviews until either Congress clarifies the meaning or the U.S. Court of Appeals for the Federal Circuit

addresses this issue.

 26 19 U.S.C. § 1675a(a)(5).

 27 SAA at 887. Among the factors that the Commission should consider in this regard are “the fungibility or

differentiation within the product in question, the level of substitutability between the imported and domestic

products, the channels of distribution used, the methods of contracting (such as spot sales or long-term contracts),

and lead times for delivery of goods, as well as other factors that may only manifest themselves in the longer term,

such as planned investment and the shifting of production facilities.” Id.

 28 19 U.S.C. § 1675a(a)(1).

7
1675(a)(4).29 The statute further provides that the presence or absence of any factor that the Commission

is required to consider shall not necessarily give decisive guidance with respect to the Commission’s

determination.30

In evaluating the likely volume of imports of subject merchandise if the orders under review are

revoked and the suspended investigations are terminated, the Commission is directed to consider whether

the likely volume of imports would be significant either in absolute terms or relative to production or

consumption in the United States.31 In doing so, the Commission must consider “all relevant economic

factors,” including four enumerated factors: (1) any likely increase in production capacity or existing

unused production capacity in the exporting country; (2) existing inventories of the subject merchandise,

or likely increases in inventories; (3) the existence of barriers to the importation of the subject

merchandise into countries other than the United States; and (4) the potential for product shifting if

production facilities in the foreign country, which can be used to produce the subject merchandise, are

currently being used to produce other products.32

In evaluating the likely price effects of subject imports if the orders and finding under review

were revoked, the Commission is directed to consider whether there is likely to be significant underselling

by the subject imports as compared to the domestic like product and whether the subject imports are

likely to enter the United States at prices that otherwise would have a significant depressing or

suppressing effect on the price of the domestic like product.33

In evaluating the likely impact of imports of subject merchandise if the orders and finding under

review are revoked, the Commission is directed to consider all relevant economic factors that are likely to

have a bearing on the state of the industry in the United States, including but not limited to the following: 

(1) likely declines in output, sales, market share, profits, productivity, return on investments, and

utilization of capacity; (2) likely negative effects on cash flow, inventories, employment, wages, growth,

ability to raise capital, and investment; and (3) likely negative effects on the existing development and

production efforts of the industry, including efforts to develop a derivative or more advanced version of

the domestic like product.34 All relevant economic factors are to be considered within the context of the

business cycle and the conditions of competition that are distinctive to the industry. As instructed by the

statute, we have considered the extent to which any improvement in the state of the domestic industry is

related to the order at issue and whether the industry is vulnerable to material injury if the order were

revoked.35

When appropriate in this review, we have relied on the facts otherwise available, which consist of

information from the original investigation and information submitted in this review, including

 29 19 U.S.C. § 1675a(a)(1). We note that no duty absorption findings have been made by Commerce.

 30 19 U.S.C. § 1675a(a)(5). Although the Commission must consider all factors, no one factor is necessarily

dispositive. SAA at 886.

 31 19 U.S.C. § 1675a(a)(2).

 32 19 U.S.C. § 1675a(a)(2)(A-D).

 33 See 19 U.S.C. § 1675a(a)(3). The SAA states that “{c}onsistent with its practice in investigations, in

considering the likely price effects of imports in the event of revocation and termination, the Commission may rely

on circumstantial, as well as direct, evidence of the adverse effects of unfairly traded imports on domestic prices.” 

SAA at 886.

 34 19 U.S.C. § 1675a(a)(4).

 35 The SAA states that in assessing whether the domestic industry is vulnerable to injury if the order is revoked,

the Commission “considers, in addition to imports, other factors that may be contributing to overall injury. While

these factors, in some cases, may account for the injury to the domestic industry, they may also demonstrate that an

industry is facing difficulties from a variety of sources and is vulnerable to dumped or subsidized imports.” SAA at

885.

8
information provided by the domestic industry, the respondent interested parties, questionnaire responses,

and information available from published sources.36 37

B. Conditions of Competition and Business Cycle

In evaluating the likely impact of the subject imports on the domestic industry, the statute directs

the Commission to consider all relevant economic factors “within the context of the business cycle and

conditions of competition that are distinctive to the affected industry.”38

1. The Commission’s Original Determination

In the original investigation, the Commission found several conditions of competition pertinent to

its analysis. With respect to demand, the Commission found that the market for ironing tables was

relatively stable over the period examined, that the market was described as mature with only modest

growth, and that the overall demand for ironing tables was likely to exhibit little change in response to

changes in price.39 The Commission found that far more lower-priced than higher-priced models entered

the U.S. market, with more than three-quarters of U.S. consumption over the period examined reportedly

in the opening price point category.40 In addition, the Commission found increased concentration among

buyers as the number of retail purchasers fell over the period examined, with only a few mass

merchandisers dominating direct sales to consumers.41

With respect to supply, the Commission found that the domestic industry’s share of the market

declined steadily and significantly between 2001 and 2003.42 The Commission found that one U.S.

producer, HPI, closed a plant and consolidated production, while the other U.S. producer, Whitney

Design, closed its U.S. production facility during the period examined. Nonetheless, the Commission

found that the domestic industry still had *** capacity to supply the U.S. market. Subject imports,

 36 19 U.S.C. § 1677e(a) authorizes the Commission to “use the facts otherwise available” in reaching a

determination when (1) necessary information is not available on the record or (2) an interested party or any other

person withholds information requested by the agency, fails to provide such information in the time or in the form or

manner requested, significantly impedes a proceeding, or provides information that cannot be verified pursuant to 19

U.S.C. § 1677m(i). The verification requirements in 19 U.S.C. § 1677m(i) are applicable only to Commerce. See

Titanium Metals Corp. v. United States, 155 F. Supp. 2d 750, 765 (Ct. Int’l Trade 2002) (“the ITC correctly

responds that Congress has not required the Commission to conduct verification procedures for the evidence before

it, or provided a minimum standard by which to measure the thoroughness of Commission investigations.”).

 37 Commissioner Okun notes that the statute authorizes the Commission to take adverse inferences in five-year

reviews, but such authorization does not relieve the Commission of its obligation to consider the record evidence as

a whole in making its determination. See 19 U.S.C. § 1677e. She generally gives credence to the facts supplied by

the participating parties and certified by them as true, but bases her decision on the evidence as a whole, and does

not automatically accept participating parties’ suggested interpretations of the record evidence. Regardless of the

level of participation, the Commission is obligated to consider all evidence relating to each of the statutory factors

and may not draw adverse inferences that render such analysis superfluous. “In general, the Commission makes

determinations by weighing all of the available evidence regarding a multiplicity of factors relating to the domestic

industry as a whole and by drawing reasonable inferences from the evidence it finds most persuasive.” SAA at 869.

 38 19 U.S.C. § 1675a(a)(4).

 39 Original Investigation at 13-14.

 40 Original Investigation at 14.

 41 Original Investigation at 14-15.

 42 Original Investigation at 15-16.

9
however, captured nearly *** of the U.S. market in 2003 compared to *** percent in 2001.43 The

Commission found that sales of nonsubject ironing tables were almost nonexistent and consisted mostly

of higher-value products.44

The Commission found that there was a relatively high degree of substitutability between

domestic ironing tables and the subject imports, with the vast majority of all market participants reporting

that they were always interchangeable.45

2. The Current Review

We find the following conditions of competition relevant to our determination.

a. Demand

Overall U.S. demand for ironing tables moves in tandem with general economic activity in the

U.S. economy, and with household formation and home purchases in particular.46 U.S. demand for

ironing tables also exhibits some seasonal variation and is subject to cyclical fluctuations.47 As a

consumer durable good, ironing table purchases are often deferrable and, as such, tend to fall during

economic downturns.48

 Market participants provided mixed responses when asked whether demand had increased,

decreased, fluctuated, or remained the same since January 2004, but most frequently indicated there had

been no change.49 The demand for ironing tables as measured by apparent U.S. consumption fluctuated

over the period examined, but decreased overall from *** units in 2004 to *** units in 2009. This

downturn in demand was particularly strong in 2009, when apparent U.S. consumption fell by ***

percent from the previous year.50 With respect to future demand, the majority of market participants

expected no change.51

 43 Original Investigation, Confidential Staff Report, INV-BB-087 (July 2, 2004), at Table C-1.

 44 Original Investigation at 15.

 45 Original Investigation at 16.

 46 Original Investigation at II-3, fn. 9.

 47 Retailer demand is reportedly high during the summer months, reflecting new household formation and backto-college purchases, and household consumer demand is high during the summer and into the fall, with some

increase in consumer demand also during March-April, when care for clothes reportedly increases. Retailer and

consumer demand tend to be low after the back-to-college purchases, particularly during October-December,

including the Christmas holiday season. CR at II-16, PR at II-10.

 48 Demand for consumer durable goods, especially at the higher price points, has a tendency to be income elastic. 

An exception may be that some consumers may purchase ironing tables in an economic downturn as a substitute for

more expensive dry cleaning services. See Hearing Transcript at 142-143 (Cooper and Scott). Such countercyclical

demand is likely a small part of total demand for ironing tables. CR at II-15 and n.28, PR at II-9 and n.28. 

Replacement demand is also likely a small part of total demand for ironing tables, as consumers replace them

infrequently. CR at II-15 and n.27, PR at II-9 and n.27.

 49 CR at II-19, PR at II-12 to 11-13.

 50 CR/PR at Table C-1.

 51 CR at II-19, PR at II-12 to II-13.

10
Ironing tables reportedly are sold in as many as five different retail price point categories.52 More

than three quarters of ironing tables consumed in the United States reportedly are in the “opening price

point” category.53 During the period examined, U.S. imports of ironing tables from China were

exclusively mesh-top, while the majority of domestic ironing tables were perforated-top.54 Although HPI

has the capability to produce both mesh-top and perforated-top tables, the ***.55 Chinese manufacturers,

by contrast, reportedly produce only mesh-top ironing tables using a labor-intensive production process.56

Direct shipments of ironing tables during the period were principally to retailers, followed by

commercial users and distributors.57 The largest purchasers of ironing tables during the period examined

were ***, with each retailer purchasing more than *** ironing tables during the period.58 Retailers sold

their ironing tables almost exclusively to household consumers. Commercial users consist primarily of

the hospitality industry, where ironing tables are used in hotels and motels by travelers, and healthcare

facilities.59 Purchasers most frequently identified Walmart and Target as retail price leaders in the U.S.

market.60

b. Supply

HPI is currently the only domestic producer of ironing tables.61 The domestic industry’s annual

capacity was unchanged from 2004 to 2009 at *** units.62 The industry’s share of the U.S. market

fluctuated between a low of *** percent and a high of *** percent.63 Subject imports’ share fluctuated

between a low of *** percent and a high of *** percent.64 Nonsubject import’s market share fell in each

 52 CR at I-15, PR at I-9. HPI describes the “value” or “opening price point” T-leg table as a perforated-top or a

mesh-top table costing $18 or less; a “good” table as generally a mesh-top 4-leg table with an optional iron rest

costing $18 to $28; a “better” table as a heavy duty mesh-top 4-leg table with an added feature, such as an iron rest,

costing $28 to $40; a “best” table as a wide-top mesh-top, heavy duty/professional 4-leg ironing table with added

features, such as an iron rest and linen rack, costing $40 to $70; and a “specialty” table as one with a wide top and

such features as an extension cord, wheels, or other special finishes. CR at I-15, PR at I-9.

 53 CR at I-15, PR at I-9.

 54 CR at I-15, PR at I-9 and CR/PR at Tables V-1 through V-6, presenting the relative sales volumes of mesh-top

and perforated-top ironing tables. ***. CR at I-16, PR at I-9 to I-10.

 55 CR at I-15, PR at I-9.

 56 CR at I-15, PR at I-9.

 57 CR/PR at II-1 and Table II-1. Twelve of 13 purchasers responding to the Commission’s questionnaires were

retailers and one was a distributor. CR/PR at II-2 n.4

 58 CR/PR at Table II-2. These retailers account for approximately *** percent of the reported purchases of

ironing tables at the wholesale level in the United States during the period examined. Calculated from CR/PR at

Table II-2. *** combined account for ***. Id.; see also HPI Final Comments (May 27, 2010) at 9. 

 59 U.S. Producer and Importer Questionnaire Responses at sections IV-21a and III-22a, respectively.

 60 CR/PR at II-1.

 61 CR/PR at Table I-5.

 62 CR/PR at Table C-1.

 63 CR/PR at Table C-1. The domestic industry’s market share was *** percent in 2004, *** percent in 2005, ***

percent in 2006, *** in 2007, *** percent in 2008, and *** percent in 2009. Id.

 64 CR/PR at Table C-1. Subject imports’ market share was *** percent in 2004, *** percent in 2005, *** percent

in 2006, *** percent in 2007, *** in 2008, and *** percent in 2009. Id.

11
year of the period examined after 2005.65 By 2009, nonsubject imports accounted for only *** percent of

apparent U.S. consumption.66

c. Other Conditions

There is a high degree of substitutability between domestically produced ironing tables and the

subject imports.67 Responding wholesale purchasers listed price and quality as the most important factors

affecting their ironing table purchasing decisions.68

Raw material costs account for a substantial share of the cost of goods sold (“COGS”) for ironing

tables.69 The principal raw material input is cold-rolled steel sheet. Reported quarterly prices for coldrolled sheet fluctuated over the period examined, increasing from January-March 2004 to July-September

2008, before decreasing through July-September 2009, and then increasing again in October-December

2009.70

Based on the evidence in the record of this five-year review, we find that conditions of

competition in the ironing table market are not likely to change significantly in the reasonably foreseeable

future. Accordingly, we find that current conditions in the market provide us with a reasonable basis on

which to assess the likely effects of revocation of the orders in the reasonably foreseeable future.

C. Likely Volume of Subject Imports

1. The Commission’s Original Determination

In the original investigation, the Commission found that the volume and market share of subject

imports increased substantially throughout the period of investigation. The Commission found that the

quantity of subject imports nearly quadrupled in terms of quantity and nearly tripled in terms of value

between 2001 and 2003. Although subject imports declined in interim 2004, the Commission attributed

the decline to the filing of the petition and the imposition of provisional duties in February 2004. The

Commission also found that subject imports’ market share increased dramatically between 2001 and

2003, rising nearly *** percentage points in terms of quantity and value.71 The domestic industry’s share

of apparent U.S. consumption fell from *** percent to *** percent in 2003 and the Commission found

that this loss was entirely due to subject imports. Finally, moderate price declines did not significantly

 65 Nonsubject imports’ market share was *** percent in 2004, *** percent in 2005, *** percent in 2006, ***

percent in 2007, *** percent in 2008, and *** percent in 2009. CR/PR at Table C-1.

 66 CR at IV-2, PR at IV-1 to IV-2. Responding U.S. importers identified the following nonsubject countries as

sources of ironing tables imported into the U.S. market: Germany, India, Italy, Latvia, Spain, Taiwan, and The

Netherlands. CR at II-14, PR at II-9. Some importers noted the presence of ironing tables from Taiwan in the U.S.

market. Participating interested parties, however, were not able to identify any producers of metal-top ironing tables

in Taiwan. Id. and HPI’s Answers to Questions from the Commission (Commissioner Pinkert) at A-39 to A-40.;

Hearing Transcript at 141 (Scott).

 67 CR at II-29, PR at II-19. Responding market participants generally reported that domestic ironing tables and

those imported from China and third countries were “always” or “frequently” interchangeable. CR/PR at Table II-4. 

 68 CR at II-27 to II-28 and n.58, PR at II-18 and n.58; and CR/PR at Table II-3.

 69 Total raw material costs averaged almost *** percent of COGS during the period examined. CR/PR at V-1.

 70 CR at III-10, PR at III-5; and CR/PR at V-1 and Figure V-1. HPI’s quarterly purchase prices of cold-rolled

steel sheet increased from $*** per pound during January-March 2004 to *** per pound by July-September 2008, an

increase of *** percent, before decreasing to *** per pound by July-September 2009 and ending at $*** per pound

during October-December 2009. U.S. Producer Questionnaire Response at section IV-24.

 71 Original Investigation at 17-18.

12
increase purchases over the period examined due to the long-lasting nature of ironing tables as a durable

good. Consequently, the Commission determined that the increased volumes of subject imports at lessthan-fair value had taken market share from the remaining domestic producer, rather than resulting in

increased domestic consumption.72

The Commission found that both perforated-top and mesh-top ironing tables were purchased by

large customers, and that HPI produced both types and had capacity to produce substantially higher

volumes.73 In addition, the Commission found that Whitney Design had sought and gained additional

customers for its subject imports.74 Nevertheless, the Commission found that a large portion of the

increase in subject import volume during the period was not attributable to Whitney Design’s shift from

domestic producer to subject importer because Whitney Design accounted for *** of total imports and its

total share of subject imports was much lower in 2003 than in 2001. Moreover, the Commission found

that a large purchaser increased its imports of mesh-top ironing tables during the period.

Consequently, the Commission found both the volume and increase in volume of subject imports

to be significant, both in absolute terms and relative to consumption and production in the United States.

2. The Current Review

 Several factors support the conclusion that the subject import volume is likely to be significant in

the event of revocation of the order.

Substantial volumes of subject imports have been present in the U.S. market over the period

examined even with the order in place. Subject imports were *** units in 2004, *** units in 2005, ***

units in 2006, *** units in 2007, *** units in 2008, and *** units in 2009.75 Subject imports’ market

share was *** percent in 2004, *** percent in 2005, *** percent in 2006, *** percent in 2007, ***

percent in 2008, and *** percent in 2009.76

The record contains data only for part of the Chinese industry.77 Thus, the record data on

Chinese production, production capacity, and shipments are likely substantially understated. However,

the Chinese producers responding to the Commission’s questionnaires have considerable production

capacity and unused capacity. Chinese producers’ reported capacity was *** units in 2004, *** units in

2005, *** units in 2006, *** units in 2007, *** units in 2008, and *** units in 2009.78 The reported

production capacity in 2009 is *** apparent U.S. consumption for that year.79 Chinese producers’

 72 Original Investigation at 18.

 73 Original Investigation at 18-19.

 74 Original Investigation at 20.

 75 CR/PR at Table IV-1. U.S. shipments of subject imports were *** units in 2004, *** units in 2005, *** units

in 2006, *** units in 2007, *** units in 2008, and *** units in 2009. CR/PR at Table C-1.

 76 CR/PR at Table C-1.

 77 As noted above, six of the 31 known Chinese producers of ironing tables responded to the Commission’s

foreign producer questionnaires. During the period, *** were the largest producers of ironing tables in China to

provide data. Proprietary Customs data indicate that ***. CR at IV-5, PR at IV-3.

This is consistent with the companies’ respective antidumping duty margins resulting from administrative

reviews by Commerce during the review period. Since Hardware’s original duty rate was 9.47 percent, and it

received a de minimis rate in 2007. In an administrative review completed in 2007, Foshan Shunde received a rate

of 2.37 percent (it had previously been 157.68 percent). Both companies exported significant volumes to the United

States under these relatively low rates. However, in 2009 and 2010, Commerce determined that Since Hardware and

Foshan Shunde, respectively, had submitted inaccurate and unreliable data, and imposed the China-wide rate of

157.68 percent on both companies. CR/PR at Table I-2, nn. 2 and 3.

 78 CR/PR at Table IV-3.

 79 CR/PR at Tables IV-3 and C-1.

13
reported capacity utilization fluctuated between 81.0 and 88.9 percent between 2004 to 2008, then fell to

70.7 percent in 2009.80 The Chinese industry’s reported capacity utilization rate, especially in 2009,

indicates that available capacity exists in China to increase production of ironing tables if the antidumping

duty order were revoked.81

The Chinese industry is highly export-oriented, with exports as a share of total shipments ranging

between *** and *** percent between 2004 and 2009.82 The United States remained a significant market

for Chinese exports over the period of review, accounting for between *** and *** percent of shipments. 

The European Union was the largest market, accounting for between *** and *** percent of shipments. 

The home market accounted for *** percent of shipments.83

The United States is a very important market for Chinese producers. The Chinese industry

continues to maintain a substantial presence in the U.S. market during the period of review despite the

order, and Chinese producers have established business relationships with U.S. purchasers of ironing

tables that would enable them to increase shipments to the United States substantially in the event of

revocation of the order.84 The Chinese industry now faces a significant barrier in its other main market,

the EU.85 In April 2007, the EU imposed definitive antidumping duties on imports of Chinese ironing

tables at margins ranging from 18.1 percent to 38.1 percent.86

Finally, end-of-period inventories of ironing tables held by producers in China increased steadily

over the period examined and were markedly higher in 2009 than in 2004.87

Based on the rapid increase of subject imports and their market share during the original

investigation, the substantial volumes of subject imports present during the period examined despite the

order, the substantial production capacity, excess capacity, and export-orientation of the Chinese industry,

the importance of the U.S. market to Chinese producers, the EU antidumping order, and Chinese

producers’ inventories, we find that Chinese producers would have the ability and incentive to ship

significant volumes of additional exports to the United States if the order were revoked. Therefore, we

find that the likely volume of subject imports, both in absolute terms and relative to production and

consumption in the United States, would be significant if the order were revoked.

 80 CR/PR at Table IV-3.

 81 We note that Chinese producer *** reported purchasing new machinery related to the production of ironing

tables during the period examined. CR at IV-6 n.12, PR at IV-4 n.12 and ***. In addition, two Chinese producers,

***, reported production of nonsubject merchandise on the same equipment used to produce subject ironing tables. 

CR at IV-6, PR at IV-4. Thus, there is a potential for these producers to shift production from nonsubject

merchandise to ironing tables.

 82 CR/PR at Table IV-3.

 83 CR/PR at Table IV-3.

 84 HPI Prehearing Brief at 34. See also CR at D-8 to D-9 and D-13, PR at D-3 and D-4 (***).

 85 The European Union is believed to be the largest non-U.S. market for ironing tables, with consumption of 8.6

million units in 2005. CR at IV-10 and n.20, PR at IV-6 and n.20.

 86 CR at IV-8 to IV-9, PR at IV-6. Although Since Hardware was originally given a zero percent duty, the EU

initiated another antidumping proceeding on this producer in October 2009; this proceeding is ongoing. The EU

announced in December 2009 that Foshan Shunde was no longer subject to antidumping duties due to a judgment by

the Court of Justice of the European Communities. However, the EU has reopened the investigation with respect to

Foshan Shunde. Id.

 87 Inventories held by Chinese producers were 136,000 units in 2004, 158,000 units in 2005, 173,000 units in

2006, 224,000 units in 2007, 215,000 units in 2008, and 359,000 units in 2009. CR/PR at Table IV-3. End-of-period

inventories of subject imports held by U.S. importers increased from *** units in 2004 to *** units in 2007, then

decreased to *** units in 2008 and *** units in 2009. CR/PR at Table IV-2.

14
D. Likely Price Effects of Subject Imports

1. The Commission’s Original Determination

In the original investigation, the Commission found that the domestic like product and subject

imports were interchangeable and that price was the most important factor in purchasing decisions. The

Commission found there was a concentration of purchasers at the wholesale level, with approximately

*** percent of the ironing tables sold to only three customers; these few large buyers could negotiate

lower prices, and lower retail pricing by one may have resulted in widespread downward retail pricing

that, in turn, may have resulted in downward pressure on wholesale prices.88

The Commission found a wide range of prices between the opening price point and the various

higher priced models, with mesh-top ironing tables historically more expensive than perforated-top

ironing tables. The Commission collected pricing data on two products – perforated-top T-leg ironing

tables and mesh-top T-leg ironing tables (the former was the predominant product of the domestic

industry and was not produced by the Chinese industry, the latter was produced by both). The

Commission found price comparisons between domestic and imported mesh-top tables to be more

probative than comparisons between perforated-top domestic tables and subject imported mesh-top

ironing tables.89

Pricing data showed that prices for Chinese mesh-top T-leg ironing tables were generally higher

than those for comparable domestic product through the first quarter of 2002. Thereafter, the Chinese

tables were priced lower than domestic product as subject import volumes rose and subject import prices

fell. The Commission found significant underselling for this product, particularly in light of the large

increase in import volumes in 2003.90

The Commission found that the evidence regarding internet reverse sales and lost sales and

revenues indicated that subject imports of mesh-top tables were overtaking the market previously

dominated by domestic perforated-top tables, and were doing so by underselling and driving prices

lower.91 Given that more than 75 percent of domestic consumption reportedly was in the opening price

point category and the majority of HPI’s sales into this category were perforated-top ironing tables, the

Commission found significant price depression based on the product specific data as well as other

information in the record, including information in the internet reverse auctions and lost sales and

revenues.92

As a result, the Commission concluded that there had been significant price underselling by the

subject imports and that the effect of such imports had been to depress prices for the domestic like

product to a significant degree.93

 88 Original Investigation at 21.

 89 Original Investigation at 21-22.

 90 Original Investigation at 23.

 91 Original Investigation at 23.

 92 Original Investigation at 25.

 93 Original Investigation at 26.

15
2. The Current Review

As stated above, more than *** percent of reported purchases of ironing tables at the wholesale

level during the period of review were made by only five customers – *** – who purchase ironing tables

with an intent to sell them at retail.94

Chinese and domestic ironing tables are interchangeable and price is an important factor in

purchasing decisions. There is a wide range of prices at the retail level between the opening price point

(generally $18 or less) and the various higher priced models (up to $70 or more).95 The Commission

collected pricing data on six products with pad and cover, but without additional equipment96- two

perforated-top T-leg models with different leg thicknesses and weight (products 1 and 2), two mesh-top

T-leg models with different leg thicknesses and weight (products 3 and 4), and two mesh-top four leg

models with different leg thicknesses and weight (products 5 and 6).97 Domestic product prices were

reported for products 1, 3, and 5, and subject import prices were reported for products 3 through 6. 

Quarterly prices of two of the three domestic products and of the four subject imported products

fluctuated, but generally increased during the period. A total of 48 quarterly price comparisons, involving

unbundled sales,98 were possible for products 3 and 5. Subject imports undersold the domestic product in

four of these comparisons with margins ranging from *** percent to *** percent. In forty-three other

comparisons, subject imports oversold the domestic product.99

We have taken several factors into consideration in evaluating these pricing data. First, these

prices are for a period when the order was in effect, which would be expected to increase subject import

prices. Second, U.S. importer *** included in its pricing data for product 3 (a lighter-weight mesh-top Tleg ironing table) sales data for a reportedly competitive *** model that, in certain configurations,

included features characteristic of ironing tables sold in higher retail price point categories.100 This

product accounted for a significant share of reported importer sales of product 3. We believe that the

higher prices of the imported *** product 3 may have caused the overall product 3 price data to be

unrepresentative of actual price competition for this product during the period examined.101

Third, *** purchaser of ironing tables,102 is a direct importer of the subject merchandise. *** for

product 3 and product 5 were lower than domestic selling prices for these products in *** of ***

quarterly comparisons. *** are not directly comparable to domestic prices.103 Nonetheless, in ***

 94 Calculated from CR/PR at Table II-2. *** collectively represent approximately *** percent of reported

purchases of ironing tables at the wholesale level. Id.

 95 *** where price competition is most intense. Approximately *** percent of its sales are of ***, and

approximately *** percent of its sales are of ***. U.S. Producer Questionnaire Response at section IV-5.

 96 The six ironing table products may include an iron rest or linen rack, but no equipment extraneous to the

ironing table, such as an iron. CR at V-12 n.15, PR at V-7 n.15

 97 CR at V-12, PR at V-7 to V-8.

 98 Bundled sales of ironing tables occur when ironing tables and other products, such as irons and other laundry

items, are sold as a group under a bundled (combined) price; prices of the different items may be specified, but are

not independently determined. CR at V-5 n.10, PR at V-3 n.10.

 99 CR at V-30, PR at V-14 and CR/PR at Table V-8. There was one price comparison with equal prices.

 100 CR at V-30 n.31, PR at V-14 n.31; CR at I-15, PR at I-9.

 101 See, e.g., HPI Final Comments at 8.

 102 CR/PR at Table II-2.

 103 *** initially indicated that its reported price data for the firm's direct imports of ironing tables from China

were the requested import prices based on landed (c.i.f), duty-paid, U.S. ports-of-entry values. However, after

further review, *** reported that the data were the foreign invoice values, f.o.b. the Chinese factory. CR at V-13 to

V-14 and V-32, PR at V-8 to V-9 and V-15. These invoice prices in China are not directly comparable to domestic

16
instances, these foreign f.o.b. values were *** percent or more below domestic prices for comparable

products.104

Finally, sales by *** of imported price product 4 (a heavier-weight, mesh-top T-leg ironing table)

were *** lower-priced than domestic sales of product 3, a lighter-weight, mesh-top T-leg ironing table.105

Normally, a heavier-weight ironing table would be expected to be priced higher than a comparable

lighter-weight ironing table, particularly where the primary raw material in the production of ironing

tables, cold-rolled steel sheet, comprises a significant portion of the unit manufacturing cost. Given these

considerations, we place only limited weight on the price comparison data for the period examined.

Based on the finding of significant underselling during the original investigation, the significant

likely volumes of subject imports if the order were revoked, the nature of the product and the market, in

particular the importance of price to the purchasing decisions, the high degree of price competition

between the domestic like product and the subject imports, and the substantial influence over U.S. prices

as well as the buying market power exercised by the few large wholesale customers, we find that the

subject imports from China likely would significantly undersell the domestic like product to gain market

share and likely would have significant depressing or suppressing effects on the prices of the domestic

like product if the order were revoked.

E. Likely Impact of Subject Imports106

1. The Commission’s Original Determination

In the original investigation, the Commission found that the exit of Whitney Design from the

industry in April 2002 significantly reduced domestic production capacity. Even accounting for this

development, the Commission found that the data for HPI, the sole domestic producer after April 2002,

indicated that production and capacity utilization decreased significantly between 2001 and 2003. 

Although the domestic industry’s end-of-period inventories fluctuated over the period and remained

steady when comparing 2003 with 2001, the Commission found that the ratio of inventories to production

and U.S. shipments *** between 2001 and 2003.

prices because they do not include the costs to ship and land ironing tables in the U.S. market, including costs of

freight, insurance, loading and off-loading, import duties, and customs clearance.

 104 CR at V-32 and n.36, PR at V-15 and n.36. Based on official statistics, charges, insurance, and freight costs for

all U.S. imports of ironing tables from China averaged 18.8 percent of the Customs value from 2004 to 2009. ***

reported that the difference between its costs f.o.b. China and its U.S. landed cost averaged *** percent over the

same period. CR at V-14 and n.24, PR at V-9 and n.24.

 105 CR at V-32 n.34, PR at V-14 n.34.

 106 The SAA states that in assessing whether the domestic industry is vulnerable to injury if the order is revoked,

the Commission “considers, in addition to imports, other factors that may be contributing to overall injury. While

these factors, in some cases, may account for the injury to the domestic industry, they may also demonstrate that an

industry is facing difficulties from a variety of sources and is vulnerable to dumped or subsidized imports.” SAA at

885, 19 U.S.C. § 1675a(a)(4). Section 752(a)(6) of the Tariff Act states that “the Commission may consider the

magnitude of the margin of dumping or the magnitude of the net countervailable subsidy” in making its

determination in a five-year review. 19 U.S.C. § 1675a(a)(6). The statute defines the “magnitude of the margin of

dumping” to be used by the Commission in five-year reviews as “the dumping margin or margins determined by the

administering authority under section 1675a(c)(3) of this title.” 19 U.S.C. § 1677(35)(C)(iv). See also SAA at 887.

In the final results of its expedited sunset review of the antidumping duty order on ironing tables from

China, Commerce found likely antidumping duty margins of 9.47 percent for Since Hardware; 72.29 percent for

Forever Holdings, Ltd., Gaoming Lihe Daily Necessities Co., Ltd., and Harvest International Housewares, Ltd.; and

157.68 percent for Shunde Yongjian Housewares Co., Ltd., Foshan Shunde, and for the PRC-wide rate. 74 Fed.

Reg. at 56795.

17
Overall, the Commission found that employment-related and financial indicators declined over

the period as well.107 Although the Commission found the domestic industry profitable in 2003 and the

industry’s operating income ratio remained *** during the period, it also noted that operating income

ratio is only one of many factors the Commission examines in making its finding with respect to the

impact of subject imports on the domestic industry. The Commission found that most of the industry’s

cost of goods sold was ***, and that the cost of HPI’s plant and equipment was ***. Thus, because the

***. The Commission concluded that the *** of operating leverage reflected in the manufacturing cost

structure of ironing tables helped to explain how the industry was able to maintain operating margins

despite experiencing declines in sales and production volume.108 As a result, the Commission found that

the injury to the domestic industry manifested itself primarily in the large declines in many of the industry

indicators other than operating margins.109

2. The Current Review

The domestic industry’s performance was inconsistent from 2004 to 2008 before improving

substantially in 2009. Production increased steadily from *** units in 2004 to *** units in 2007, then fell

to *** units in 2008 and *** units in 2009.110 Production capacity remained constant from 2004 to 2009

at *** units. Capacity utilization increased steadily from *** percent in 2004 to *** percent in 2007,

then fell to *** percent in 2008 and *** percent in 2009.111 U.S. shipments increased from *** units in

2004 to *** units in 2007, then fell to *** units in 2008 and 2009. Net sales increased from *** units in

2004 to *** units in 2007, then fell to *** units in 2008 and 2009.112 End-of-period inventories peaked in

2006, then fell to 2004 levels by the end of the period; the ratio of inventories to production followed a

similar pattern.113 The number of production and related workers (PRWs) fluctuated from *** in 2004 to

*** in 2007, then fell to *** in 2008 and *** in 2009. The number of hours worked fluctuated from ***

in 2004 to *** in 2007, then fell to *** in 2008 and increased to *** in 2009.114

The domestic industry’s financial performance fluctuated greatly from 2004 to 2007, with a

marked decrease in 2008 that reflects significant increases in raw material costs, particularly cold-rolled

steel sheet.115 The industry’s financial performance improved in 2009, despite no significant increase in

net sales, due to a decrease in its steel costs.116 The industry’s operating income was $*** in 2004, $***

 107 Original Investigation at 28-29.

 108 Original Investigation at 29.

 109 Original Investigation at 30.

 110 CR/PR at Table C-1.

 111 CR/PR at Table C-1.

 112 CR/PR at Table C-1.

 113 CR/PR at Table III-4.

 114 CR/PR at Table C-1. Productivity (units/hour) was *** in 2004, *** in 2005, *** in 2006, *** in 2007, *** in

2008, and *** in 2009. Id.

 115 From 2007 to 2008, the domestic industry's unit cost of goods sold ***. CR/PR at Table C-1.

 116 Most of the domestic industry’s cost of goods sold is ***. Thus, the average unit manufacturing costs of

ironing tables increased dramatically as the price of the principal raw material for ironing tables, cold-rolled steel

sheet, increased significantly in 2008. CR/PR at Figure V-1. The easing of steel prices in 2009 led to a reduction in

the average unit manufacturing costs and a return to profitability for the domestic industry despite a slight decrease

in net sales from the prior year. CR/PR at Table C-1.

The ratio of COGS to net sales was *** percent in 2004, *** percent in 2005, *** percent in 2006, ***

percent in 2007, *** percent in 2008, and *** percent in 2009. CR/PR at Table C-1. 

18
in 2005, $*** in 2006, $*** in 2007, *** in 2008, and $*** in 2009.117 The industry’s operating income

margin was *** percent in 2004, *** percent in 2005, *** percent in 2006, *** percent in 2007, ***

percent in 2008, and *** percent in 2009. Based on these mixed data, we do not find that the domestic

industry is in a vulnerable state.

Based on the record in this review, we conclude that revocation of the order would likely lead to a

significant increase in subject imports that likely would undersell the domestic like product and

significantly suppress or depress U.S. prices. The vast majority of ironing tables sold in the U.S. market

by the domestic industry are to a limited number of large retailers at the wholesale level.118 The loss of

one of these large purchasers to subject imports would have a substantial impact on the domestic

industry’s condition.119

We have also considered the role of other factors, including nonsubject imports and demand, that

might have an effect on the domestic industry in the reasonably foreseeable future. Nonsubject imports

have had only a minimal share of the market, ranging from a high of *** percent in 2005 to a low of ***

percent in 2009. The share fell every year since 2005.120 Thus, nonsubject imports, given the small

volumes, are not likely to prevent a substantial increase in the volume of subject imports after

revocation.121 With the current recession and the durable nature of product, future demand for ironing

tables is expected to decrease or remain flat at best. However, we find that this makes the industry more

susceptable to injury by the likely volume and price of subject imports. Although the domestic industry’s

financial performance improved greatly in 2009, this was largely due to the decrease in raw material

costs, particularly cold-rolled steel sheet, and the imposition of substantial antidumping duty deposits for

Since Hardware in March 2009.122 Such favorable cost conditions are not likely to recur in the reasonably

foreseeable future.123 Finally, Respondents allege that plastic-top ironing tables produced in both China

and the United States are now replacing metal-top ironing tables in the U.S. market.124 Plastic-top ironing

tables, however, are high priced and represent an extremely small share of the U.S. market, reportedly

less than one percent.125 In addition, market interest in the plastic-top ironing table reportedly was driven,

 117 The industry’s capital expenditures were $*** in 2004, $*** in 2005, $*** in 2006, $*** in 2007, $*** in

2008, and $*** in 2009. CR/PR at Table C-1.

 118 Sales to *** accounted for *** percent of HPI’s U.S. shipments of ironing tables over the period examined,

while *** accounted for *** percent and *** for *** percent. Calculated from CR/PR at Tables I-7 and II-2.

 119 See CR at D-4 to D-5, PR at D-3 (HPI’s Answer to Question II-4 - Impact of Revocation).

 120 CR/PR at Table C-1.

 121 The Respondents allege that India is an emerging source of ironing tables and that there will be little impact on

the U.S. industry if the antidumping order is lifted because those nonsubject imports are replacing the Chinese

subject imports. Respondent Prehearing Brief at 15-16 and Posthearing Brief, Answers to Questions from the

Commission (Chairman Aranoff) at 11-12 and Appendix PH-4. However, the record does not indicate that India

was a substantial source of ironing tables over the period examined, nor does it show any increase in imports of

ironing tables from India in the most recent years of the period examined. CR/PR at Table C-2.

 122 As discussed earlier, Commerce determined in 2009 that Since Hardware was no longer eligible for separate

rate status and subsequently included Since Hardware in the PRC-wide Entity with an antidumping duty cash deposit

rate of 157.68 percent. 74 Fed. Reg. 11085 (March 16, 2009).

 123 Prices for cold-rolled steel sheet reportedly have increased 40 percent in March 2010 compared to March

2009. HPI’s Answers to Questions from the Commission (Chairman Aranoff and Commissioners Okun, Pinkert,

and Williamson) at A-15. 

 124 Respondent Prehearing Brief at 16 and Posthearing Brief, Answers to Questions from the Commission

(Chairman Aranoff) at 10, 13-14 and Appendix PH-4.

 125 HPI Posthearing Brief at 2-3 and Answer to Questions from the Commission (Chairman Aranoff) at A-43 to

A-44; Hearing Transcript at 130 (Cooper).

19
at least in part, by the antidumping duty order on metal-top ironing tables from China.126 Therefore,

considerations of factors other than the subject imports do not detract from our finding that the subject

imports will have a likely material adverse impact on the domestic industry.

Consequently, based on the record of this review, we find that the likely volume and price effects

of the subject imports would likely have a significant adverse impact on the production, shipments, sales,

market share, and revenues of the domestic industry. Declines in these indicators of industry performance

would have a direct adverse impact on the industry’s profitability and employment, as well as its ability to

raise capital and to make and maintain capital investments. Therefore, we conclude that, if the

antidumping duty order were revoked, subject imports from China would likely have a significant adverse

impact on the domestic industry within a reasonably foreseeable time.

CONCLUSION

For the above reasons, we determine that revocation of the antidumping duty order on ironing

tables and parts thereof from China would be likely to lead to continuation or recurrence of material

injury to an industry in the United States within a reasonably foreseeable time.

 126 HPI Posthearing Brief at 2-3 and Answer to Questions from the Commission (Chairman Aranoff) at A-43 to

A-44; Hearing Transcript at 130 (Cooper).

20
PART I: INTRODUCTION AND OVERVIEW

BACKGROUND

Effective July 1, 2009, the U.S. International Trade Commission (“Commission” or “USITC”)

gave notice, pursuant to section 751(c) of the Tariff Act of 1930, as amended (“the Act”),1

 that it had

instituted a review to determine whether revocation of the antidumping duty order on ironing tables and

certain parts thereof (“ironing tables”) from China would likely lead to the continuation or recurrence of

material injury to a domestic industry.2 3

 Effective October 5, 2009, the Commission determined that it

would conduct a full review pursuant to section 751(c)(5) of the Act.4

 Information relating to the

background and schedule of this proceeding appears in the following tabulation:5

Effective date Action

August 6, 2004 Commerce’s antidumping duty order on ironing tables from China (69 FR 47868)

July 1, 2009 Commission’s institution of five-year review (74 FR 31755, July 2, 2009)

July 1, 2009 Commerce’s initiation of five-year review (74 FR 31412)

October 5, 2009

Commission’s determination to conduct a full five-year review (74 FR 54066,

October 21, 2009)

November 3, 2009

Commerce’s final results of expedited five-year review of the antidumping duty

order on ironing tables from China (74 FR 56794)

November 16, 2009 Commission’s scheduling of the review (74 FR 62593, November 30, 2009)

April 13, 2010 Commission’s hearing

May 21, 2010 Commission’s vote

June 8, 2010 Commission’s determinations transmitted to Commerce

 1 19 U.S.C. 1675(c).

 2 Ironing Tables from China, 74 FR 31755, July 2, 2009. All interested parties were requested to respond to this

notice by submitting the information requested by the Commission. The Commission received comments from

Groupe SEB USA, Inc., Home Products International, Inc., Polder Inc., Since Hardware Co., and Whitney Design.

 3

 In accordance with section 751(c) of the Act, the U.S. Department of Commerce (“Commerce”) published a

notice of initiation of five-year review of the subject antidumping duty order. Initiation of Five-year (“Sunset”)

Review, 74 FR 31412, July 1, 2009. 

 4 Ironing Tables from China, 74 FR 54066, October 21, 2009. The Commission found that both the domestic and

respondent interested party group responses to its notice of institution were adequate. 

 5

 The Commission’s notice of institution, notice to conduct full review, scheduling notice, and statement on

adequacy appear in appendix A and may also be found at the Commission’s web site (internet address

www.usitc.gov). Commissioners’ votes on whether to conduct an expedited or full review may also be found at the

web site. Appendix B presents the witnesses appearing at the Commission’s hearing.

I-1
THE ORIGINAL INVESTIGATION

The original investigation resulted from a petition filed by Home Products International, Inc.

(“HPI”), Chicago, IL, on June 30, 2003. Following notification of a final determination by Commerce

that imports of ironing tables from China were being sold at LTFV, the Commission determined on July

29, 2004, that a domestic industry was materially injured by reason of LTFV imports of ironing tables

from China.6

 Commerce published the antidumping duty order on ironing tables from China on August 6,

2004.7

 

The Commission had conducted no previous investigations concerning ironing tables prior to

HPI’s petition. The agency has conducted no related investigations concerning ironing tables since the

completion of its original investigation.

SUMMARY DATA

Table I-1 presents a summary of data from the original investigation and the current full five-year

review.8

 The domestic industry producing ironing tables consists of one company, Home Products

International, Inc. (“HPI”). The largest known manufacturers of ironing tables in China are *** The

largest U.S. importers are ***. Floor-standing, metal-top ironing tables are sold by the domestic

producers and importers to mass retail stores such as ***, as well as to the hospitality/hotel market.9

Table I-1

Ironing tables: Comparative data from the original investigation and current review, 2001-03 and

2004-09

* * * * * * *

Note.– Data regarding U.S. shipments of imports from all sources during 2001-03 are public, and can be

found in Ironing Tables and Certain Parts Thereof from China, Inv. No. 731-TA-1047 (Final), USITC Publication

3711, July 2004, tables IV-1 and C-1. Data regarding U.S. shipments of imports from all sources during 2004-

09 are similarly public, and can be found in this report in table C-1.

 6 Ironing Tables and Certain Parts Thereof from China, Inv. No. 731-TA-1047 (Final), USITC Publication 3711,

July 2004.

 7 Notice of Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order: FloorStanding, Metal-Top Ironing Tables and Certain Parts Thereof From the People’s Republic of China, 69 FR 47868,

August 6, 2004.

 8

 Domestic industry data include Whitney Design until 2002, when the company ceased domestic production. 

U.S. import data in the original investigation were drawn from questionnaire responses because until July 1, 2003,

there was no statistical reporting number dedicated to ironing tables. Since July 1, 2003, a statistical reporting

number dedicated to floor-standing, metal-top ironing tables has been in effect. However, misclassification has

resulted in the overstatement of imports of ironing tables, even under the dedicated statistical reporting number. 

Accordingly, the import data presented in table I-1 and throughout the report are compiled from questionnaire

responses. A summary for U.S. imports based on official Commerce statistics is located at C-2 in appendix C. Staff

notes that the Commission has received questionnaires from all major known importers of ironing tables, which are

largely the same importers that responded in the final phase of the investigation investigation. 

 9

 There is no known domestic production or imports of major parts or components of ironing tables, as defined by

Commerce’s scope, separate from the production and sale of finished ironing tables.

I-2
STATUTORY CRITERIA AND ORGANIZATION OF THE REPORT

Statutory Criteria

Section 751(c) of the Act requires Commerce and the Commission to conduct a review no later

than five years after the issuance of an antidumping or countervailing duty order or the suspension of an

investigation to determine whether revocation of the order or termination of the suspended investigation

“would be likely to lead to continuation or recurrence of dumping or a countervailable subsidy (as the

case may be) and of material injury.”

Section 752(a) of the Act provides that in making its determination of likelihood of continuation

or recurrence of material injury--

(1) IN GENERAL.-- . . . the Commission shall determine whether revocation of

an order, or termination of a suspended investigation, would be likely to lead to

continuation or recurrence of material injury within a reasonably foreseeable time. The

Commission shall consider the likely volume, price effect, and impact of imports of the

subject merchandise on the industry if the order is revoked or the suspended investigation

is terminated. The Commission shall take into account--

(A) its prior injury determinations, including the volume, price

effect, and impact of imports of the subject merchandise on the industry

before the order was issued or the suspension agreement was accepted, 

(B) whether any improvement in the state of the industry is

related to the order or the suspension agreement, 

(C) whether the industry is vulnerable to material injury if the

order is revoked or the suspension agreement is terminated, and 

(D) in an antidumping proceeding . . ., (Commerce’s findings)

regarding duty absorption . . ..

(2) VOLUME.--In evaluating the likely volume of imports of the subject

merchandise if the order is revoked or the suspended investigation is terminated, the

Commission shall consider whether the likely volume of imports of the subject

merchandise would be significant if the order is revoked or the suspended investigation is

terminated, either in absolute terms or relative to production or consumption in the

United States. In so doing, the Commission shall consider all relevant economic factors,

including--

(A) any likely increase in production capacity or existing unused

production capacity in the exporting country, 

(B) existing inventories of the subject merchandise, or likely

increases in inventories, 

(C) the existence of barriers to the importation of such

merchandise into countries other than the United States, and 

(D) the potential for product-shifting if production facilities in

the foreign country, which can be used to produce the subject

merchandise, are currently being used to produce other products.

(3) PRICE.--In evaluating the likely price effects of imports of the subject

merchandise if the order is revoked or the suspended investigation is terminated, the

Commission shall consider whether--

I-3
(A) there is likely to be significant price underselling by imports

of the subject merchandise as compared to domestic like products, and 

(B) imports of the subject merchandise are likely to enter the

United States at prices that otherwise would have a significant

depressing or suppressing effect on the price of domestic like products.

(4) IMPACT ON THE INDUSTRY.--In evaluating the likely impact of imports of

the subject merchandise on the industry if the order is revoked or the suspended

investigation is terminated, the Commission shall consider all relevant economic factors

which are likely to have a bearing on the state of the industry in the United States,

including, but not limited to–

(A) likely declines in output, sales, market share, profits,

productivity, return on investments, and utilization of capacity, 

(B) likely negative effects on cash flow, inventories, employment,

wages, growth, ability to raise capital, and investment, and 

(C) likely negative effects on the existing development and

production efforts of the industry, including efforts to develop a

derivative or more advanced version of the domestic like product.

The Commission shall evaluate all such relevant economic factors . . . within the context

of the business cycle and the conditions of competition that are distinctive to the affected

industry.

Section 752(a)(6) of the Act states further that in making its determination, “the Commission may

consider the magnitude of the margin of dumping or the magnitude of the net countervailable subsidy. If

a countervailable subsidy is involved, the Commission shall consider information regarding the nature of

the countervailable subsidy and whether the subsidy is a subsidy described in Article 3 or 6.1 of the

Subsidies Agreement.”

Organization of the Report

Information obtained during the course of the review that relates to the statutory criteria is

presented throughout this report. A summary of trade and financial data for ironing tables as collected in

the review is presented in appendix C. U.S. industry data are based on the questionnaire response of one

U.S. producer of ironing tables that is believed to have accounted for all domestic production of ironing

tables in 2009. U.S. import data and related information are based on the questionnaire responses of 10

U.S. importers of ironing tables. These data are based on responses from the largest known U.S.

importers and foreign producers exporting to the U.S. and are believed to cover the large majority of

imports from China as well as from nonsubject sources. Foreign industry data and related information are

based on questionnaire responses from six Chinese manufacturers/exporters of ironing tables, including

those most active in the U.S. market, as well as limited published information. Responses by the U.S.

producer, importers, purchasers, and foreign producers of ironing tables to a series of questions

concerning the significance of the existing antidumping duty order and the likely effects of revocation of

the order are presented in appendix D. Appendix E presents an additional compilation of price data

collected in this review.

I-4
COMMERCE’S REVIEWS

Administrative Reviews10

Commerce has completed four administrative reviews of the outstanding antidumping duty order

on ironing tables from China.11 The results of the administrative reviews are shown in table I-2. 

Table I-2

Ironing tables: Administrative reviews of the antidumping duty order for China

Date results

published Period of review Producer or exporter Margin (percent)

March 21, 2007 

(72FR 13239)

as corrected on 

April 19, 2007

(72 FR 19689) 2/3/04 - 7/31/05

Since Hardware 

(Guangzhou) Co., Ltd. 0.45 (de minimis)

Foshan Shunde Yongjian 

Houseware & Hardware Co., Ltd.1 2.37

Forever Holdings Ltd. 10.18

March 18, 2008 

(73 FR 14437) 8/1/05 - 7/31/06

Since Hardware 

(Guangzhou) Co., Ltd. 0.34 (de minimis)

March 16, 2009 

(74 FR 11085) 8/1/06 - 7/31/07

Forever Holdings Ltd. 0.00

PRC-wide Entity (which includes 

Since Hardware2

) 157.68

January 20, 2010

(75 FR 3201) 8/1/07 - 7/31/08

PRC-wide Entity (which includes 

Foshan Shunde3

) 157.68

 1 There has been confusion surrounding Foshan Shunde Yongjian Houseware & Hardware Co., Ltd. and

Shunde Yongjian Housewares Co., Ltd. in the original antidumping duty order for ironing tables and subsequent

administrative reviews. On August 31, 2005, Shunde Yongjian sent a letter to Commerce stating that it wanted to

clarify that its request for an administrative review should also include a variation of the name that may have been

used to export subject merchandise during the period of review. Shunde Yongjian stated that the name variation is

as follows: Foshan Shunde Yongjian Housewares and Hardware Co., Ltd. However, in Commerce’s final results of

the administrative review of the time period February 3, 2004 - July 31, 2005, published March 21, 2007, Commerce

states that, “based on our analysis of information and comments received from interested parties on this issue, as

discussed in depth in the accompanying Issues and Decision Memorandum at Comment 8, the Department has

determined that Foshan Shunde and Shunde Yongjian should not be collapsed and that Foshan Shunde is not the

successor-in-interest to Shunde Yongjian. Therefore, the Department is rescinding this administrative review with

respect to Shunde Yongjian, but will continue to calculate a separate rate for Foshan Shunde.”

 2

 Commerce determined that because Since Hardware had provided inaccurate and unreliable data, it was no

longer eligible for separate rate status, and thus was properly considered to be part of the PRC–wide entity.

 3

 Commerce found that Foshan Shunde provided inaccurate and unreliable data, and as such, Commerce was

unable to determine Foshan Shunde’s eligibility for separate rate status. Thus, Commerce determined Foshan

Shunde was properly considered to be part of the PRC-wide entity.

Note.– ***.

Source: Cited Federal Register notices and HPI’s posthearing brief, exhibit 2.

 10 No duty absorption findings were made.

 11 For previously reviewed or investigated companies not included in an administrative review, the cash deposit

rate continues to be the company-specific rate published for the most recent period.

I-5
Five-Year Review

Commerce has issued the final results of its expedited review. Table I-3 presents the dumping

margins calculated by Commerce in its original investigations and first review. 

Table I-3

Ironing tables: Commerce’s original and first five-year review dumping margins for

producers/exporters1

Producer/exporter

Original margin

(percent)

First five-year review margin

(percent)

Since Hardware (Guangzhou)

Co., Ltd. 9.47 9.47

Shunde Yongjian Housewares

Co., Ltd. 157.68 157.68

Forever Holdings Ltd. 72.29 72.29

Gaoming Lihe Daily Necessities

Co., Ltd. 72.29 72.29

Harvest International

Housewares Ltd. 72.29 72.29

Foshan Shunde (2

) 157.68

All others 157.68 157.68

 1 Antidumping duty order, 69 FR 47868, August 6, 2004; final results of Commerce’s review, 74 FR 56794,

November 3, 2009.

 2

 Foshan Shunde was not listed separately in the original antidumping duty order.

Source: Cited Federal Register notices.

DISTRIBUTION OF CONTINUED DUMPING AND SUBSIDY OFFSET ACT FUNDS

The Continued Dumping and Subsidy Offset Act of 2000 (“CDSOA”) (also known as the Byrd

Amendment) provides that assessed duties received pursuant to antidumping or countervailing duty

orders must be distributed to affected domestic producers for certain qualifying expenditures that these

producers incur after the issuance of such orders.12 During the review period, qualified U.S. producers of

ironing tables were eligible to receive disbursements from the U.S. Customs and Border Protection

(“Customs”) under CDSOA relating to the order covering the subject merchandise beginning in Federal

fiscal year 2006.13 Table I-4 presents CDSOA disbursements and claims for Federal fiscal years 2005 -

2009.14

 12 Section 754 of the Tariff Act of 1930, as amended (19 U.S.C. § 1675(c)). The Deficit Reduction Act of 2005

repealed the CDSOA with respect to duties on entries of goods made and filed on or after October 1, 2007. See Pub.

L. No. 109-171, 120 Stat. 4, 154 (2006).

 13 19 CFR 159.64 (g).

 14 The Federal fiscal year begins on October 1 and ends on September 30 of the next calendar year.

I-6
Table I-4

Ironing tables: CDSOA disbursements to HPI and total claims, Federal fiscal years 2005-09

Item

Federal fiscal year

2005 2006 2007 2008 2009

Disbursements (dollars)

HPI --- 4,894.85 28,705.70 53,483.05 725,802.80

Claims (dollars)

HPI --- 38,190,000 56,857,120 75,608,400 75,554,920

Source: U.S. Customs and Border Protection’s CDSOA Annual Reports. Retrieved from

www.cbp.gov/xp/cgov/import/add_cvd.

THE SUBJECT MERCHANDISE

Commerce’s Scope

The imported product subject to the antidumping duty order under review, as defined by

Commerce in its original order, is as follows.15

(F)loor-standing, metal-top ironing tables, assembled or unassembled,

complete or incomplete, and certain parts thereof. The subject tables are

designed and used principally for the hand ironing or pressing of

garments or other articles of fabric. The subject tables have full-height

leg assemblies that support the ironing surface at an appropriate (often

adjustable) height above the floor. The subject tables are produced in a

variety of leg finishes, such as painted, plated, or matte, and they are

available with various features, including iron rests, linen racks, and

others. The subject ironing tables may be sold with or without a pad

and/or cover. All types and configurations of floor-standing, metal-top

ironing tables are covered by this order. 

Furthermore, the order specifically covers imports of ironing tables,

assembled or unassembled, complete or incomplete, and certain parts

thereof. For purposes of this order, the term “unassembled” ironing table

means a product requiring the attachment of the leg assembly to the top

or the attachment of an included feature such as an iron rest or linen rack. 

The term “complete” ironing table means a product sold as a ready-touse ensemble consisting of the metal-top table and a pad and cover, with

or without additional features, e.g., iron rest or linen rack. The term

“incomplete” ironing table means product shipped or sold as a “bare

board” i.e., a metal-top table only, without the pad and cover, with or

without additional features, e.g. iron rest or linen rack. The major parts

or components of ironing tables that are intended to be covered by the

order under the term “certain parts thereof” consist of the metal top

component (with or without assembled supports and slides) and/or the

leg components, whether or not attached together as a leg assembly. 

 15 Notice of Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order: FloorStanding, Metal Top Ironing Tables and Certain Parts Thereof From the People’s Republic of China, 69 FR 47868,

August 6, 2004.

I-7
This order covers separately shipped metal top components and leg

components, without regard to whether the respective quantities would

yield an exact quantity of assembled ironing tables. Ironing tables

without legs (such as models that mount on walls or over doors) are not

floor-standing and are specifically excluded. Additionally, tabletop or

countertop models with short legs that do not exceed 12 inches in length

(and which may or may not collapse or retract) are specifically excluded.

Tariff Treatment

The subject ironing tables were previously covered by Harmonized Tariff Schedule of the United

States (HTS) statistical reporting number 9403.20.0010. Effective July 1, 2003, the subject ironing tables

have been properly entered as imports under HTS statistical reporting number 9403.20.0011. The subject

metal top and leg components are imported under HTS statistical reporting number 9403.90.8040. 

Products of China entering the United States under HTS subheadings 9403.20.00 and 9403.90.80 are free

of duty.

THE DOMESTIC LIKE PRODUCT

Description and Applications16

In this report, the term “ironing tables” is used to distinguish the subject floor-standing metal-top

product from “ironing boards,”a term used to describe products excluded from the scope: countertop,

tabletop, over-the-door, and wall-mounted ironing boards. Ironing tables are used in households, hotel

rooms, and workplaces for the purpose of pressing apparel and other textile items. The standard size of

an ironing table is 48 to 54 inches in length and 13 to 18 inches in width. The table may be equipped with

special features such as an iron rest or linen racks.

Ironing tables and their components are produced from flat-rolled steel and wire, as well as

fasteners, plastic fittings, foam, and textile fabric. The principal components of an ironing table are its

metal ironing surface, legs, feet, slide bar, handle, hangers, ribs, and foot cover.

The ironing surface of ironing tables is either mesh-top or perforated-top and is attached to either

a T-leg or a 4-leg stand. The 4-leg stand is considered superior to the T-leg because some perceive it to

offer more stability. Typically, T-leg ironing tables are offered at opening price points of $18 or less,

while only the 4-leg is offered on higher-end models. A T-leg is made of a single metal tube inserted into

a metal leg base that is shaped as an inverted “T.” A 4-leg ironing table has two legs, each made of two

metal tubes that run parallel to each other, flare out to form a 4-footed base on the floor, and typically

have a cross brace at or near the flare or at the end of the tubes. In each system, users press a lever that

allows the legs to drop down and subsequently raise the height of the table or fold flat for storage.

 16 Unless noted, the information in this section is based on the staff report in Ironing Tables and Certain Parts

Thereof from China, Inv. No. 731-TA-1047 (Final). Confidential data is drawn from INV-BB-087 (July 2, 2004)

while public information is drawn from USITC Publication 3711, July 2004.

I-8
Ironing tables reportedly are sold in as many as five different retail price point categories. The

following tabulation describes ironing tables at various price points:17

1) Value / open price point (OPP) (T-leg) $18 or less

Perforated or mesh-top with T-leg 

2) Good (4-Leg) $18-$28

Mostly mesh-top 4-leg and optionally an iron rest

3) Better (Heavy Duty) $28-$40

Mesh-top with heavy duty 4-leg and an added feature such as

an iron rest 

4) Best (Wide Top) $40-$70

Mesh wide top with heavy duty/Professional 4-leg and

multiple added features such as an iron rest and linen rack.

5) Specialty $70 +

Typically wide tops with extension cord, wheels and/or other

combinations of accessories and special finishes

More than three-quarters of ironing tables consumed in the United States reportedly are in the

open price point category. 

U.S. imports of ironing tables from China are exclusively mesh-top, while the majority of

domestic ironing tables are perforated.18 HPI has the capability of producing a mesh-top or perforatedtop table, but produces more perforated-top tables as ***.19 Chinese manufacturers, in contrast,

reportedly produce only mesh-top tables through a labor-intensive production process. None of the

companies responding to the Commission's questionnaires reported producing, exporting, or importing

perforated-top tables from China. ***.20

Manufacturing Processes21

Ironing tables are produced in several countries, most notably in China, Italy, Poland, the United

Kingdom, Turkey, India, and the United States, primarily from flat-rolled steel and wire. The production

of ironing tables involves common capital equipment such as a metal roll-former, punch press, welding

equipment, and painting facilities. The metal top may be formed by various processes, including

pressing, stamping, and punching. Alternatively, much of the production may be accomplished by hand,

with tools such as hand benders and welders, wire cutters, metal shears, and a sewing machine for covers. 

The production process in the United States purportedly is more capital-intensive than the production

process in China.22

 17 E-mail from ***, December 22, 2009.

 18 ***. See also Part V, tables V-1 through V-6, presenting the relative sales volumes of mesh-top and

perforated-top ironing tables.

 19 ***.

 20 ***. Several U.S. importers, purchasers, and Chinese producers rate performance differences as an important

purchase consideration. See Part V for a discussion of perforated- vs. mesh-top ironing tables.

 21 Unless noted, the information in this section is based on the staff report in Ironing Tables and Certain Parts

Thereof from China, Inv. No. 731-TA-1047 (Final). Confidential information is drawn from INV-BB-087 (July 2,

2004) while public information is drawn from USITC Publication 3711, July 2004.

 22 ***.

I-9
HPI manufactures ironing tables in two plants in Seymour, IN. ***.23

Perforated-top, T-leg models are the opening price point ironing tables for HPI and account for

about *** percent of HPI’s shipments, in terms of units shipped. ***.24 

According to HPI, flat-rolled steel is first formed into various parts. In a perforated-top, flat

rolled steel is pressed in a series of sequential dies to form the top. However, for a mesh-top, steel is

processed through a metal expanding machine and then is cut into the top shape by a die. The shaped

steel mesh is inserted into a groove in the inner surface of the rim. The rim is then crimped tightly over

the mesh in an automated process.25 26

Following fabrication of the metal top, a set of tracks (hangers) is welded to the underside of the

metal ironing surface. These hangers run the full length of the table. The hangers are stamped on a punch

press. Vertical supports (ribs), produced on a roll former, are attached to the hangers. Legs and feet are

made from steel tubes which are manufactured on site in an automated tube mill. The steel tubing is bent

in an automated leg bending machine. The tops and legs are painted in either a wet or powder process. 

Various metal components are joined by a combination of welding27 and riveting. The legs are connected

to the hangers by a stamped piece of metal known as a hinge bar and are connected to the ribs with a slide

bar. A height-adjusting handle, made on a wire machine, is also added to the ironing table. The foam pad

and fabric cover are attached to the ironing table before the table is shrink-wrapped and packed in a

carton.28

Elastic is sewn into the outer edge of the textile fabric on site for ironing tables destined for the

household market. The elastic holds the cover over the foam pad and metal table top. Fabric covers for

ironing tables destined for the hospitality market are permanently affixed to the foam pads and table

tops.29

All of the components for the metal tops and legs are manufactured by HPI in Seymour, with the

exception of plastic tips for the legs, which are purchased from domestic producers.30 Accessories 

consist of foam pads and fabric covers for the tops and additional features, such as iron rests and linen

racks. ***.31 

Plastic-top ironing tables, which are not within the scope of this review, have emerged as a

potential alternative to metal-top ironing tables in the U.S. market. See the section “Substitute Products”

for a brief discussion regarding the substitutability of plastic-top ironing tables for metal-top ironing

tables. Plastic-top ironing tables are not produced in the United States. HPI’s plastic-top ironing tables

for its “Revolution 360” line of upper-end ironing tables are produced in China and Korea.32

 23 ***.

 24 ***.

 25 ***.

 26 None of the ironing table producers in China offer a perforated top. All ironing tables imported from China

have mesh tops, which are more labor-intensive to manufacture. In China, the shaped mesh is welded on top of the

ironing table rim instead of being attached through a crimping process. Ibid.

 27 The U.S. manufacturer uses resistance welding, in contrast to MIG and spot welding used to produce ironing

tables in China. ***.

 28 ***.

 29 ***.

 30 ***.

 31 ***.

 32 Hearing transcript, p. 102 (Volles).

I-10
DOMESTIC LIKE PRODUCT ISSUES

In its original determination, the Commission defined the domestic like product as a single

product consisting of floor-standing, metal-top ironing tables, coextensive within the scope of the

investigation.33 In its notice of institution in the current five-year review, the Commission solicited

comments from interested parties regarding the appropriate domestic like product and domestic industry.34

Domestic producer HPI indicated in its response to the Commission’s notice of institution in this first

review that it agrees with the Commission’s definitions of domestic like product and domestic industry. 

Respondent interested parties Polder, Since, and Whitney indicated in their responses that they do not

contest the domestic like product finding of the Commission. Groupe SEB did not indicate its position on

the definitions of the domestic like product and domestic industry in its response to the Commission’s

notice of institution. No party requested that the Commission collect data concerning other possible

domestic like products in their comments on the Commission’s draft questionnaires.35 The domestic

interested party’s prehearing brief observed that, “in the first five-year review of the original

determination, no facts have arisen that would suggest the Commission should revisit its original like

product finding, nor has any party suggested that the Commission should do so,”36 while its posthearing

brief did not address the issue of like product further. The respondent interested parties did not address

the issue of domestic like product in their briefs.

U.S. MARKET PARTICIPANTS

U.S. Producer

During the original investigation, two firms supplied the Commission with information on their

U.S. operations with respect to ironing tables. These firms accounted for all U.S. production of ironing

tables during the period January 2001 - March 2004.37 In these current proceedings, the Commission

issued producers’ questionnaires to these two firms, one of which, HPI, provided the Commission with

information on its ironing tables operations. The other, Whitney, is no longer a producer of ironing

tables. Whitney ceased ironing table operations in April 2002 during the original investigation and has

not produced ironing tables during the period for which data were collected. HPI is believed to account

for all U.S. production of ironing tables in 2009. Presented in table I-5 is the current domestic producer

of ironing tables, HPI, and its position on continuation of the order, production location, related and/or

affiliated firms, and share of reported production of ironing tables in 2009.

 33 Ironing Tables and Certain Parts Thereof from China, Inv. No. 731-TA-1047 (Final), USITC Publication 3711,

July 2004, pp. 4-8.

 34 Ironing Tables from China, 74 FR 31755, July 2, 2009.

 35 Response to Commission’s Notice of Institution of Domestic Interested Parties, Ironing Tables and Certain

Parts Thereof (Inv. No. 73l-TA-1047 (Review)), July 31, 2009, p. 39; Response to Commission’s Notice of

Institution of Since Hardware Co., Ironing Tables and Certain Parts Thereof (Inv. No. 73l-TA-1047 (Review)), July

31, 2009, p. 9; Response to Commission’s Notice of Institution of Whitney Design, Ironing Tables and Certain Parts

Thereof (Inv. No. 73l-TA-1047 (Review)), July 31, 2009, p. 9; Response to Commission’s Notice of

Institution of Polder Inc., Ironing Tables and Certain Parts Thereof (Inv. No. 73l-TA-1047 (Review)), July 31, 2009,

p. 8; and Response to Commission’s Notice of Institution of Groupe SEB USA Inc., Ironing Tables and Certain Parts

Thereof (Inv. No. 73l-TA-1047 (Review)), July 31, 2009. 

 36 HPI’s prehearing brief, p. 9.

 37 The two U.S. producers that supplied the Commission with usable questionnaire information during the original

investigation were HPI and Whitney Design Inc. (“Whitney”).

I-11
Table I-5

Ironing tables: HPI’s position on the order, plant location, related and/or affiliated firms, and shares

of 2009 reported U.S. production

Firm

Position on

continuation

of the order

U.S. production

location Related and/or affiliated firms

Share of

production

(percent)

HPI Support Seymour, IN None 100.0

Source: Compiled from data submitted in response to Commission questionnaires.

As indicated in the table above, the only U.S. producer, HPI, is not related to any foreign

producers of the subject merchandise and is not related to any U.S. importers of the subject merchandise.

As discussed in greater detail in Part III, HPI ***. HPI has not purchased the subject merchandise from

U.S. importers during the period for which data were collected. HPI has *** with ***. Although ***,

HPI has ***.38

U.S. Importers

In the original investigation, 11 U.S. importing firms supplied the Commission with usable

information on their operations involving the importation of ironing tables, accounting for an estimated

90.0 percent of U.S. imports of ironing tables during 2003. Both U.S. producers of ironing tables during

the original investigation reported importing the product.

In the current proceeding, the Commission issued importers’ questionnaires to 33 firms believed

to be importers of subject ironing tables, as well as to all U.S. producers of ironing tables. Usable

questionnaire responses were received from 10 companies. Seven of the 11 importers from the original

investigation provided the Commission with usable questionnaire responses in the review and one

company responded that it has not imported ironing tables during the period for which data were

collected.39 The seven responding importers were companies that accounted for *** of reported imports

in 2003. Table I-6 lists all responding U.S. importers of ironing tables from China and other sources,

their locations, and their shares of U.S. imports in 2009.

 38 HPI’s posthearing brief, exh. 2, p. 4.

 39 Questionnaire responses were not received from IHW, Inc., Galactic Inc., and Ironees from the original

investigation. These companies accounted for *** percent of the imports in 2003. IHW ***. Numerous attempts

were made to contact Galactic and Ironees to no avail. The numbers listed in the original investigation had been

disconnected, and there were no websites associated with these companies.

I-12
Table I-6

Ironing tables: U.S. importers, source(s) of imports, U.S. headquarters, and shares of imports in

2009

Firm Headquarters

Source of

imports

Share of imports (percent)

China Other Total

American Hotel Register Co. Vernon Hills, IL *** *** *** ***

Bajer Design and Marketing, Inc. Waukesha, WI *** *** *** ***

Brabantia USA Inc. Woodcliff Lake, NJ *** *** *** ***

Groupe SEB USA Inc. West Orange, NJ *** *** *** ***

Home Products International, Inc. Chicago, IL *** *** *** ***

Ikea Inc. Westampton, NJ *** *** *** ***

Polder Inc. Oxford, CT *** *** *** ***

Target Inc. Minneapolis, MN *** *** *** ***

Whitmor Manufacturing Company Southaven, MS *** *** *** ***

Whitney Design, Inc.1 Hazelwood, MO *** *** *** ***

Total 100.0 100.0 100.0

 1 Whitney Design filed for chapter 11 bankruptcy in November 2009. Whitney’s assets except subject ironing

tables were sold to Household Essentials LLC in January 2010.

Note.–Because of rounding, figures may not add to the totals shown.

Source: Compiled from data submitted in response to Commission questionnaires.

I-13
U.S. Purchasers

The Commission received 13 usable U.S. purchaser questionnaire responses from firms that

bought ironing tables during 2004-09.40 Twelve of the responding purchasers are retailers and the 1

remaining purchaser is a distributor.41 Reported purchases from these 13 purchasers totaled *** ironing

tables during 2004-09, which is *** percent of the quantity of total U.S. consumption of these products

during this period.42

The top three responding purchasers of ironing tables during 2009, in descending order, were

***. These three purchasers accounted for *** percent of apparent U.S. consumption of ironing tables

during 2009.43 44 This is less than the approximately *** percent of apparent U.S. consumption of ironing

tables accounted for by virtually the same top three purchasers in 2003.45

Of the thirteen responding purchasers, six purchased predominantly the domestic products,46 and

the seven other firms purchased47 exclusively or predominantly the imported Chinese products.48

APPARENT U.S. CONSUMPTION

As shown in table I-7 and figure I-1, apparent U.S. consumption of ironing tables has been

declining for most of the period for which data were collected. Apparent U.S. consumption in 2009 was

*** percent lower than in 2004, and was *** percent lower than in the peak year of 2005.49

 40 Of the 13 responding purchasers, 5 purchased the domestic ironing tables and the imported ironing tables from

China, 4 purchased only the imported ironing tables from China, 2 purchased imported ironing tables from China

and from third countries, 1 firm purchased domestic ironing tables and ironing tables imported from China and the

Netherlands, and the 1 remaining firm purchased only the domestic ironing tables (this firm also imported ironing

tables from China and other countries). Of the total purchase quantities reported during 2004-09, the domestic

ironing tables accounted for *** percent, the imported ironing tables from China accounted for *** percent, and

ironing tables imported from third countries (Germany, Italy, and The Netherlands) accounted for the remaining ***

percent. 

 41 The lone responding distributor, ***, reported selling its ironing tables to retail housewares and variety stores.

 42 *** was the only responding purchaser that also imported ironing tables. *** imported approximately ***

ironing tables from China and *** ironing tables from all other countries during 2004-09. Adding these imports to

the total reported purchases results in *** ironing tables accounted for by the responding purchasers during 2004-09,

or *** percent of total apparent U.S. consumption of ironing tables during this period.

 43 This includes the *** ironing tables imported by *** during 2009.

 44 *** was the largest purchaser, accounting for *** percent of apparent U.S. consumption of ironing tables in

2009. 

 45 *** were listed as the top three U.S. purchasers of ironing tables in 2003. Original staff report, confidential

version, p. II-1.

 46 These six firms accounted for *** percent of the total reported purchases (and imports by ***) of ironing tables

during 2004-09.

 47 One of these seven firms, ***, also imported ironing tables directly, primarily those produced in China.

 48 These seven firms accounted for *** percent of the total reported purchases (and imports by ***) of ironing

tables during 2004-09.

 49 HPI has indicated that this is a “mature” industry. A trend toward wrinkle-free garments, as well as a more

casual-dress in professional environments has caused apparent U.S. consumption to decline. This trend is amplified

by a weaker economy beginning in 2008. ***.

I-14
Table I-7

Ironing tables: U.S. shipments of domestic product, U.S. shipments of imports, and apparent U.S.

consumption, 2004-09

* * * * * * *

Note.– Data regarding U.S. shipments of imports from all sources during 2004-09 are public, and can be

found in this report in table C-1.

Figure I-1

Ironing tables: Apparent U.S. consumption, by sources, 2004-09

* * * * * * *

U.S. MARKET SHARES

U.S. market share data are presented in table I-8. U.S. producer shipments as a share of apparent

U.S. consumption increased by *** percentage points from 2004 to 2009. U.S. shipments of imports

from China accounted for slightly less than *** of apparent U.S. consumption in four of the six years for

which data were collected, but for only *** percent in 2007 and *** percent in 2009.

Table I-8

Ironing tables: U.S. consumption and market shares, 2004-09

* * * * * * *

I-15

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. CHANNELS OF DISTRIBUTION

HPI (the lone U.S. producer), U.S. importers of ironing tables from China, and U.S. importers of

ironing tables from nonsubject countries reported in their questionnaire responses their annual U.S.

shipment quantities of the subject products to three specified categories of customers during 2004-09. 

The shares of the reported shipment quantities relative to total reported shipments are shown by country

and customer category in table II-1.

Table II-1

Ironing tables: Channels of distribution for domestic product and U.S. imports sold in the U.S.

market (as a share of U.S. commercial shipments), annually, 2004-09

* * * * * * *

Total U.S. shipments to--

 Distributors 3.1 2.7 2.6 2.6 3.4 2.6

 Retailers 86.6 87.6 87.6 87.5 87.3 88.4

 Commercial users 10.3 9.6 9.8 9.9 9.3 8.9

 Total 100.0 100.0 100.0 100.0 100.0 100.0

Note.–Due to rounding, numbers may not add to totals. Individual allocations have been redacted for reasons of

confidentiality.

Source: Compiled from data submitted in response to Commission questionnaires.

As seen in table II-1, the largest customer category by far was retailers for all direct shipments of

ironing tables during 2004-09, followed by direct shipments to commercial users, and lastly, by direct

shipments to distributors.1

 Retailers sell their ironing tables almost exclusively to household consumers. 

Commercial users consist primarily of the hospitality market, where ironing tables are used in hotels and

motels by travelers and in healthcare facilities.2

 *** responding importers and purchasers reported that

there were no changes in types of customers or end users, no emergence of new markets for ironing tables

during 2004-09, and no anticipated changes in these factors in the future.3

 *** reported in its purchaser

questionnaire responses that the U.S. ironing table market is stable for both products and vendors.

*** reported in its questionnaire response that the market power of the larger retailers of ironing

tables has made it difficult for *** to pass along steel price increases. Purchasers commenting in their

questionnaire responses on price leaders of ironing tables in the U.S. market identified Wal-Mart most

frequently followed by Target as retail price leaders. On the supply side, they mentioned HPI, Polder

(importer), and Whitney Design (importer) as wholesale price leaders.

In addition, two purchasers, *** (retailer) and *** (distributor) reported in their questionnaire

responses that they compete with their suppliers for sales of ironing tables. *** indicated that its two

 1 This distribution is similar to that reported during the original investigation. Original staff report, confidential

version, p. II-1.

 2

 U.S. producer and importer questionnaire response, sections IV-21a and III-22a, respectively.

 3

 U.S. producer, importer, and purchaser questionnaire responses, sections IV-21-23, III-22-24, and III-5-7 and

III-29, respectively.

II-1
suppliers also sell ironing tables on their company websites, and *** indicated that its suppliers have

representatives that also sell in its sales area.

Although the predominant share of wholesale sales of ironing tables are to retailers the

responding purchasers differ in terms of relative sizes and mix of U.S.-produced and imported ironing

tables. Reported purchases of the 13 responding purchasers4

 and their reported purchase quantities of

ironing tables5

 are shown in table II-2.

Table II-2

Ironing tables: Total purchases of ironing tables, by country sources, 2004-09

* * * * * * *

Regional Sales

HPI, four U.S. importers of ironing tables from China, and two U.S. importers of ironing tables

from all other countries reported in their questionnaire responses the U.S. geographic market area(s)

during 2009 where they shipped their domestic and imported ironing tables. The weighted-average U.S.

shipment shares by each of the specified geographic areas for the subject products produced domestically,

imported from China, and imported from all other countries are shown in the following tabulation.

U.S. geographic area

Share of U.S. shipments of ironing tables in 2009 (percent)

U.S.-produced

Imported from

China

Imported from all

other countries

Northeast1 *** 22.9 ***

Midwest2 *** 26.2 ***

Southeast3 *** 20.6 ***

Central Southwest4 *** 7.2 ***

Mountains5 *** 8.3 ***

Pacific Coast6 *** 12.8 ***

Other7 *** 2.1 ***

Total 100.0 100.0 100.0

 1 Includes CT, ME, MA, NH, NJ, NY, PA, RI, and VT.

 2

 Includes IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.

 3

 Includes AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.

 4

 Includes AR, LA, OK, and TX.

 5

 Includes AZ, CO, ID, MT, NV, NM, UT, and WY.

 6

 Includes CA, OR, and WA.

 7

 Includes all other markets in the United States not previously listed, including AK, HI, PR, VI, among

others.

Note.–Totals may not add to 100 due to rounding.

HPI and six U.S. importers of ironing tables from China reported in their questionnaire responses

their lead times for delivery of their products and shipment shares that were from inventory and from

 4 Twelve of the 13 responding purchasers are retailers and one, ***, is a distributor. 

 5

 Total purchases also include direct imports by ***, the only responding purchaser that also imported ironing

tables directly.

II-2
production during 2009. The weighted-average shipment shares and lead times are shown in the

following tabulation.

Shipment source

U.S. ironing tables

Imported ironing tables from

China

Share of U.S.

shipments

(percent)

Lead time

(days)

1

Share of U.S.

shipments

(percent)

Lead time

(days)

1

U.S. inventory *** *** 96.6 6

U.S. production *** *** - -

China inventory/production *** *** 3.4 59

Total 100.0 100.0

 1

 Average lead times were rounded to the nearest full day.

U.S. MARKET CHARACTERISTICS

U.S. demand for ironing tables, principally a household consumer product, is driven largely by

consumer preferences, where price, design, and quality features are important. Demand for metal-top

ironing tables may also be affected by consumer demand for substitute products such as plastic-top

ironing tables, tabletop ironing boards, ironing pads, hand steamers, over-the-door ironing boards and, to

a lesser extent, wall-mounted ironing boards, and by demand for alternatives such as wrinkle-free clothing

and dry cleaning services.

The T-leg ironing tables, including domestic and imported ironing tables, are the predominant

type purchased in the United States. Perforated tops versus mesh tops may be differentiating features in

ironing tables, but reportedly more so at the high-end of the market; a full discussion of the two different

styles of tops appears in Part V. The mesh-top ironing tables may provide a more desirable ironing

surface3

 than perforated-top ironing tables. The U.S. producer offers primarily T-leg ironing tables with a

perforated top but also some mesh-top tables, whereas the importers of the Chinese ironing tables offer

only the mesh-top ironing tables and reportedly offer more diversity in the styles of ironing tables.

Supplier brand-name ironing tables may offer more features and higher price points than retailer

private-label ironing tables, especially where brand-names have consumer recognition. HPI sells the vast

majority of its ironing tables as private label products.4

 An importer, Polder, sells mostly brand-name

ironing tables that it imports from China;5

 *** two other major importers of the Chinese ironing tables,

***, sell mostly *** products.6

 

 3 Mesh-top ironing tables reportedly allow for increased passage of steam compared to perforated-top ironing

tables.

 4

 HPI’s posthearing brief, p. A-41.

 5

 Hearing transcript, p. 139-140 (Scott).

 6

 *** reported their imports of metal-top ironing tables by private label versus brand name during 2004-09. ***

reported that all of its imported ironing tables from China during this period were *** tables (e-mail from ***, April

20, 2010). *** reported that *** tables (e-mail from ***, April 20, 2010). 

II-3
Purchases of Ironing Tables Before and After the Order

Seven of the 13 responding U.S. purchasers of ironing tables reported that they purchased the

imported ironing tables from China prior to the 2004 application of the antidumping duty order on the

subject product from China.7

 Three of these seven firms indicated that they have not changed their

purchase patterns since 2004, another firm, ***, indicated that it discontinued its purchases due to the

antidumping duty order, two other firms, ***, indicated that they changed their purchase pattern for other

reasons, and the remaining firm did not comment. *** indicated that it increased its purchases of the

imported ironing tables from China due to the styles available and sales performance. *** indicated that

it increased its purchases due to sales volume.8

Four of six purchasers who had not purchased the imported ironing tables from China prior to

2004 reported in their questionnaire responses that they began purchasing the Chinese ironing tables after

the antidumping duties were imposed. Only one of the four firms, ***, offered an explanation. The firm

indicated that it began buying the Chinese ironing tables because the Rowenta brand ironing tables were

not available from the U.S. producer, but the retailer has since reduced its purchases because it now has

fewer retail outlets.

Information on Suppliers of Ironing Tables

U.S. purchasers were requested to provide information in their questionnaire responses on their

suppliers of ironing tables during 2004-09. Their responses are summarized in the following discussion.9

Purchasers were requested to identify the number of suppliers that they contact in making a

purchase of ironing tables. Of the 11 purchasers (all retailers) responding, nine reported contacting from

2 to 3 suppliers, one firm reported contacting 4 suppliers, and the remaining firm, ***, reported

contacting 10 suppliers.

Purchasers were requested to indicate if their purchases of ironing tables involved negotiations

with their suppliers. Of the 12 purchasers responding, 2 indicated no and the remaining 10 indicated that

they negotiate with their suppliers. Negotiations include factors such as price, quantity, delivery

schedules, timeliness, and product specifications/features; none of the responding purchasers reported

quoting competing prices while several of the firms specifically indicated that they do not share

competing prices. Five of the firms specifically noted that larger quantities purchased resulted in volume

discounts.

Purchasers were requested to indicate if they vary purchases of ironing tables from a given

supplier within a specific time period based on the price offered during that period. Of the 11 purchasers

responding, 9 indicated no and 2 indicated yes. One of these latter two firms, ***, provided an

explanation. The firm indicated that if it received a better price quote from that of its current supplier, it

would request that the current supplier lower its price.

Purchasers were asked if they changed suppliers of ironing tables since 2004. Of the 12 firms

responding, 4 indicated no and 8 indicated yes. The latter 8 purchasers each reported generally dropping

and adding one supplier. *** reported that suppliers change infrequently and the change is usually based

 7 U.S. purchaser questionnaire responses, section II-3.

 8

 One of the U.S. purchasers, ***, which indicated that its purchase pattern of ironing tables from China had not

changed during 2004-09, actually *** ironing tables from China. This firm indicated that its Chinese supplier ***. 

 9

 The 13 firms returning useable questionnaire responses reported having marketing knowledge of ironing tables

sold in the United States that were produced domestically and imported from China, Germany, India, Italy, and the

Netherlands. On the other hand, *** later reported that it had imported *** ironing tables from Taiwan during ***,

but it did not know the producer(s) in Taiwan as it purchased these products *** (staff telephone interview with

***). 

II-4
on new products offered, or, as with ***, its reported Chinese supplier, ***, was dropped because the

company ***. *** reported that it changed its supplier to obtain a comprehensive ironing table and

laundry accessory program from a single supplier at a good price.

Purchasers were asked if they were aware of any new suppliers of ironing tables, either domestic

or foreign, since 2004, and whether they expected new suppliers to enter the market in the future. On the

question of any new suppliers since 2004, 8 of the 12 responding purchasers reported no and 4 reported

yes. The new suppliers cited by the latter 4 purchasers were typically new to the responding firm, not

necessarily new in the market. New suppliers that were identified included Speedomax in India, as well

as Honey Can Do and Whitney Designs in China. On the question of expected new suppliers in the

future, all nine of the responding purchasers reported none.

Purchasers were requested to indicate whether they required their suppliers of ironing tables to be

certified or prequalified. Four of the 10 responding purchasers required their suppliers to be qualified,10

and the six remaining firms did not require qualification. One of the four firms requiring qualification,

***, provided additional comments and reported qualifying its suppliers based on the vendors’ financial

history and a site inspection by *** to assure the vendors have proper quality assurance measures in place

and capability to manage and produce the required volume. The remaining three purchasers requiring

qualifications and the six not requiring qualifications all relied on product quality testing of their

suppliers. All of the responding purchasers reported that their suppliers, domestic and foreign, had never

failed when qualifying their ironing tables.

SUPPLY AND DEMAND CONSIDERATIONS11

U.S. Supply12

U.S. Production

Based on available information, HPI may have had the ability to respond to changes in U.S.

demand with substantial changes in the quantity of shipments of its U.S.-produced ironing tables to the

U.S. market during 2004-09. *** was the major factor contributing to this degree of responsiveness of

supply; the relevant factors are discussed below.13

Industry capacity

Based on HPI’s reported fixed domestic capacity during 2004-09 and increasing production

during 2004-07, its capacity utilization for ironing tables increased from *** percent in 2004 to ***

percent in 2007, but decreasing production thereafter led to decreasing capacity utilization, which was

*** percent in 2009. This level of capacity utilization indicates that the U.S. producer of ironing tables

 10 The quantity of reported purchases of ironing tables in 2009 requiring qualification accounted for 9.5 percent of

total reported purchases of ironing tables in that year.

 11 Short-run effects discussed in the supply and demand sections refer to changes that could occur within 12

months, unless otherwise indicated.

 12 Data on U.S. ironing table production, production capacity, capacity utilization, inventories, and exports are

shown in detail in Part III.

 13 HPI reported in its questionnaire response that ***.

II-5
may have had a *** amount of *** with which it could increase production of ironing tables in the short

run in the event of an increase in demand during 2004-09.14

Inventory levels

HPI reported its end-of-period inventory quantities of its U.S.-produced ironing tables, which

decreased *** during 2004-09 as a share of total shipments. End-of-period inventories ranged from a ***

of *** percent of total shipments in 2009 to a *** of *** percent during 2006. The flexibility to use

inventories to respond to price changes in the short run may be restrained to the extent that the U.S.

producer’s inventories consist of products that are not required by the increased demand, or consist of

products already committed to customers in the U.S. market. HPI reported in its questionnaire response

that ***. As a result, HPI may be constrained in its ability to use reported inventories to increase supply

flexibility in the short run.

Alternate markets

HPI reported *** exports (***) of its U.S.-produced ironing tables during 2004-09, which

averaged *** percent of its total shipments during this period.15 As a result, such exports may *** the

supply flexibility of the U.S. producer in the short run, but only to the extent that its exported ironing

table products consist of products useable/acceptable in the U.S. market, or consist of products not

already committed to customers in its export markets.

Production alternatives

HPI reported in its questionnaire responses that it produced *** on some of the same equipment

and with the same labor that were used to produce the subject ironing tables in the United States; this ***

accounted for *** percent of its sales in 2009. Because of *** alternative production, its impact on HPI’s

ability to change production of ironing tables and the impact on measures of capacity and capacity

utilization for U.S.-produced ironing tables may ***.

Supply of Imported Ironing Tables from China to the U.S. Market

Based on responses of six Chinese producers of ironing tables, staff believes that Chinese

producers of ironing tables may have had some ability to respond to changes in U.S. demand with

changes in shipments of ironing tables to the U.S. market during 2004-09. The main contributing factor

to this supply flexibility is large third-country shipments; the relevant factors are discussed below.

Nine U.S. importers commented in their questionnaire responses on the availability of Chinese

ironing tables in the U.S. market during 2004-09 and on the anticipated availability of these U.S. imports

in the future. During the historical period, all nine firms indicated that availability of the ironing tables

from China decreased after the initial antidumping duty orders went into affect in 2004 and decreased

again in 2009 when the antidumping duties on ironing tables from two principal Chinese exporters of

ironing tables to the United States (according to the importers), Since Hardware and Foshan Shunde,

increased markedly. The decrease in availability during 2004-09 reportedly involved lower supply,

higher prices, and limited design options of the imported ironing tables from China. Two of the

 14 This supply flexibility may be constrained to the extent that there is any limited capability of the U.S. producer

to produce the required types/styles and sizes of ironing tables demanded.

 15 *** reported that ironing tables are difficult to export because of their weight and the space they occupy. ***

asserted that *** (HPI’s posthearing brief, exhibit 4). 

II-6
responding importers, ***, indicated that the only viable Chinese factory for ironing tables with a zero

duty rate is Forever Holdings, but it reportedly has an exclusive distribution agreement with a U.S.

supplier, believed by these two importers to be HPI.16

Five of the nine responding importers commenting on anticipated changes in the future

availability of the imported Chinese ironing tables in the U.S. market indicated no change, while three

importers anticipated decreased availability, and the remaining importer indicated that it did not know

what the future availability would be since it would be determined by the outcome of the Commission’s

review and future Commerce administrative reviews.17 The anticipated decrease in future availability of

the Chinese ironing tables was based largely on the increased duty rates for the two main Chinese

suppliers in late 2009.18

Industry capacity

Six Chinese producers reported the requested trade data and their combined capacity utilization

for ironing tables fluctuated but averaged 85.9 percent during 2004-08, before decreasing to 70.7 percent

in 2009.19 This level of capacity utilization, especially in 2009, indicates that Chinese producers of

ironing tables had available capacity with which they could increase production of ironing tables in the

short run in the event of a change in demand.

Three of the five responding Chinese producers reported producing several other products on the

same equipment and machinery that they used to produce ironing tables, such that measures of capacity

and capacity utilization for each type of product, including ironing tables, may be subject to allocations

and may change as relative prices and demand for the various types of products change.

Inventory levels

The six responding Chinese producers of ironing tables reported combined end-of-period

inventories in China that increased during 2004-09, ranging from 1.8 percent of total shipments in 2005 to

6.1 percent in 2009. These data indicate that Chinese producers may have an ability to use inventories as

a means to increase shipments to the U.S. market in the short run. This flexibility may be restrained in

the short run to the extent that Chinese producers’ inventories consist of products not useable/acceptable

in the U.S. market, or consist of products already committed to customers in home and/or third-country

markets.

U.S. importers’ end-of-period inventories of the Chinese ironing tables in the U.S. market during

2004-09 ranged from *** percent of total shipments of such imports in *** to *** percent in ***. Seven

of eight responding U.S. importers reported in their questionnaire responses that they had no supply

commitments or other restrictions to using their inventories to increase shipments to the U.S. market. The

remaining importer, ***, reported that it had a number of quantity-specific short-term sales programs that

 16 U.S. importer questionnaire responses, section III-27; and hearing transcript, p. 11 (Perry).

 17 This latter importer, ***, further commented that it was confident that either this review will determine no

injury by the Chinese ironing tables to the U.S. industry or that multiple Chinese producers will be deemed to be

importing at an acceptable duty rate. 

 18 Four of five responding Chinese producers reported in their questionnaire responses that they anticipate no

change in future availability of Chinese ironing tables in the U.S. market, whereas the remaining producer indicated

that, if the antidumping duty is removed, it will increase business volume.

 19 Chinese capacity to produce ironing tables increased by 53.8 percent during 2004-08, but decreased by almost

16.0 percent in 2009 from the level in 2008.

II-7
locked up item-specific inventory of ironing tables.20 These data indicate that U.S. importers have an

ability to use inventories as a means to increase shipments of the Chinese ironing tables in the U.S.

market in the short run.

Alternate markets

Combining responses of the six reporting Chinese producers of ironing tables showed that their

products were shipped principally to third-country markets,21 secondarily to the U.S. market, and thirdly

to the home country market (the latter includes internal consumption/transfers) during 2004-09.22 These

data indicate that Chinese ironing table producers have large third-country markets and, to a lesser extent,

the home market, from which they may be able to shift shipments of ironing tables to the United States in

the short run in the event of a change in demand in the U.S. market. This flexibility may be restrained in

the short run to the extent that Chinese producers’ sales of ironing tables exported to third-country

markets and/or to their home market were not used/acceptable in the U.S. market, or to the extent that

Chinese producers have binding supply agreements longer than 12 months with customers in thirdcountry and/or home markets.

Production alternatives

Three of the five responding Chinese producers reported producing several other products on the

same equipment and machinery that were used to produce ironing tables; the two remaining Chinese

producers (***) reported producing only ironing tables. These other products represented *** percent of

sales of these three firms in the most recent year. The three firms also indicated that they were able to

shift production between ironing tables and the other products.23 The ability of Chinese producers to shift

production between ironing tables and other products enhances their supply responsiveness in the short

run in response to relative price changes between ironing tables and alternative production products.

 20 *** U.S. inventories averaged about *** percent of total U.S. importers’ end-of-period inventories of the

Chinese products during 2004-09. This left a substantial amount of the other importers’ inventories available to

increase shipments to the U.S. market.

 21 The European Union (EU) was the principal third-country market for Chinese ironing tables during 2005-09. 

The EU had imposed antidumping duties on many Chinese producers of ironing tables ranging from 18.1 to 38.1

percent in 2006. However, recent actions by the EU may change the impact of these duties. In 2009 the EU lifted

the order on Foshan Shunde (though an investigation of this company was subsequently re-opened). In early 2010

the EU completed a new shipper review and assessed a 22.7 percent duty on imports of Chinese ironing tables

produced by Greenwood Houseware (Zhuhai); this rate is lower than the EU-wide rate. (Various issues of the

Official Journal of the European Union, April 26, 2007, LI09/12; October 2, 2009, C 237/5; December 18, 2009, C

308/44; and January 28, 2010, L24/1).

 22 During 2004-09, exports to third-country markets averaged *** percent of Chinese producers’ total ironing

table shipment quantities; shipments to the U.S. market averaged *** percent; and shipments to the home market

accounted for the remaining *** percent. For third-country shipments, the European Union accounted for ***

percent of total Chinese ironing table shipments to third-countries during this period, other non-Asian markets

accounted for *** percent, and non-China Asian countries accounted for *** percent of the total.

 23 One of these Chinese producers, ***, indicated that its production process was engineered as a flexible

production system, enabling the firm to change product mix in a flexible way.

II-8
Imports from Nonsubject Countries

Based on questionnaire responses, U.S. imports of ironing tables from countries other than China

decreased markedly from *** units in 2004 to *** units by 2009, or by *** percent. Responding U.S.

importers identified the following nonsubject countries as sources of ironing tables imported into the U.S.

market: Germany, India, Italy, Latvia, Spain, Taiwan, and The Netherlands.

HPI and five U.S. importers of ironing tables reported in their questionnaire responses how the

availability of ironing tables from nonsubject countries changed in the U.S. market during 2004-09. ***

indicated that such availability had not changed, while *** reported some change and noted the presence

of ironing tables in the U.S. market from Taiwan and/or India. On the other hand, *** indicated that it

has not been able to identify any ironing table producers in Taiwan. In addition, at the hearing HPI and

Polder reported that they were not aware of any U.S. imports of the subject ironing tables from Mexico

and Polder also indicated that it was not aware of any imports from Taiwan.24

HPI and six U.S. importers also reported on the anticipated availability of ironing tables in the

U.S. market from nonsubject countries. *** expected no change in the future availability of ironing

tables from nonsubject countries, and *** expected an increase, primarily from India and Vietnam. One

of the importers expecting an increase, ***, asserted that it expected a major shift of U.S. imports of

ironing tables from China to India in 2010, which it expected to continue over the next decade as new

factories arise in India.25 Another responding importer, the ***, reported that in 2010 it added *** from

India as a source of its ironing tables.26 Two of the importers expecting no change, ***, gave the

following two reasons: (1) HPI reportedly would lower its prices in the face of any increase in imports of

ironing tables from nonsubject countries; and (2) the dollar exchange rate reportedly will limit such

exports to the U.S. market.

U.S. Demand

Demand for ironing tables, as measured by annual apparent U.S. consumption, fluctuated but

decreased during 2004-09, by approximately *** percent on a quantity basis during this period. This

downturn in demand was particularly strong in 2009, when apparent U.S. consumption fell by ***

percent from the previous year.

Overall U.S. demand for ironing tables, primarily a consumer durable product,27 reportedly 

moves with general economic activity in the U.S. economy and,28 in particular, with household formation

and home purchases.29 U.S. demand for ironing tables also exhibits seasonal variation as reported by HPI,

 24 Hearing transcript, p. 56 (Volles) and p. 141 (Scott).

 25 *** reported that metal-top, floor-standing ironing table capacity in India for export to the U.S. market is ***.

 26 *** U.S. importer and purchaser questionnaire responses, sections III-28 and II-3/III-15, respectively.

 27 Due to the durability of ironing tables, consumers would be expected to replace these products infrequently; the

major exception would be due to frequent changes in styling/features, which does not appear to occur with ironing

tables (*** purchaser questionnaire responses, section III-5c). As a result, replacement demand is likely a small part

of total demand for ironing tables.

 28 Demand for consumer durable goods, especially at the higher price points, generally has a tendency to be

income elastic. An exception may be that, with a downturn in the economy, some consumers may purchase ironing

tables as a substitute for more expensive dry cleaning services (hearing transcript, pp. 142-143 (Cooper and Scott)). 

Such countercyclical demand is likely a small part of total demand for ironing tables.

 29 Ironing Tables and Certain Parts Thereof from China, Inv. No. 731-TA-1047 (Final), USITC Publication 3711,

July 2004, p. II-3, fn. 9.

II-9
seven of the eight responding U.S. importers, and 4 of the 11 responding purchasers.30 Retailer demand is

reportedly high during the summer months reflecting new household formation and back-to-college

purchases, and household consumer demand is high during the summer and into the fall, with some uptick

in consumer demand during March-April, when care for clothes reportedly increases.31 Retailer and

consumer demand tends to be low after the back-to-college purchases, particularly during OctoberDecember, including the Christmas holiday season.32 33

Business Cycles

HPI reported in its questionnaire response that ironing tables are a consumer durable good, which

makes demand for this product subject to cyclical fluctuations. The firm further stated that durable goods

purchases are often deferrable and tend to fall during economic downturns, which is true for ironing

tables. HPI asserted that its ironing table sales ***, reflecting the cyclical downturn in consumer durables

caused by the recession.

U.S. real gross domestic product (GDP), real personal consumption expenditures for durable

goods, and housing starts during 2004-09 are shown in figure II-1 for quarterly real GDP and durable

goods expenditures,34 and figure II-2 for annual housing starts.35 U.S. quarterly real GDP and durable

goods expenditures generally increased during 2004-07, reaching period highs during the fourth quarter

of 2007, but decreased throughout 2008. During 2009, quarterly real GDP decreased during the first two

quarters and increased in the last two quarters, whereas durable goods expenditures increased in the first,

third, and fourth quarters but decreased in the second quarter. Despite some recovery during 2009, real

GDP and durable goods expenditures remained below their period highs. Although not shown in table II1, quarterly real GDP and durable goods expenditure are forecast to increase throughout 2010; real GDP

is forecast to recover to its period high by the third quarter of 2010.36 Annual U.S. housing starts

increased in 2005 from the level in 2004, but declined steadily thereafter through 2009. Not shown in

figure II-2, housing starts are forecast to increase in 2010, but remain below their period high in 2005.37

 30 U.S. producer, importer, and purchaser questionnaire responses, sections IV-31, III-29, and III-29, respectively.

 31 In recent years, some retailers reportedly attempted a January spring cleaning event to try to increase sales. 

However, that did not drive incremental sales, it simply shifted first quarter sales a little bit earlier in the year

(hearing transcript, p. 27 (Volles)).

 32 Hotel industry demand for ironing tables reportedly peaks during May-August and is the lowest during

November-February.

 33 A single importer and two purchasers provided some additional information regarding peak season demand

periods in their questionnaire responses. The importer, ***, reported that promotional activities of retailers at the

opening price points during seasonal upswings result in less demand for moderate and upscale ironing tables. A

retailer/purchaser, ***, reported that it increases advertising during the peak consumer demand periods, and another

retailer/purchaser, ***, reported that it purchases higher volumes of ironing tables for its back-to-college program,

for which it receives a volume discount (from ***).

 34 U.S. quarterly real GDP and durable goods expenditures are seasonally adjusted annual rates based on chained

2005 dollars; National Income and Product Accounts–Table 1.1.6, Real Gross Domestic Product, Chained Dollars,

Bureau of Economic Analysis, DOC, http://www.bea.gov/national/nipaweb/, retrieved March 23, 2010.

 35 U.S. annual housing starts are based on data from Annual Housing Starts, National Association of Home

Builders, http://www.nahb.org, retrieved March 23, 2010; New Privately-Owned Housing Units Started, U.S. Census

Bureau, http://www.census.gov/const/startsua/pdf, retrieved March 23, 2010.

 36 Blue Chip Economic Indicators, Aspen Publishers, Inc., Vol. 35, No. 4, April 10, 2010, p. 5.

 37 Blue Chip Economic Indicators, Aspen Publishers, Inc., Vol. 35, No. 4, April 10, 2010, p. 2.

II-10
Figure II-1

U.S. real gross domestic product (GDP) and durable goods’ expenditures: Real GDP and personal

consumption expenditures for durable goods, quarterly, 2004-09

Note.--Real values are seasonally adjusted at annual rates and based on chained 2005 dollars.

Source: National Income and Product Accounts–Table 1.1.6, Real Gross Domestic product, Chained Dollars, Bureau

of Economic Analysis, DOC, http://www.bea.gov/national/nipaweb/, retrieved March 23, 2010.

II-11
Figure II-2

U.S. housing starts: Number of new housing starts, annually, 2004-09

Source: For 2004-08--Annual housing starts, National Association of Home Builders, http://www.nahb.org, retrieved

March 23, 2010; and for 2009--New Privately-Owned Housing Units Started, U.S. Census Bureau,

http://www.census.gov/const/startsua/pdf, retrieved March 23, 2010.

Questionnaire Responses Concerning Changes in U.S. Demand

HPI, U.S. importers, and purchasers were requested to indicate in their questionnaire responses

whether U.S. demand for ironing tables increased, decreased, fluctuated, or did not change since January

2004 and how they anticipate this demand will change in the future. Responses were mixed regarding

U.S. demand. Useable responses are summarized in the following tabulation.

U.S. demand changes for ironing tables

Types of firms

Number of firms responding

Increase Decrease Fluctuate No change

U.S. demand changes since January 2004

U.S. producers *** *** *** ***

U.S. importers *** *** *** ***

U.S. purchasers *** *** *** ***

Total 1 6 4 7

Types of firms U.S. demand changes anticipated in the future

U.S. producers *** *** *** ***

U.S. importers *** *** *** ***

U.S. purchasers *** *** *** ***

Total 1 5 0 13

II-12
The questionnaire responses most frequently indicate that U.S. demand for ironing tables has not

changed since 2004, followed closely by responses that demand has decreased. The majority of responses

for anticipated future U.S. demand for ironing tables, led by purchasers, indicate no change in future

demand, followed by responses that demand will decrease in the future.

With regard to historical U.S. demand for ironing tables, the responding firm that indicated

increased demand referred only to hotel/motel demand and cited increased occupancy rates and available

rooms. The responding firms that indicated decreased demand cited the slowdown in household

formation, continuing development of wrinkle-free textiles, the downturn in the U.S. economy in 2008

and 2009, the longevity/durability of medium and upper-price ironing tables requiring fewer

replacements, and the higher prices of ironing tables decreased demand, especially in the recent economy. 

The responding firms that indicated fluctuating demand cited reasons such as the downturn in the

economy and, a single purchaser, ***, asserted that new technology in non-wrinkle fabrics has created a

soft sales category in ironing tables. The responding firms that indicated no change in demand typically

did not cite reasons.

Concerning future U.S. demand for ironing tables, the responding firm that indicated increased

demand referred only to hotel/motel demand and cited increased demand as the economy recovers in

2010. The responding firms that anticipate decreased future demand cited a continually declining demand

for ironing tables as availability of wrinkle-free clothing increases, continuing low economic growth, and

a trend toward smaller homes leading to increased demand for other types of ironing surfaces and less

demand for ironing tables. The responding firms that anticipate no change in demand typically did not

cite reasons except for ***, which asserted that ironing table demand is flattening at about *** per year as

housing starts are not expected to rise at a fast rate in the near term.

Substitute Products

The existence of substitutes and the durable nature of ironing tables suggest that U.S. household

consumers and commercial users of ironing tables are likely to respond to changes in the prices of ironing

tables with low to moderate changes in their total purchases of ironing tables, such that the price elasticity

of demand for ironing tables may range from inelastic to somewhat elastic.38 On the other hand, the low

cost share of ironing tables in consumer and commercial user budgets may tend to reduce the price

elasticity of demand.

HPI, U.S. importers, and purchasers identified and discussed in their questionnaire responses

substitutes for ironing tables in the U.S. market during 2004-09, any changes in substitutes during this

period, and any anticipated changes in substitutes in the future. HPI, six of the seven responding U.S.

importers, and 8 of the 10 responding U.S. purchasers identified substitutes/alternatives, whereas the

remaining single importer and the two remaining purchasers indicated that there were no substitutes for

ironing tables. The substitute products/alternatives and the number of responses identifying the products

are shown in the following tabulation.

 38 The price elasticity of demand for a particular product is higher the greater the number of substitutes. In

addition, the price elasticity of demand for consumer durables is generally higher than that for consumer

nondurables.

II-13
Substitutes/alternatives for ironing tables

(Number of responses)

Type of substitute/alternative

U.S.

producer

U.S.

importers

U.S.

purchasers Total

Table/counter top ironing boards *** *** *** 9

Over-the-door ironing boards *** *** *** 6

Built-in/wall-mounted ironing

boards *** *** *** 4

Pads/mats for ironing on tables *** *** *** 3

Hand-held garment steamers *** *** *** 2

Non-steel top ironing tables1 *** *** *** 1

All other ironing boards *** *** *** 1

Dry cleaning *** *** *** 1

Wrinkle-free/iron-free

clothing/fabrics *** *** *** 1

 Total *** *** *** 28

 1 Respondent interested parties (Polder, Whitney Design, and Since Hardware) asserted that

plastic-top ironing tables are replacing metal-top ironing tables, particularly in the lower price points,

because the plastic-top tables are lighter and will not rust vis-a-vis the metal-top tables (respondent

interested parties’ prehearing brief, pp. 15-17 and appendix PH-8). In addition, HPI imports a plastictop ironing table from China called the Revolution 360, which is produced by *** (HPI’s posthearing

brief, exhibit 2, attachment 3). In addition, websites, such as those of HSN and Bed Bath & Beyond,

feature the Revolution 360 ironing table and HSN’s website indicates that it is produced in China

(http://home-solutions.hsn/homez-revolution-360-ironing-board-with-insert-and clip_p-5364550_xp...,

and http://www.bedbathandbeyond.com/product.asp?order_num=-1&SKU=16424501).

Note.–Some responding firms reported more than one alternative product.

Substitutes/alternatives to ironing tables that more than one firm cited are, in descending order,

the following: table/counter-top ironing boards, over-the-door ironing boards, built-in/wall-mounted

ironing boards, table ironing pads/mats, and hand-held garment steamers. All of the responding firms

identifying substitutes/alternatives indicated that these products were used by households and/or students,

but that changes in the prices of the substitutes/alternatives did not affect the price for ironing tables. ***

provided follow-up comments on the substitutes/alternatives. *** asserted that ***.39 *** asserted that

the substitute/alternative products are not perfect substitutes and, as a result, do not work in the same way

as an ironing table and many have operational constraints that prevent the end user from using the

products in the same manner as an ironing table.

 39 *** cited in its questionnaire response the following ConsumerSearch article: “Most experts agree that a

garment steamer cannot completely replace an iron for all of your clothing. The Good Housekeeping review notes

that while garment steamers can be an alternative for a traditional steam iron, garment steamers struggle with sharp

creases and stiff fabrics, like dress shirts. An advantage to garment steamers is that a quick steam can refresh

garments between dry cleanings, perk up creased coats taken out of storage, and smooth wrinkles from a rarely worn

cocktail dress (Garment Steamers at http://www.consumersearch.com/garment-steamers/review, October 2009).

II-14
Six of the seven responding U.S. importers and eight of the nine responding purchasers reported

that no changes occurred in substitutes/alternatives for ironing tables during 2004-09, whereas HPI, one 

U.S. importer, and one purchaser reported changes during this period and provided follow-up comments. 

HPI indicated that ***. An importer, ***, noted the following three changes in substitutes/alternatives: 

(1) increased availability of wrinkle-free clothing at all price points; (2) hardware supercenters carry

built-in DIY ironing boards (Home Depot, Lowes, and Menards); and (3) mini boards and pressing cloths

are available on the internet. A purchaser, ***, remarked that hand-held garment steamers have increased

in popularity. 

HPI, six of the eight responding U.S. importers, and 9 of the 10 responding U.S. purchasers

reported that they anticipated no changes in substitutes/alternatives for ironing tables in the future,

whereas two U.S. importers and a single U.S. purchaser anticipated changes in the future. One importer,

***, which anticipated future changes, provided additional information. The importer asserted that very

few consumers take pleasure in ironing such that technological advances in clothing will further reduce

the need for ironing.

At the hearing, both HPI and an importer, Polder, provided additional discussion of plastic-top

ironing tables as a possible substitute for metal-top ironing tables currently and in the future.40 Plastic-top

ironing tables appear to be a relatively new and currently a limited product in the U.S. market.41 HPI

indicated that its imported plastic-top ironing table, the Revolution 360,42 is priced higher than its

professional metal-top ironing table and, because the plastic top can be rotated, does not compete with

any of its metal-top ironing tables.43 HPI also indicated that its Revolution 360 ironing table positions the

firm in the marketplace as an innovative leader.44 HPI further states that it has seen few plastic-top

ironing tables in the U.S. market, that it does not know if the consumer will accept such an ironing table,

and that it does not expect much growth in the market place for this product in the foreseeable future.45

On the other hand, Polder indicated that plastic-top ironing tables have been imported into the U.S.

market by several firms and are sold across the product range (from T-leg to more expensive boards) in

direct competition with metal-top ironing tables at price points similar to the metal-top tables.46 HPI and

 40 Both companies indicated that plastic-top ironing tables are being imported into the U.S. market to avoid the

antidumping duty order on metal-top ironing tables from China (hearing transcript, p. 64 (Ikenson) and p. 130

(Cooper)). Polder indicated advantages of the plastic-top table in that it is lighter and can be shaped more easily than

the metal-top table (hearing transcript, p. 128, (Cooper)).

 41 Polder indicated that, although new in the U.S. market, plastic-top ironing tables have been widely accepted for

quite some time in Asia, Japan, and parts of the Middle East (hearing transcript, pp. 128-129 (Scott)).

 42 HPI indicated that it has one version of this product produced in China and another version produced in Korea

(hearing transcript, p. 102 (Volles)).

 43 Hearing transcript, p. 63 (Volles).

 44 Ibid.

 45 Hearing transcript, pp. 63 and 65 (Volles). HPI reported that it *** (HPI’s posthearing brief, exhibit 2,

attachment 3).

 46 Hearing transcript, pp. 117 and 127-128 (Scott). *** reported importing *** floor-standing plastic-top ironing

tables from China in 2009. In addition, *** reported importing *** floor-standing plastic-top ironing tables from

China during January-March 2010 and selling *** of these tables during this period. (E-mail from ***, April 20,

2010.) 

II-15
Polder indicated that the cost of plastic is higher than the cost of steel on a per pound basis,47 and Polder

noted that the cost of plastic and steel both fluctuate.48 

Cost Share

The cost share of ironing tables relative to the total budget of household consumers and

commercial users is likely low. HPI, U.S. importers, and purchasers commented in their questionnaire

responses on the cost share of ironing tables in household consumer budgets and in commercial user

budgets. The responding U.S. importers and purchasers indicated that either these cost shares were low

or they did not know the cost shares. *** provided the most complete response. For households, ***

indicated that ironing tables are a relatively small share of household budgets because of their low price

and durability (lasting 10 years or more). *** asserted that a large proportion of ironing tables are

purchased when setting up a new household and the cost of an ironing table is small relative to other costs

in a new home. For hotels and motels, *** cited a recent hotel survey that showed the cost of furniture,

fixtures, and equipment in a hotel room ranges from $8,500 to $23,200,49 such that a $15 to $30 ironing

table would represent a minuscule portion of that budget. 

SUBSTITUTABILITY ISSUES

The degree of substitution in demand between ironing tables produced in the United States and

ironing tables imported from China depends upon such factors as relative prices, conditions of sale (e.g.,

delivery lead times, reliability/availability of supply, technical service, etc.), purchaser supply

requirements, qualified status of supplier, and product differentiation. Product differentiation among

different ironing tables depends on factors such as physical characteristics (e.g., sizes, types (perforatedversus mesh-top), T-leg versus 4-leg or other leg designs, accessories, etc.), brand name recognition,

consumer preferences, and the market perception of these factors. Based on the reported information in

this review, there appears to be at least moderate substitution in demand between domestic ironing tables

and those imported from China.

HPI and U.S. importers of the subject ironing tables were requested to describe in their

questionnaire responses any significant changes in the product range, product mix, or marketing of

ironing tables in the United States since January 2004 and any anticipated future changes. With respect to

any historical changes, *** reported no changes, but *** reported some changes since January 2004. The

changes identified included the following: (1) ironing table brands are now made with recycled steel; (2)

more decorative ironing tables available with powder coated legs; (3) since the 2004 antidumping duty

order prices for ironing tables have increased, which recently channeled new sales to less expensive

models; (4) when the economy was growing, high-priced ironing tables were popular as retailers tried to

increase their margins with these products; and (5) less innovation has been brought to the ironing table

market place. 

 47 Household Essentials reported that there is more plastic material than steel in a mesh-top ironing table. The

firm also indicated that plastic-top tables cannot be produced as quickly as perforated-top tables, but plastic top

tables are more ergonomically designed than the perforated metal-top tables. Respondent interested parties’

posthearing brief, p. 26.

 48 Hearing transcript, pp. 9 and 64 (Ikenson and Volles), and pp. 130 and 150 (Cooper and Scott).

 49 The survey referred to is the following: “Elaine Sahlins, Hotel Development Cost Survey, 2009,” reported on

November 17, 2009 at www.hvs.com (***). 

II-16
With respect to any anticipated future changes, *** reported that they expected no changes.50 ***

cited some expected future changes, including the following: (1) an increase in the price of ironing

tables, particularly at the mid and low price points, if the antidumping duty order is continued; (2) sales of

high-end ironing tables mostly through the internet; (3) a temporary decrease in product range due to the

viable producers in China receiving increased duty-rates, with a reversal, likely as early as March 2010 as

ironing table production in India gears up;51 (4) a decrease in ironing table demand as clothing technology

improvements continue to eliminate the need for ironing; and (5) a switch to smaller ironing boards

(tabletop, etc.) as an asserted trend toward smaller homes continues.

At the hearing, both HPI and an importer, Polder, discussed competition between private (retailer)

label ironing tables and supplier brand-name ironing tables in the U.S. market. HPI and Polder indicated

that large retailers (Walmart, Target, K-Mart, etc.) sell principally their own private label ironing tables,

whereas smaller retailers sell mostly the brand name ironing tables.52 Although HPI and Polder sell both

their brand name ironing tables (the Homz brand53 and Polder brand, respectively) and private label

ironing tables, HPI reported selling a majority of its ironing tables as private label ironing tables,54 while

Polder reported selling mostly its brand name ironing tables.55 According to HPI, the brand name does

not necessarily influence the price point of ironing tables.56 On the other hand, Polder reported that its

supplier brand name enables the firm to sell a higher-priced ironing board that is heavier with a wider

board and more features; whereas most of the private label brands retail for $30 and below.57

 50 Although *** indicated that the product range and mix will remain unchanged in the future, it reported that the

firm would continue to develop innovative ironing tables and improve the value of its ironing tables.

 51 A U.S. importer, ***, indicated in its questionnaire responses that it has been shifting its U.S. imports of

ironing tables from China to India, which will be completed by ***.

 52 Hearing transcript, pp. 57 and 91 (Volles) and p. 140 (Scott).

 53 HPI reported that ***; submitted separately on February 4, 2010 in response to question I-8 of the U.S.

producer questionnaire).

 54 In addition, HPI reported that, based on its annual sales values of the domestic ironing tables, it sells about ***

percent under private labels and *** percent under the Homz brand name (HPI’s posthearing brief, pp. A-41-42).

 55 Hearing transcript, p. 57 (Volles) and pp. 139-140 (Scott). Polder also indicated that other importers of ironing

tables from China tend to sell private label ironing tables (hearing transcript, p. 160 (Scott)). Two other large

importers of ironing tables from China, ***, reported their imports of these ironing tables by private label versus

brand name during 2004-09. *** reported that *** tables (e-mail from *, April 20, 2010). *** reported that ***

tables (e-mail from ***, April 20, 2010). 

 56 Hearing transcript, p. 75 (Volles).

 57 Hearing transcript, p. 140 (Scott) and p. 152 (Cooper).

II-17
Factors Affecting Purchasing Decisions

U.S. purchasers were requested in their questionnaire responses to list the top three factors that

they consider when deciding from whom to purchase ironing tables. Responses of the 12 reporting

purchasers are shown in the following tabulation.

Factors 

Number of purchasers responding

First

important

factor

Second

important

factor

Third

important

factor

Price 4 5 4

Quality 5 4 1

Availability 1 2 4

Reliable supplier 1 1 1

Complete laundry

accessory program 1 - -

Product features - - 1

Product line - - 1

Service - - 1

Note.–In addition to listing their top three factors, *** also reported reliability

and *** reported availability as additional factors considered by their firms.

As shown in the tabulation, price and quality were reported most frequently as the most important

and second most important factors, and price and availability were reported most frequently as the third

most important factor. Purchasers also reported that quality considerations of ironing tables included

construction of the top, thickness of steel in legs, ease of operation/locking mechanism, stability, silicone

iron rust coating, cover fabric/print, accessories/extra features, and appearance of the table and pad.

Thirteen U.S. purchasers responded to a request in the purchaser questionnaire to rank 15

specified purchase factors as ‘very important’, ‘somewhat important’, or ‘not important’. The total

number of responses is shown in table II-3 for each purchase factor. Three purchase factors--availability,

product consistency, and product quality meets standards--were considered most frequently to be ‘very

important’ purchase factors for ironing tables;58 these factors were followed closely by price and reliable

supply as ‘very important’. Product quality exceeds standards and technical support was considered most

frequently to be ‘somewhat important’, followed by minimum quantity requirements and product range. 

U.S. transportation costs was considered most frequently to be ‘not important’, followed by extension of

credit.

 58 Price, quality, and availability, in descending order, were reported as the top purchase factors in another part of

the purchaser questionnaire and were discussed earlier.

II-18
Table II-3

Ironing tables: Ranking of purchase factors, as reported by U.S. purchasers of ironing tables

Purchase factors Very important Somewhat important Not important

Availability * 13 - -

Delivery terms 9 4 -

Delivery time 9 4 -

Discounts offered 3 6 3

Extension of credit 3 6 4

Price * 12 1 -

Minimum quantity requirements 3 7 2

Packaging 6 6 1

Product consistency 13 - -

Product quality meets standards * 13 - -

Product quality exceeds standards 4 9 -

Product range 5 7 1

Reliable supply 12 1 -

Technical support 2 9 2

U.S. transportation costs 3 3 7

Note.–The top 3 purchase factors as discussed earlier are identified with asterisks.

Source: Compiled from data submitted in response to Commission questionnaires.

Comparisons of the Domestic Products and Subject Products from China from Third Countries

HPI, U.S. importers, and purchasers of ironing tables were requested in their questionnaire

responses to report on the extent of interchangeability among the various country sources of ironing

tables in the U.S. market. In addition, U.S. producers and importers were requested to report on the

extent of any differences other than price that would affect sales in the U.S. market among the various

country sources of ironing tables.

Responses of HPI, the eight reporting importers, and the 10 reporting purchasers regarding the

degree of interchangeability between domestic and imported ironing tables are summarized in table II-4. 

Responses of HPI and the five reporting importers regarding differences other than price affecting

competition are summarized in table II-5 for comparisons involving the U.S.-produced and imported

ironing tables.

HPI and the responding U.S. importers and purchasers generally reported that U.S.-produced 

ironing tables and those imported from China and third countries are generally ‘always’ or ‘frequently’

interchangeable. HPI reported that factors other than price were *** a factor in competition among the

domestic and imported ironing tables. On the other hand, responding U.S. importers reported more

frequently that such factors were always a factor, especially between the domestic and imported Chinese

ironing tables. Two importers, ***, indicated that quality, innovation, and a variety of options were other

important factors.

II-19
Table II-4

Ironing tables: Perceived degree of interchangeability among U.S.-produced ironing tables and 

those imported from China and third countries, based on sales in the U.S. market during 2004-09

Country pair

Number of U.S.

producers’ responses

Number of U.S.

importers’ responses

Number of U.S.

purchasers’ responses1

A FS N A F S N A F S N

United States vs.--

 China *** *** *** *** 2 2 2 1 6 1 - -

 Taiwan *** *** *** *** 2 1 - 1 1 - - -

 Other countries1 *** *** *** *** 1 1 1 1 1 - 1 -

China vs.--

 Taiwan *** *** *** *** 2 1 - 1 1 - - -

 Germany *** *** *** *** - - - - 1 - - -

 Italy *** *** *** *** - - - - - - 1 -

 Other countries1 *** *** *** *** 1 2 - 1 1 - - -

Taiwan vs.–

 Other countries1 *** *** *** *** 1 1 - 1 - - - -

 1 None of the responding firms identified specific other countries.

Note.--A = Always, F = Frequently, S = Sometimes, N = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

Table II-5

Ironing tables: Perceived degree of importance of differences in nonprice factors among U.S.-

produced ironing tables and those imported from China and third-countries, based on sales in the

U.S. market during 2004-09

Country pair

Number of U.S. producers’

responses

Number of U.S. importers’

responses

A F S N AF S N

United States vs.--

 China *** *** *** *** 4 - 1 -

 Taiwan *** *** *** *** - - 1 -

 Other countries1 *** *** *** *** 1 - 1 -

China vs.–

 Taiwan *** *** *** *** - - 1 -

 Other countries1 *** *** *** *** - - 1 -

Taiwan vs.–

 Other countries1 *** *** *** *** - - 1 -

 1 None of the responding firms identified specific other countries.

Note.--A = Always, F = Frequently, S = Sometimes, N = Never.

Source: Compiled from data submitted in response to Commission questionnaires.

II-20
Country of origin and producer identity do not appear to be important for U.S. retailers or

distributors of ironing tables. All 13 responding purchasers reported in their questionnaire responses that

the country of origin was ‘sometimes’ or ‘never’ important in their purchases of ironing tables.59 Ten of

13 responding purchasers reported that the identity of the producer of the ironing tables was ‘sometimes’

or ‘never’ important in their purchases of such products, whereas the 3 remaining firms reported that the

identity of the producer was ‘always’ or ‘usually’ important.60 Three retailer purchasers, ***, provided

some further explanation about when country-of-origin or the specific producer are important. ***

indicated country of origin would be considered if there were import restrictions. *** indicated that it

chose the *** brand of ironing table, so that the specific producer was important. *** indicated that for

its ***, it uses *** to respond quickly to market demand.61

All 12 responding purchasers reported in their questionnaire responses that they did not purchase

ironing tables from one country in particular over other possible sources of supply during 2004-09.62 In

addition, 10 of the 11 responding purchasers reported that certain types/sizes of ironing tables were not 

exclusively available from a single country source.63 The remaining responding purchaser, ***, reported

that better higher-end ironing tables with additional features were offered from China.

Purchasers were requested in their questionnaire responses to make country-of-origin

comparisons among the domestic ironing tables and those imported from China and third countries for

which they have market knowledge based on the 15 specified purchase factors discussed earlier, and to

indicate for each purchase factor whether product from one country was ‘superior’, ‘comparable’, or

‘inferior’ to product from another country. Eight purchasers responded, but not for every country/country

category comparison; purchaser responses are summarized in table II-6. The U.S.-produced ironing

tables were generally comparable to the imported ironing tables from China and India, the two importcountry sources reported. The single exception was price where the domestic ironing tables were rated

‘inferior’ more frequently than for any other factor in comparison with the products from China and India.

 59 All the responding purchasers reported in their questionnaire responses that the domestic and/or imported

ironing tables from China, Italy, or the Netherlands (the only countries that they reported for this question) ‘always’

or ‘usually’ met their minimum quality specifications.

 60 The purchasers also reported that their customers, mostly household consumers, felt similarly as the retailers

and one distributor about the importance of country-of-origin and identity of the producer in their purchases of

ironing tables.

 61 ***, however, differed from other purchasers in the emphasis it placed on domestic supply.

 62 In addition, 12 of 13 responding purchasers reported that purchasing the domestic product was not important in

their purchases of ironing tables. The single remaining purchaser, ***, reported that its purchases of the domestic

ironing tables have a shorter lead time and are required to respond as needed for its back-to-college program.

 63 One of these 9 purchasers, ***, indicated that HPI had the largest product availability and variety of the T-leg

style of ironing table.

II-21
Table II-6

Ironing tables: Comparisons of domestic ironing tables vis-a-vis imported ironing tables from

China and India, based on sales in the U.S. market during 2004-09

Purchase factors

U.S.-produced products compared to imported products from–

China India

SCI S C I

Availability * - 8 - - 1 -

Delivery terms - 8 - - 1 -

Delivery time 3 5 - 1 - -

Discounts offered - 8 - - 1 -

Extension of credit 1 7 - - 1 -

Price1

 * 2 33 - - 1

Minimum quantity

requirements 2 6 - - 1 -

Packaging 2 5 1 - 1 -

Product consistency - 8 - - 1 -

Product quality meets

standards * - 8 - - 1 -

Product quality exceeds

standards 1 6 1 - 1 -

Product range 3 5 - - 1 -

Reliable supply - 8 - - 1 -

Technical support 1 6 - - 1 -

U.S. transportation costs1 1 61 - 1 -

 1 A rating of “S” on price and/or transportation costs indicates that the U.S. product has lower prices or

transportation costs than the product from the country with which it is being compared.

Note.–S=superior, C=comparable, and I=inferior.

Note.–The overall top 3 purchase factors as discussed earlier are identified with asterisks.

Source: Compiled from data submitted in response to Commission questionnaires.

II-22
ELASTICITY ESTIMATES64

U.S. Supply Elasticity

The domestic supply elasticity for U.S.-produced ironing tables measures the sensitivity of the

quantity supplied by the U.S. producer to a change in the U.S. market price of these products. The

elasticity of domestic supply depends on several factors including the U.S. producer’s level of excess

capacity, the ease with which the U.S. producer can alter its productive capacity, the existence of

inventories, and the availability of alternate markets for domestic ironing tables. Analysis of these factors

indicates that, due principally to unused production capacity, the U.S. producer had flexibility in the short

run to alter its supply of ironing tables to the U.S. market in response to relative changes in the demand

for their products. The domestic elasticity of supply for ironing tables is estimated to be in the range of 

4-8.

U.S. Demand Elasticity

The U.S. price elasticity of demand for ironing tables measures the sensitivity of the overall

quantity demanded for ironing tables to changes in the U.S. market price of ironing tables. The price

elasticity of demand depends on factors discussed earlier such as the existence and availability of

substitute products for ironing tables and alternatives to household ironing, such as wrinkle-free clothing

and dry cleaning. Based on available information, the demand elasticity for ironing tables is estimated to

be in the range of -0.5 to -1.5.65

Substitution Elasticity66

The elasticity of substitution largely depends upon the degree to which there is an overlap of

competition between domestic ironing tables and imported ironing tables from China, and the extent of 

product differentiation. Product differentiation, in turn, depends on such factors as physical

characteristics (e.g., sizes, types (perforated- versus mesh-top), T-leg versus 4-leg or other leg designs,

accessories, etc.), brand name recognition, consumer preferences, and conditions of sale (e.g., delivery

lead times, reliability/availability of supply, technical service, etc.). Based on available information

discussed earlier, the elasticity of substitution between domestic ironing tables and imported ironing

tables from China is estimated to be in the range of 2-5.

 64 The suggested ranges for the various elasticities were presented in the prehearing report for purposes of

discussion in the prehearing briefs, hearing testimony, and/or posthearing briefs. Although there were no

discussions of the elasticity ranges, HPI asserted that demand was price inelastic (HPI’s prehearing brief, p. 11). 

The elasticity responses in this section refer to changes that could occur within 12 months, unless otherwise

indicated.

 65 The greater the effect of substitutes for ironing tables, the closer the elasticity is to the higher end of the range.

 66 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of the imports

and the U.S. domestic like product to changes in their relative prices. This reflects how easily purchasers switch

from the U.S. product to the imported product (or vice versa) when prices change.

II-23

PART III: CONDITION OF THE U.S. INDUSTRY

OVERVIEW

Information presented in this section is based on the questionnaire response of one firm, HPI, that

accounted for all U.S. production of ironing tables during the period for which data were collected.1 2

HPI reported that it does not anticipate any changes in the character of its operations relating to the

production of ironing tables. Table III-1 summarizes important events that have taken place in the U.S.

industry since January 1, 1998.

Table III-1

Ironing tables: Survey of U.S. industry events since January 1, 1998

Period Description of event

January 1998

HPI acquires Seymour Housewares, leading supplier of laundry management

products in the United States.

April 2002 Whitney Designs halts U.S. production of ironing tables

November 2004

Home Products International – North America, Inc. is purchased by Private Equity

Groups led by Equity Group International, Inc., Walnut Group, and Triyar Capital. 

Company delisted from NASDAQ exchange. New management team installed.

December 2006 HPI files for Chapter 11 bankruptcy.

March 2007 Third Avenue Management becomes majority shareholder of HPI.

November 2007 ***.

December 2007 ***.

January 2008

HPI decides to close its East Plant, which produces its 4-leg ironing tables, and

***.

November 2009 Whitney Design files for Chapter 11 bankruptcy.

January 2010

Whitney Design’s assets except subject ironing boards are sold and Whitney

Design ceases operations.1

 1 Most of Whitney Design’s assets and certain liabilities were purchased by Household Essentials, LLC under a

bankruptcy court approved code section 363 sale order on January 29, 2010. Whitney Design ***. At the time of

the 363 transaction, ***. 

Source: Compiled from data submitted in response to Commission questionnaires; E-mail from ***, April 15, 2010;

HPI’s posthearing brief, exh. 2;

“http://www.chicagobusiness.com/cgi-bin/news.pl?id=23253,” retrieved March 16, 2010;

“http://www.hpii.com/corporate/aboutus.aspx,” retrieved March 11, 2010;

“http://stlouis.bizjournals.com/stlouis/stories/2009/11/30/story6.html,” retrieved April 27, 2010;

“http://stlouis.bizjournals.com/stlouis/stories/2010/02/01/daily34.html,” retrieved April 27, 2010; and 

“http://www.tribtown.com/news/company-6044-home-seymour.html,” retrieved April 27, 2010.

 1 *** reported no production or sales of ***.

 2

 As discussed in greater detail below, ***.

III-1
U.S. CAPACITY, PRODUCTION, AND CAPACITY UTILIZATION

U.S. producers’ capacity, production, and capacity utilization data for ironing tables are presented

in table III-2.3

 Overall domestic capacity has remained consistent throughout the period for which data

were collected.4

 HPI’s production and capacity utilization steadily increased during 2004 to 2007, but

declined in 2008 and 2009. HPI reported in its questionnaire that the *** in production ***. HPI

maintains that the recession is the cause for the decrease in production during 2008 and 2009. HPI

primarily produces perforated-top T-leg models, although the company also produces mesh-top T-leg

models and perforated and mesh-top 4-leg models.5

 

Table III-2

Ironing tables: U.S. capacity, production, and capacity utilization, 2004-09

* * * * * * *

In addition to metal-topped ironing tables, HPI also produces over-the-door ironing boards in the

same facilities. HPI does not produce plastic-topped ironing tables, but rather ***.6

 

U.S. PRODUCER’S SHIPMENTS

Table III-3 presents data on HPI’s shipments of ironing tables. The domestic commercial market

accounted for *** of HPI’s U.S. shipments of ironing tables and for more than *** percent of HPI’s total

shipments of ironing tables throughout the period for which data were collected in this review. Export

shipments, which accounted for less than *** percent of HPI’s total shipments of ironing tables

throughout the period, were to ***. ***.7

Table III-3

Ironing tables: U.S. producer’s shipments, by types, 2004-09

* * * * * * *

U.S. PRODUCERS’ INVENTORIES

As shown in table III-4, HPI, generally maintained inventories equivalent to *** of total

shipments over the period for which data were collected. Inventories increased from 2004 to 2006 but

decreased during 2007-09, reaching *** in 2009.

Table III-4

Ironing tables: U.S. producer’s end-of-period inventories, 2004-09

* * * * * * *

 3 ***. ***.

 4

 The manufacturing bottleneck that constrains HPI’s capacity is its ***. ***.

 5

 HPI estimates that the opening price point T-leg style with a perforated top and 4-legged mesh top ironing tables

account for *** percent of the U.S. market for ironing tables. ***.

 6

 HPI ***. HPI’s posthearing brief, exh. 2, att. 3. 

 7

 HPI’s posthearing brief, exh. 4.

III-2
U.S. PRODUCERS’ IMPORTS AND PURCHASES

HPI imported ***. HPI’s *** are presented in table III-5.8

Table III-5

Ironing tables: U.S. producer’s imports, 2004-09

* * * * * * *

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

HPI’s employment data for ironing tables are presented in table III-6. The number of production

and related workers fluctuated during the period for which data were collected but were ultimately ***

percent lower in 2009 than in 2004. The hours worked per PRW also fluctuated during the same period,

but ultimately were *** percent higher in 2009 than in 2004, resulting in a smaller decline in the number

of hours worked. Hourly wages generally increased between 2004 and 2008 but fell to their lowest level

in 2009, a year which also saw the lowest levels of employment and overall wages of the 2004-09 period. 

As previously noted, HPI announced in January 2008 that it would be shutting down its East Plant to

transfer production to China. HPI reversed its decision shortly after, and the plant remained in operation.9

Table III-6

Ironing tables: U.S. producer’s employment-related data, 2004-09

* * * * * * *

 8 Testimony from respondent interested party at the hearing suggested that HPI has an “exclusive arrangement”

with Forever Holdings for imports of ironing tables. Hearing transcript, p. 115 (Scott). In response, HPI submitted

***. HPI’s posthearing brief, exhibit 2.

 9

 “http://www.tribtown.com/news/company-6044-home-seymour.html,” retrieved April 27, 2010, and HPI’s

posthearing brief, exh. 2, pp. 2-4.

III-3
FINANCIAL EXPERIENCE OF THE U.S. PRODUCER

Background

The sole U.S. producer, HPI, representing all known U.S. production during the period for which

data were collected in this review, provided usable financial data on its ironing table operations.10 11 HPI

acquired its ironing table operations in 1998 when the company purchased Seymour Housewares, a

leading supplier of laundry management products to the U.S. market. In 2004, Storage Acquisition LLC

acquired 93 percent of HPI’s outstanding shares, delisted the company from the NASDAQ exchange, and

installed a new management team. In January 2006, HPI ceased filing public reports with the SEC.12 On

December 20, 2006, HPI filed for bankruptcy under Chapter 11 of the U.S. Bankruptcy Code, and on

March 21, 2007, the U.S. Bankruptcy Court for the District of Delaware confirmed HPI’s plan for

reorganization. HPI reportedly based its decision to file for bankruptcy on a number of factors, including

an increase in resin and steel prices, an inability to increase prices to cover increased costs, payments due

on a $5.6 million interest payment, and excess capacity in the marketplace.13 The reorganization plan

eliminated $116.1 million of interest bearing notes by exchanging that debt for 95 percent of new

company stock, with the remaining new stock issued to HPI’s existing shareholders.14

Operations on Ironing Tables

Income-and-loss data for HPI are presented in table III-7. HPI experienced an irregular increase

in operating income from 2004 to 2007, followed by an *** in 2008 and a *** in operating income in

2009.15 Both total net sales quantity and value experienced a *** increase from 2004 to 2007, followed

by declines in both net sales quantity and value in 2008. In 2009, net sales quantity experienced a further

*** decline, while net sales value experienced a *** improvement. Overall, net sales quantity declined

by *** percent, net sales value increased by *** percent, and operating income increased *** from 2004

to 2009.

Table III-7

Ironing tables: Results of operations of U.S. producer HPI, 2004-09

* * * * * * *

 10 HPI’s fiscal year ends on December 31. The company records underlying the financial data for HPI were

examined by staff in Washington, D.C. Adjustments resulting from this examination have been incorporated in this

final report. ***. 

 11 HPI’s sales of ironing tables represented *** percent of net sales revenue for its laundry management segment

and *** percent of its total sales revenue for 2009. These percentages were *** and *** percent, respectively, in

2004. HPI’s operating income from ironing tables *** its company-wide operating income during 2009 ***, up

from representing only *** percent of total operating income in 2004. E-mail correspondence from ***, March 4,

2010.

 12 See http://www.homzproducts.com/corporate/aboutus.aspx. Retrieved on February 23, 2010. See also HPI’s

posthearing brief, p. A-20.

 13 See http://www.goldbergkohn.com/news-1061.html. Retrieved on March 2, 2010. See also HPI’s posthearing

brief, p. A-21.

 14 See http://www.goldbergkohn.com/news-1070.html. Retrieved on March 2, 2010. See also HPI’s posthearing

brief, p. A-21. 

 15 HPI’s CEO stated that, “***.” HPI’s posthearing brief, exh. 2.

III-4
The per-unit net sales value generally declined from 2004 to 2007; however, the per-unit cost of

goods sold (“COGS”) and selling, general, and administrative (“SG&A”) expenses generally declined by

more than per-unit revenue. Thus, per-unit operating income increased irregularly from 2004 to 2007. In

2008, per-unit revenue *** while per-unit raw material costs *** increased, which resulted in *** in that

year. In contrast, per-unit revenue increased in 2009 to *** level reported during the period of review

while per-unit raw material costs *** declined, which resulted in *** operating income reported during

the period of review on a per-unit basis, as a ratio to net sales, and in terms of absolute income.

Raw material costs accounted for approximately *** percent of total COGS during the period

2004-09, and had a considerable influence on HPI’s reported operating results. HPI reported that the cost

of steel for subject ironing tables accounted for *** percent of total raw material costs between 2004 and

2009. HPI experienced a large increase in steel costs in 2008, rising from $*** per pound in 2007 to

$*** per pound in 2008. In 2009, HPI’s steel costs declined to $*** per pound.16 17

Variance Analysis

A variance analysis for ironing tables is presented in table III-8.18 The information for the

variance analysis is derived from table III-7. The analysis shows that the increase in operating income in 

2009 as compared with 2004 is primarily attributable to favorable price and cost/expense variances (that

is, prices increased and costs/expenses decreased in 2009 as compared with 2004).19

Table III-8

Ironing tables: Variance analysis on operations of U.S. producer HPI, 2004-09

* * * * * * *

Capital Expenditures and Research and Development Expenses

HPI’s reported capital expenditures and research and development (“R&D”) expenses are shown

in table III-9. According to HPI, reported capital expenditures primarily reflect ***. Reported R&D

expenses primarily reflect ***.20

 16 E-mail correspondence from ***, March 4, 2010. See HPI’s posthearing brief, pp. A-14 to A-20, for additional

discussion of the firm’s operating performance during the period for which data were collected in this review.

 17 HPI reported that the firm’s more recent steel purchases ***. See HPI’s U.S. producer questionnaire response,

pp. 39-40.

 18 A variance analysis is calculated in three parts, sales variance, cost of sales variance, and SG&A expense

variance. Each part consists of a price variance (in the case of the sales variance) or a cost variance (in the case of

the cost of sales and SG&A expense variance) and a volume variance. The sales or cost variance is calculated as the

change in unit price times the new volume, while the volume variance is calculated as the change in volume times

the old unit price. Summarized at the bottom of the table, the price variance is from sales; the cost/expense variance

is the sum of those items from COGS and SG&A variances, respectively; and the volume variance is the sum of the

volume variance lines under price and cost/expense variance. 

 19 The analysis also shows that from 2007 to 2008, ***. In contrast, the *** from 2008 to 2009 reflects ***.

 20 E-mail correspondence from ***, February 26, 2010.

III-5
Table III-9

Ironing tables: Capital expenditures and research and development expenses of U.S. producer

HPI, 2004-09

* * * * * * *

Assets and Return on Investment

The Commission’s questionnaire requested data on assets used in the production, warehousing,

and sale of ironing tables to compute return on investment (“ROI”). Data on HPI’s total assets and their

ROI are presented in table III-10. HPI emerged from bankruptcy in March 2007, and accounting entries

necessary to record the bankruptcy included writing down the gross value of all fixed assets to their

respective net book values, and removing the associated accumulated depreciation from the books. 

Intangible assets were also written down as part of the bankruptcy accounting entries.21 Thus, the total

assets for ironing tables declined from $*** in 2004 to $*** in 2009. The ROI irregularly increased by

*** percentage points from 2004 to 2007, but then declined by *** percentage points in 2008 to ***

percent before once again increasing to *** percent in 2009. 

Table III-10

Ironing tables: Asset values and return on investment of U.S. producer HPI, 2004-09

* * * * * * *

 21 E-mail correspondence from ***, February 25 and March 8, 2010. 

III-6
PART IV: U.S. IMPORTS AND THE FOREIGN INDUSTRY

U.S. IMPORTS

Overview

The Commission issued questionnaires to 33 firms believed to have imported ironing tables

between 2004 and 2009. Ten firms provided data and information in response to the questionnaires,1 2

while 13 firms indicated that they had not imported ironing tables during the period for which data were

collected. These data are based on responses from the largest known U.S. importers and foreign

producers and are believed to cover the large majority of imports from China as well as from nonsubject

sources. Seven of the responding importers also provided questionnaires in the original investigation. 

These importers accounted for *** percent of the imports from the original investigation in 2003.3

Although the HTS subheading for ironing tables should be dedicated to metal-top, floor-standing ironing

tables, there is evidence that reporting has been over-inclusive,4

 and therefore import data in this report

are based on data submitted in response to Commission questionnaires. 

Imports from Subject and Nonsubject Countries

Table IV-1 presents data for U.S. imports of ironing tables from China and all other sources. 

Leading nonsubject sources of imports are Taiwan,5

 Italy, India,6 France, and the Netherlands.7 In

 1 The responding firms are American Hotel Register, Bajer Design, Brabantia USA, Groupe SEB, Home Products

International, Ikea, Polder, Target, Whitmor, and Whitney Design. 

 2

 Whitney Design filed for Chapter 11 bankruptcy protection in November 2009. Whitney has ceased operations. 

Most of Whitney Design’s assets and certain liabilities were purchased by Household Essentials, LLC, with the same

owners and “nearly all” of the company’s 46 employees, under a bankruptcy court approved code section 363 sale

order on January 29, 2010. ***. *** contends that, ***. E-mail from ***, April 15, 2010;

“http://stlouis.bizjournals.com/stlouis/stories/2009/11/30/story6.html,” retrieved April 27, 2010; and

“http://stlouis.bizjournals.com/stlouis/stories/2010/02/01/daily34.html,” retrieved April 27, 2010; 

 3

 Ironing tables were covered by HTS statistical reporting number 9403.20.0010 under the broad heading “Metal

Household Furniture” until July 1, 2003, when they were reclassified into the more specific HTS statistical reporting

number 9403.20.0011, “Floor-standing metal-top ironing boards, household.” The subject metal top and leg

components are imported under HTS statistical reporting number 9403.90.8040. No responding company, however,

reported imports of ironing table components. Customs import data also indicate that antidumping duties have not

been paid on ironing table components by any of the known importers of ironing tables. 

 4

 The Customs data include many seemingly large importers of ironing tables that reported that they do not import

ironing tables. Eleven of the 13 companies that responded that they have not imported ironing tables are listed in

Customs data as having imported at least *** units from China or from other countries. 

 5

 Testimony at the hearing indicated that there were no known sources of ironing table from Taiwan. ***. 

Hearing transcript, p. 141, 157 (Scott); E-mail from ***, April 20, 2010.

 6

 Polder is currently importing ironing tables from India. At the hearing, Calvin Scott stated that “India is quickly

becoming the new China for production of metal-topped, floor-standing ironing boards.” According to an email

from ***, ***. Hearing transcript, p. 117 (Scott). ***. Commerce data indicate that there were 9,044 units of

ironing tables imported from India in 2009 and 8,096 units in January and February of 2010. 

 7

 Of the leading nonsubject sources of imports, Taiwan, Italy, India, and the Netherlands were identified as

sources of imports in the questionnaires.

IV-1
addition, Mexico is a source of product entering the United States under the statistical reporting number

for metal-topped, floor-standing ironing tables, but is not known to be a producer of this product.8

 

Table IV-1

Ironing tables: U.S. imports, by sources, 2004-09

Source

Calendar year

2004 2005 2006 2007 2008 2009

Quantity (1,000 units)

China1 *** *** *** *** *** ***

Other sources *** *** *** *** *** ***

Total 1,521 1,941 1,770 1,161 1,550 652

Value (1,000 dollars)

2

China *** *** *** *** *** ***

Other sources *** *** *** *** *** ***

Total 13,706 19,638 18,290 13,713 17,514 8,701

Unit value (per unit)

China $*** $*** $*** $*** $*** $***

Other sources *** *** *** *** *** ***

Total 9.01 10.12 10.33 11.81 11.30 13.35

Share of quantity (percent)

China *** *** *** *** *** ***

Other sources *** *** *** *** *** ***

Total 100.0 100.0 100.0 100.0 100.0 100.0

Share of value (percent)

China *** *** *** *** *** ***

Other sources *** *** *** *** *** ***

Total 100.0 100.0 100.0 100.0 100.0 100.0

 1 Staff notes that total reported imports from China are lower than reported exports to the United States by

Chinese producers. This has been identified as a difference between reported imports of *** and exports to *** by

Chinese producer ***. However, ***’s reported imports are relatively consistent with Customs data, and are

therefore considered to be more accurate.

 2

 Landed, duty-paid.

Source: Compiled from data submitted in response to Commission questionnaires.

The quantity of imports from China decreased overall from 2004 to 2009, declining by ***

percent. The quantity of imports from China remained well above *** units during 2004-06, but dropped

noticeably in 2007, as ***’s imports from China declined from *** units in 2004-06 to just *** units in

2007. The increase in imports from China in 2008, is also attributable to ***, as its quantities of imports

increased to *** units. However, in 2009 U.S. imports from China fell below *** units for the first time,

reflecting a decline in imports by *** leading importers. 

***’s imports also had an effect on *** imports. *** reported importing ironing tables from ***

in ***; these imports accounted for *** percent of total nonsubject imports, respectively.

 8 None of the witnesses at the hearing reported being aware of any imports of ironing tables produced in Mexico. 

Hearing transcript, p. 56 (Volles) and pp. 141, 158 (Scott).

IV-2
U.S. IMPORTERS’ INVENTORIES

Table IV-2 presents data for inventories of U.S. imports of ironing tables from China and all other

sources held in the United States. *** reported holding the largest quantity of inventories from China,

accounting for between *** and *** percent annually of importers’ inventories during 2004-09. As ***,

overall inventories ***. *** did not report holding any inventories during the period in which data were

collected.

Table IV-2

Ironing tables: U.S. importers’ end-of-period inventories of imports, by source, 2004-09

* * * * * * *

U.S. IMPORTERS’ IMPORTS SUBSEQUENT TO DECEMBER 31, 2009

The Commission requested importers to indicate whether they imported or arranged for the

importation of ironing tables after December 31, 2009. Four companies, ***, responded that they have

current orders. *** responded that they had imported or arranged for the importation of *** ironing tables

from China after December 31, 2009. *** responded that they had imported or arranged for the

importation of *** and *** units, respectively, of ironing tables from nonsubject sources after December

31, 2009.

THE INDUSTRY IN CHINA

Overview

At the time of the Commission’s original investigation, usable questionnaire responses were

received from four Chinese companies. These firms were: Forever Holdings, Ltd.; Foshan City Gaoming

Lihe Daily Necessities Co., Ltd.; Harvest International Housewares Ltd.; and Shunde Yongjian

Housewares Co., Ltd.9

 Collectively, the four responding producers in China reported shipments of 4.2

million ironing tables in 2003, of which, 891,000 (21 percent) were exported to the United States. 

Ironing Tables Operations

In this review, the Commission sent questionnaires to 31 Chinese firms believed to produce 

and /or export ironing tables; six companies provided usable data. The firms that responded are Forever

Holdings Ltd. (“Forever”), Foshan Shunde Yongjian Housewares & Hardware Co., Ltd. (“Foshan”),

Greenwood Houseware (Zhuhai) Ltd. (“Greenwood”), Harvest International Housewares (“Harvest”),

Heshan Zhishan Hengfeng Metal Co., Ltd. (“Heshan”), and Since Hardware (Guangzhou) Co. Ltd.

(“Since Hardware”). During the period for which data were collected, *** were the largest producers of

ironing tables in China to provide data.10 Proprietary Customs data indicate that ***. This is consistent

 9 U.S. International Trade Commission, Ironing Tables and Certain Parts Thereof From China, Investigation No.

731-TA-1047 (Final), INV-BB-087, p. VII-1.

 10 The foreign producers that responded to questionnaires are largely the same as the foreign producers in the final

phase of the investigation. However, Since Hardware was noted in the final phase of the original investigation as

being “a large and expanding producer” but did not submit a questionnaire response. The universe of ironing table

producers in China is likely much larger than those that provided data to the Commission. At exhibit 3 of the HPI’s

posthearing brief, a list of 40 possible manufacturers, 10 suppliers, and 3 companies with the capacity to produce

(continued...)

IV-3
with the companies’ respective antidumping duty margins resulting from administrative reviews by

Commerce during the review period.11

Data for all responding Chinese producers of ironing tables are presented in table IV-3. ***

reported the production of nonsubject merchandise on the same equipment as ironing tables. Nonsubject

merchandise such as *** comprised *** percent of products produced by *** and *** percent produced

by *** in 2009. Capacity of the responding Chinese producers increased from 2004-8 and declined ***

in 2009. *** began operations in 2007 and has increased capacity in each of the remaining years during

the period for which data were collected. *** reported increasing capacity from 2004-08 and stable

capacity in 2009.12 ***’s capacity fluctuated between *** units from 2004-08, but decreased to *** units

in 2009.

Table IV-3

Ironing tables: China’s capacity, production, shipments, and inventories, 2004-09

Item

Calendar year

2004 2005 2006 2007 2008 2009

Quantity (1,000 units)

Capacity 6,588 9,888 9,988 9,352 10,132 8,512

Production 5,658 8,795 8,813 8,010 8,209 6,022

End of period inventories 136 158 173 224 215 359

Shipments:

 Internal consumption *** *** *** *** *** ***

 Commercial home market

 shipments *** *** *** *** *** ***

 Exports:

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia other than China *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** *** *** *** *** ***

 Total shipments 5,569 8,773 8,798 7,958 8,218 5,877

Table continued on next page.

 10 (...continued)

ironing tables is included. However, the companies exporting to the United States have been relatively constant

during 2001-09.

 11 ***. ***’s questionnaire response, section II-7a, and proprietary Customs data.

 12 *** reported buying new machinery related to the production of ironing tables during the period for which data

were collected. ***.

IV-4
Table IV-3 – Continued

Ironing tables: China’s capacity, production, shipments, and inventories, 2004-09

Item

Calendar year

2004 2005 2006 2007 2008 2009

Value ($1,000)

Commercial shipments:

 Home market *** *** *** *** *** ***

 Exports to--

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia other than China *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** *** *** *** *** ***

 Total shipments 37,175 58,369 63,499 63,958 77,536 57,044

Average unit value (dollars per unit)

Commercial shipments:

 Home market *** *** *** *** *** ***

 Exports to--

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia other than China *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** *** *** *** *** ***

 Total shipments 6.68 6.66 7.22 8.04 9.44 9.72

Ratios and shares (percent)

Capacity utilization 85.9 88.9 88.2 85.6 81.0 70.7

Inventories to production 2.4 1.8 2.0 2.8 2.6 6.0

Inventories to total shipments 2.4 1.8 2.0 2.8 2.6 6.1

Share of total quantity of:

 Internal consumption *** *** *** *** *** ***

 Home market *** *** *** *** *** ***

 Exports to--

 United States *** *** *** *** *** ***

 European Union *** *** *** *** *** ***

 Asia other than China *** *** *** *** *** ***

 All other markets *** *** *** *** *** ***

 Total exports *** *** *** *** *** ***

Note.– [Foshan and Harvest] reported all values in RMB 1,000 Yuan. Staff used oanda.com to convert these values to dollars by

using the rate as of July 1st for each year. These conversion rates were $1= 0.12104, 0.1210, 0.12530, 0.13150, 0.14610, and

0.14660 for 2004, 2005, 2006, 2007, 2008, and 2009, respectively.

Source: Compiled from data submitted in response to Commission questionnaires.

IV-5
Among the Chinese producers providing data, *** reported exporting ironing tables to the United

States. Other export markets, including *** accounted for the majority of shipments during the period for

which data were collected from the responding firms.

On February 4, 2006, the European Union initiated an antidumping proceeding concerning

imports of ironing boards from China and Ukraine. On October 30, 2006, the European Union imposed a

provisional antidumping duty on such imports, and on April 23, 2007, it imposed a definitive duty.13

Antidumping duties ranged from 18.1 percent (for Foshan Shunde) to 36.5 percent (for Guangzhou Power

Team Houseware) for specified Chinese manufacturers and 38.1 percent for all other Chinese

manufacturers, with the exception of Since Hardware (0 percent rate of duty).14 On October 2, 2009, the

European Union initiated an antidumping proceeding concerning imports of ironing boards originating

from Chinese exporting producer Since Hardware, a proceeding that is ongoing at this time.15 In

December 2009, the European Union announced that, as a result of a judgement by the Court of Justice of

the European Communities, that ruled on procedural grounds, imports of ironing boards from Chinese

producer Foshan Shunde are no longer subject to the antidumping measures.16 However, the European

Union has re-opened the antidumping investigation with regards to Foshan Shunde.17 Most recently, on

January 19, 2010, the European Union amended the definitive antidumping duty on imports of ironing

boards from China to reflect the results of a new exporter review (imposing a definitive duty of 22.7

percent on imports of ironing boards from Chinese manufacturer Greenwood Houseware (Zhuhai)).18

GLOBAL MARKET

As a practical matter, there is limited information available with respect to the subject

merchandise as defined by Commerce’s scope. However, some respondents to U.S. and foreign

producers’ questionnaires provided brief assessments regarding global markets and the market in China.19

The Official Journal of the European Union provided information about the market for ironing tables in

the European Union. Also, certain inferences can be made about demand in developed-country markets

based on field interviews. 

Demand

The European Union is believed to be the largest non-U.S. market for ironing tables, with

consumption of 8.6 million units in 2005.20 The EU market, at least prior to 2007, was considered a

growing market, according to Chinese producer ***. Respondents to foreign producers’ questionnaires

indicated that economic growth during 2004-09 increased demand for ironing tables both in China and

other non-U.S. markets. One respondent stated that only a small portion of the potential market in China

 13 Official Journal of the European Union, April 26, 2007, L109/12.

 14 Ibid.

 15 Official Journal of the European Union, October 2, 2009, C 237/5.

 16 Foshan Shunde Yongjian Housewares & Hardware Co. Ltd, v. Council of the European Commission, et al.,

Case No. C-141/08 P.

 17 Official Journal of the European Union, December 18, 2009, C 308/44.

 18 Official Journal of the European Union, January 28, 2010, L24/1.

 19 Two producers of ironing tables in China offered contradictory assessments of the level of competition among

producers in the Chinese domestic market, one indicating that the competition was “gentle” and the other indicating

it was “big” by about 5 or 6 factories.

 20 Official Journal of the European Union, “Commission Regulation (EC) No. 1620/2006 of 30 October 2006

Imposing a Provisional Anti-dumping Duty on Imports of Ironing Boards Originating in the People’s Republic of

China and Ukraine,” October 31, 2006, p. L 300/25.

IV-6
possesses metal ironing tables. However, wooden ironing tables continue to be a viable alternative to

metal top ironing tables in China. 

Supply

Producers in China are the leading suppliers of ironing tables to the world market. In 2005, at

least 8 producers in China exported ironing tables to the European Union (EU) (a market with

approximately 30 companies producing ironing tables). One producer in the Ukraine supplied ironing

tables to the EU through its affiliated company based in Switzerland in 2005.21 High-end ironing tables

manufactured in Europe are sold to global markets. Production capacity by EU producers amounted to

8.8 million units in 2005, with actual production, however, amounting to only 3.5 million units.22

***.23 

Sources indicate that at least two companies selling ironing tables in the U.S. market have shifted 

some or all of their foreign sourcing of metal-top ironing tables from China to India.24 One witness at the

Commission’s hearing testified that “factories in India offer stronger engineering, better R&D, ***

produce higher quality products at prices similar to China.”25 That witness indicated that his company

made a substantial investment to bring tooling for the manufacture of ironing tables into India,26 but the

costs of production in India are now similar to those in China.27 The witness stated that his company

imports only mesh-top, 4-leg ironing tables from India and that his company would not be able to produce

T-leg models in India that would be price competitive with comparable models produced in the United

States by HPI.28 Respondent interested parties specifically identified four companies in India as

producers of metal-top, floor-standing ironing tables, with production capacity expected to grow from ***

units in 2010 to *** units in 2012.29

 21 The leading EU producers of ironing tables in 2005 were located in Italy, Poland, and the United Kingdom.

Four companies accounted for 45 percent of total EU production that year. Nearly all of the EU’s imports of ironing

tables in 2005 came from China and Ukraine. Official Journal of the European Union, “Commission Regulation

(EC) No. 1620/2006 of 30 October 2006 Imposing a Provisional Anti-dumping Duty on Imports of Ironing Boards

Originating in the People’s Republic of China and Ukraine,” October 31, 2006, pp. L 300/14 and L 300/24.

 22 Official Journal of the European Union, “Commission Regulation (EC) No. 1620/2006 of 30 October 2006

Imposing a Provisional Anti-dumping Duty on Imports of Ironing Boards Originating in the People’s Republic of

China and Ukraine,” October 31, 2006, p. L 300/28 and 32.

 23 ***.

 24 Carl Scott, President, Polder Inc., and Kerry Cooper, Sales Manager, Polder Inc., testified at the Commission’s

hearing on April 13, 2010, that Polder had shifted all of its sourcing of metal-top ironing tables from China to India.

Hearing transcript, p. 113 (Scott) and p. 118 (Cooper). Mr. Scott also testified that “India is also becoming a very

attractive player in the U.S. market as an alternative to China.” Hearing transcript, p. 117 (Scott). Proprietary

Customs data indicate that another company in India, ***, supplies metal-top ironing tables to a second U.S.

importer, ***, which had previously imported ironing tables from China. William Perry, of counsel to Polder,

testified that he was told that “Ikea is moving half of its products out of China to India.” Hearing transcript, p. 131

(Perry). 

 25 Hearing transcript, p. 117 (Scott). 

 26 Hearing transcript, p. 132 (Scott). 

 27 Hearing transcript, p. 133 (Scott). 

 28 Hearing transcript, p. 168 (Scott). 

 29 The companies identified as producers in India were IEDL, Omax, Savera, and Uttam. See respondent

interested parties’ posthearing brief, Appendix PH-4.

IV-7
Table IV-4 provides a brief description of these companies and six other potential producers

identified through staff research.30

Table IV-4

Ironing Tables: Companies identified as producers of metal-top, floor-standing ironing tables in

India

Company name Location Leading products

Alok Chawla Enterprises Faridabad, Haryana Ironing tables, dry cleaning

machines, washing machines,

stain-removing machines,

centrifugal separators, electrical

boilers, hydro extractors

Bhatia Electricals Mumbai, Maharashtra Ironing tables, lamp holders,

magazine racks, clothes drying

racks, lighting fittings

Casa & Kuchen Palam Vihar Gurgaon, Haryana Ironing tables

Cipla Industries New Delhi, Delhi Ironing boards (both of mesh-top

metal and of wood), clothes drying

racks, bathroom accessories,

serving trays, bathroom shelves 

International Electron

Devices Ltd. (IEDL)

New Delhi, Delhi Ironing tables, components for

cathode ray tubes, aperture masks

for color televisions and computer

monitors, customized engineered

sheet metal products, motorcycle

spare parts and clutch plates

Pull ‘n’ Dry

(C-Line Industries)

Bengaluru, Karnataka Ironing tables, hangers, and

clothes drying racks

Savera Not available Ironing tables

Speedomax (a Unit of

OMAX Autos Ltd.)

Gurgaon, Delhi Ironing tables, sheet metal,

machined and tubular

components, bicycle parts, 5th

leading auto parts manufacturer in

India: framed bodies, pedal &

brake shoe assemblies, seat

frames, and oil pump assemblies 

Uttam Not available Ironing tables

Vinayaka Tradings Coimbatore, Tamil Nadu Ironing tables

Sources: IndiaMart Search and respondents’ posthearing brief, Annex PH-4.

 30 USITC staff sent inquiries to each of the companies identified independently of the respondents’ posthearing

brief as manufacturers of metal-top, floor-standing ironing tables in India to verify whether or not the companies

were indeed producing ironing tables in India and whether they were exporting ironing tables to the United States or

other markets. They were also asked questions regarding the size and competitiveness of the ironing table industry in

India. None of the companies responded to the inquiries.

IV-8
Prices

When asked to compare prices in the United States and other countries, all three responding

Chinese producers reported that prices for ironing tables sold in China, the United States, and third

country markets are about the same.31 *** In the EU market, imports in 2005 from China were sold at

prices that undercut prices of EU-made ironing tables by margins ranging from 30.8 percent to 45.5

percent (imports from Ukraine undercut EU producer prices by 17.3 percent).32

 31 The Chinese producers reported that the prices of ironing tables sold in China, the United States, and third

country markets were “no major differences,” “more or less the same,” and “no different.”

 32 Official Journal of the European Union, “Commission Regulation (EC) No. 1620/2006 of 30 October 2006

Imposing a Provisional Anti-dumping Duty on Imports of Ironing Boards Originating in the People’s Republic of

China and Ukraine,” October 31, 2006, p. L 300/27.

IV-9

PART V: PRICING AND RELATED INFORMATION

FACTORS AFFECTING PRICING

U.S. prices of ironing tables can fluctuate based on demand factors such as overall U.S. economic

activity and sectoral demand, particularly in housing. On the supply side, prices of ironing tables

fluctuate based on the cost of the steel and due to a number of product specifications, including thickness

of steel in the legs and number and type of leg styles, width and length of ironing table top, whether

perforated or mesh top, and inclusion of additional features such as an iron rest and linen rack. In

addition, the prices of ironing tables can fluctuate due to quantities contracted and the relative bargaining

strength between purchasers and suppliers. U.S. prices of ironing tables may also be affected by prices of

alternative products, including table-top ironing boards.1

 

Raw Material Costs

Total raw material costs averaged almost *** percent of HPI’s total costs of goods sold to

produce ironing tables during 2004-09. The principal raw material input used to produce domestic

ironing tables is cold-rolled steel sheet. As seen in figure V-1, HPI’s quarterly purchase prices of coldrolled steel sheet fluctuated but increased from $*** per pound during January-March 2004 to *** per

pound by July-September 2008, or by *** percent, before decreasing to *** per pound by July-September

2009 and ending at $*** per pound during October-December 2009.2

 HPI indicated that it experienced

*** purchase prices for its steel during 2004 and 2008, when its costs of steel on an annual basis

increased by *** percent and *** percent, respectively.3

Figure V-1

Cold-rolled steel sheet: HPI’s purchase prices, by quarter, 2004-09

* * * * * * *

*** reported that, because of market power of the larger retailers, it has been difficult ***. HPI

reported that, as a result, when steel prices change, its profits ***.4

U.S.-Inland Transportation Costs

The U.S. producer of ironing tables, HPI, and five responding U.S. importers of ironing tables

from China reported in their questionnaire responses the average U.S. freight costs to their U.S.

 1 Part II discusses in detail substitution between ironing tables and alternative products and substitution between

the U.S.-produced ironing tables and imports of ironing tables from nonsubject countries.

 2 U.S. producer questionnaire response, section IV-24.

 3 As discussed in Part III, HPI’s unit raw material costs increased *** in 2004 and 2008, which correspond to

increases in its steel costs during these years.

 4 *** with this assertion is the observation that changes in HPI’s reported quarterly selling prices of the three

ironing table products for which it reported pricing data, shown later in Part V, were *** correlated with the

quarterly movements in its reported purchase prices of steel sheet during 2004-09. The correlation coefficients

between prices of the ironing table products and steel sheet ranged from *** percent for product 1 to *** percent for

product 3.

V-1
customers’ locations. U.S.-inland freight costs for domestic ironing tables averaged *** percent of the

delivered prices,5

 and U.S.-inland freight costs of imported ironing tables from China averaged 5.7

percent of the delivered prices. HPI and seven responding U.S. importers of ironing tables from China

also reported in their questionnaire responses their U.S. shipments of the domestic and subject imported

products, during 2004-09, that were shipped to U.S. customers in three specified distance categories. HPI

and U.S. importers’ reported weighted-average shipment shares of the domestic and subject imported

ironing tables, by distance categories from their U.S. selling locations, are shown in the following

tabulation.

Distance shipped

Share of U.S. shipments (percent)

U.S. ironing tables

Imported ironing tables

from China

Within 100 miles *** 0.1

101 to 1,000 miles *** 12.1

Over 1,000 miles *** 87.9

Total 100.0 100.0

PRICING PRACTICES6

HPI and U.S. importers of ironing tables from China sell the majority of their products to

retailers, and the remainder to distributors and commercial users, typically on a short-term basis.7

 HPI

and five importers of the ironing tables from China reported their 2009 U.S. shipments by length of sales

period in their questionnaire responses. Weighted-average shares of the 2009 U.S. commercial shipment

quantities of the domestically produced and subject imported ironing tables, by length of sales period, are

shown in the following tabulation.

Length of sales

period

Share of U.S. shipments (percent)

U.S. ironing tables

Imported ironing tables

from China

Spot sales *** 4.6

Short-term sales *** 77.5

Long-term sales *** 17.8

Total 100.0 100.0

Note.–Figures may not add to 100 due to rounding.

 5 ***.

 6 Information on pricing practices discussed in this section was based on questionnaire responses of the U.S.

producer of ironing tables and importers of ironing tables from China, unless otherwise noted.

 7 Spot sales are usually one-time delivery, within 30 days of the purchase agreement; short-term sales are for

multiple deliveries for up to 12 months after the purchase agreement; and long-term sales are for multiple deliveries

for more than 12 months after the purchase agreement. Short-term and long-term sales can be arranged by contracts

or verbal agreements.

V-2
HPI and four U.S. importers of ironing tables from China reported the terms of their short-term

contracts, while three U.S. importers reported the terms of their long-term contracts. HPI reported that

(1) short-term contract periods ranged from *** months for promotions to *** months; (2) prices were

generally *** during the promotional period, but *** during the ***-month contracts; (3) short-term

contracts typically specified ***, and (4) short-term contracts generally *** meet or release provisions. 

The responding U.S. importers reported that (1) short-term contract periods ranged from 3 to 12 months

and long-term contracts were 12 months with renewable provisions; (2) they were evenly split between

whether prices could be renegotiated in short-term contracts, but typically indicated no renegotiations in

long-term contracts; (3) short- and long-term contracts generally fixed price only; and (4) short- and longterm contracts generally had no meet or release provisions.8

HPI and six U.S. importers of ironing tables from China reported that they generally determined

price on a combination of individual transaction basis, contracts, and price list. The U.S. producer and six

of seven responding U.S. importers reported offering quantity discounts; the remaining U.S. importer

reported that it did not offer quantity discounts. HPI reported selling its products primarily on *** basis. 

Five of six U.S. importers of the ironing tables from China reported selling their products on an f.o.b.

U.S. location basis, and the remaining importer reported selling on a delivered basis. HPI reported

offering payment terms of net *** days, whereas the seven responding importers reported offering

payment terms of net 30-90 days. 

HPI and six responding U.S. importers of the ironing tables from China reported in their

questionnaire responses that their sales negotiations occurred during traditional line reviews of the

customers and,9

 except for a ***, their ironing tables were sold as separate items. *** ironing table sales

by HPI and sales by one importer were “bundled” with other products.10 HPI, all nine responding U.S.

importers of the ironing tables from China, and all 13 responding U.S. purchasers reported that they did

not sell/purchase their ironing tables via internet auctions during 2004-09.11

Line Reviews

A line review is conducted by the retailer and can occur annually or more frequently for reasons

such as seasonal promotions (e.g., back-to-college demand), price increases of existing supplier(s), poor

demand for current offerings of ironing table products, etc. Typical factors considered in a line review by

purchasers include the following: product innovations; suggestions from suppliers to improve retail sales;

supplier capabilities, ability to ship desired quantities, financial stability, management continuity, quality,

ability to provide comprehensive ironing table and accessory program, and product innovations; to see

new product technology; customer complaints/returns; pricing; vendor payment terms; and review of

 8 Twelve purchasers reported in their questionnaire responses the number of times prices of ironing tables

changed during 2004-09. Their responses ranged from 2 to 7 times, not frequently, annually, with fluctuations in the

price of steel, and with changes in the materials and product features of the ironing table purchased.

 9 One of these six importers, ***, is a retailer that also purchases ironing tables, and based its line review

response on its imports rather than sales. 

 10 Bundled sales of ironing tables occur when ironing tables and other products, such as irons and other laundry

items, are sold as a group under a bundled (combined) price; prices of the different items may be specified but are

not independently determined.

 11 U.S. producer, importer, and purchaser questionnaire responses, sections IV-8, III-9, and II-7, respectively.

V-3
sales and profits for the previous period.12 HPI and two U.S. importers, ***, also provided discussions of

their line review experiences that provide additional information about price negotiations and sales

strategies for ironing tables.

“***”

“***”

“***”

Importance of Product Features13

HPI, U.S. importers, and purchasers were requested to indicate whether mesh-top and perforatedtop ironing tables were interchangeable in use; their responses are shown in the following tabulation.

Type of

responding firm

Mesh-top interchangeable

with perforated-top ironing

tables 

Yes No

U.S. producer *** ***

U.S. importers *** ***

Purchasers *** ***

Total 14 9

Three of the firms indicating that the two different style tops were interchangeable also provided

comments, which are the following: Most consumers are not aware of the type of table top because they

are used with a cover (***); all purchases of *** are the mesh-top; and, despite being interchangeable,

mesh tops provide better pressing than perforated tops (***). The firms indicating that the two different

style tops were not interchangeable asserted that mesh-top ironing tables provide better ventilation for

heat and moisture for superior ironing results. In addition, two importers, ***, asserted that the mesh-top

style enables production of rounded surface designs of the table top for better user-interface with garment

items.

The responding firms were also requested to indicate the importance of any performance

differences between mesh-top and perforated-top ironing tables in their sales/purchases of ironing tables

during 2004-09. The firms were requested to identify any such performance differences as ‘very

important’, ‘somewhat important’, or ‘not important’; their responses are shown in the tabulation below.

 12 U.S. producer, importer, and purchaser questionnaire responses, sections IV-12b, III-13b, and II-6b,

respectively.

 13 The discussion in this section is based on questionnaire responses of the U.S. producer, importers, and

purchasers of ironing tables.

V-4
Type of responding

firm

Importance of performance differences

between mesh-top and perforated-top

ironing tables 

Very

important

Somewhat

important

Not

important

U.S. producer *** *** ***

U.S. importers *** *** ***

Purchasers *** *** ***

Total 8 3 11

*** indicated that its perforated-top ironing tables compete head-to-head with similar mesh-top

ironing tables and asserted that the most important determinant is price. On the other hand, an importer

also reporting ‘not important’, ***, asserted that its customers would never accept a perforated-top

ironing table for their assortment at price points over $***.

 HPI, U.S. importers, and purchasers were requested to indicate whether mesh-top or perforatedtop ironing tables with comparable features carried a price premium vis-a-vis each other during 2004-09;

their responses are shown in the following tabulation.

Type of responding

firm

Price difference between mesh-top and

perforated-top ironing tables 

Mesh-top

higher

priced

Perforatedtop higher

price

No price

difference

U.S. producer1 *** *** ***

U.S. importers *** *** ***

Purchasers *** *** ***

Total 9 2 9

 1 ***.

HPI, U.S. importers, and purchasers were requested to indicate and discuss the importance of

additional features (e.g. iron rests, cord holders, linen racks, etc.) attached to ironing tables in their

sales/purchases of ironing tables during 2004-09. The firms were requested to identify the degree of

importance as ‘very important’, ‘somewhat important’, or ‘not important’; there responses are shown in

the tabulation below.

V-5
Type of responding

firm

Importance of additional features of

ironing tables 

Very

important

Somewhat

important

Not

important

U.S. producer *** *** ***

U.S. importers *** *** ***

Purchasers *** *** ***

Total 7 9 7

 

The 16 firms reporting that additional features of ironing tables were very or somewhat important

identified iron rests most frequently followed by cord minders, garment/linen racks, built-in socket for the

iron, heavier pad/better quality cover for the top, extra pad and cover, fashion colors, quiet sliding

mechanism, locking mechanisms on height adjustment, wheels for moving to storage, and wider tops. 

One or more of these features reportedly are found on the higher-end ironing tables.

Four of the seven firms reporting that additional features of ironing boards were not important

provided additional comments. *** indicated that additional features were not important in its sales

because about *** percent of its ironing table sales consisted of opening price-point T-leg tables, which

have no additional features, and another *** percent of its sales consist of basic 4-leg ironing tables,

which have no or minimal additional features. ***, an importer asserted that 90 percent of the volume of

ironing table sales in the U.S. market were the basic T-leg and 4-leg tables. ***, a purchaser, reported

purchasing a single basic-style ironing table with no additional features. ***, another purchaser, asserted

that the most important feature for the firm was the ability to provide a coordinated ironing table and

accessory program that has a matching style and packaging.

HPI, U.S. importers, and purchasers were also requested to report and discuss whether they

sold/purchased high-end ironing tables and to report the number of U.S.-produced and imported Chinese

high-end ironing tables that they purchased in 2009. For purposes of this question, the following

description of high-end ironing tables, provided in part by HPI, was specified in the questionnaires: Floor

standing, metal-top ironing tables with metal thickness of legs greater than 1.0 mm and total table weight

greater than 7.5 kg and suggested retail price of $70 or more.14 The responding firm’s reported

sales/purchases of the high-end ironing tables are shown in the tabulation on the following page.

 14 Two responding U.S. importers disputed this definition of high-end. *** asserted that 70-75 percent of the

U.S. market for steel-top ironing tables rests with suggested retail prices less than $19.99 per table and that upper

price points start at $19.99 per table, with $70.00 per table representing the high-end of the spectrum. *** asserted

that thickness of steel and weight of the product are not relevant parameters for a definition of high-end ironing

tables. The firm asserted that better parameters for high-end ironing tables should include the following: (1) a

branded product; (2) at least 10 years of guaranty; (3) added features; (4) quality; and (5) service of the supplier. 

The firm further indicated that all of its ironing tables retail for more than $70.00 per table, which appear to be

imported from Europe.

V-6
Type of

responding

firm

Sales/purchases of highend ironing tables 2009 sales/purchases (units)

Yes No

U.S. -produced

products

Imported

products from

China

U.S. producer *** *** *** ***

U.S. importers *** *** *** ***

Purchasers *** *** ***1 ***

Total 8 13 ***

 1 *** (staff telephone interview with ***). 

The eight firms selling/purchasing high-end ironing tables identified the features that customers

find in high-end ironing tables, which included all of the additional features listed earlier that were

reported by firms that found additional features ‘important’ or ‘somewhat important’. In addition, brand

name was also considered a major characteristic of high-end ironing tables.

PRICE DATA

U.S. selling value and quantity data were requested from the U.S. producer of ironing tables, HPI,

and U.S. importers for their U.S. sales of the following ironing table products15 produced in the United

States and imported from China:16

Product 1.--Floor-standing, metal perforated-top ironing tables, T-leg, with metal

thickness of legs # 1.0 mm, total table weight # 7.5 kg, with pad and cover, and no

additional equipment.

Product 2.--Floor-standing, metal perforated-top ironing tables, T-leg, with metal

thickness of legs > 1.0 mm, total table weight > 7.5 kg, with pad and cover, and no

additional equipment.

 15 The six ironing table products may include an iron rest and/or linen rack, but no equipment extraneous to the

ironing table, such as an iron. In addition, the responding firm’s were requested to provide price data for products

that competed with the specified product even if the product specifications of their product did not exactly meet the

product specifications of the specified product, and to provide a description of their product. 

 16 HPI and Group SEB both made suggestions regarding the proposed pricing products in their comments on the

draft questionnaires. HPI asserted that the two pricing products used in the final investigation were appropriate

product categories, but asserted that obtaining information on 4-leg ironing tables would be difficult due to

differences among these ironing tables (letter from HPI, “Comments on Draft Questions from HPI,” December 15,

2009). Group SEB suggested three product categories, specified by mesh or perforated metal tops and by weight

and metal thickness, but not by number of legs (letter from Group SEB, “Comments on Draft Questionnaires,”

December 15, 2009). Staff decided on the above six products by dividing the original two products into four

products based on the metal thickness and total weight thresholds suggested by Group SEB, and adding two meshtop 4-leg ironing table products differentiated by the suggested metal thickness and total weight thresholds. This

approach accounts for the fact that raw materials, principally steel, comprise the *** cost in producing ironing

tables.

V-7
Product 3.--Floor-standing, metal mesh-top ironing tables, T-leg, with metal thickness

of legs # 1.0 mm, total table weight # 7.5 kg, with pad and cover, and no additional 

equipment.

Product 4.--Floor-standing, metal mesh-top ironing tables, T-leg, with metal thickness

of legs > 1.0 mm, total table weight > 7.5 kg, with pad and cover, and no additional 

equipment.

Product 5.--Floor-standing, metal mesh-top ironing tables, four legs, with metal thickness

of legs # 1.0 mm, total table weight # 7.5 kg, with pad and cover, and no additional

equipment.

Product 6.--Floor-standing, metal mesh-top ironing tables, four legs, with metal thickness

of legs > 1.0 mm, total table weight > 7.5 kg, with pad and cover, and no additional

equipment.

HPI and U.S. importers were requested to report their quarterly net U.S. f.o.b. selling price data

for their respective shipments of the specified domestic ironing tables and the imported ironing tables

from China to U.S. retailers unrelated to the suppliers during 2004-09.17 In addition, retailers that

imported ironing tables from China were requested to provide their quarterly import price data on a

landed (c.i.f.), duty-paid, U.S. ports-of-entry basis during 2004-09.18 The selling price and import price

data were requested separately for unbundled and bundled sales of ironing tables.19 Staff did not request

selling price data of ironing tables by purchaser or type of purchaser or purchase prices of retailers or

distributors.20 As noted earlier in the report, the responding purchasers (overwhelmingly retailers) bought

predominantly the domestic or imported Chinese ironing tables, such that selling price comparisons,

based on prices to an individual retailer or type of retailer, could have magnified the impact of volume

differences by country of origin.

HPI and five U.S. importers of ironing tables from China reported useable selling price

information, but not necessarily for all periods or all products. In addition, ***, a U.S. retailer, reported

import price data for their imported ironing tables from China. HPI reported total sales quantities of the

U.S.-produced ironing tables for pricing purposes during 2004-09 that accounted for virtually all (***)

percent of its reported U.S. commercial shipments of U.S.-produced ironing tables during this period.21

The responding U.S. importers reported total sales quantities for selling price purposes during 2004-09

that accounted for 56.0 percent of total reported U.S. commercial shipments of imported ironing tables

from China during this period. Most of the selling price data of the domestic and imported ironing tables

from China are based on unbundled sales, with only a limited quantity of bundled sales.

 17 Selling price data were requested f.o.b. the U.S. producer’s plant and f.o.b. U.S. ports-of-entry. Any sales

from U.S. warehouses not located at the U.S. plant or ports-of-entry were to exclude from the value the U.S.-inland

freight costs to the warehouses and then to the customers.

 18 The import price data were to exclude any U.S. inland freight from the U.S. ports-of-entry to the retail

outlets/warehouses.

 19 For purposes of this review, the term “bundled” is defined as the sale/import of ironing tables with one or more

other products, where the price of the ironing tables may or may not be affected by the group negotiated price. A

bundled sale/import does not include the sale/import of ironing tables that includes other products for one-stopshopping purposes and where no group price is considered.

 20 Purchaser records do not always track the country of origin of the purchased ironing tables. ***.

 21 HPI’s reported ironing table pricing data ***. Staff telephone interview with *** and e-mail from ***, May 5,

2010.

V-8
In addition, *** reported total import quantities for pricing purposes during 2004-09 that

accounted for an additional *** percent of total reported U.S. commercial shipments of imported ironing

tables from China during this period. However, after further review, the values that *** reported for its

imports were ***.22 The firm reported that ***.23 Staff notes that, based on official statistics, the charges,

insurance, and freight costs for all U.S. imports of ironing tables from China averaged 18.8 percent of the

customs value during 2004-09.24

Total quantities of the specified six ironing table products for which HPI and U.S. importers

reported their requested pricing data during 2004-09 are shown in the following tabulation.

Quantities of ironing tables (1,000 units)

Products

Sales of U.S.-produced ironing

tables Ironing tables from China

TOTAL

Unbundled Bundled Total

Importer sales

Retailer

imports Total

Unbundled Bundled

Product 11 *** *** *** - - *** *** ***

Product 22 *** *** *** - - *** *** ***

Product 33 *** *** *** 559 185 *** *** ***

Product 44 *** *** *** 1,323 - *** *** ***

Product 55 *** *** *** 2,356 66 *** *** ***

Product 66 *** *** *** 387 - *** *** ***

Totals *** *** *** 4,625 251 *** *** ***

 1 Product 1 is a T-leg, perforated-top ironing table with metal thickness # 1.0 mm and total table weight # 7.5 kg.

 2

 Product 2 is a T-leg, perforated-top ironing table with metal thickness > 1.0 mm and total table weight > 7.5 kg.

 3

 Product 3 is a T-leg, mesh-top ironing table with metal thickness # 1.0 mm and total table weight # 7.5 kg. One

of the importers, ***, reported unbundled sale price data of the Chinese product 3 for its *** ironing tables as its

imported product competitive with the domestic T-leg table.

 4

 Product 4 is a T-leg, mesh-top ironing table with metal thickness > 1.0 mm and total table weight > 7.5 kg.

 5

 Product 5 is a 4-leg, mesh-top ironing table with metal thickness # 1.0 mm and total table weight # 7.5 kg.

 6

 Product 6 is a 4-leg, mesh-top ironing table with metal thickness > 1.0 mm and total table weight > 7.5 kg

Note.–All of the retailer import quantities for pricing purposes were unbundled.

 22 E-mail from ***, March 26, 2010.

 23 ***. Ibid.

 24 On the other hand, Polder reported that the percentage difference between its cost price f.o.b. China and its

U.S. landed cost of its imported T-leg ironing tables from China during 2004-09 averaged (simple average) ***

percent and ranged from *** percent during 2009 to *** percent during 2005 (respondent interested parties’

posthearing brief, appendix PH-5).

V-9
As indicated in the preceding tabulation, sales of product *** represented the largest-volume

sales of the domestic ironing tables and product 5 represented the largest-volume sales of the imported

ironing tables from China. Product *** represented the largest-volume of sales where the domestic

ironing tables and those from China can be compared for a single product. Bundled sales of the domestic

ironing tables and those imported from China were *** less than unbundled sales of these products; the

reported bundled sales did not provide any direct price comparisons between the domestic ironing tables

and imported ironing tables from China. Also, no price data were reported for product 2.

Price trends and price comparisons of quarterly weighted-average selling prices and the quarterly

shipment quantities are based on the reported net U.S. f.o.b. selling price data. The price data for

unbundled sales are shown for product 1 and products 3-6 in tables V-1 through V-5 and figures V-2

through V-6, respectively. The retailer import data for imported products 3 and 5 are also shown in tables

V-2 and V-4, respectively.25 Price data for bundled sales of the domestic ironing tables and imported

ironing tables from China are shown in table 6,26 but are not discussed further due to the relatively limited

volume of such data and the uncertainty about how such prices are determined from one sale to another.27

In addition, U.S. producer selling prices for products 1 and 3 combined, with selling prices of the

imported product 3 from China, are shown in appendix E, table E-1; and selling prices for the imported

products 3 and 4 combined from China, with the U.S. producer’s selling prices for product 3, are shown

in appendix E, table E-2. 

Table V-1

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic ironing table product 1 by quarters, January 2004-December 2009

* * * * * * *

Table V-2

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic and imported Chinese ironing table product 3, retailer import (unbundled) prices and

quantities for product 3 from China, and margins of under/(over)selling, by quarters, January 2004-

December 2009

* * * * * * *

Table V-3

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

imported Chinese ironing table product 4 by quarters, January 2004-December 2009

* * * * * * *

 25 As noted earlier, the values reported for these imports are ***.

 26 The bundled prices are shown separately because they are determined differently than the unbundled prices,

which were often markedly different from the bundled prices. This difference likely occurs where prices of related

products directly impacted the prices of ironing tables in bundled sales.

 27 The impact of other products on the price of ironing tables in a bundled sale may differ from one sale-toanother and from one supplier-to-another, such that use of this data may be limited.

V-10
Table V-4

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic and imported Chinese ironing table product 5, retailer import (unbundled) prices and

quantities for product 5 from China, and margins of under/(over)selling, by quarters, January 2004-

December 2009

* * * * * * *

Table V-5

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the 

imported Chinese ironing table product 6 by quarters, January 2004-December 2009

* * * * * * *

Table V-6

Ironing tables: Net weighted-average U.S. f.o.b. selling (bundled) prices and quantities of the

domestic ironing table product 1 and the imported Chinese products 3 and 5, by quarters, January

2004-December 2009

* * * * * * *

Figure V-2

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic ironing table product 1, by quarters, January 2004-December 2009

* * * * * * *

Figure V-3

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic and imported Chinese ironing table product 3, by quarters, January 2004-December 2009

* * * * * * *

Figure V-4

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the 

imported Chinese ironing table product 4, by quarters, January 2004-December 2009

* * * * * * *

Figure V-5

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic and imported Chinese ironing table product 5, by quarters, January 2004-December 2009

* * * * * * *

Figure V-6

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the 

imported Chinese ironing table product 6, by quarters, January 2004-December 2009

* * * * * * *

V-11
Price Trends28

Quarterly prices of two of the three domestic ironing table products for which prices were

reported (products 1, 3, and 5) and the four ironing table products imported from China for which prices

were reported (products 3-6) fluctuated but generally increased during January 2004-December 2009.29

The lone exception was product 5 where prices of the domestic ironing tables decreased. Quarterly

shipment quantities of the three domestic products showed more pronounced fluctuation than prices of the

domestic products during January 2004-December 2009, with quantities of products 1 and 3 showing

little trend during this period, but product 5 quantities generally decreasing. Quarterly shipment

quantities of the imported ironing table products 3 and 5 fluctuated but showed little trend during January

2004-December 2009, while quantities of the imported product 4 generally decreased and quantities of

the imported product 6 generally increased during this period.30 A summary of price trends and high/low

prices for the domestic and imported ironing table products from China are shown in table V-7.

Quarterly prices of the domestic ironing table products 1 and 3 generally remained above their

initial period prices during January 2004-December 2009 and increased by *** percent and *** percent,

respectively, during this period. On the other hand, quarterly prices of the domestic ironing table product

5 generally remained below the initial period price and decreased by *** percent during this period.

Quarterly prices of the imported products 3, 4, and 6 from China generally remained above their

initial period prices during January 2004-December 2009 and increased by *** percent, *** percent, and

*** percent, respectively, during this period. It should be noted that both prices and quantities of the

imported product 3 fluctuated markedly during January 2004-December 2009 and reached their

respective period highs during January-March 2007. Quarterly prices of the imported product 5 remained

below the initial period price during 12 of the 24 quarters during January 2004-December 2009, but

prices generally increased during July 2008-December 2009 to end the period *** percent above the

initial period price.

The importer *** was an important source of the fluctuations in prices and quantities of the

imported product 3 from China.31

 28 The reported price data for the domestic and imported ironing tables from China were dominated by one or two

firms for each product. As a result, some of the price data, particularly for the imported products, may show marked

quarterly fluctuations in prices and or quantities that result from changes in quantities and prices of a single

dominant firm or due to relative changes quarter-to-quarter of one firm vis-a-vis the other. The latter explanation

appeared to occur for prices and quantities of the imported product 3, where *** was the dominant importer.

 29 No price data were reported for product 2.

 30 Quarterly fluctuations in shipment quantities within a year may also be due to a seasonal demand pattern,

where shipments to retailers peaks during the summer months due new household formations and back-to-college

purchases. Changes in a particular quarter from one year to the next may also be due to cyclical demand

fluctuations, especially in 2008 and 2009 compared to 2007 due to the economic recession. ***.

 31 *** stated that ***. E-mail from ***, February 24, 2010.

V-12
Table V-7

Ironing tables: Summary of trends in quarterly weighted-average net f.o.b. selling (unbundled)

prices for domestic and subject imported ironing table products 1 and 3-6, by country of origin,

January 2004-December 2009

Country

Number of

quarters

reported

Highest price in

the period (per

unit)

Lowest price in

the period (per

unit)

Percentage

change in price

in the period1

Product 1 (perforated top, T-leg, # 7.5 kg table weight)

United States 24 $*** $*** ***

Product 3 (mesh top, T-leg, # 7.5 kg table weight)

United States 24 *** *** ***

China 24 *** *** ***

Product 4 (mesh top, T-leg, > 7.5 kg table weight)

China 24 *** *** ***

Product 5 (mesh top, 4-legs, # 7.5 kg table weight)

United States 24 *** *** ***

China 24 *** *** ***

Product 6 (mesh top, 4-legs, > 7.5 kg table weight)

China 24 *** *** ***

 1 Price changes are from the first quarter of 2004 to the fourth quarter of 2009.

Source: Compiled from data submitted in response to Commission questionnaires.

Price Comparisons

A total of 48 quarterly net weighted-average U.S. f.o.b. selling price comparisons, involving

unbundled sales, were possible between the domestic ironing table products 3 and 5 and those imported

from China during January 2004-December 2009. Four of the 48 selling price comparisons showed that

the imported products were priced less than the domestic products. Forty-three other price comparisons

showed that the imported products 3 and 5 from China were priced higher than the domestic products,

and the remaining single price comparison showed that the domestic and subject imported product 5 were

priced the same. Such overselling may result at least partially because ***.32 The selling price

comparisons are shown by period and by product in table V-8.

Table V-8

Ironing tables: Number of quarterly net weighted-average U.S. f.o.b. selling (unbundled) price

comparisons between U.S. ironing tables and imported ironing tables from China, by year and by

product, import quantities, and ranges of under/(over)selling, January 2004-December 2009

* * * * * * *

 32 HPI sells close to *** percent of its ironing tables *** (U.S. producer questionnaire response, section IV-5). 

In addition, HPI indicated that ***; submitted separately on February 4, 2004 in response to question I-8 of the U.S.

producer questionnaire).

V-13
The *** U.S. importer to report selling price data, ***, reported selling price data for Chinese

product 4, a heavier more steel-intensive version of product 3;33 selling prices of the imported product 4

were consistently lower than selling prices of the domestic product 3.34 35 Combining price data for all the

reported imported products 3 and 4 from China and comparing such weighted-average prices with prices

of the domestic product 3 showed that the imported products were priced less than the domestic product

in 9 of 24 quarters, but were priced higher in the remaining 15 quarters. These price data are shown in

appendix E, table E-2.

Although not shown, *** reported quarterly prices (f.o.b. the Chinese factory) of the two ironing

table products, 3 and 5, that it imported from China during 2004-09 were generally *** HPI’s reported

selling prices of its domestic ironing table products 3 and 5, respectively. The price differences for the 32

quarters where the prices of the Chinese products were less than prices of the domestic products ranged

from *** percent to *** percent below prices of the domestic products,36 whereas the price differences in

the 4 quarters where the Chinese product (product 5) was priced higher than the domestic product ranged

from *** percent to *** percent above prices of the domestic product.

U.S. purchasers were requested to indicate in their questionnaire responses any price changes that

they observed in the U.S. market during 2004-09 between the domestic and imported ironing tables from

China. Six of nine responding purchasers indicated that the price of the domestic ironing tables changed

relative to the price of the imported ironing tables from China, while the remaining three responding

purchasers indicated that prices of the domestic and imported ironing tables changed by the same amount. 

In addition, three of seven responding purchasers reported that prices of domestic ironing tables were

higher than the imported ironing tables from China, whereas the remaining four purchasers reported that

prices of the domestic products were lower.

U.S. purchasers were also requested to indicate in their questionnaire responses how frequently

(‘always’, ‘usually’, ‘sometimes’, or ‘never’) they purchased ironing tables that were the lowest in price.

Of the 11 purchasers that responded, five purchasers reported that they ‘always’ or ‘usually’ purchase

ironing tables that were lowest in price, whereas the remaining six purchasers reported that they

‘sometimes’ or ‘never’ do so.37

The price comparisons from the final investigation, based on the Commission’s traditional

approach, were based on quarterly selling price data during January 2001-March 2004 for the following

 33 ***; both of its products 3 and 4 were the specified T-leg, mesh-top, ironing tables. In response to a staff

request for clarification, *** (e-mail from ***, February 22, 2010). ***.

 34 Although not shown, the selling prices of product 4 imported from China by *** were consistently less than

selling prices of the domestic product 3 during all 24 quarters that these price data were reported and ranged from

*** percent to *** percent below prices of the domestic product 3. It should be noted that based on responding

purchasers, *** sold to only *** of the 13 responding purchasers. Of these *** purchasers, *** sold the domestic

and imported Chinese ironing table products to ***, such that during 2009, the only period that *** reported

purchases of both domestic and imported Chinese ironing tables, *** domestic ironing tables and *** imported

ironing tables were purchased by this firm (it is not known what ironing table products were included in these

figures). 

 35 Household Essentials reported that HPI’s selling prices of the T-leg ironing tables to Walmart were well below

Whitney Design’s landed costs of the T-leg ironing tables from China, and that HPI has had all of Walmart’s T-leg

business since 2007 (respondent interested parties’ posthearing brief, appendix PH-3).

 36 Twenty-seven of these comparisons involved prices of the Chinese products that were at least *** percent less

than prices of the domestic products.

 37 In addition, five purchasers identified the following non-price factors that were important in sourcing their

ironing tables: product quality, service, reliability, shorter lead times, and vendor support and relationship.

V-14
single product–floor standing, metal mesh-top ironing tables, T-leg, with pad and cover. A total of 13

quarterly net weighted-average U.S. f.o.b. selling price comparisons were possible between the domestic

and imported ironing table product from China during January 2001-March 2004. Nine of the 13 selling

price comparisons showed that the imported product was priced less than the domestic product, by

margins ranging from *** percent to *** percent. The remaining four price comparisons showed that the

imported product from China was priced higher than the domestic product, by margins ranging from ***

percent to *** percent.38

In addition, price comparisons from the final phase of the original investigation were based on

sales of the following domestic product–floor standing, metal perforated-top ironing tables, T-leg, with

pad and cover and the following product imported from China--floor standing, metal mesh-top ironing

tables, T-leg, with pad and cover. A total of 13 quarterly net weighted-average U.S. f.o.b. selling price

comparisons were possible between these domestic and imported ironing table products from China

during January 2001-March 2004. The Chinese product was priced higher than the domestic product in

all 13 quarters.39

 38 Original staff report, confidential version, Table V-2 and p. V-11.

 39 Original staff report, confidential version, Table V-1 and p. V-11.

V-15

APPENDIX A

FEDERAL REGISTER NOTICES

A-1

31412 Federal Register / Vol. 74, No. 125 / Wednesday, July 1, 2009 / Notices 

Dated: June 24, 2009. 

James H. Lecky, 

Office Director, Office of Protected Resources, 

National Marine Fisheries Service. 

[FR Doc. E9–15552 Filed 6–30–09; 8:45 am] 

BILLING CODE 3510–22–S 

DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric 

Administration 

RIN 0648–XP85 

Incidental Taking of Marine Mammals; 

Taking of Marine Mammals Incidental 

to the Explosive Removal of Offshore 

Structures in the Gulf of Mexico 

AGENCY: National Marine Fisheries 

Service (NMFS), National Oceanic and 

Atmospheric Administration (NOAA), 

Commerce. 

ACTION: Notice; issuance of letters of 

authorization. 

SUMMARY: In accordance with the 

Marine Mammal Protection Act 

(MMPA) and implementing regulations, 

notification is hereby given that NMFS 

has issued one-year Letters of 

Authorization (LOA) to take marine 

mammals incidental to the explosive 

removal of offshore oil and gas 

structures (EROS) in the Gulf of Mexico. 

DATES: These authorizations are 

effective from July 1, 2009 through June 

30, 2010. 

ADDRESSES: The application and LOAs 

are available for review by writing to P. 

Michael Payne, Chief, Permits, 

Conservation, and Education Division, 

Office of Protected Resources, National 

Marine Fisheries Service, 1315 EastWest Highway, Silver Spring, MD 

20910–3235 or by telephoning the 

contact listed here (see FOR FURTHER

INFORMATION CONTACT), or online at: 

http://www.nmfs.noaa.gov/pr/permits/ 

incidental.htm. Documents cited in this 

notice may be viewed, by appointment, 

during regular business hours, at the 

aforementioned address. 

FOR FURTHER INFORMATION CONTACT: 

Howard Goldstein or Ken Hollingshead, 

Office of Protected Resources, NMFS, 

301–713–2289. 

SUPPLEMENTARY INFORMATION: Section 

101(a)(5)(A) of the MMPA (16 U.S.C. 

1361 et seq.) directs the NMFS to allow, 

upon request, the incidental, but not 

intentional, taking of small numbers of 

marine mammals by United States 

citizens who engage in a specified 

activity (other than commercial fishing) 

within a specified geographical region, 

if certain findings are made by NMFS 

and regulations are issued. Under the 

MMPA, the term ‘‘taking’’ means to 

harass, hunt, capture, or kill or to 

attempt to harass, hunt capture, or kill 

marine mammals. 

Authorization for incidental taking, in 

the form of annual LOAs, may be 

granted by NMFS for periods up to five 

years if NMFS finds, after notification 

and opportunity for public comment, 

that the taking will have a negligible 

impact on the species or stock(s) of 

marine mammals, and will not have an 

unmitigable adverse impact on the 

availability of the species or stock(s) for 

subsistence uses (where relevant). In 

addition, NMFS must prescribe 

regulations that include permissible 

methods of taking and other means 

effecting the least practicable adverse 

impact on the species and its habitat 

(i.e., mitigation), and on the availability 

of the species for subsistence uses, 

paying particular attention to rookeries, 

mating rounds, and areas of similar 

significance. The regulations also must 

include requirements pertaining to the 

monitoring and reporting of such taking. 

Regulations governing the taking 

incidental to EROS were published on 

June 19, 2008 (73 FR 34889), and remain 

in effect through July 19, 2013. For 

detailed information on this action, 

please refer to that Federal Register 

notice. The species that applicants may 

take in small numbers during EROS 

activities are bottlenose dolphins 

(Tursiops truncatus), Atlantic spotted 

dolphins (Stenella frontalis), 

pantropical spotted dolphins (Stenella 

attenuata), Clymene dolphins (Stenella 

clymene), striped dolphins (Stenella 

coeruleoalba), spinner dolphins 

(Stenella longirostris), rough-toothed 

dolphins (Steno bredanensis), Risso’s 

dolphins (Grampus griseus), melonheaded whales (Peponocephala electra), 

short-finned pilot whales (Globicephala 

macrorhynchus), and sperm whales 

(Physeter macrocephalus). 

Pursuant to these regulations, NMFS 

has issued an LOA to St. Mary Land & 

Exploration Company and Apache 

Corporation. Issuance of these LOAs is 

based on a finding made in the 

preamble to the final rule that the total 

taking by these activities (with 

monitoring, mitigation, and reporting 

measures) will result in no more than a 

negligible impact on the affected species 

or stock(s) of marine mammals and will 

not have an unmitigable adverse impact 

on subsistence uses. NMFS also finds 

that the applicants will meet the 

requirements contained in the 

implementing regulations and LOA, 

including monitoring, mitigation, and 

reporting requirements. 

Dated: June 25, 2009. 

James H. Lecky, 

Director, Office of Protected Resources, 

National Marine Fisheries Service. 

[FR Doc. E9–15551 Filed 6–30–09; 8:45 am] 

BILLING CODE 3510–22–S 

DEPARTMENT OF COMMERCE 

International Trade Administration 

Initiation of Five-year (‘‘Sunset’’) 

Review 

AGENCY: Import Administration, 

International Trade Administration, 

Department of Commerce. 

SUMMARY: In accordance with section 

751(c) of the Tariff Act of 1930, as 

amended (‘‘the Act’’), the Department of 

Commerce (‘‘the Department’’) is 

automatically initiating a five-year 

review (‘‘Sunset Review’’) of the 

antidumping duty orders listed below. 

The International Trade Commission 

(‘‘the Commission’’) is publishing 

concurrently with this notice its notice 

of Institution of Five-year Review which 

covers the same orders. 

EFFECTIVE DATE: July 1, 2009. 

FOR FURTHER INFORMATION CONTACT: The 

Department official identified in the 

Initiation of Review section below at 

AD/CVD Operations, Import 

Administration, International Trade 

Administration, U.S. Department of 

Commerce, 14th Street & Constitution 

Avenue, NW, Washington, DC 20230. 

For information from the Commission 

contact Mary Messer, Office of 

Investigations, U.S. International Trade 

Commission at (202) 205–3193. 

SUPPLEMENTARY INFORMATION: 

Background 

The Department’s procedures for the 

conduct of Sunset Reviews are set forth 

in its Procedures for Conducting Fiveyear (‘‘Sunset’’) Reviews of 

Antidumping and Countervailing Duty 

Orders, 63 FR 13516 (March 20, 1998) 

and 70 FR 62061 (October 28, 2005). 

Guidance on methodological or 

analytical issues relevant to the 

Department’s conduct of Sunset 

Reviews is set forth in the Department’s 

Policy Bulletin 98.3 - Policies Regarding 

the Conduct of Five-year (‘‘Sunset’’) 

Reviews of Antidumping and 

Countervailing Duty Orders: Policy 

Bulletin, 63 FR 18871 (April 16, 1998). 

Initiation of Review 

In accordance with 19 CFR 

351.218(c), we are initiating the Sunset 

Review of the following antidumping 

duty orders: 

Federal Register / Vol. 74, No. 125 / Wednesday, July 1, 2009 / Notices 31413 

1 In comments made on the interim final sunset 

regulations, a number of parties stated that the 

proposed five-day period for rebuttals to 

substantive responses to a notice of initiation was 

insufficient. This requirement was retained in the 

final sunset regulations at 19 CFR 351.218(d)(4). As 

provided in 19 CFR 351.302(b), however, the 

Department will consider individual requests to 

extend that five-day deadline based upon a showing 

of good cause. 

DOC Case No. ITC Case No. Country Product Department Contact 

A–570–007 ......... 731–TA–149 PRC Barium Chloride (3rd Review) Matthew Renkey (202) 482–2312 

A–570–002 ......... 731–TA–130 PRC Chloropicrin (3rd Review) Matthew Renkey (202) 482–2312 

A–570–888 ......... 731–TA–1047 PRC Floor–Standing, Metal Top Ironing Tables 

And Parts Thereof 

Dana Mermelstein (202) 482–1391 

A–570–886 ......... 731–TA–1043 PRC Polyethylene Retail Carrier Bags Dana Mermelstein (202) 482–1391 

A–557–813 ......... 731–TA–1044 Malaysia Polyethylene Retail Carrier Bags Dana Mermelstein (202) 482–1391 

A–549–821 ......... 731–TA–1045 Thailand Polyethylene Retail Carrier Bags Dana Mermelstein (202) 482–1391 

A–427–001 ......... 731–TA–44 France Sorbitol (3rd Review) Dana Mermelstein (202) 482–1391 

A–475–820 ......... 731–TA–770 Italy Stainless Steel Wire Rod (2nd Review) Brandon Farlander (202) 482–0182 

A–588–843 ......... 731–TA–771 Japan Stainless Steel Wire Rod (2nd Review) Brandon Farlander (202) 482–0182 

A–580–829 ......... 731–TA–772 South Korea Stainless Steel Wire Rod (2nd Review) Brandon Farlander (202) 482–0182 

A–469–807 ......... 731–TA–773 Spain Stainless Steel Wire Rod (2nd Review) Brandon Farlander (202) 482–0182 

A–401–806 ......... 731–TA–774 Sweden Stainless Steel Wire Rod (2nd Review) Brandon Farlander (202) 482–0182 

A–583–828 ......... 731–TA–775 Taiwan Stainless Steel Wire Rod (2nd Review) Brandon Farlander (202) 482–0182 

A–570–887 ......... 731–TA–1046 PRC Tetrahydrofurfuryl Alcohol Matthew Renkey (202 482–2312 

Filing Information 

As a courtesy, we are making 

information related to Sunset 

proceedings, including copies of the 

pertinent statute and Department’s 

regulations, the Department schedule 

for Sunset Reviews, a listing of past 

revocations and continuations, and 

current service lists, available to the 

public on the Department’s sunset 

Internet Web site at the following 

address: ‘‘http://ia.ita.doc.gov/sunset/.’’ 

All submissions in these Sunset 

Reviews must be filed in accordance 

with the Department’s regulations 

regarding format, translation, service, 

and certification of documents. These 

rules can be found at 19 CFR 351.303. 

Pursuant to 19 CFR 351.103 (d), the 

Department will maintain and make 

available a service list for these 

proceedings. To facilitate the timely 

preparation of the service list(s), it is 

requested that those seeking recognition 

as interested parties to a proceeding 

contact the Department in writing 

within 10 days of the publication of the 

Notice of Initiation. 

Because deadlines in Sunset Reviews 

can be very short, we urge interested 

parties to apply for access to proprietary 

information under administrative 

protective order (‘‘APO’’) immediately 

following publication in the Federal 

Register of this notice of initiation by 

filing a notice of intent to participate. 

The Department’s regulations on 

submission of proprietary information 

and eligibility to receive access to 

business proprietary information under 

APO can be found at 19 CFR 351.304– 

306. 

Information Required from Interested 

Parties 

Domestic interested parties defined in 

section 771(9)(C), (D), (E), (F), and (G) of 

the Act and 19 CFR 351.102(b)) wishing 

to participate in a Sunset Review must 

respond not later than 15 days after the 

date of publication in the Federal 

Register of this notice of initiation by 

filing a notice of intent to participate. 

The required contents of the notice of 

intent to participate are set forth at 19 

CFR 351.218(d)(1)(ii). In accordance 

with the Department’s regulations, if we 

do not receive a notice of intent to 

participate from at least one domestic 

interested party by the 15-day deadline, 

the Department will automatically 

revoke the order without further review. 

See 19 CFR 351.218(d)(1)(iii). 

If we receive an order–specific notice 

of intent to participate from a domestic 

interested party, the Department’s 

regulations provide that all parties 

wishing to participate in the Sunset 

Review must file complete substantive 

responses not later than 30 days after 

the date of publication in the Federal 

Register of this notice of initiation. The 

required contents of a substantive 

response, on an order–specific basis, are 

set forth at 19 CFR 351.218(d)(3). Note 

that certain information requirements 

differ for respondent and domestic 

parties. Also, note that the Department’s 

information requirements are distinct 

from the Commission’s information 

requirements.1 Please consult the 

Department’s regulations for 

information regarding the Department’s 

conduct of Sunset Reviews. Please 

consult the Department’s regulations at 

19 CFR Part 351 for definitions of terms 

and for other general information 

concerning antidumping and 

countervailing duty proceedings at the 

Department. 

This notice of initiation is being 

published in accordance with section 

751(c) of the Act and 19 CFR 351.218 

(c). 

June 23, 2009. 

John M. Andersen, 

Acting Deputy Assistant Secretary for 

Antidumping and Countervailing Duty 

Operations. 

[FR Doc. E9–15570 Filed 6–30–04; 8:45 am] 

BILLING CODE 3510–DS–S 

DEPARTMENT OF COMMERCE 

National Oceanic and Atmospheric 

Administration 

RIN 0648–XQ09 

Marine Mammals; File No. 774–1847 

AGENCY: National Marine Fisheries 

Service (NMFS), National Oceanic and 

Atmospheric Administration (NOAA), 

Commerce. 

ACTION: Notice; receipt of application 

for an amendment 

SUMMARY: Notice is hereby given that 

NMFS Southwest Fisheries Science 

Center, Antarctic Marine Living 

Resources Program (Michael Gobel, Ph 

D, Principal Investigator), 3333 N Torrey 

Pines Ct, La Jolla, CA 92037, has 

requested an amendment to scientific 

research Permit No. 774–1847–03. 

DATES: Written, telefaxed, or e-mail 

comments must be received on or before 

July 31, 2009. 

ADDRESSES: The application and related 

documents are available for review by 

selecting ‘‘Records Open for Public 

Comment’’ from the Features box on the 

Applications and Permits for Protected 

Species (APPS) home page, https:// 

apps.nmfs.noaa.gov, and then selecting 

File No. 774–1847–04 from the list of 

available applications. 

These documents are also available 

upon written request or by appointment 

in the following office(s): 

Permits, Conservation and Education 

Division, Office of Protected Resources, 

Federal Register / Vol. 74, No. 126 / Thursday, July 2, 2009 / Notices 31755 

1No response to this request for information is 

required if a currently valid Office of Management 

and Budget (OMB) number is not displayed; the 

OMB number is 3117–0016/USITC No. 09–5–197, 

expiration date June 30, 2011. Public reporting 

burden for the request is estimated to average 15 

hours per response. Please send comments 

regarding the accuracy of this burden estimate to 

the Office of Investigations, U.S. International Trade 

Commission, 500 E Street, SW., Washington, DC 

20436. 

Merchandise from the Subject Country 

accounted for by your firm’s(s’) exports. 

(12) Identify significant changes, if 

any, in the supply and demand 

conditions or business cycle for the 

Domestic Like Product that have 

occurred in the United States or in the 

market for the Subject Merchandise in 

the Subject Country since the Order 

Date, and significant changes, if any, 

that are likely to occur within a 

reasonably foreseeable time. Supply 

conditions to consider include 

technology; production methods; 

development efforts; ability to increase

production (including the shift of 

production facilities used for other 

products and the use, cost, or 

availability of major inputs into 

production); and factors related to the 

ability to shift supply among different 

national markets (including barriers to 

importation in foreign markets or 

changes in market demand abroad). 

Demand conditions to consider include 

end uses and applications; the existence 

and availability of substitute products; 

and the level of competition among the 

Domestic Like Product produced in the 

United States, Subject Merchandise 

produced in the Subject Country, and 

such merchandise from other countries. 

(13) (OPTIONAL) A statement of 

whether you agree with the above 

definitions of the Domestic Like Product 

and Domestic Industry; if you disagree 

with either or both of these definitions, 

please explain why and provide 

alternative definitions. 

Authority: This review is being conducted 

under authority of title VII of the Tariff Act 

of 1930; this notice is published pursuant to 

section 207.61 of the Commission’s rules. 

By order of the Commission. 

Marilyn R. Abbott, 

Secretary. 

Issued: June 29, 2009. 

William R. Bishop, 

Acting Secretary to the Commission. 

[FR Doc. E9–15647 Filed 7–1–09; 8:45 am] 

BILLING CODE P

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–1047 (Review)] 

Ironing Tables From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Institution of a five-year review 

concerning the antidumping duty order 

on ironing tables from China. 

SUMMARY: The Commission hereby gives 

notice that it has instituted a review 

pursuant to section 751(c) of the Tariff 

Act of 1930 (19 U.S.C. 1675(c)) (the Act) 

to determine whether revocation of the 

antidumping duty order on ironing 

tables from China. would be likely to 

lead to continuation or recurrence of 

material injury. Pursuant to section 

751(c)(2) of the Act, interested parties 

are requested to respond to this notice 

by submitting the information specified 

below to the Commission; 1 to be 

assured of consideration, the deadline 

for responses is July 31, 2009. 

Comments on the adequacy of responses 

may be filed with the Commission by 

September 15, 2009. For further 

information concerning the conduct of 

this review and rules of general 

application, consult the Commission’s 

Rules of Practice and Procedure, part 

201, subparts A through E (19 CFR part 

201), and part 207, subparts A, D, E, and 

F (19 CFR part 207). 

DATES: Effective Date: July 1, 2009. 

FOR FURTHER INFORMATION CONTACT: 

Mary Messer (202–205–3193), Office of 

Investigations, U.S. International Trade 

Commission, 500 E Street SW., 

Washington, DC 20436. Hearingimpaired persons can obtain 

information on this matter by contacting 

the Commission’s TDD terminal on 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its internet server (http:// 

www.usitc.gov). The public record for 

this review may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://edis.usitc.gov. 

SUPPLEMENTARY INFORMATION: 

Background. On August 6, 2004, the 

Department of Commerce issued an 

antidumping duty order on imports of 

ironing tables from China (69 FR 47868). 

The Commission is conducting a review 

to determine whether revocation of the 

order would be likely to lead to 

continuation or recurrence of material 

injury to the domestic industry within 

a reasonably foreseeable time. It will 

assess the adequacy of interested party 

responses to this notice of institution to 

determine whether to conduct a full 

review or an expedited review. The 

Commission’s determination in any 

expedited review will be based on the 

facts available, which may include 

information provided in response to this 

notice. 

Definitions. The following definitions 

apply to this review: 

(1) Subject Merchandise is the class or 

kind of merchandise that is within the 

scope of the five-year review, as defined 

by the Department of Commerce. 

(2) The Subject Country in this review 

is China. 

(3) The Domestic Like Product is the 

domestically produced product or 

products which are like, or in the 

absence of like, most similar in 

characteristics and uses with, the 

Subject Merchandise. In its original 

determination, the Commission found 

one Domestic Like Product consisting of 

floor-standing, metal-top ironing tables, 

coexistent with the scope. 

(4) The Domestic Industry is the U.S. 

producers as a whole of the Domestic 

Like Product, or those producers whose 

collective output of the Domestic Like 

Product constitutes a major proportion 

of the total domestic production of the 

product. In its original determination, 

the Commission defined the Domestic 

Industry as U.S. producers of the 

Domestic Like Product. 

(5) The Order Date is the date that the 

antidumping duty order under review 

became effective. In this review, the 

Order Date is August 6, 2004. 

(6) An Importer is any person or firm 

engaged, either directly or through a 

parent company or subsidiary, in 

importing the Subject Merchandise into 

the United States from a foreign 

manufacturer or through its selling 

agent. 

Participation in the review and public 

service list. Persons, including 

industrial users of the Subject 

Merchandise and, if the merchandise is 

sold at the retail level, representative 

consumer organizations, wishing to 

participate in the review as parties must 

file an entry of appearance with the 

Secretary to the Commission, as 

provided in section 201.11(b)(4) of the 

Commission’s rules, no later than 21 

days after publication of this notice in 

the Federal Register. The Secretary will 

maintain a public service list containing 

the names and addresses of all persons, 

or their representatives, who are parties 

to the review. 

Former Commission employees who 

are seeking to appear in Commission 

five-year reviews are advised that they 

may appear in a review even if they 

participated personally and 

substantially in the corresponding 

underlying original investigation. The 

Commission’s designated agency ethics 


rmajette on PRODPC74 with NOTICES
31756 Federal Register / Vol. 74, No. 126 / Thursday, July 2, 2009 / Notices 

official recently has advised that a fiveyear review is no longer considered the 

‘‘same particular matter’’ as the 

corresponding underlying original 

investigation for purposes of 18 U.S.C. 

207, the post employment statute for 

Federal employees, and Commission 

rule 201.15(b) (19 CFR 201.15(b)), 73 FR 

24609 (May 5, 2008). This advice was 

developed in consultation with the 

Office of Government Ethics. 

Consequently, former employees are no 

longer required to seek Commission 

approval to appear in a review under 

Commission rule 19 CFR 201.15, even if 

the corresponding underlying original 

investigation was pending when they 

were Commission employees. For 

further ethics advice on this matter, 

contact Carol McCue Verratti, Deputy 

Agency Ethics Official, at 202–205– 

3088. 

Limited disclosure of business 

proprietary information (BPI) under an 

administrative protective order (APO) 

and APO service list. Pursuant to 

section 207.7(a) of the Commission’s 

rules, the Secretary will make BPI 

submitted in this review available to 

authorized applicants under the APO 

issued in the review, provided that the 

application is made no later than 21 

days after publication of this notice in 

the Federal Register. Authorized 

applicants must represent interested 

parties, as defined in 19 U.S.C. 1677(9), 

who are parties to the review. A 

separate service list will be maintained 

by the Secretary for those parties 

authorized to receive BPI under the 

APO. 

Certification. Pursuant to section 

207.3 of the Commission’s rules, any 

person submitting information to the 

Commission in connection with this 

review must certify that the information 

is accurate and complete to the best of 

the submitter’s knowledge. In making 

the certification, the submitter will be 

deemed to consent, unless otherwise 

specified, for the Commission, its 

employees, and contract personnel to 

use the information provided in any 

other reviews or investigations of the 

same or comparable products which the 

Commission conducts under Title VII of 

the Act, or in internal audits and 

investigations relating to the programs 

and operations of the Commission 

pursuant to 5 U.S.C. Appendix 3. 

Written submissions. Pursuant to 

section 207.61 of the Commission’s 

rules, each interested party response to 

this notice must provide the information 

specified below. The deadline for filing 

such responses is July 31, 2009, 

pursuant to section 207.62(b) of the 

Commission’s rules, eligible parties (as 

specified in Commission rule 

207.62(b)(1)) may also file comments 

concerning the adequacy of responses to 

the notice of institution and whether the 

Commission should conduct an 

expedited or full review. The deadline 

for filing such comments is September 

15, 2009. All written submissions must 

conform with the provisions of sections 

201.8 and 207.3 of the Commission’s 

rules and any submissions that contain 

BPI must also conform with the 

requirements of sections 201.6 and 

207.7 of the Commission’s rules. The 

Commission’s rules do not authorize 

filing of submissions with the Secretary 

by facsimile or electronic means, except 

to the extent permitted by section 201.8 

of the Commission’s rules, as amended, 

67 FR 68036 (November 8, 2002). Also, 

in accordance with sections 201.16(c) 

and 207.3 of the Commission’s rules, 

each document filed by a party to the 

review must be served on all other 

parties to the review (as identified by 

either the public or APO service list as 

appropriate), and a certificate of service 

must accompany the document (if you 

are not a party to the review you do not 

need to serve your response). 

Inability to provide requested 

information. Pursuant to section 

207.61(c) of the Commission’s rules, any 

interested party that cannot furnish the 

information requested by this notice in 

the requested form and manner shall 

notify the Commission at the earliest 

possible time, provide a full explanation 

of why it cannot provide the requested 

information, and indicate alternative 

forms in which it can provide 

equivalent information. If an interested 

party does not provide this notification 

(or the Commission finds the 

explanation provided in the notification 

inadequate) and fails to provide a 

complete response to this notice, the 

Commission may take an adverse 

inference against the party pursuant to 

section 776(b) of the Act in making its 

determination in the review. 

Information to be Provided in 

Response to this Notice of Institution: 

As used below, the term ‘‘firm’’ includes 

any related firms. 

(1) The name and address of your firm 

or entity (including World Wide Web 

address if available) and name, 

telephone number, fax number, and Email address of the certifying official. 

(2) A statement indicating whether 

your firm/entity is a U.S. producer of 

the Domestic Like Product, a U.S. union 

or worker group, a U.S. importer of the 

Subject Merchandise, a foreign producer 

or exporter of the Subject Merchandise, 

a U.S. or foreign trade or business 

association, or another interested party 

(including an explanation). If you are a 

union/worker group or trade/business 

association, identify the firms in which 

your workers are employed or which are 

members of your association. 

(3) A statement indicating whether 

your firm/entity is willing to participate 

in this review by providing information 

requested by the Commission. 

(4) A statement of the likely effects of 

the revocation of the antidumping duty 

order on the Domestic Industry in 

general and/or your firm/entity 

specifically. In your response, please 

discuss the various factors specified in 

section 752(a) of the Act (19 U.S.C. 

1675a(a)) including the likely volume of 

subject imports, likely price effects of 

subject imports, and likely impact of 

imports of Subject Merchandise on the 

Domestic Industry. 

(5) A list of all known and currently 

operating U.S. producers of the 

Domestic Like Product. Identify any 

known related parties and the nature of 

the relationship as defined in section 

771(4)(B) of the Act (19 U.S.C. 

1677(4)(B)). 

(6) A list of all known and currently 

operating U.S. importers of the Subject 

Merchandise and producers of the 

Subject Merchandise in the Subject 

Country that currently export or have 

exported Subject Merchandise to the 

United States or other countries since 

the Order Date. 

(7) A list of 3–5 leading purchasers in 

the U.S. market for the Domestic Like 

Product and the Subject Merchandise 

(including street address, World Wide 

Web address, and the name, telephone 

number, fax number, and E-mail address 

of a responsible official at each firm). 

(8) A list of known sources of 

information on national or regional 

prices for the Domestic Like Product or 

the Subject Merchandise in the U.S. or 

other markets. 

(9) If you are a U.S. producer of the 

Domestic Like Product, provide the 

following information on your firm’s 

operations on that product during 

calendar year 2008, except as noted 

(report quantity data in number of tables 

and value data in U.S. dollars, f.o.b. 

plant). If you are a union/worker group 

or trade/business association, provide 

the information, on an aggregate basis, 

for the firms in which your workers are 

employed/which are members of your 

association. 

(a) Production (quantity) and, if 

known, an estimate of the percentage of 

total U.S. production of the Domestic 

Like Product accounted for by your 

firm’s(s’) production; 

(b) Capacity (quantity) of your firm to 

produce the Domestic Like Product (i.e., 

the level of production that your 

establishment(s) could reasonably have 

expected to attain during the year, 


rmajette on PRODPC74 with NOTICES
Federal Register / Vol. 74, No. 126 / Thursday, July 2, 2009 / Notices 31757 

1No response to this request for information is 

required if a currently valid Office of Management 

and Budget (OMB) number is not displayed; the 

OMB number is 3117–0016/USITC No. 09–5–195, 

expiration date June 30, 2011. Public reporting 

burden for the request is estimated to average 15 

hours per response. Please send comments 

regarding the accuracy of this burden estimate to 

the Office of Investigations, U.S. International Trade 

Commission, 500 E Street, SW., Washington, DC 

20436. 

assuming normal operating conditions 

(using equipment and machinery in 

place and ready to operate), normal 

operating levels (hours per week/weeks 

per year), time for downtime, 

maintenance, repair, and cleanup, and a 

typical or representative product mix); 

(c) The quantity and value of U.S. 

commercial shipments of the Domestic 

Like Product produced in your U.S. 

plant(s); and 

(d) The quantity and value of U.S. 

internal consumption/company 

transfers of the Domestic Like Product 

produced in your U.S. plant(s). 

(e) The value of (i) net sales, (ii) cost 

of goods sold (COGS), (iii) gross profit, 

(iv) selling, general and administrative 

(SG&A) expenses, and (v) operating 

income of the Domestic Like Product 

produced in your U.S. plant(s) (include 

both U.S. and export commercial sales, 

internal consumption, and company 

transfers) for your most recently 

completed fiscal year (identify the date 

on which your fiscal year ends). 

(10) If you are a U.S. importer or a 

trade/business association of U.S. 

importers of the Subject Merchandise 

from the Subject Country, provide the 

following information on your firm’s(s’) 

operations on that product during 

calendar year 2008 (report quantity data 

in number of tables and value data in 

U.S. dollars). If you are a trade/business 

association, provide the information, on 

an aggregate basis, for the firms which 

are members of your association. 

(a) The quantity and value (landed, 

duty-paid but not including 

antidumping duties) of U.S. imports 

and, if known, an estimate of the 

percentage of total U.S. imports of 

Subject Merchandise from the Subject 

Country accounted for by your firm’s(s’) 

imports; 

(b) The quantity and value (f.o.b. U.S. 

port, including antidumping duties) of 

U.S. commercial shipments of Subject 

Merchandise imported from the Subject 

Country; and 

(c) The quantity and value (f.o.b. U.S. 

port, including antidumping duties) of 

U.S. internal consumption/company 

transfers of Subject Merchandise 

imported from the Subject Country. 

(11) If you are a producer, an exporter, 

or a trade/business association of 

producers or exporters of the Subject 

Merchandise in the Subject Country, 

provide the following information on 

your firm’s(s’) operations on that 

product during calendar year 2008 

(report quantity data in number of tables 

and value data in U.S. dollars, landed 

and duty-paid at the U.S. port but not 

including antidumping duties). If you 

are a trade/business association, provide 

the information, on an aggregate basis, 

for the firms which are members of your 

association. 

(a) Production (quantity) and, if 

known, an estimate of the percentage of 

total production of Subject Merchandise 

in the Subject Country accounted for by 

your firm’s(s’) production; and 

(b) Capacity (quantity) of your firm to 

produce the Subject Merchandise in the 

Subject Country (i.e., the level of 

production that your establishment(s) 

could reasonably have expected to 

attain during the year, assuming normal 

operating conditions (using equipment 

and machinery in place and ready to 

operate), normal operating levels (hours 

per week/weeks per year), time for 

downtime, maintenance, repair, and 

cleanup, and a typical or representative 

product mix); and 

(c) The quantity and value of your 

firm’s(s’) exports to the United States of 

Subject Merchandise and, if known, an 

estimate of the percentage of total 

exports to the United States of Subject 

Merchandise from the Subject Country 

accounted for by your firm’s(s’) exports. 

(12) Identify significant changes, if 

any, in the supply and demand 

conditions or business cycle for the 

Domestic Like Product that have 

occurred in the United States or in the 

market for the Subject Merchandise in 

the Subject Country since the Order 

Date, and significant changes, if any, 

that are likely to occur within a 

reasonably foreseeable time. Supply 

conditions to consider include 

technology; production methods; 

development efforts; ability to increase 

production (including the shift of 

production facilities used for other 

products and the use, cost, or 

availability of major inputs into 

production); and factors related to the 

ability to shift supply among different 

national markets (including barriers to 

importation in foreign markets or 

changes in market demand abroad). 

Demand conditions to consider include 

end uses and applications; the existence 

and availability of substitute products; 

and the level of competition among the 

Domestic Like Product produced in the 

United States, Subject Merchandise 

produced in the Subject Country, and 

such merchandise from other countries. 

(13) (OPTIONAL) A statement of 

whether you agree with the above 

definitions of the Domestic Like Product 

and Domestic Industry; if you disagree 

with either or both of these definitions, 

please explain why and provide 

alternative definitions. 

Authority: This review is being conducted 

under authority of title VII of the Tariff Act 

of 1930; this notice is published pursuant to 

section 207.61 of the Commission’s rules. 

By order of the Commission. 

Marilyn R. Abbott, 

Secretary. 

Issued: June 29, 2009. 

William R. Bishop, 

Acting Secretary to the Commission. 

[FR Doc. E9–15646 Filed 7–1–09; 8:45 am] 

BILLING CODE P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–149 (Third 

Review)] 

Barium Chloride From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Institution of a five-year review 

concerning the antidumping duty order 

on barium chloride from China. 

SUMMARY: The Commission hereby gives 

notice that it has instituted a review 

pursuant to section 751(c) of the Tariff 

Act of 1930 (19 U.S.C. 1675(c)) (the Act) 

to determine whether revocation of the 

antidumping duty order on barium 

chloride from China would be likely to 

lead to continuation or recurrence of 

material injury. Pursuant to section 

751(c)(2) of the Act, interested parties 

are requested to respond to this notice 

by submitting the information specified 

below to the Commission; 1 to be 

assured of consideration, the deadline 

for responses is July 31, 2009. 

Comments on the adequacy of responses 

may be filed with the Commission by 

September 15, 2009. For further 

information concerning the conduct of 

this review and rules of general 

application, consult the Commission’s 

Rules of Practice and Procedure, part 

201, subparts A through E (19 CFR part 

201), and part 207, subparts A, D, E, and

F (19 CFR part 207), as most recently 

amended at 74 FR 2847 (January 16, 

2009). 

DATES: Effective Date: July 1, 2009. 

FOR FURTHER INFORMATION CONTACT: 

Mary Messer (202–205–3193) Office of 

Investigations, U.S. International Trade 

Commission, 500 E Street, SW., 

Washington, DC 20436. Hearingimpaired persons can obtain 

information on this matter by contacting


rmajette on PRODPC74 with NOTICES

54066 Federal Register / Vol. 74, No. 202 / Wednesday, October 21, 2009 / Notices 

and, after the investigation, issue an 

exclusion order and a cease and desist 

order. 

ADDRESSES: The amended complaint, 

except for any confidential information 

contained therein, is available for 

inspection during official business 

hours (8:45 a.m. to 5:15 p.m.) in the 

Office of the Secretary, U.S. 

International Trade Commission, 500 E

Street, SW., Room 112, Washington, DC 

20436, telephone 202–205–2000. 

Hearing impaired individuals are 

advised that information on this matter 

can be obtained by contacting the 

Commission’s TDD terminal on 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its internet server at http:// 

www.usitc.gov. The public record for 

this investigation may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://edis.usitc.gov. 

FOR FURTHER INFORMATION CONTACT: Rett 

Snotherly, Office of Unfair Import 

Investigations, U.S. International Trade 

Commission, telephone (202) 205–2599. 

Authority: The authority for 

institution of this investigation is 

contained in section 337 of the Tariff 

Act of 1930, as amended, and in section 

210.10 of the Commission’s Rules of 

Practice and Procedure, 19 CFR 210.10 

(2009). 

Scope of Investigation: Having 

considered the amended complaint, the 

U.S. International Trade Commission, 

on October 14, 2009, ordered that— 

(1) Pursuant to subsection (b) of 

section 337 of the Tariff Act of 1930, as 

amended, an investigation be instituted 

to determine whether there is a 

violation of subsection (a)(1)(B) of 

section 337 in the importation into the 

United States, the sale for importation, 

or the sale within the United States after 

importation of certain dual access locks 

or products containing same that 

infringe one or more of claims 1–21 of 

U.S. Patent No. 7,021,537 and claims 1– 

20 of U.S. Patent No. 7,036,728, and 

whether an industry in the United 

States exists as required by subsection 

(a)(2) of section 337; 

(2) For the purpose of the 

investigation so instituted, the following 

are hereby named as parties upon which 

this notice of investigation shall be 

served: 

(a) The complainants are— 

Safe Skies, LLC, 165 Norfolk Street, 

Brooklyn, NY 11235 

David Tropp, 165 Norfolk Street, 

Brooklyn, NY 11235 

(b) The respondents are the following 

entities alleged to be in violation of 

section 337, and are the parties upon 

which the complaint is to be served: 

C&C Luggage Manufacturing Co., Ltd., 

No. 1, Crown Road, The Second Ind. 

Park, Sanxiang, Zhongshan, 

Guangdong, China 

Formosa Tai Rank Industrial Corp., 

Room 1102, 11th Floor, 328 Sung 

Chiang Road, Taipei, Taiwan, 104, 

Hangzhou Gema Suitcases & Bags Co., 

Ltd 

M16–1–5 Hangshou Economic and 

Technologic Development Zone, 

Hangzhou, Zhejiang, China 

La Pearl Luggage and Leather Goods Co., 

Ltd., No. 441, Xihuan Road, Jiangmen 

Guangdong, 529000 China 

Hinomoto Jomae, Ltd. 1–19–19 

Nishigahara, Kita-Ku, Tokyo, Japan 

Sinox Company, Ltd. 3F, No. 2, Lane 93, 

Chien-1 Road, Chung-Ho City, Taipei 

Hsien, 235, Taiwan 

Yi Feng Manufacturing, Co., Ltd. 

Zhangyang Zone, Shangmutou Town, 

Dongguan City, China 523637 

Jin Tay Industries Co., Ltd. 486 Section 

3, Ming Chih Road, Taishan Hsiang, 

Taipei Hsien, Taiwan 

FULLYEAR-Brother Enterprise, Co., 

Ltd., 41–21, Guan Tso Street, Fu 

Shing, Changhwa Taiwan, 506 

Zhuhai SkyGood Tech. Industrial Corp., 

Ltd., 4/F., 3rd Building, 30 Nanwan 

Road (north), Nanping, Zhuhai, 

Guangdong, China 

Ningbo Xianfeng Art & Craft Co., Ltd., 

Room B–303, Zhongshanyinzuo, No. 

579, Zhongshan East Road, Ningbo, 

China 

Paloma Enterprises Co., Ltd., 3F, No. 

1320, Chung-Cheng Road, Taoyun 

City, Taiwan 

Tekraft Industrial Co., Ltd., Room 5E10, 

No. 5 Hsin Yi Road, Sec. 5, Taipei, 

Taiwan 

Hangzhou Travelsky Co., Ltd., 1–6–G 

Guodu Development Building, 182 

Zhaohui Road, Hangshou, China 

The Sun Lock Company Ltd., Room 5, 

Block C, 16/F, Hang Wai, Industrial 

Center, 6 Kin Tai Street, Tuen Mun, 

New Territories, Hong Kong 

Alloy Metal Manufactory, Ltd., Flat H, 

3/F, On Ho Industrial Building, 17–19 

Shing Wan Road, Tai Wai, Shatin, 

New Territories, Hong Kong 

Cometform, Ltd., Unit 24 Irving Way, 

Garrick Industrial Estate, Hendon, 

London NW9 6AQ, England 

Design Go Ltd., Unit 1, Mill Hill 

Industrial Estate, Flower Lane, 

London NW7 2HU, England 

Franzen International, S. Franzen Sohne 

GmbH, Fuerbachstrasse 8, D–42719 

Solingen, Germany 

M–Power Lock Manufactory, Unit 2702, 

Modern Warehouse, 6 Shing Yip 

Street, Kwun Tong, Kowloon, Hong 

Kong 

(c) The Commission investigative 

attorney, party to this investigation, is 

Rett Snotherly, Esq., Office of Unfair 

Import Investigations, U.S. International 

Trade Commission, 500 E Street, SW., 

Suite 401, Washington, DC 20436; and 

(3) For the investigation so instituted, 

the Honorable Paul J. Luckern, Chief 

Administrative Law Judge, U.S. 

International Trade Commission, shall 

designate the presiding Administrative 

Law Judge. 

Responses to the amended complaint 

and the notice of investigation must be 

submitted by the named respondents in 

accordance with section 210.13 of the 

Commission’s Rules of Practice and 

Procedure, 19 CFR 210.13. Pursuant to 

19 CFR 201.16(d) and 210.13(a), such 

responses will be considered by the 

Commission if received not later than 20 

days after the date of service by the 

Commission of the amended complaint 

and the notice of investigation. 

Extensions of time for submitting 

responses to the amended complaint 

and the notice of investigation will not 

be granted unless good cause therefor is 

shown. 

Failure of a respondent to file a timely 

response to each allegation in the 

amended complaint and in this notice 

may be deemed to constitute a waiver of 

the right to appear and contest the 

allegations of the amended complaint 

and this notice, and to authorize the 

administrative law judge and the 

Commission, without further notice to 

the respondent, to find the facts to be as 

alleged in the amended complaint and 

this notice and to enter an initial 

determination and a final determination 

containing such findings, and may 

result in the issuance of an exclusion 

order or a cease and desist order or both 

directed against a respondent. 

Issued: October 14, 2009. 

By order of the Commission. 

Marilyn R. Abbott, 

Secretary to the Commission. 

[FR Doc. E9–25245 Filed 10–20–09; 8:45 am] 

BILLING CODE 7020–02–P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–1047 (Review)] 

Ironing Tables From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Notice of Commission 

determination to conduct a full five-year 


jlentini on DSKJ8SOYB1PROD with NOTICES
Federal Register / Vol. 74, No. 202 / Wednesday, October 21, 2009 / Notices 54067 

SUMMARY: The Commission hereby gives 

notice that it will proceed with a full 

review pursuant to section 751(c)(5) of 

the Tariff Act of 1930 (19 U.S.C. 

1675(c)(5)) to determine whether 

revocation of the antidumping duty 

order on ironing tables from China 

would be likely to lead to continuation 

or recurrence of material injury within 

a reasonably foreseeable time. A 

schedule for the review will be 

established and announced at a later 

date. For further information concerning 

the conduct of this review and rules of 

general application, consult the 

Commission’s Rules of Practice and 

Procedure, part 201, subparts A through 

E (19 CFR part 201), and part 207, 

subparts A, D, E, and F (19 CFR part 

207). 

DATES: Effective Date: October 5, 2009. 

FOR FURTHER INFORMATION CONTACT: 

Mary Messer (202–205–3193), Office of 

Investigations, U.S. International Trade 

Commission, 500 E Street, SW., 

Washington, DC 20436. Hearingimpaired persons can obtain 

information on this matter by contacting 

the Commission’s TDD terminal on 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its Internet server (http:// 

www.usitc.gov). The public record for 

this review may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://edis.usitc.gov. 

SUPPLEMENTARY INFORMATION: On 

October 5, 2009, the Commission 

determined that it should proceed to a 

full review in the subject five-year 

review pursuant to section 751(c)(5) of 

the Act. The Commission found that 

both the domestic and respondent 

interested party group responses to its 

notice of institution (74 FR 31755, July 

2, 2009) were adequate. A record of the 

Commissioners’ votes, the 

Commission’s statement on adequacy, 

and any individual Commissioner’s 

statements will be available from the 

Office of the Secretary and at the 

Commission’s Web site. 

Authority: This review is being conducted 

under authority of title VII of the Tariff Act 

of 1930; this notice is published pursuant to 

section 207.62 of the Commission’s rules. 

Issued: October 14, 2009. 

By order of the Commission. 

Marilyn R. Abbott, 

Secretary to the Commission. 

[FR Doc. E9–25247 Filed 10–20–09; 8:45 am] 

BILLING CODE 7020–02–P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–1046 (Review)] 

Tetrahydrofurfuryl Alcohol From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Scheduling of an expedited fiveyear review concerning the antidumping 

duty order on tetrahydrofurfuryl alcohol 

from China. 
56794 Federal Register / Vol. 74, No. 211 / Tuesday, November 3, 2009 / Notices 

filed comments in response to Roquette Freres on 

August 18, 2009 and on September 1, 2009, ADM 

filed comments on the Adequacy of Responses and 

Appropriateness of an Expedited Review.

751(c)(3)(B) of the Act and 19 CFR. 

351.218(e)(1)(ii)(C)(2), the Department 

has conducted an expedited sunset 

review of this order. 

Scope of the Orders 

The products covered by this order 

are shipments of crystalline sorbitol 

(sorbitol), a polyol produced by the 

hydrogenation of sugars (glucose), used 

in the production of sugarless gum, 

candy, groceries, and pharmaceuticals. 

The above–described sorbitol is 

classified under HTS subheading 

2905.44.00. The HTS subheading is 

provided for convenience and for 

customs purposes. The written 

description remains dispositive. 

Analysis of Comments Received 

All issues raised in this case are 

addressed in the ‘‘Issues and Decision 

Memorandum’’ from Richard Weible, 

Director Office 7 to John M. Andersen, 

Acting Deputy Assistant Secretary for 

AD/CVD Operations, Import 

Administration, dated October 28, 2009, 

(Decision Memorandum), which is 

hereby adopted by this notice. The 

issues discussed in the Decision 

Memorandum include the likelihood of 

continuation or recurrence of dumping 

and the magnitude of the margin likely 

to prevail if the order was revoked. 

Parties can find a complete discussion 

of all issues raised in this sunset review 

and the corresponding 

recommendations in this public 

memorandum, which is on file in room 

1117 of the main Department building. 

In addition, a complete version of the 

Decision Memorandum can be accessed 

directly on the Internet at http:// 

ia.ita.doc.gov/frn/. The paper copy and 

electronic version of the Decision 

Memorandum are identical in content. 

Final Results of Sunset Reviews 

The Department has determined that 

revocation of the antidumping duty 

order on sorbitol from France would 

likely lead to continuation or recurrence 

of dumping at the following percentage 

weighted–average margins: 

Manufacturers/Exporters/Producers Weighted–Average 

Margin (Percent) 

Roquette Freres ............ 2.90 percent 

All Others ...................... 2.90 percent 

This notice serves as the only 

reminder to parties subject to 

administrative protective orders (APO) 

of their responsibility concerning the 

return or destruction of proprietary 

information disclosed under APO in 

accordance with 19 CFR 351.305. 

Timely notification of the return or 

destruction of APO materials or 

conversion to judicial protective order is 

hereby requested. Failure to comply 

with the regulations and terms of an 

APO is a violation which is subject to 

sanction. 

The Department is issuing and 

publishing these results and this notice 

in accordance with sections 751(c), 752, 

and 777(i)(1) of the Act. 

Dated: October 28, 2009. 

John M. Andersen, 

Acting Deputy Assistant Secretary for 

Antidumping and Countervailing Duty 

Operations. 

[FR Doc. E9–26427 Filed 11–2–09; 8:45 am] 

BILLING CODE 3510–DS–S 

DEPARTMENT OF COMMERCE 

International Trade Administration 

[A–570–888] 

Floor–Standing Metal–Top Ironing 

Tables and Parts Thereof from the 

People’s Republic of China: Final 

Results of Expedited Five-year 

(Sunset) Review of Antidumping Duty 

Order 

AGENCY: Import Administration, 

International Trade Administration, 

Department of Commerce. 

SUMMARY: On July 1, 2009, the 

Department of Commerce (the 

Department) initiated a sunset review of 

the antidumping duty order on floor– 

standing metal–top ironing tables and 

parts thereof (ironing tables) from the 

People’s Republic of China (the PRC) 

pursuant to section 751(c) of the Tariff 

Act of 1930, as amended (the Act). The 

Department conducted an expedited 

(120-day) sunset review of this 

antidumping duty order. As a result of 

this sunset review, the Department finds 

that revocation of the antidumping duty 

order would be likely to lead to 

continuation or recurrence of dumping 

at the levels identified below in the 

‘‘Final Results of Review’’ section of this 

notice. 

EFFECTIVE DATE: November 3, 2009. 

FOR FURTHER INFORMATION: David 

Cordell, AD/CVD Operations, Office 7, 

or Dana Mermelstein, AD/CVD 

Operations, Office 6, Import 

Administration, International Trade 

Administration, U.S. Department of 

Commerce, 14th Street and Constitution 

Avenue, NW, Washington, DC 20230; 

telephone: (202) 482–0408, or (202) 

482–1391, respectively. 

SUPPLEMENTARY INFORMATION: 

Background 

On July 1, 2009, the Department 

initiated a sunset review of the 

antidumping duty order on ironing 

tables from the PRC pursuant to section 

751(c) of the Act. See Initiation of Fiveyear (Sunset) Reviews, 74 FR 31412 

(July 1, 2009). The Department received 

a notice of intent to participate from one 

domestic interested party, Home 

Products International (HPI), within the 

deadline specified in 19 CFR 

351.218(d)(1)(i) of the Department’s 

regulations. HPI claimed interested 

party status under section 771(9)(C) of 

the Act as a domestic producer of the 

domestic like product. We received a 

complete substantive response from HPI 

within the 30-day deadline specified in 

19 CFR 351.218(d)(3)(i). 

The Department also received a 

substantive response from one 

respondent party, Since Hardware 

(Guangzhou) Co., Ltd. (Since Hardware) 

within the 30-day deadline specified in 

19 CFR 351.218(d)(3)(i). On August 5, 

2009 HPI submitted rebuttal comments 

to Since Hardware’s substantive 

response. On August 19, 2009 the 

Department determined Since 

Hardware’s substantive response to be 

inadequate because it failed to meet 

certain requirements in 19 CFR 

351.218(c)(1)(ii)(A) and (d)(3)(iii)(E). For 

a more detailed discussion of the 

Department’s determination regarding 

Since Hardware’s substantive response, 

please see the Memorandum to the File, 

‘‘Adequacy Determination of 

Respondent’s Substantive Comments: 

Sunset Review of the Antidumping Duty 

Order on Floor–Standing Metal–Top 

Ironing Tables and Parts Thereof from 

the People’s Republic of China (PRC)’’ 

dated August 19, 2009. As a result of the 

foregoing, the Department conducted an 

expedited (120-day) sunset review of 

this order pursuant to section 

751(C)(3)(B) of the Act and 19 CFR 

351.218(e)(1)(ii)(c)(2). 

Scope of the Order 

For purposes of the order, the product 

covered consists of floor–standing, 

metal–top ironing tables, assembled or 

unassembled, complete or incomplete, 

and certain parts thereof. The subject 

tables are designed and used principally 

for the hand ironing or pressing of 

garments or other articles of fabric. The 

subject tables have full–height leg 

assemblies that support the ironing 

surface at an appropriate (often 

adjustable) height above the floor. The 

subject tables are produced in a variety 

of leg finishes, such as painted, plated, 

or matte, and they are available with 

mstockstill on DSKH9S0YB1PROD with NOTICES

Federal Register / Vol. 74, No. 211 / Tuesday, November 3, 2009 / Notices 56795 

various features, including iron rests, 

linen racks, and others. The subject 

ironing tables may be sold with or 

without a pad and/or cover. All types 

and configurations of floor–standing, 

metal–top ironing tables are covered by 

this order. 

Furthermore, the order specifically 

covers imports of ironing tables, 

assembled or unassembled, complete or 

incomplete, and certain parts thereof. 

For purposes of this order, the term 

‘‘unassembled’’ ironing table means a 

product requiring the attachment of the 

leg assembly to the top or the 

attachment of an included feature such 

as an iron rest or linen rack. The term 

‘‘complete’’’ ironing table means a 

product sold as a ready–to-use ensemble 

consisting of the metal–top table and a 

pad and cover, with or without 

additional features, e.g., iron rest or 

linen rack. The term ‘‘incomplete’’ 

ironing table means product shipped or 

sold as a ‘‘bare board’’ i.e., a metal–top 

table only, without the pad and cover, 

with or without additional features, e.g. 

iron rest or linen rack. The major parts 

or components of ironing tables that are 

intended to be covered by the order 

under the term ‘‘certain parts thereof≥’ 

consist of the metal top component 

(with or without assembled supports 

and slides) and/or the leg components, 

whether or not attached together as a leg 

assembly. This order covers separately 

shipped metal top components and leg 

components, without regard to whether 

the respective quantities would yield an 

exact quantity of assembled ironing 

tables. 

Ironing tables without legs (such as 

models that mount on walls or over 

doors) are not floor–standing and are 

specifically excluded. Additionally, 

tabletop or countertop models with 

short legs that do not exceed 12 inches 

in length (and which may or may not 

collapse or retract) are specifically 

excluded. 

The subject ironing tables are 

currently classifiable under HTSUS 

subheading 9403.20.0011. The subject 

metal top and leg components are 

classified under HTSUS subheading 

9403.90.8040. Although the HTS 

subheadings are provided for 

convenience and Customs purposes, the 

written description of the scope remains 

dispositive. 

Analysis of Comments Received 

All issues raised in this case are 

addressed in the ‘‘Issues and Decision 

Memorandum’’ from Richard Weible, 

Director Office 7 to John M. Andersen, 

Acting Deputy Assistant Secretary for 

AD/CVD Operations, Import 

Administration, dated October 27, 2009 

(Decision Memorandum), which is 

hereby adopted by this notice. The 

issues discussed in the Decision 

Memorandum include the likelihood of 

continuation or recurrence of dumping 

and the magnitude of the margin likely 

to prevail if the order was revoked. 

Parties can find a complete discussion 

of all issues raised in this sunset review 

and the corresponding 

recommendations in this public 

memorandum, which is on file in room 

1117 of the main Commerce building. In 

addition, a complete version of the 

Decision Memorandum can be accessed 

directly on the Internet at http:// 

ia.ita.doc.gov/frn/. The paper copy and 

electronic version of the Decision 

Memorandum are identical in content. 

Final Results of Sunset Reviews 

We determine that revocation of the 

antidumping duty order on ironing 

tables from the PRC would likely lead 

to continuation or recurrence of 

dumping at the following percentage 

weighted–average margins: 

Manufacturers/Exporters/Producers Weighted–Average 

Margin (Percent) 

Since Hardware ............ 9.47 percent 

Shunde Yongjian .......... 157.68 percent 

Forever Holdings .......... 72.29 percent 

Gaoming ....................... 72.29 percent 

Harvest ......................... 72.29 percent 

Foshan Shunde ............ 157.68 percent 

PRC–Wide Rate ........... 157.68 percent 

This notice serves as the only 

reminder to parties subject to 

administrative protective orders (APO) 

of their responsibility concerning the 

return or destruction of proprietary 

information disclosed under APO in 

accordance with 19 CFR 351.305. 

Timely notification of the return or 

destruction of APO materials or 

conversion to judicial protective order is 

hereby requested. Failure to comply 

with the regulations and terms of an 

APO is a violation which is subject to 

sanction. 

We are issuing and publishing these 

results and this notice in accordance 

with sections 751(c), 752(c), and 

777(i)(1) of the Act. 

Dated: October 27, 2009. 

John M. Andersen, 

Acting Deputy Assistant Secretary for 

Antidumping and Countervailing Duty 

Operations. 

[FR Doc. E9–26426 Filed 11–2–09; 8:45 am] 

BILLING CODE 3510–DS–S 

DEPARTMENT OF COMMERCE 

International Trade Administration 

University of Notre Dame, et al. 

Notice of Consolidated Decision on 

Applications for Duty–Free Entry of 

Electron Microscopes 

This is a decision consolidated 

pursuant to Section 6(c) of the 

Educational, Scientific, and Cultural 

Materials Importation Act of 1966 (Pub. 

L. 89–651, as amended by Pub. L. 106– 

36; 80 Stat. 897; 15 CFR part 301). 

Related records can be viewed between 

8:30 a.m. and 5:00 p.m. in Room 3705, 

U.S. Department of Commerce, 14th and 

Constitution Avenue., NW, Washington, 

D.C. 

Docket Number: 09–051. Applicant: 

University of Notre Dame, Notre Dame, 

IN 46556. Instrument: Electron 

Microscope. Manufacturer: FEI 

Company, Czech Republic. Intended 

Use: See notice at 74 FR 49363, 

September 28, 2009. 

Docket Number: 09–052. Applicant: 

Youngstown State University, 

Youngstown, OH 44555. Instrument: 

Electron Microscope. Manufacturer: 

JEOL, Ltd., Japan. Intended Use: See 

notice at 74 FR 49363, September 28, 

2009. 

Docket Number: 09–053. Applicant: 

University of Notre Dame, Notre Dame, 

IN 46556. Instrument: Electron 

Microscope. Manufacturer: FEI 

Company, the Netherlands. Intended 

Use: See notice at 74 FR 49363, 

September 28, 2009. 

Docket Number: 09–054. Applicant: 

University of Nebraska Medical Center 

986395, Nebraska Medical Center, 

Omaha, NE 68198. Instrument: Electron 

Microscope. Manufacturer: FEI 

Company, Czech Republic. Intended 

Use: See notice at 74 FR 49363, 

September 28, 2009. 

Comments: None received. Decision: 

Approved. No instrument of equivalent 

scientific value to the foreign 

instrument, for such purposes as these 

instruments are intended to be used, 

was being manufactured in the United 

States at the time the instruments were 

ordered. Reasons: Each foreign 

instrument is an electron microscope 

and is intended for research or scientific 

educational uses requiring an electron 

microscope. We know of no electron 

microscope, or any other instrument 

suited to these purposes, which was 

being manufactured in the United States 

at the time of order of each instrument. 

mstockstill on DSKH9S0YB1PROD with NOTICES

Federal Register / Vol. 74, No. 228 / Monday, November 30, 2009 / Notices 62593 

Spansion, Inc. (‘‘Spansion’’) of 

Sunnyvale, California; and Nanya 

Technology Corporation (‘‘Nanya’’) of 

Taiwan. The complaint further alleged 

that an industry in the United States 

exists as required by subsection (a)(2) of 

section 337. 

On September 21, 2009, the ALJ 

issued his final ID finding no violation 

of section 337 by the remaining 

respondents. He concluded that each 

accused process was covered by one or 

more of asserted claims 1, 3, and 4 of 

the ‘335 patent, but also that all asserted 

claims were anticipated under 35 U.S.C. 

102(g) in view of the IBM Process A 

prior art. On October 5, 2009, 

complainants, respondents, and the 

Commission investigative attorney 

(‘‘IA’’) filed petitions for review of the 

final ID. Also, four separate petitions for 

review were filed on the same date by 

respondents Grace, IDT, Tower/Jazz, 

and Nanya/Powerchip/Spansion. The 

IA, complainants, and respondents filed 

responses to the other parties’ petitions 

on October 13, 2009. 

Upon considering the parties’ filings, 

the Commission has determined to 

review-in-part the ID. Specifically, the 

Commission has determined to review: 

(1) Invalidity of claims 1, 3, and 4 of the 

‘335 patent under 35 U.S.C. 102(g) & 103 

with respect to the IBM Process A, IBM 

Process B, and AMD prior art; and (2) 

Jazz’s stipulation regarding whether its 

process meets the complete, third 

recited step of claim 1, i.e., ‘‘depositing 

a tungsten layer by chemical vapor 

deposition, said tungsten layer covering 

said glue layer on said dielectric and 

said exposed material.’’ The 

Commission has determined not to 

review the remainder of the ID. 

In addition, the Commission has 

determined to issue an order remanding 

the investigation to the ALJ for further 

proceedings relating to whether claim 4 

is rendered obvious by IBM Process A 

in light of the other prior art asserted by 

respondents. 

The Commission has instructed the 

ALJ to make his determination on 

remand at the earliest practicable time, 

and to extend the target date of the 

above-captioned investigation as he 

deems necessary to accommodate the 

remand proceedings. The parties are 

invited to file written submissions on 

the ALJ’s remand determination within 

fourteen days after service of the ALJ’s 

determination and to file responses to 

the written submissions within seven 

days after service of the written 

submissions. The Commission also 

requests briefing on remedy, the public 

interest, and bonding from the parties, 

consistent with these submission dates, 

as described in detail below. 

In connection with the final 

disposition of this investigation, the 

Commission may issue an order that 

results in the exclusion of the subject 

articles from entry into the United 

States. Accordingly, the Commission is 

interested in receiving written 

submissions that address the form of 

remedy, if any, that should be ordered. 

If a party seeks exclusion of an article 

from entry into the United States for 

purposes other than entry for 

consumption, the party should so 

indicate and provide information 

establishing that activities involving 

other types of entry either are adversely 

affecting it or likely to do so. For 

background, see In the Matter of Certain 

Devices for Connecting Computers via 

Telephone Lines, Inv. No. 337–TA–360, 

USITC Pub. No. 2843 (December 1994) 

(Commission Opinion). 

When the Commission contemplates 

some form of remedy, it must consider 

the effects of that remedy upon the 

public interest. The factors the 

Commission will consider include the 

effect that an exclusion order and/or 

cease and desist orders would have on 

(1) the public health and welfare, (2) 

competitive conditions in the U.S. 

economy, (3) U.S. production of articles 

that are like or directly competitive with 

those that are subject to investigation, 

and (4) U.S. consumers. The 

Commission is therefore interested in 

receiving written submissions that 

address the aforementioned public 

interest factors in the context of this 

investigation. 

When the Commission orders some 

form of remedy, the U.S. Trade 

Representative, as delegated by the 

President, has 60 days to approve or 

disapprove the Commission’s action. 

See section 337(j), 19 U.S.C. 1337(j) and 

the Presidential Memorandum of July 

21, 2005, 70 FR 43251 (July 26, 2005). 

During this period, the subject articles 

would be entitled to enter the United 

States under bond, in an amount 

determined by the Commission. The 

Commission is therefore interested in 

receiving submissions concerning the 

amount of the bond that should be 

imposed if a remedy is ordered. 

Written Submissions: Parties to the 

investigation, interested government 

agencies, and any other interested 

parties are encouraged to file written 

submissions on the issues of remedy, 

the public interest, and bonding, and 

such submissions should address the 

recommended determination by the ALJ 

on remedy and bonding. The 

complainant and the IA are also 

requested to submit proposed remedial 

orders for the Commission’s 

consideration. Complainant is also 

requested to state the date that the 

patent at issue expires and the HTSUS 

numbers under which the accused 

articles are imported. The written 

submissions and proposed remedial 

orders, and any reply submissions, must 

be filed consistent with the dates stated 

above relating to the remand ID. No 

further submissions on these issues will 

be permitted unless otherwise ordered 

by the Commission. 

Persons filing written submissions 

must file the original document and 12 

true copies thereof on or before the 

deadlines stated above with the Office 

of the Secretary. Any person desiring to 

submit a document to the Commission 

in confidence must request confidential 

treatment unless the information has 

already been granted such treatment 

during the proceedings. All such 

requests should be directed to the 

Secretary of the Commission and must 

include a full statement of the reasons 

why the Commission should grant such 

treatment. See 19 CFR 210.6. Documents 

for which confidential treatment by the 

Commission is sought will be treated 

accordingly. All nonconfidential written 

submissions will be available for public 

inspection at the Office of the Secretary. 

The authority for the Commission’s 

determination is contained in section 

337 of the Tariff Act of 1930, as 

amended, 19 U.S.C. 1337, and in 

sections 210.42–46 of the Commission’s 

Rules of Practice and Procedure, 19 CFR 

210.42–46. 

By order of the Commission. 

Issued November 23, 2009. 

William R. Bishop, 

Acting Secretary to the Commission. 

[FR Doc. E9–28465 Filed 11–27–09; 8:45 am] 

BILLING CODE P 

INTERNATIONAL TRADE 

COMMISSION 

[Investigation No. 731–TA–1047 (Review)] 

Ironing Tables From China 

AGENCY: United States International 

Trade Commission. 

ACTION: Scheduling of a full five-year 

review concerning the antidumping 

duty order on ironing tables from China. 

SUMMARY: The Commission hereby gives 

notice of the scheduling of a full review 

pursuant to section 751(c)(5) of the 

Tariff Act of 1930 (19 U.S.C. 1675(c)(5)) 

(the Act) to determine whether 

revocation of the antidumping duty 

order on ironing tables from China 

would be likely to lead to continuation 

or recurrence of material injury within 

a reasonably foreseeable time. For 

WReier-Aviles on DSKGBLS3C1PROD with NOTICES

62594 Federal Register / Vol. 74, No. 228 / Monday, November 30, 2009 / Notices 

further information concerning the 

conduct of this review and rules of 

general application, consult the 

Commission’s Rules of Practice and 

Procedure, part 201, subparts A through 

E (19 CFR part 201), and part 207, 

subparts A, D, E, and F (19 CFR part 

207). 

DATES: Effective Date: November 16, 

2009. 

FOR FURTHER INFORMATION CONTACT: 

Jennifer Merrill (202–205–3188), Office 

of Investigations, U.S. International 

Trade Commission, 500 E Street SW., 

Washington, DC 20436. Hearingimpaired persons can obtain 

information on this matter by contacting 

the Commission’s TDD terminal on 202– 

205–1810. Persons with mobility 

impairments who will need special 

assistance in gaining access to the 

Commission should contact the Office 

of the Secretary at 202–205–2000. 

General information concerning the 

Commission may also be obtained by 

accessing its Internet server (http:// 

www.usitc.gov). The public record for 

this review may be viewed on the 

Commission’s electronic docket (EDIS) 

at http://edis.usitc.gov. 

SUPPLEMENTARY INFORMATION: 

Background.—On October 5, 2009, 

the Commission determined that 

responses to its notice of institution of 

the subject five-year review were such 

that a full review pursuant to section 

751(c)(5) of the Act should proceed (74 

FR 54066, October 21, 2009). A record 

of the Commissioners’ votes, the 

Commission’s statement on adequacy, 

and any individual Commissioner’s 

statements are available from the Office 

of the Secretary and at the 

Commission’s Web site. 

Participation in the review and public 

service list.—Persons, including 

industrial users of the subject 

merchandise and, if the merchandise is 

sold at the retail level, representative 

consumer organizations, wishing to 

participate in this review as parties 

must file an entry of appearance with 

the Secretary to the Commission, as 

provided in section 201.11 of the 

Commission’s rules, by 45 days after 

publication of this notice. A party that 

filed a notice of appearance following 

publication of the Commission’s notice 

of institution of the review need not file 

an additional notice of appearance. The 

Secretary will maintain a public service 

list containing the names and addresses 

of all persons, or their representatives, 

who are parties to the review. 

Limited disclosure of business 

proprietary information (BPI) under an 

administrative protective order (APO) 

and BPI service list.—Pursuant to 

section 207.7(a) of the Commission’s 

rules, the Secretary will make BPI 

gathered in this review available to 

authorized applicants under the APO 

issued in the review, provided that the 

application is made by 45 days after 

publication of this notice. Authorized 

applicants must represent interested 

parties, as defined by 19 U.S.C. 1677(9), 

who are parties to the review. A party 

granted access to BPI following 

publication of the Commission’s notice 

of institution of the review need not 

reapply for such access. A separate 

service list will be maintained by the 

Secretary for those parties authorized to 

receive BPI under the APO. 

Staff report.—The prehearing staff 

report in the review will be placed in 

the nonpublic record on March 24, 

2010, and a public version will be 

issued thereafter, pursuant to section 

207.64 of the Commission’s rules. 

Hearing.—The Commission will hold 

a hearing in connection with the review 

beginning at 9:30 a.m. on April 13, 

2010, at the U.S. International Trade 

Commission Building. Requests to 

appear at the hearing should be filed in 

writing with the Secretary to the 

Commission on or before April 8, 2010. 

A nonparty who has testimony that may 

aid the Commission’s deliberations may 

request permission to present a short 

statement at the hearing. All parties and 

nonparties desiring to appear at the 

hearing and make oral presentations 

should attend a prehearing conference 

to be held at 9:30 a.m. on April 12, 

2010, at the U.S. International Trade 

Commission Building. Oral testimony 

and written materials to be submitted at 

the public hearing are governed by 

sections 201.6(b)(2), 201.13(f), 207.24, 

and 207.66 of the Commission’s rules. 

Parties must submit any request to 

present a portion of their hearing 

testimony in camera no later than 7 

business days prior to the date of the 

hearing. 

Written submissions.—Each party to 

the review may submit a prehearing 

brief to the Commission. Prehearing 

briefs must conform with the provisions 

of section 207.65 of the Commission’s 

rules; the deadline for filing is April 2, 

2010. Parties may also file written 

testimony in connection with their 

presentation at the hearing, as provided 

in section 207.24 of the Commission’s 

rules, and posthearing briefs, which 

must conform with the provisions of 

section 207.67 of the Commission’s 

rules. The deadline for filing 

posthearing briefs is April 22, 2010; 

witness testimony must be filed no later 

than three days before the hearing. In 

addition, any person who has not 

entered an appearance as a party to the 

review may submit a written statement 

of information pertinent to the subject of 

the review on or before April 22, 2010. 

On May 13, 2010, the Commission will 

make available to parties all information 

on which they have not had an 

opportunity to comment. Parties may 

submit final comments on this 

information on or before May 17, 2010, 

but such final comments must not 

contain new factual information and 

must otherwise comply with section 

207.68 of the Commission’s rules. All 

written submissions must conform with 

the provisions of section 201.8 of the 

Commission’s rules; any submissions 

that contain BPI must also conform with 

the requirements of sections 201.6, 

207.3, and 207.7 of the Commission’s 

rules. The Commission’s rules do not 

authorize filing of submissions with the 

Secretary by facsimile or electronic 

means, except to the extent permitted by 

section 201.8 of the Commission’s rules, 

as amended, 67 FR 68036 (November 8, 

2002). Even where electronic filing of a 

document is permitted, certain 

documents must also be filed in paper 

form, as specified in II (C) of the 

Commission’s Handbook on Electronic 

Filing Procedures, 67 FR 68168, 68173 

(November 8, 2002). 

Additional written submissions to the 

Commission, including requests 

pursuant to section 201.12 of the 

Commission’s rules, shall not be 

accepted unless good cause is shown for 

accepting such submissions, or unless 

the submission is pursuant to a specific 

request by a Commissioner or 

Commission staff. 

In accordance with sections 201.16(c) 

and 207.3 of the Commission’s rules, 

each document filed by a party to the 

review must be served on all other 

parties to the review (as identified by 

either the public or BPI service list), and 

a certificate of service must be timely 

filed. The Secretary will not accept a 

document for filing without a certificate 

of service. 

Authority: This review is being conducted 

under authority of title VII of the Tariff Act 

of 1930; this notice is published pursuant to 

section 207.62 of the Commission’s rules. 

By order of the Commission. 

Issued: November 24, 2009. 

William R. Bishop, 

Acting Secretary to the Commission. 

[FR Doc. E9–28547 Filed 11–27–09; 8:45 am] 

BILLING CODE P 

WReier-Aviles on DSKGBLS3C1PROD with NOTICES

EXPLANATION OF COMMISSION DETERMINATION ON ADEQUACY

in

Ironing Tables from China

Inv. No. 731-TA-1047 (Review) 

On October 5, 2009, the Commission determined that it should proceed to a full review in

the subject five-year review pursuant to section 751(c)(3)(B) of the Tariff Act of 1930, as

amended, 19 U.S.C. § 1675(c)(5). 

The Commission determined that the response to its notice of institution filed by Home

Products International, Inc., the sole domestic producer of ironing tables and the petitioner in the

original investigation, was individually adequate. The Commission further determined that the

domestic interested party group response was adequate.

The Commission also determined that the responses to its notice of institution filed by

Group SEB USA, Inc., Polder Inc. and Whitney Design, U.S. importers of the subject

merchandise, were individually adequate. The Commission determined that the response to its

notice of institution filed by Since Hardware (Guangzhou) Co., Ltd., a Chinese manufacturer and

exporter to the United States of ironing tables, was individually adequate. Because the

responding U.S. importers accounted for a majority of imports of subject ironing tables in 2008,

and a foreign producer also responded, the Commission further determined that the respondent

interested party group response was adequate. Accordingly, the Commission determined to

proceed to a full review in Ironing Tables from China. 

A record of the Commissioners’ votes is available from the Office of the Secretary and

the Commission’s web site (http://www.usitc.gov).

APPENDIX B

HEARING WITNESSES

B-1

CALENDAR OF PUBLIC HEARING

Those listed below appeared as witnesses at the United States International Trade

Commission’s hearing:

Subject: Ironing Tables and Certain Parts Thereof from China

Inv. Nos.: 731-TA-1047 (Review)

Date and Time: April 13, 2010 - 11:00 a.m.

Sessions were held in connection with this review in the Main Hearing Room, 500 E Street

(room 101), SW, Washington, D.C.

OPENING REMARKS:

In Support of Continuation of Order (Frederick L. Ikenson,

Blank Rome LLP)

In Opposition to Continuation of Order (William E. Perry,

Dorsey & Whitney)

In Support of Continuation of

 Antidumping Duty Order:

Blank Rome LLP

Washington, D.C.

on behalf of

Home Products International, Inc. (“HPI”)

David R. Kogan, Director of Operations, HPI

Jaci G. Volles, Executive Vice President of Sales

and Marketing, HPI

Dr. Michael D. Bradley, Department of Economics,

The George Washington University

Frederick L. Ikenson ) – OF COUNSEL

B-3
In Opposition to Continuation of

 Antidumping Duty Order:

Dorsey & Whitney

Seattle, WA

on behalf of

Polder Inc.

Whitney Design

Since Hardware

Cal Scott, president and Owner, Polder Inc.

Kerry Cooper, Sales Manager, Polder Inc.

William E. Perry ) – OF COUNSEL

REBUTTAL/CLOSING REMARKS:

In Support of Continuation of Order (Frederick L. Ikenson,

Blank Rome LLP)

In Opposition to Continuation of Order (William E. Perry,

Dorsey & Whitney)

B-4
APPENDIX C

SUMMARY DATA

C-1

Table C-1

Ironing tables: Summary data concerning the U.S. market, 2004-09

(Quantity=1,000 units, value=1,000 dollars, unit values, unit labor costs, and unit expenses are per unit; period changes=percent, except where noted)

Reported data Period changes

Item 2004 2005 2006 2007 2008 2009 2004-09 2004-05 2005-06 2006-07 2007-08 2008-09

U.S. consumption quantity: *** *** *** *** *** *** *** *** *** *** *** ***

 Amount . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Producers' share (1) . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Importers' share (1): *** *** *** *** *** *** *** *** *** *** *** ***

 China . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 All other sources . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Total imports . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

U.S. consumption value: *** *** *** *** *** *** *** *** *** *** *** ***

 Amount . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Producers' share (1) . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Importers' share (1): *** *** *** *** *** *** *** *** *** *** *** ***

 China . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 All other sources . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Total imports . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

U.S. shipments of imports from:

 China:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Ending inventory quantity . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 All other sources:

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Ending inventory quantity . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 All sources:

 Quantity . . . . . . . . . . . . . . . . . . 1,641 1,925 1,741 1,116 1,553 755 -54.0 17.3 -9.5 -35.9 39.1 -51.4

 Value . . . . . . . . . . . . . . . . . . . . 16,730 22,160 21,101 17,548 20,975 12,181 -27.2 32.5 -4.8 -16.8 19.5 -41.9

 Unit value . . . . . . . . . . . . . . . . $10.20 $11.51 $12.12 $15.72 $13.51 $16.14 58.3 12.9 5.3 29.7 -14.1 19.5

 Ending inventory quantity . . . . *** *** *** *** *** *** *** *** *** *** *** ***

U.S. producers': *** *** *** *** *** *** *** *** *** *** *** ***

 Average capacity quantity . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Production quantity . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Capacity utilization (1) . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 U.S. shipments: *** *** *** *** *** *** *** *** *** *** *** ***

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Export shipments: *** *** *** *** *** *** *** *** *** *** *** ***

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Ending inventory quantity . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Inventories/total shipments (1) . *** *** *** *** *** *** *** *** *** *** *** ***

 Production workers . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Hours worked (1,000s) . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Wages paid ($1,000s) . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Hourly wages . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Productivity (units per hour) . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit labor costs . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Net sales: *** *** *** *** *** *** *** *** *** *** *** ***

 Quantity . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Value . . . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit value . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Cost of goods sold (COGS) . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Gross profit or (loss) . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 SG&A expenses . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Operating income or (loss) . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Capital expenditures . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit COGS . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit SG&A expenses . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Unit operating income or (loss) . *** *** *** *** *** *** *** *** *** *** *** ***

 COGS/sales (1) . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 Operating income or (loss)/ *** *** *** *** *** *** *** *** *** *** *** ***

 sales (1) . . . . . . . . . . . . . . . . . . *** *** *** *** *** *** *** *** *** *** *** ***

 (1) "Reported data" are in percent and "period changes" are in percentage points.

 (2) Undefined.

Note.--Financial data are reported on a fiscal year basis and may not necessarily be comparable to data reported on a calendar year basis. Because of rounding, figures may not add to the totals shown.

Unit values and shares are calculated from the unrounded figures.

Source: Compiled from data submitted in response to Commission questionnaires.

C-3
Table C-2

Ironing tables: U.S. imports, by leading sources, 2004-09

Source

Calendar year

2004 2005 2006 2007 2008 2009

Quantity (1,000 units)

China 2,798 2,345 2,045 1,602 1,883 1,077

Taiwan 565 299 357 42 43 24

Italy 156 123 29 32 24 13

Mexico 85 50 65 32 27 20

India 27 35 37 65 31 20

France 19 31 37 16 57 13

Netherlands 54 58 6 2 13 3

Poland 2 18 20 24 23 15

All other sources 168 119 65 98 80 23

Total 3,873 3,079 2,663 1,914 2,180 1,208

Value (1,000 dollars)

1

China 28,785 23,067 20,130 16,858 20,485 13,708

Taiwan 4,340 3,123 2,972 430 576 152

Italy 2,649 1,698 592 588 649 359

Mexico 1,372 1,208 1,242 886 692 628

India 304 305 325 528 270 303

France 304 440 519 305 802 186

Netherlands 793 786 104 60 205 70

Poland 30 220 321 366 399 262

All other sources 3,812 2,376 1,428 1,656 1,687 585

Total 42,390 33,223 27,633 21,676 25,765 16,254

Unit value (per unit)

China 10.29 9.84 9.84 10.52 10.88 12.72

Taiwan 7.68 10.44 8.32 10.29 13.45 6.22

Italy 16.97 13.86 20.37 18.46 27.27 27.69

Mexico 16.22 24.28 19.14 27.29 25.77 32.08

India 11.14 8.63 8.68 8.14 8.78 15.05

France 16.39 14.01 13.90 18.51 14.01 14.09

Netherlands 14.80 13.51 17.27 26.81 15.53 22.40

Poland 16.82 12.14 15.75 15.47 17.62 17.53

All other sources 22.74 19.99 21.94 16.82 20.97 26.02

Average 10.95 10.79 10.38 11.33 11.82 13.45

 1 Landed, duty-paid.

Note.–Countries ranked based on total quantity of imports during 2004-09.

Source: Compiled from official Commerce statistics (HTS 9403.20.0011).

C-4
Figure C-1

Ironing tables: U.S. imports, by quarters and by sources, 2004-09

Source: Compiled from official Commerce statistics.

C-5

APPENDIX D

COMMENTS BY U.S. PRODUCER, IMPORTERS, PURCHASERS, 

AND FOREIGN PRODUCERS REGARDING THE EFFECTS OF THE 

ORDERS AND THE LIKELY EFFECTS OF REVOCATION

D-1

U.S. PRODUCER’S COMMENTS REGARDING THE SIGNIFICANCE OF THE

ANTIDUMPING DUTY ORDER AND THE LIKELY EFFECTS OF REVOCATION

Effect Of The Order

(Question II-16)

The Commission requested U.S. producer to describe the significance of the existing

antidumping duty order covering imports of ironing tables and certain parts thereof from China in

terms of its effect on its firm’s production capacity, production, U.S. shipments, inventories,

purchases, employment, revenues, costs, profits, cash flow, capital expenditures, research and

development expenditures, and asset values. Its response is as follows:

* * * * * * *

Likely Effect Of Revocation Of The Order

(Question II-17)

The Commission requested U.S. producer to describe any anticipated changes in its

production capacity, production, U.S. shipments, inventories, purchases, employment, revenues,

costs, profits, cash flow, capital expenditures, research and development expenditures, or asset

values relating to the production of ironing tables and certain parts thereof in the future if the

antidumping duty order on ironing tables and certain parts thereof from China were to be revoked. 

Its responses are as follows:

* * * * * * *

Anticipated Changes In Operations In The Event The Order Is Revoked

(Question II-4)

The Commission requested U.S. producer to describe anticipated changes in the character

of its operations or organization relating to the production of ironing tables and certain parts

thereof in the future if the antidumping duty order on ironing tables and certain parts thereof from

China were to be revoked. Its response is as follows:

* * * * * * *

D-3
U.S. IMPORTERS’ COMMENTS REGARDING THE SIGNIFICANCE OF THE

ANTIDUMPING DUTY ORDER AND THE LIKELY EFFECTS OF REVOCATION

Effect Of The Order

(Question II-10)

The Commission requested U.S. importers to describe the significance of the existing

antidumping duty order covering imports of ironing tables and certain parts thereof in terms of its

effect on their firm’s imports, U.S. shipments of imports, and inventories. Their responses are as

follows:

* * * * * * *

Likely Effect Of Revocation Of Order

(Question II-11)

The Commission requested U.S. importers to describe anticipated changes in their imports,

U.S. shipments of imports, or inventories of ironing tables and certain parts thereof in the future if

the antidumping duty order on ironing tables and certain parts thereof were to be revoked. Their

responses are as follows:

* * * * * * *

Anticipated Changes In Operations In The Event The Order Is Revoked

(Question II-4) 

The Commission requested U.S. importers to describe anticipated changes in the character

of their operations or organization relating to the importation of ironing tables and certain parts

thereof in the future if the antidumping duty order on ironing tables and certain parts thereof from

China were to be revoked.

* * * * * * *

PURCHASER COMMENTS REGARDING LIKELY EFFECTS OF REVOCATION

Likely Effects of Revocation (Question III-27)

 The Commission requested U.S. purchasers to describe likely effects of any revocation of

the antidumping duty order for imports of ironing tables from China. As appropriate, please

discuss any potential effects of revocation of the antidumping duty order on (1) the future activities

of your firm and (2) the market as a whole.

* * * * * * *

D-4
FOREIGN PRODUCERS'/EXPORTERS' COMMENTS REGARDING THE SIGNIFICANCE OF

THE ANTIDUMPING DUTY ORDER AND THE LIKELY EFFECTS OF REVOCATION

Signficance Of The Order

(Question II-12)

The Commission requested foreign producers/exporters to describe the significance of the

existing antidumping duty order covering imports of ironing tables and certain parts thereof from

China in terms of its effect on their firms’ production capacity, production, home market

shipments, exports to the United States and other markets, and inventories. Their responses are as

follows:

* * * * * * *

Anticipated Changes If The Order Revoked 

(Question II-13)

The Commission requested foreign producers/exporters to describe any anticipated changes

in their production capacity, production, home market shipments, exports to the United States and

other markets, or inventories relating to the production of ironing tables and certain parts thereof

from China if the antidumping duty order on ironing tables and certain parts thereof from China

were to be revoked. Their responses are as follows:

* * * * * * *

Anticipated Changes In Operations In The Event The Order Is Revoked

(Question II-4)

The Commission requested foreign producers/exporters to describe anticipated changes in

the character of their operations or organization relating to the production of ironing tables and

certain parts thereof in the future if the antidumping duty order on ironing tables and certain parts

thereof from China were to be revoked. Their responses are as follows:

* * * * * * *

D-5

APPENDIX E

U.S. PRODUCER’S SELLING PRICES OF PRODUCTS 1 AND 3 COMBINED,

AND

U.S. IMPORTERS’ SELLING PRICES OF THE CHINESE PRODUCTS 3 AND

4 COMBINED

E-1

Tables E-1 and E-2 show selling prices based on combinations of ironing table products to

account for any competition between certain products. Table E-1 shows price data for the domestic

products 1 and 3 combined and price data for the imported product 3 from China; this corresponds to

price data comparisons in the final phase of the original investigation between the domestic product–floor

standing, metal perforated-top ironing tables, T-leg, with pad and cover and the following product

imported from China--floor standing, metal mesh-top ironing tables, T-leg, with pad and cover. Table E2 shows price data for the domestic product 3 and combined price data for the imported products 3 and 4. 

These latter data are shown to include *** prices of product 4, the heavier-steel version of product 3,

which were consistently below those of domestic product 3.

Table E-1

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic ironing table products 1 and 3 combined and the imported Chinese product 3, by

quarters, January 2004-December 2009

* * * * * * *

Table E-2

Ironing tables: Net weighted-average U.S. f.o.b. selling (unbundled) prices and quantities of the

domestic ironing table product 3 and the imported Chinese products 3 and 4 combined, by

quarters, January 2004-December 2009

* * * * * * *

E-3