U.S. International Trade Commission

Publication 4479 July 2014

Washington, DC 20436

Polyethylene Terephthalate Film, Sheet, 

and Strip from India and Taiwan

Investigation Nos. 701-TA-415 and 731-TA-933 and 934 (Second Review)
U.S. International Trade Commission

COMMISSIONERS 

 

Meredith M. Broadbent, Chairman 

Dean A. Pinkert, Vice Chairman 

Irving A. Williamson 

David S. Johanson 

F. Scott Kieff 

Rhonda K. Schmidtlein

Robert B. Koopman

Staff assigned

Address all communications to 

Secretary to the Commission 

United States International Trade Commission 

Washington, DC 20436

Director of Operations

Cynthia Trainor, Investigator 

Raymond Cantrell, Industry Analyst 

Cindy Cohen, Economist 

Charles Yost, Accountant 

Rhonda Hughes, Attorney 

Lita David-Harris, Statistician 

Darlene Smith, Statistical Assistant 

James McClure, Supervisory Investigator
U.S. International Trade Commission

Washington, DC 20436 

www.usitc.gov

Publication 4479 July 2014

Polyethylene Terephthalate Film, Sheet, 

and Strip from India and Taiwan

Investigation Nos. 701-TA-415 and 731-TA-933 and 934 (Second Review)

  

CONTENTS

Page

i

Determinations............................................................................................................................... 1

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

Part I: Introduction................................................................................................................ I‐1

Background................................................................................................................................ I‐1

The original investigations..................................................................................................... I‐2

Subsequent five‐year reviews............................................................................................... I‐3

Related investigations............................................................................................................... I‐3

Summary data ........................................................................................................................... I‐4

Statutory criteria and organization of the report ..................................................................... I‐9

Statutory criteria ................................................................................................................... I‐9

Organization of report......................................................................................................... I‐10

Commerce’s reviews............................................................................................................... I‐11

Administrative reviews........................................................................................................ I‐11

New shipper reviews........................................................................................................... I‐12

Scope reviews...................................................................................................................... I‐13

Five‐year reviews................................................................................................................. I‐13

The subject merchandise ........................................................................................................ I‐14

Commerce’s scope .............................................................................................................. I‐14

Tariff treatment................................................................................................................... I‐15

The product............................................................................................................................. I‐16

Description and applications............................................................................................... I‐16

Manufacturing processes.................................................................................................... I‐16

Domestic like product issues................................................................................................... I‐20

U.S. market participants.......................................................................................................... I‐21

U.S. producers..................................................................................................................... I‐21

U.S. importers...................................................................................................................... I‐22

U.S. purchasers.................................................................................................................... I‐23

Apparent U.S. consumption .................................................................................................... I‐24

U.S. market shares .................................................................................................................. I‐25
  

CONTENTS

Page

ii

Part II: Conditions of competition in the u.s. market ............................................................ II‐1

U.S. market characteristics....................................................................................................... II‐1

Channels of distribution ........................................................................................................... II‐1

Geographic distribution ........................................................................................................... II‐2

Supply and demand considerations......................................................................................... II‐3

U.S. supply ............................................................................................................................ II‐3

U.S. demand ......................................................................................................................... II‐7

Substitutability issues............................................................................................................. II‐10

Lead times .......................................................................................................................... II‐10

Knowledge of country sources........................................................................................... II‐10

Factors affecting purchasing decisions............................................................................... II‐11

Comparisons of domestic products, subject imports, and nonsubject imports................ II‐14

Comparison of U.S.‐produced and imported PET film....................................................... II‐15

Elasticity estimates................................................................................................................. II‐18

U.S. supply elasticity........................................................................................................... II‐18

U.S. demand elasticity ........................................................................................................ II‐18

Substitution elasticity ......................................................................................................... II‐18

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

Overview ................................................................................................................................. III‐1

Changes experienced by the industry ................................................................................. III‐1

Anticipated changes in operations...................................................................................... III‐2

U.S. production, capacity, and capacity utilization................................................................. III‐2

The Commission asked U.S. producers whether the production equipment and the

production and related workers (“PRWs”) employed in the production of PET film were

used to produce other products.  ***.  ***.   ***. ............................................................. III‐3

Constraints on capacity ....................................................................................................... III‐5

U.S. producers’ U.S. shipments and exports........................................................................... III‐5

U.S. producers’ inventories..................................................................................................... III‐7

U.S. producers’ imports and purchases.................................................................................. III‐7

U.S. employment, wages, and productivity ............................................................................ III‐8
  

CONTENTS

Page

iii

    Financial experience of U.S. producers............................................................................. III‐9

Background.......................................................................................................................... III‐9

Operations on PET Film ....................................................................................................... III‐9

Variance analysis............................................................................................................... III‐20

Capital expenditures and research and development expenses...................................... III‐21

Assets and return on investment...................................................................................... III‐23

Part IV: U.S. imports and the foreign industries...................................................................IV‐1

U.S. imports............................................................................................................................. IV‐1

Overview.............................................................................................................................. IV‐1

Imports from subject and nonsubject countries.................................................................IV‐1

U.S. importers’ inventories .....................................................................................................IV‐5

Cumulation considerations .....................................................................................................IV‐5

Fungibility ............................................................................................................................ IV‐5

Geographical markets .........................................................................................................IV‐5

Subject country producers......................................................................................................IV‐6

The industry in India................................................................................................................IV‐7

Overview.............................................................................................................................. IV‐7

Operations on PET film........................................................................................................IV‐7

The industry in Taiwan ............................................................................................................IV‐9

Overview.............................................................................................................................. IV‐9

Operations on PET Film .......................................................................................................IV‐9

The industries in India and Taiwan Combined......................................................................IV‐11

Global market........................................................................................................................IV‐11

Foreign demand.................................................................................................................IV‐19
  

CONTENTS

Page

iv

Part V: Pricing data...............................................................................................................V‐1

Factors affecting prices............................................................................................................V‐1

Raw material costs ...............................................................................................................V‐1

Transportation costs to the U.S. market..............................................................................V‐1

U.S. inland transportation costs...........................................................................................V‐2

Exchange rates......................................................................................................................V‐3

Pricing practices .......................................................................................................................V‐4

Pricing methods....................................................................................................................V‐4

Sales terms and discounts....................................................................................................V‐5

Price leadership ....................................................................................................................V‐5

Price data..................................................................................................................................V‐5

Price trends...........................................................................................................................V‐7

Price comparisons ................................................................................................................V‐8

Appendixes

A. Federal Register notices.................................................................................................... A‐1

B. List of hearing witnesses  .................................................................................................. B‐1

C. Summary data................................................................................................................... C‐1

D. Comments on the significance of the existing antidumping and countervailing duty orders

and the likely effects of revocation...................................................................................D‐1

Note.—Information that would reveal confidential operations of individual concerns may not

be published and therefore has been deleted.  Such deletions are indicated by asterisks.
UNITED STATES INTERNATIONAL TRADE COMMISSION

Investigation Nos. 701‐TA‐415 and 731‐TA‐933 and 934 (Second Review)

POLYETHYLENE TEREPHTHALATE FILM, SHEET, AND STRIP FROM INDIA AND TAIWAN

DETERMINATIONS

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 countervailing duty order on polyethylene

terephthalate film, sheet, and strip (“PET film”) from India and the antidumping duty orders on PET film

from India and Taiwan 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 these reviews on April 1, 2013 (78 F.R. 19524) and determined on

July 5, 2013 that it would conduct full reviews (78 F.R.42105, July 15, 2013).    Notice of the scheduling

of the Commission=s reviews 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 January 16, 2014 (79 F.R. 2883).   

The hearing was cancelled on May 14, 2014 (79 F.R. 28949, May 20, 2014).

 

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

207.2(f)).

3

Views of the Commission

Based on the record in these five‐year reviews, we determine under section 751(c) of

the Tariff Act of 1930, as amended (“the Tariff Act”), that revocation of the countervailing duty

order on polyethylene terephthalate film, sheet and strip (“PET film”) from India and the

antidumping duty orders on PET film from India and Taiwan 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

Original Investigations:  In June 2002, the Commission unanimously determined that an

industry in the United States was materially injured by reason of subsidized imports of PET film

from India and less‐than‐fair‐value (“LTFV”) imports of PET film from India and Taiwan.  The

Department of Commerce (“Commerce”) issued the countervailing duty order on PET film from

India on July 1, 2002 and the antidumping duty order on PET film from India on May 16, 2002.  

It issued the antidumping duty order on PET film from Taiwan on May 20, 2002.1

First Reviews:  On June 1, 2007, the Commission instituted the first five‐year reviews

concerning PET film from India and Taiwan and conducted full reviews.2

  In April 2008, the

Commission made affirmative determinations with respect to imports from both subject

countries.3

  Commerce subsequently issued notices continuing the countervailing duty order on

subject imports from India and the antidumping duty orders on subject imports from India and

Taiwan.4

Current Reviews:  The Commission instituted the instant reviews on April 1, 2013.5  The

Commission received a joint response to its notice of institution from domestic producers

DuPont Teijin Films (“DTF”), Mitsubishi Polyester Film, Inc. (“Mitsubishi”), and SKC, Inc. (“SKC”),

as well as a response from foreign producer Nan Ya Plastics Corporation, Ltd. (“Nan Ya”)

concerning the antidumping duty order on subject imports from Taiwan.  On July 5, 2013, the

Commission determined that the domestic industry interested party group response was

adequate for all reviews and the respondent interested party group response was adequate

with respect to the review of the antidumping duty order on PET film from Taiwan.  

Accordingly, the Commission determined to conduct a full review for that order.  The

Commission did not receive a substantive response from any respondent interested party in the

                                                      

1 Confidential Report (“CR”) at I‐2 ‐ I‐3, Public Report (“PR”) at I‐2; see Polyethylene

Terephthalate Film, Sheet and Strip from India and Taiwan, Inv. Nos. 701‐TA‐415 and 731‐TA‐933‐934

(Final), USITC Pub. 3518 (June 2002) (“Original Determinations”); Polyethylene Terephthalate Film, Sheet

and Strip from India and Taiwan, Inv. Nos. 701‐TA‐415 and 731‐TA‐933‐934 (Review), USITC Pub. 3994

(April 2008) (“First Review Determinations”). 2 72 Fed. Reg. 30627 (June 1, 2007).

3 First Review Determinations, USITC Pub. 3994 at 3. 4 73 Fed. Reg. 26079, 26080 (May 8, 2008). 5 78 Fed. Reg. 19524 (April 1, 2013).
4

reviews concerning subject merchandise from India, and thus determined that the respondent

interested party group response for those reviews was inadequate.  However, the Commission

determined to conduct full reviews with respect to all of the orders in these subject reviews in

order to promote administrative efficiency in light of its decision to conduct full reviews with

respect to the order on PET film from Taiwan.6

Parties to the Proceedings:  The Commission received prehearing and posthearing briefs

from domestic producers DTF, Mitsubishi, and SKC.  Although the Commission received a

response to its notice of institution from one foreign producer, Nan Ya of Taiwan, counsel for

Nan Ya withdrew subsequent to the Commission’s decision to conduct full reviews.7 8

Data Coverage:  U.S. industry data for these reviews are based on the responses of 11

U.S. producers of PET film that are believed to have accounted for 100 percent of U.S.

production in 2013.9

  U.S. import data and related information are based on official import

statistics and the questionnaire responses of 21 U.S. importers that accounted for 83.3 percent

of total U.S. imports during 2008‐13 and 67.8 percent of total subject imports during that

period.10  Foreign industry data and related information are based on market research and the

questionnaire responses of three producers and exporters of subject merchandise:  one

producer/exporter in India, accounting for *** percent of total production of PET film in India

and an estimated *** percent of total exports to the United States of PET film from India in

2013,11 and two producer/exporters in Taiwan, accounting for *** percent of PET film capacity

in Taiwan in 2012.12  

                                                      

6 CR/PR at I‐1 n.4. 7

  No briefs supporting revocation of the orders regarding India and Taiwan were filed.  After the

hearing date Nan Ya filed comments pro se, although most of the comments pertained to matters not

contained in the record that we disregarded pursuant to 19 U.S.C. § 1677m(g) and 19 C.F.R. § 207.30.  

We also disregarded the domestic industry’s arguments regarding these comments in its final comments

for the same reason.   8 In light of the absence of any respondent interested party to file a notice to participate in the

hearing, see 19 C.F.R. § 201.13(c)(2), the domestic producers requested that the Commission cancel the

hearing in these proceedings.   The Commission therefore exercised its discretion to not conduct a

hearing in these reviews.  79 Fed. Reg. 28949 (May 20, 2014).

9 CR at I‐28, PR at I‐21.

10 CR/PR at IV‐1.  These data are believed to have accounted for 93.8 percent of the value of

total subject imports from India and 61.4 percent of the value of total subject imports from Taiwan in

this period.  CR at I‐12, PR at I‐10. 11 CR at IV‐11, PR at IV‐7 – IV‐8.  According to *** percent of PET film capacity in India in 2012.  

CR/PR at Table IV‐6. 12 CR/PR at Table IV‐6.  In view of these data, cited in the ***, we believe Nan Ya’s claim in its

foreign producer questionnaire response that it accounted for *** percent of that country’s total PET

film production and *** percent of total PET film exports to the United States in 2013, CR at IV‐16 – IV‐

17, PR at IV‐9 – IV‐10, to be in error.
5

II. Domestic Like Product and Industry

A. Domestic Like Product

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

defines the “domestic like product” and the “industry.”13  The Tariff 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.”14  The Commission’s

practice in five‐year reviews is to examine the domestic like product definition from the original

investigation and consider whether the record indicates any reason to revisit the prior

findings.15

Commerce has defined the scope of the countervailing duty order in the five‐year

review of PET film from India as follows:

all gauges of raw, pretreated, or primed PET film, whether extruded or coextruded.  

Excluded are metalized films and other finished films that have had at least one of their

surfaces modified by the application of a performance‐enhancing resinous or inorganic

layer of more than 0.00001 inches thick.  Imports of PET film are classifiable in the

Harmonized Tariff Schedule of the United States (‘‘HTSUS’’) under item number

3920.62.00.90.  Effective July 1, 2003, the HTSUS subheading 3920.62.00.00 was divided

into 3920.62.00.10 (metallized PET film) and 3920.62.00.90 (nonmetallized PET film).  

Although the HTSUS numbers are provided for convenience and customs purposes, the

written product description remains dispositive.16

                                                      

13 19 U.S.C. § 1677(4)(A). 14 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).

15 See, e.g., Internal Combustion Industrial Forklift Trucks from Japan, Inv. No. 731‐TA‐377

(Second Review), USITC Pub. 3831 at 8‐9 (Dec. 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 (Feb. 2003).

16 78 Fed. Reg. 47276, 47277 (Aug. 5, 2013).  The scope of the countervailing duty order on PET

film from India differs slightly from the scope of the antidumping duty orders on PET film from India and

Taiwan.  Specifically, the former cites the item number as the 10‐digit statistical reporting number and

provides an explanation of changes made to the Harmonized Tariff Schedule effective July 1, 2003.  In

addition, the countervailing duty order scope does not mention the scope determination cited in the

antidumping duty order, in which Commerce determined that tracing and drafting film is outside the

scope of the order on PET film from India.  See 79 Fed. Reg. 12153, 12154 (Mar. 4, 2014).
6

The Original Determinations and First Five‐Year Reviews

In the original determinations, the Commission defined a single domestic like product

consisting of all PET film, not including equivalent PET film,17 corresponding to Commerce’s

scope.18  In the first reviews, all parties indicated that they agreed with the Commission’s

definition of the domestic like product in the original determinations.  The Commission again

defined a single domestic like product consisting of all products corresponding to Commerce’s

scope.19  

The Current Reviews

  

In five‐year reviews, when no party has argued for a different domestic like product

definition and the record does not suggest that any change is appropriate, the Commission

generally adopts without further analysis the domestic like product definition from the original

investigations for the same reasons previously articulated.  Neither the domestic producers nor

the sole responding respondent interested party objected to the definition of the domestic like

product in their responses to the notice of institution or briefs in these reviews.20  Moreover,

the record of these reviews contains no information that would suggest a reconsideration of

the domestic like product definition.21  Therefore, we again define the domestic like product as

consisting of all PET film, not including equivalent PET film, corresponding to the scope of the

orders, for the same reasons articulated in the original investigations and first reviews.

B. Domestic Industry  

Section 771(4)(A) of the Tariff 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 constitutes a major proportion of the total domestic production of

the product.”22  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.  

We must determine whether any producer of the domestic like product should be

excluded from the domestic industry pursuant to section 771(4)(B) of the Tariff Act.  This

provision allows the Commission, if appropriate circumstances exist, to exclude from the

                                                      

17 “Equivalent” PET film is PET film with a coating more than 0.00001 inch thick.  Original

Determinations, USITC Pub. 3518 at 4.

18 Original Determinations, USITC Pub. 3518 at 6.

19 First Review Determinations, USITC Pub. 3994 at 6.

20 Nan Ya’s Response to Notice of Institution at 15; Domestic Industry’s Prehearing Brief at 10. 21 See CR at I‐19 – I‐27, PR at I‐16 – I‐21. 22 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.
7

domestic industry producers that are related to an exporter or importer of subject merchandise

or which are themselves importers.23  Exclusion of such a producer is within the Commission’s

discretion based upon the facts presented in each investigation.24

In the original investigations, no domestic producer was a related party.  Accordingly, in

view of its definition of the domestic like product, the Commission defined a single domestic

industry consisting of all domestic producers of PET film.25  In the first reviews, there were two

domestic producers that could be considered related parties by virtue of their imports or

purchases of subject merchandise during the period of review.  The Commission found that

appropriate circumstances did not exist to exclude either producer from the domestic industry

and defined the domestic industry as all U.S. producers of PET film.26

In these reviews, no party has argued that any U.S. producer should be excluded from

the domestic industry as a related party.  However, *** is related to a subject producer and is

arguably a related party.  Two U.S. producers, *** and are thus related parties.27  As explained

below, we find that circumstances are not appropriate to exclude any of these producers from

the domestic industry.

***.  *** was the *** largest domestic producer in 2013,28 ***.29  *** does not itself

import or purchase subject merchandise, but is affiliated with several foreign producers of PET

film and is ***.30  ***.31  *** supports continuation of the orders.32  It does not appear to be

                                                      

23 See Torrington Co v. United States, 790 F. Supp. 1161, 1168 (Ct. Int’l Trade 1992), aff’d without

opinion, 991 F.2d 809 (Fed. Cir. 1993); Sandvik AB v. United States, 721 F. Supp. 1322, 1331‐32 (Ct. Int’l

Trade 1989), aff’d mem., 904 F.2d 46 (Fed. Cir. 1990); Empire Plow Co. v. United States, 675 F. Supp.

1348, 1352 (Ct. Int’l Trade 1987).

24 The primary factors the Commission has examined in deciding whether appropriate

circumstances exist to exclude a related party include the following:

(1) the percentage of domestic production attributable to the importing producer;

(2) the reason the U.S. producer has decided to import the product subject to investigation, i.e.,

whether the firm benefits from the LTFV sales or subsidies or whether the firm must import in order to

enable it to continue production and compete in the U.S. market; and

(3) the position of the related producer vis‐a‐vis the rest of the industry, i.e., whether inclusion

or exclusion of the related party will skew the data for the rest of the industry. See, e.g., Torrington Co.  

v. United States, 790 F. Supp. at 1168.

25 Original Determinations, USITC Pub. 3518 at 6.

26 First Review Determinations, USITC Pub. 3994 at 6‐8.

27 Although *** purchased subject merchandise during the period, we do not consider it to be a

related party.  Its purchases were modest and insufficient to indicate that 3M controls an individual

importer of subject merchandise.  CR/PR at Tables III‐8 & IV‐1, CR at IV‐2, PR at IV‐1.

28 CR/PR at Table III‐4.

29 CR/PR at Table III‐2.

30 CR at III‐3, PR at III‐2.  *** did not complete a foreign producers’ questionnaire response, CR

at IV‐11, PR at IV‐7, so the record does not indicate whether it exported subject merchandise during the

period of review.  The record also does not indicate the nature of the relationships among ***.    31 CR at III‐30, PR at III‐23.

32 CR/PR at Table I‐5.
8

benefitting from its relationship with a subject producer, as its operating income to net sales

ratio was *** in 2013, and it experienced an *** of $*** in 2013.33 34  We conclude that

circumstances are not appropriate to exclude *** from the domestic industry.

***.  *** is ***.35  It was the *** largest domestic producer in 201336 and ***.37  *** on

the continuation of the orders.38  *** imported subject merchandise from *** in 2013, ***, and

the ratio of these imports to its U.S. production was *** percent.39  It does not appear to be

benefitting from its subject imports that year, as its operating income to net sales ratio was ***

percent in 2013.40  It also experienced an *** of $*** in 2013.41  We find that circumstances are

not appropriate to exclude *** from the domestic industry.

  ***.  ***, which *** PET film production in mid‐2011,42 imported subject merchandise

from *** in three years during the period of review and purchased subject imports from both

*** throughout the period.  Its share of domestic 2008‐13 PET film production was *** percent,

which renders it the *** domestic producer during the period of review.43  It imported ***

pounds of subject merchandise from *** in 2010, *** pounds in 2011 and *** pounds in 2013.  

Its ratio of subject imports to its U.S. production was *** percent in 2010 and *** percent in

2011.44

*** does not appear to benefit from its imports and purchases of subject merchandise,

as its operating income to net sales ratio was *** in every year of the period of review for

which it reported data (*** percent in 2008, *** percent in 2009, *** percent in 2010, ***

percent in 2011, and *** percent in 2012).45  It also experienced *** throughout the period

($*** in 2008, $*** in 2009, $*** in 2010, $*** in 2011, and $*** in 2012) and had ***

                                                      

33 CR/PR at Table III‐11.

34 Commissioner Pinkert does not rely upon financial performance to determine whether there

are appropriate circumstances to exclude *** from the domestic industry.  In his view, the present

record is not sufficient to link the companies’ financial performance with respect to U.S. operations to

any benefit they derive as related parties.

35 CR at III‐3 – III‐4, PR at III‐3.

36 CR/PR at Table III‐4.

37 CR/PR at Tables III‐2, III‐13.

38 CR/PR at Table I‐5.

39 CR/PR at Table III‐7.

40 CR/PR at Table III‐11. 41 CR/PR at Table III‐11.

42 CR/PR at Table III‐2.

43 CR/PR at Table I‐5. 44 CR/PR at Table III‐7.  *** also purchased *** pounds of subject imports from *** in

2010, *** pounds in 2011, *** pounds in 2012, and *** pounds in 2013.  It purchased ***

pounds of subject imports from *** in 2008, *** pounds in 2009, *** pounds in 2010, ***

pounds in 2011, and *** pounds in 2012.  CR/PR at Table III‐8.

45 CR/PR at Table III‐11.
9

operating income in 2013.46  Accordingly, *** that *** *** the continuation of the orders,47 we

determine that circumstances are not appropriate to exclude *** from the domestic industry.  

In view of the foregoing, we define the domestic industry, as the Commission did in the

original investigations and first five‐year reviews, to include all domestic producers of PET film.

III. Cumulation

A. Legal Standard

With respect to five‐year reviews, section 752(a) of the Tariff Act provides as follows:

the Commission may cumulatively assess the volume and effect of imports of the

subject merchandise from all countries with respect to which reviews under

section 1675(b) or (c) of this title were initiated on the same day, if such imports

would be likely to compete with each other and with domestic like products in

the United States market.    The Commission shall not cumulatively assess the

volume and effects of imports of the subject merchandise in a case in which it

determines that such imports are likely to have no discernible adverse impact on

the domestic industry.48

Cumulation therefore is discretionary in five‐year reviews, unlike original investigations,

which are governed by section 771(7)(G)(i) of the Tariff Act.49  The Commission may exercise its

discretion to cumulate, however, only if the reviews are initiated on the same day, the

Commission determines that the subject imports are likely to compete with each other and the

domestic like product in the U.S. market, and imports from each such subject country are not

likely to have no discernible adverse impact on the domestic industry in the event of

revocation.  Our focus in five‐year reviews is not only on present conditions of competition, but

also on likely conditions of competition in the reasonably foreseeable future.

In the original investigations, the Commission found that there was a reasonable

overlap of competition between the subject imports from India and Taiwan and between

subject imports and the domestic like product and consequently cumulated subject imports

                                                      

46 CR/PR at Table III‐11. 47 CR/PR at Table I‐5.

48 19 U.S.C. § 1675a(a)(7).

49 19 U.S.C. § 1677(7)(G)(i); see also, e.g., Nucor Corp. v. United States, 601 F.3d 1291, 1293 (Fed.

Cir. 2010) (Commission may reasonably consider likely differing conditions of competition in deciding

whether to cumulate subject imports in five‐year reviews); Allegheny Ludlum Corp. v. United States, 475

F. Supp. 2d 1370, 1378 (Ct. Int’l Trade 2006) (recognizing the wide latitude the Commission has in

selecting the types of factors it considers relevant in deciding whether to exercise discretion to cumulate

subject imports in five‐year reviews); Nucor Corp. v. United States, 569 F. Supp. 2d 1328, 1337‐38 (Ct.

Int’l Trade 2008).
10

from India and Taiwan.50  In the first five‐year reviews, the Commission did not find that subject

imports from India or Taiwan were likely to have no discernible adverse impact on the domestic

industry in the event of revocation of the orders.51  In the first reviews the Commission also

found that there would likely be a reasonable overlap in competition between subject imports

from each country and the domestic like product, as well as between subject imports, should

the orders be revoked.52  Consequently, the Commission determined to exercise its discretion

to cumulate subject imports from India and Taiwan.53

B. Likelihood of No Discernible Adverse Impact

The statute precludes cumulation if the Commission finds that subject imports from a

country are likely to have no discernible adverse impact on the domestic industry.54  Neither the

statute nor the Uruguay Round Agreements Act (“URAA”) Statement of Administrative Action

(“SAA”) provides specific guidance on what factors the Commission is to consider in

determining that imports “are likely to have no discernible adverse impact” on the domestic

industry.55  With respect to this provision, the Commission generally considers the likely volume

of subject imports and the likely impact of those imports on the domestic industry within a

reasonably foreseeable time if the orders are revoked.  Our analysis for each of the subject

countries takes into account, among other things, the nature of the product and the behavior of

subject imports in the original investigations.

India.  In the original investigations, U.S. shipments of subject imports from India

increased from *** pounds in 1999 to *** pounds in 2001.  During the first five‐year reviews,

subject import shipments decreased from *** pounds in 2002 to *** pounds in 2006.  Subject

imports from India were present each year during the current period of review; U.S. shipments

of such imports totaled *** pounds in 2008 and fluctuated from a low of *** pounds in 2010 to

a high of *** pounds in 2011, decreasing to *** pounds in 2013.56   

In these reviews, the Commission received information on the PET film industry in India

from one producer, Polyplex.  Polyplex’s capacity in India *** during the period of review, from

*** pounds in 2008 to *** pounds in 2013.57  Its capacity utilization ***.58  Market research

data show that there were *** producers of PET film in India in 2012, with total capacity of ***

pounds.59

                                                      

50 Original Determinations, USITC Pub. 3518 at 8.

51 First Review Determinations, USITC Pub. 3994 at 9.

52 First Review Determinations, USITC Pub. 3994 at 12.

53 First Review Determinations, USITC pub. 3994 at 13.

54 19 U.S.C. § 1675a(a)(7). 55 SAA, H.R. Rep. No. 103‐316, vol. I at 887 (1994).

56 CR/PR at Table I‐1. 57 CR/PR at Table IV‐8.

58 CR/PR at Table IV‐8.

59 CR at IV‐10 ‐ IV‐11, PR at IV‐7.  ***.   CR at II‐8 & n.10, PR at II‐8 & n.10.

(Continued...)
11

India was the sixth largest PET film exporter worldwide in 2013.  Its exports increased

from 92.4 million pounds in 2008 to 206.8 million pounds in 2013.60  Polyplex India’s total

exports increased from *** million pounds in 2008 to *** pounds in 2013.  During this period,

its export shipments to the United States as a share of total shipments fluctuated between ***

percent and *** percent,61 but the United States was India’s third largest export market for PET

film in 2013.62  Its home market shipments as a share of total shipments decreased from ***

percent in 2008 to *** percent in 2013.63

Based on the foregoing, we do not find that subject imports from India would likely have

no discernible adverse impact on the domestic industry if the orders were revoked.

Taiwan.  In the original investigations, U.S. shipments of subject imports from Taiwan

increased from *** pounds in 1999 to *** pounds in 2000, then decreased to *** pounds in

2001.  During the first five‐year reviews, subject import shipments declined from *** pounds in

2002 to *** pounds in 2005, before rising to *** pounds in 2006.  Subject imports from Taiwan

were present in each year of the current period of review, and their U.S. shipments increased

from *** pounds in 2008 to *** pounds in 2009, falling to *** pounds in 2013.64  

The Commission received information on the PET film industry in Taiwan from two of

the three subject producers that comprised the industry during the period of these reviews,  

Nan Ya and Vast Plastic Corp.  Reported capacity from these two producers increased from ***

pounds in 2008 to *** pounds in 2013, and Nan Ya reported that ***.65  Reported capacity

utilization was full or near full throughout the period, fluctuating between *** percent and ***

percent.66  Although total exports from Taiwan fell over the period, they remained high.  The

total export shipments of PET film producers in Taiwan fell from *** pounds in 2008 to ***

pounds in 2013.  Export shipments to the United States as a share of total shipments declined

from *** percent in 2008 to *** percent in 2013, but exports to the United States continued

during the entire period of review.  In contrast, home market shipments by producers in Taiwan

as a share of their total shipments rose from *** percent in 2008 to *** percent in 2013.67

Based on the foregoing, we do not find that subject imports from Taiwan would likely

have no discernible adverse impact on the domestic industry if the order were revoked.

                                                                                                                                                                              

(...Continued)

We note that the domestic producers argue that the best available information on the record

with regard to the PET film industries in India and Taiwan consists of information and data provided by

***.  Domestic Industry’s Prehearing Brief at 5‐6.  However, we do not find these data to be more

reliable than the questionnaire and CEH Marketing Research Report data upon which we have relied.

60 CR/PR at Table IV‐14.

61 CR/PR at Table IV‐8.

62 CR/PR at Table IV‐9.

63 CR/PR at Table IV‐8.

64 CR/PR at Table I‐1.

65 CR/PR at Table IV‐11, CR at IV‐17, PR at IV‐10.

66 CR/PR at Table IV‐11.

67 CR/PR at Table IV‐11.
12

C. Likelihood of a Reasonable Overlap of Competition

The Commission generally has considered four factors intended to provide a framework

for determining whether subject imports compete with each other and with the domestic like

product.68  Only a “reasonable overlap” of competition is required.69  In five‐year reviews, the

relevant inquiry is whether there likely would be competition even if none currently exists

because the subject imports are absent from the U.S. market.70

Fungibility.  In the original investigations, the Commission found that there was at least

a moderate level of fungibility between domestic PET film and the subject imports and between

imports from India and Taiwan.71  In the first five‐year reviews, most purchasers, importers and

U.S. producers reported that domestic and imported products were always or frequently

interchangeable.  The majority of U.S. producers and importers reported that differences other

than price were either never or only sometimes significant.72

The record in these reviews indicates a high degree of substitutability between

domestically produced PET film and PET film imported from subject sources.73  The majority of

U.S. producers, importers and purchasers reported that U.S.‐produced PET film and imported

PET film from India, Taiwan and other countries can “always” or “frequently” be used

interchangeably.74  Most producers and importers reported that differences other than price

were either “sometimes” or “never” significant, while most purchasers reported that such

                                                      

68 The four factors generally considered by the Commission in assessing whether imports

compete with each other and with the domestic like product are as follows:  (1) the degree of fungibility

between subject imports from different countries and between subject imports and the domestic like

product, including consideration of specific customer requirements and other quality‐related questions;

(2) the presence of sales or offers to sell in the same geographical markets of imports from different

countries and the domestic like product; (3) the existence of common or similar channels of distribution

for subject imports from different countries and the domestic like product; and (4) whether subject

imports are simultaneously present in the market with one another and the domestic like product.  See,

e.g., Wieland Werke, AG v. United States, 718 F. Supp. 50 (Ct. Int’l Trade 1989).

69 See Mukand Ltd. v. United States, 937 F. Supp. 910, 916 (Ct. Int’l Trade 1996); Wieland Werke,

718 F. Supp. at 52 (“Completely overlapping markets are not required.”); United States Steel Group v.

United States, 873 F. Supp.  673, 685 (Ct. Int’l Trade 1994), aff’d, 96 F.3d 1352 (Fed. Cir. 1996).  We note,

however, that there have been investigations where the Commission has found an insufficient overlap in

competition and has declined to cumulate subject imports.  See, e.g., Live Cattle from Canada and

Mexico, Inv. Nos. 701‐TA‐386 and 731‐TA‐812‐13 (Preliminary), USITC Pub. 3155 at 15 (Feb. 1999), aff’d

sub nom, Ranchers‐Cattlemen Action Legal Foundation v. United States, 74 F. Supp. 2d 1353 (Ct. Int’l

Trade 1999); Static Random Access Memory Semiconductors from the Republic of Korea and Taiwan, Inv.

Nos. 731‐TA‐761‐62 (Final), USITC Pub. 3098 at 13‐15 (Apr. 1998).

70 See generally, Chefline Corp. v. United States, 219 F. Supp. 2d 1313, 1314 (Ct. Int’l Trade 2002). 71 Original Determinations, USITC Pub. 3518 at 7‐8.

72 First Review Determinations, USITC Pub. 3994 at 11.

73 CR at II‐18, PR at II‐10. 74 CR/PR at Table II‐10.
13

differences between domestic product and that from India and Taiwan were “always” or

“frequently” significant.75  

Channels of Distribution.  In the original investigations, the Commission found that most

sales of domestically produced PET film and of the subject imports from Taiwan are made to

processors who specialize in coating PET film for a particular end use.  Some sales were also

made through distributors, and some sales were made directly to end users.  Subject imports

from India were sold to end users to a greater extent than subject imports from Taiwan or the

domestic product.76  In the first five‐year reviews, the Commission found the majority of U.S.

producers’ domestic shipments were to end users and processors, although some shipments

were also made to distributors.  The majority of shipments of subject imports from India were

to end users, with the remainder going to processors or distributors.  The majority of shipments

of subject imports from Taiwan were to processors, with the remainder going to end users or

distributors.77

In these reviews, the majority of U.S. producers’ shipments were to end users, as were

the majority of U.S. shipments of imports from India and Taiwan.78  Approximately one‐third of

U.S. production and some imports from Taiwan went to converters, while no imports from India

went to converters.79  Some domestically produced PET film, as well as subject imports from

India and Taiwan, went to distributors.80

Simultaneous Presence and Geographic Overlap.  In the original investigations, the

record showed that there were significant imports of the subject merchandise from both India

and Taiwan throughout the period of investigation.81  In the first reviews, the Commission

found that imports from each of the subject countries had been present in the U.S. market

during the period of review.82  The record in the original investigations and the first reviews

showed that the domestic product and subject imports were sold throughout the U.S. market.83

                                                      

75 CR/PR at Table II‐12.

76 Original Determinations, USITC Pub. 3518 at 8. 77 First Review Determinations, USITC Pub. 3994 at 11‐12.

78 In 2013, *** percent of U.S. producers’ U.S. shipments went to end users.  The comparable

figure for U.S. shipments from India that year was *** percent; for U.S. shipments from Taiwan that

year, it was *** percent.  CR/PR at Table II‐1.

79 In 2013, *** percent of U.S. producers’ U.S. shipments went to converters.  The comparable

figure for U.S. shipments of imports from India that year was *** percent; for U.S. shipments from

Taiwan, it was *** percent.  CR/PR at Table II‐1.

80 In 2013, *** percent of U.S. producers’ U.S. shipments went to distributors.  The comparable

figure for U.S. shipments of imports from India that year was *** percent; for U.S. shipments from

Taiwan, it was *** percent.  CR/PR at Table II‐1.

81 Original Determinations, USITC Pub. 3518 at 8.

82 First Review Determinations, USITC Pub. 3994 at 12.

83 Original Determinations, USITC Pub. 3518 at 8; First Review Determinations, USITC Pub. 3994

at 12.
14

In the current reviews, subject imports from both India and Taiwan were present in all

72 months of the period of review.84  U.S. imports of PET film from both India and Taiwan

entered the country in all customs districts, competing for users without regard to geographical

location, and were sold nationwide.85  U.S.‐produced PET film was also sold nationwide

throughout the period of review.86

Conclusion.  The record indicates that U.S.‐produced PET film and subject imports from

both countries generally are fungible, are primarily shipped through the same channels of

distribution, and were simultaneously present in overlapping geographic markets in the United

States during the period of review.  No party argues that a reasonable overlap of competition is

not likely.  We consequently find that there likely would be a reasonable overlap in competition

between subject imports from each country and the domestic like product as well as between

subject imports from each country should the orders be revoked.

D. Likely Conditions of Competition

In determining whether to exercise our discretion to cumulate the subject imports, we

assess whether subject imports from India and Taiwan would compete under similar or

different conditions in the U.S. market if the orders were revoked.

The record in these reviews does not indicate that there would likely be any significant

difference in the conditions of competition between subject imports from India and Taiwan if

the orders were revoked.  Accordingly, we exercise our discretion to cumulate subject imports

from India and Taiwan.

IV. Legal Standards

In a five‐year review conducted under section 751(c) of the Tariff 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.”87  

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 proceeding and the

elimination of its restraining effects on volumes and prices of imports.”88  Thus, the likelihood

                                                      

84 CR/PR at Table I‐1, CR at IV‐8, PR at IV‐5.

85 CR at IV‐8 – IV‐9, PR at IV‐5 – IV‐6, CR/PR at Tables II‐2 & IV‐5.

86 CR/PR at Table II‐2.

87 19 U.S.C. § 1675a(a).

88 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.
15

standard is prospective in nature.89  The CIT 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.90  

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.”91  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.”92

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

original 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.”93  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 a suspension agreement is terminated, and any findings by

Commerce regarding duty absorption pursuant to 19 U.S.C. § 1675(a)(4).94  The statute further

                                                      

89 While 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.

90 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, 26 CIT 1059, 1070

(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’”).

91 19 U.S.C. § 1675a(a)(5).

92 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. 93 19 U.S.C. § 1675a(a)(1).

94 19 U.S.C. § 1675a(a)(1). No duty absorption findings have been made for any of the subject

countries.  CR at I‐13 n.24, PR at I‐11 n.24.
16

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.95

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

review are revoked and/or a suspended investigation is 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.96  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.97

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

revoked and/or a suspended investigation is terminated, 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.98

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

review are revoked and/or a suspended investigation is terminated, 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.99  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

                                                      

95 19 U.S.C. § 1675a(a)(5).  Although the Commission must consider all factors, no one factor is

necessarily dispositive.  SAA at 886.

96 19 U.S.C. § 1675a(a)(2).

97 19 U.S.C. § 1675a(a)(2)(A‐D).

98 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.

99 19 U.S.C. § 1675a(a)(4).
17

which any improvement in the state of the domestic industry is related to the orders under

review and whether the industry is vulnerable to material injury upon revocation.100

V. Findings from the Original Investigations and Prior Reviews

A. Conditions of Competition

Original Investigations:  In the original investigations, the Commission found that the

demand for PET film could be divided into five broad market segments (packaging, industrial,

magnetics, electrical, and imaging) and that the domestic product had a substantial presence in

all segments.  Overall demand for PET film was growing until 2000 or 2001, when it experienced

a slowdown. 101

There was one significant new entrant into the U.S. market during the original period of

investigation:  SKCA, owned by Korean producer SKC.102  Nonsubject imports were a substantial

source of supply to the U.S. market throughout the period of investigation, albeit at declining

levels, and U.S. producers imported the majority of nonsubject imports during the period.103

The Commission also found that there was at least a moderate degree of substitutability

among domestically produced PET film and the subject imports.  The subject imports competed

primarily in the industrial and packaging segments of the market, which together accounted for

over 60 percent of 2001 consumption.  However, subject imports were present in the electrical

and imaging segments as well.104

The Commission also found that PET film production is capital intensive and that in

order to recover the high fixed costs involved, producers must achieve and sustain high rates of

capacity utilization.  The domestic industry underwent restructuring during the period of

investigation, and many of the firms in the domestic industry changed ownership or entered

into joint ventures with other (often foreign) producers.105   

Although the Commission found that the domestic industry captively consumed part of

its production of the domestic like product in the manufacture of downstream articles, it did

not find that it was required to focus its injury analysis primarily on the merchant market.  

Instead, it considered captive consumption to be an important condition of competition.106

                                                      

100 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.

101 Original Determinations, USITC Pub. 3518 at 11‐12.

102 Original Determinations, USITC Pub. 3518 at 11‐12.

103 Original Determinations, USITC Pub. 3518 at 12.

104 Original Determinations, USITC Pub. 3518 at 12.

105 Original Determinations, USIC Pub. 3518 at 12.

106 Original Determinations, USITC Pub. 3518 at 9‐11.
18

Lastly, the Commission found that the domestic industry had obtained relief from

unfairly traded imports in the past.  Antidumping duty orders had been imposed on imports

from Japan and Korea in 1991.  The order on PET film from Japan was revoked in 1995, and the

order on PET film from Korea remained in effect.107

First Reviews:  In the first reviews, the Commission found that overall demand for PET

film is derived from demand for its primary end use applications, which include the five market

segments discussed in the original investigations.  During the period of review, the magnetic

media and imaging market segments declined as digital media increasingly replaced the older

technologies encompassed by those two market segments.  In contrast, demand in the

packaging and industrial market segments increased, as did demand in the electrical market

segment.108

The Commission found that apparent U.S. consumption increased irregularly over the

period.  Reasons cited included growth in the U.S. economy and increased demand for transfer

thermal ribbons, packaging, and hot stamped foil.  Market participants’ predictions regarding

future demand were mixed.109

As another condition of competition, the Commission observed that commodity grade

film represented approximately 65 percent of the U.S. market and specialty grade film

represented approximately 35 percent of the market, with the latter commanding a price

premium relative to the former.  The pricing of the commodity grades was reportedly the

benchmark for the pricing of all PET film.  Producers in both subject countries sold both

commodity and specialized PET film in the U.S. market.110

The Commission also found that, as was true during the original investigations, most

U.S. production capacity was devoted to the merchant market, although a significant

percentage was captively consumed.  PET film produced for captive consumption primarily was

converted to photographic films or magnetic media.111

During the first period of review, the U.S. market was supplied by the domestic industry,

subject imports and nonsubject imports.  Subject imports maintained only a small presence in

the U.S. market after imposition of the orders.  The U.S. market share held by nonsubject

imports fluctuated, but increased overall over the period.  The volume of nonsubject imports

during the period of review may have been affected by existing antidumping duty orders or

ongoing investigations, i.e. the antidumping duty order on imports of PET film from Korea and

the affirmative preliminary determinations in November 2007 regarding imports of PET film

from Brazil, China, Thailand, and the United Arab Emirates.112

The Commission found that the domestic like product and the subject imports were

highly interchangeable.  It also found that price was an important factor in purchasing

                                                      

107 Original Determinations, USITC Pub. 3518 at 12‐13.

108 First Review Determinations, USITC Pub. 3994 at 16.

109 First Review Determinations, USITC Pub. 3994 at 17.

110 First Review Determinations, USITC Pub. 3994 at 17. 111 First Review Determinations, USITC Pub. 3994 at 18. 112 First Review Determinations, USITC Pub. 3994 at 18‐19.
19

decisions, as it was in the original investigations.  The domestic like product and the subject

imports were sold on both a contract basis and a spot sales basis.113

As in the original investigations, the Commission found the manufacture of PET film to

be capital intensive.  Thus, to remain profitable, plants must run at a relatively high capacity

utilization rate for sustained periods.114

The Commission found that the demand for and supply of PET film outside the United

States increased during the first review period, with growth in capacity outpacing growth in

demand.  Global consumption was projected to increase in the near future.115

B. Likely Volume of Subject Imports

Original Investigations:  The Commission found in the original investigations that the

volume of subject imports increased by 14.1 percent during the period.  Subject import volume

declined in the second half of 2001, after the filing of the petitions and consistent with a decline

in demand.  The Commission found the volume and increase in volume of cumulated subject

imports, both in absolute terms and relative to apparent consumption, to be significant.116

First Reviews:  In the first five‐year reviews, the Commission found that the volume and

market share of cumulated subject imports had generally declined, although there was an

increase late in the period.  Subject producers had both the incentive and the capability to

significantly increase shipments of the subject product to the United States within a reasonably

foreseeable time if the orders were revoked.  Production capacity in India and Taiwan had

increased substantially over the period.  Additionally, subject producers in both countries had

*** unused capacity that could be used to increase sales to the U.S. market if the orders were

revoked.  Given the high fixed costs associated with PET film production, the Commission found

that there was an incentive for subject producers to maximize the use of available capacity.  

Thus, subject producers had a significant incentive to increase exports to the relatively large

U.S. market if the orders were revoked.117

The Commission found that, in addition to the U.S. market, subject producers in both

countries exported substantial volumes to other countries.  Subject producers exported

substantial and increasing volumes of their PET film production during the first period of review

despite purportedly higher prices for PET film in their home markets and increasing demand in

the Indian home market.118  If the orders were revoked, the attractiveness of the relatively open

U.S. market and its generally higher prices would serve as incentives for producers in the

subject countries to direct exports to the U.S. market that were then being shipped to other

markets.  The record indicated that prices for PET film in the United States tended to be

appreciably higher than those in most other markets.  Moreover, the European Union (“EU”)

                                                      

113 First Review Determinations, USITC Pub. 3994 at 19. 114 First Review Determinations, USITC Pub. 3994 at 19.

115 First Review Determinations, USITC Pub. 3994 at 20.

116 Original Determinations, USITC Pub. 3518 at 13. 117 First Review Determinations, USITC Pub. 3994 at 20‐21.

118 First Review Determinations, USITC Pub. 3994 at 21‐22.
20

had imposed antidumping duties on subject imports from India and Taiwan, reducing to some

extent the price advantages of the EU market and providing subject producers an incentive to

direct export shipments to the U.S. market if the orders were lifted.119  The Commission

concluded that the likely cumulated volume of the subject merchandise, both in absolute terms

and relative to consumption and production in the United States, would be significant absent

the restraining effect of the orders.120

C. Likely Price Effects of Subject Imports

Original Investigations:  In the original investigations, the Commission found that the

domestically produced PET film and the subject imports were at least moderately substitutable

and that price was a significant factor in purchasing decisions.  Subject imports undersold

domestically produced PET film in 76.6 percent of the quarterly sales comparisons.  The

margins of underselling were in many cases substantial and remained substantial throughout

the period of investigation.  The Commission found the underselling to be significant.121

The Commission also found that the domestic industry experienced a substantial cost‐

price squeeze, particularly towards the end of the period.  In particular, the industry’s ratio of

cost of goods sold (“COGS”) to net sales increased steadily throughout the period.  Its costs

were driven up over the period by increases in energy and raw material prices and by the fact

that fixed costs were being spread over a shrinking level of domestic sales.  The Commission

concluded that, in light of the significant volume of subject imports, the substitutability of

subject imports and the domestic product, the significant underselling by subject imports, and

the inability of domestic producers to raise prices in the face of significant increased costs,

subject imports had a significant price suppressing effect.122  

First Reviews:  In the first five‐year reviews, the Commission found that domestically

produced and imported PET film were highly substitutable.  The general importance of price in

purchasing decisions had not changed since the time of the original investigations.  Quality and

price were reported by the greatest number of purchasers as being the most important factors

in purchasing decisions.  The Commission also found that sustained underselling by even a

relatively moderate volume of subject imports would be likely to have significant price‐

suppressing or price‐depressing effects.123

Even with the orders in place, subject imports from both countries undersold the

domestic like product in 89 out of 113 quarterly comparisons, frequently by substantial

margins.  The Commission found that there was an incentive for producers to ship to the U.S.

market because subject producers likely would be able to receive a higher price in the U.S.  

market relative to many third‐country markets, while still underselling the domestic producers

                                                      

119 First Review Determinations, USITC Pub. 3994 at 22‐23.

120 First Review Determinations, USITC Pub. 3994 at 23. 121 Original Determinations, USITC Pub. 3518 at 14. 122 Original Determinations, USITC Pub. 3518 at 15.

123 First Review Determinations, USITC Pub. 3994 at 23‐24.
21

sufficiently to gain market share.  In light of the underselling in the first reviews and the

underselling information from the original investigations, the Commission concluded that there

would likely continue to be significant price underselling if the orders were revoked.124

The Commission also found that downward price movements for domestic PET film

beginning in the second half of 2005 and continuing throughout the first review period, along

with significant underselling by the subject imports, supported a finding that price depression

existed and would likely continue if the orders were revoked.  The downward price trends,

accompanied by the significant underselling and the inability of the industry in the latter part of

the first review period to cover the increase in overall cost of goods sold and particularly raw

material costs, indicated that prices for domestic PET film had been depressed and would likely

continue to be depressed if the orders were revoked.125

Given the finding of a likely significant volume of subject imports from India and Taiwan

in the event of revocation of the orders, the importance of price in the market, the

substitutability of the domestic and subject products, the significant underselling by subject

imports during both the original investigations and the first reviews, and the declining price

trends for the domestic like product, the Commission found that if the orders were revoked,

subject imports would be likely to undersell the domestic like product significantly and would

likely have significant depressing or suppressing effects on the prices of the domestic like

product within a reasonably foreseeable time.126

D. Likely Impact of Subject Imports

Original Investigations:  In the original investigations, the Commission found that the

domestic industry’s capacity increased between 1999 and 2000, mainly due to SKC’s entry into

the market, and then declined in 2001.  However, the domestic industry’s production declined

in each year of the period of investigation, and capacity utilization declined throughout.  The

industry’s U.S. shipments and sales increased between 1999 and 2000, then declined in 2001 to

levels below those of 1999.  Although the domestic industry gained market share over the

period of investigation, this increase largely reflected that SKC’s U.S. production replaced

imports from its owner in Korea.  Inventories as a ratio to U.S. shipments declined from 1999 to

2000, before increasing in 2001.  Most employment‐related indicators declined over the period

of investigation.127

The Commission also found that the financial position of the industry deteriorated

throughout the period.  The number of domestic producers reporting operating losses rose.  

The decline in the domestic industry’s financial position was due to a cost‐price squeeze, as the

                                                      

124 First Review Determinations, USITC Pub. 3994 at 24.

125 First Review Determinations, USITC Pub. 3994 at 24‐25.

126 First Review Determinations, USITC Pub. 3994 at 25.

127 Original Determinations, USITC Pub. 3518 at 16‐17.
22

unit cost of goods increased and net sales value fell.128  The Commission concluded that subject

imports were having a significant adverse impact on the domestic industry.129

First Reviews:  In the first five‐year reviews, the Commission found that the domestic

industry had benefitted from the orders, as there was a marked improvement in its condition as

subject imports decreased.  However, after the first three years of strong performance, many of

the domestic industry’s performance and financial factors declined as shipments decreased,

raw material and energy costs rose, and sales values flattened or declined from 2005 through

2007.  Cumulated subject imports maintained only a small presence in the U.S. market after the

imposition of the orders, while nonsubject sources increased their presence during the period

of review.130

The Commission found that the domestic industry’s capacity increased from 2003 to

2005, but then declined.  Production rose steadily from 2002 to 2004, then declined as well.  

Capacity utilization, particularly critical to this capital‐intensive industry, fluctuated, increasing

from 2002 to 2004, then declining, reaching a period low in interim 2007.  The domestic

industry’s U.S. shipments showed patterns similar to those for production.  While the domestic

industry continued to account for a substantial share of apparent U.S. consumption, its share

fluctuated, declining from 2002 to 2006, but increasing thereafter.  While the number of

production and related workers declined steadily from 2002 to 2006, productivity steadily

increased, although it was lower in interim 2007 than in interim 2006.  Wages paid steadily

declined as hourly wages fluctuated, but decreased overall.131

Although the domestic industry’s net sales by quantity decreased from 2002 to 2006,

total net sales by value increased between 2002 and 2006 due to increases in the average unit

value of sales.  At the same time, the domestic industry’s operating income increased, despite

the increase in the total value of COGS.  The domestic industry’s operating income margin

increased from 2002 to 2004 before declining in 2006.  Capital expenditures decreased

irregularly from 2002 to 2006, but were higher in interim 2007 than in interim 2006.  Research

and development expenses declined throughout the first period of review.  Given the industry’s

performance since 2004, the Commission found it to be in a vulnerable or weakened state.132

The Commission also found that if the orders were revoked, subject imports might

displace some nonsubject imports, but the domestic industry would likely lose market share to

the likely high volume of aggressively priced subject imports.  At the same time, the domestic

industry’s profitability would likely decline as it would be forced to lower domestic prices to

compete with subject imports.133

                                                      

128 Original Determinations, USITC Pub. 3518 at 17.

129 Original Determinations, USITC Pub. 3518 at 18.

130 First Review Determinations, USITC Pub. 3994 at 26.

131 First Review Determinations, USITC Pub. 3994 at 27‐28.

132 First Review Determinations, USITC Pub. 3994 at 28.

133 First Review Determinations, USITC Pub. 3994 at 28.
23

In light of its volume and price findings, along with its findings on the condition of the

domestic industry, the Commission concluded that revocation of the orders would likely have a

significant adverse impact on the domestic industry.134

VI. Conditions of Competition and the Business Cycle

In evaluating the likely impact of the subject imports on the domestic industry if an

order is revoked, 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.”135  The following conditions of competition inform our determinations in

these second reviews.

A. Demand Conditions

As in the original investigations and prior reviews, the overall demand for PET film is

derived from the demand for the downstream products.136  There are five main end use

segments (packaging, industrial, electrical, imaging, and magnetics), although the magnetic end

use segment has virtually disappeared since the time of the first reviews and the imaging end

use segment is reportedly also in decline.137  Within the larger segments, there are numerous

sub‐segments, with each consisting of a particular type of PET film (defined by gauge, coatings

and other specifications) that is often produced for that particular sub‐segment and sold to

purchasers who participate primarily in that sub‐segment.138   

Apparent U.S. consumption declined during the current period of review and was at its

lowest level since the original period of investigation.  Apparent U.S. consumption fell from

749.2 million pounds in 2008 to 649.4 million pounds in 2009.  After the recession, it increased

to 726.4 million pounds in 2010 before declining to 665.5 million pounds in 2011.  It fell further

to 650.0 million pounds in 2012, then rose to 662.1 million pounds in 2013 – still lower than

pre‐recession levels.139   

Most market participants reported an increase in U.S. demand since 2008.  The majority

of U.S. producers, importers, purchasers, and foreign producers reported demand had  

increased,140 although the reporting was more mixed regarding future demand. 141  Most U.S.

producers, importers and purchasers expect that U.S. demand will increase in the future, but no

foreign producers reported this expectation.142

                                                      

134 First Review Determinations, USITC Pub. 3994 at 29.

135 19 U.S.C. § 1675a(a)(4).

136 CR at II‐14, PR at II‐7.

137 CR at I‐25 – I‐26, II‐1, II‐14, PR at I‐19 – I‐20, II‐1, II‐7.

138 CR/PR at II‐1.

139 CR/PR at Table I‐8.  In 2001, during the original investigations, apparent U.S. consumption

totaled *** pounds; during the first reviews, it was at its lowest in 2003, when it totaled *** pounds.  

CR/PR at Table I‐1.

140 CR/PR at Table II‐4.
24

As during the original investigations and the first reviews, most U.S. production capacity

is devoted to the merchant market.  Captive consumption remains substantial, although it

decreased over the current period of review.143

B. Supply Conditions

There is no indication in the record that PET film is sold differently than it was in the

original investigations and first reviews in terms of the widths, thicknesses and other properties

governing its sale.  PET film types can be classified as commodity film, semi‐specialty film and

specialty film.144  According to the domestic producers, the majority of PET film sold in the U.S.

market is commodity film.145

There were nine domestic producers during the original investigations,146 eight during

the first reviews147 and 11 during these current reviews.148  *** of the 11 domestic producers

reported that they had experienced changes in the character of their operations or organization

since 2008.  These included ***; the addition of capacity in ***; shutdowns in *** and in 2010

***; shutdowns and plant closings ***; the retirement of two assets by ***; and the halting of

production in ***.  SKC ***.149  Both PET film capacity150 and production151 decreased over the

current period of review.

During the period, the U.S. market was supplied by the domestic industry, subject

imports and nonsubject imports.  Of the three sources, the domestic industry held the largest

share of apparent U.S. consumption, as measured by quantity, but that share decreased

irregularly over the period.152  Subject import market share, which was quite small throughout

                                                                                                                                                                              

(...Continued) 141 ***.  Domestic Industry’s Prehearing Brief at 32‐33.

142 CR/PR at Table II‐4.

143 As a share of the quantity of U.S. shipments, commercial U.S. shipments increased from ***

percent in 2008 to *** percent in 2013.  Internal consumption decreased from *** percent in 2008 to

*** percent in 2013.  CR/PR at Table III‐5. 144 CR/PR at II‐1.

145 According to ***.  Domestic Industry’s Prehearing Brief at 21.

146 Original Determinations, USITC Pub. 3518 at III‐1. 147 First Review Determinations, USITC Pub. 3994 at III‐1.

148 CR/PR at III‐1.

149 CR/PR at Table III‐2.

150 Capacity was 720.1 million pounds in 2008, 702.7 million pounds in 2009, 701.0 million

pounds in 2010, 624.6 million pounds in 2011, 620.2 million pounds in 2012, and 710.0 million pounds in

2013.  CR/PR at Table III‐4.

151 Production was 620.2 million pounds in 2008, 550.7 million pounds in 2009, 602.7 million

pounds in 2010, 510.8 million pounds in 2011, 495.4 million pounds in 2012, and 543.0 million pounds in

2013.  CR/PR at Table III‐4.

152 The domestic industry’s market share was 77.7 percent in 2008, 79.6 percent in 2009, 75.3

percent in 2010, 71.8 percent in 2011, 69.9 percent in 2012, and 76.0 percent in 2013.  CR/PR at Table I‐

9.
25

the period, also decreased irregularly.153  Nonsubject import market share fluctuated during the

current period of review, but rose slightly overall.154  The largest sources of nonsubject imports

during 2008‐13 were Mexico, Korea, and the UAE.155

Most producers, but a smaller percentage of importers and purchasers, reported that

the market is subject to business cycles, with periods of high demand and tight supply followed

by capacity expansions and periods of oversupply.156  Seasonality varies between end use

markets, with some markets experiencing higher demand at the same time demand is lowest in

other markets.157  As noted above, demand peaked in 2010, which led to a shortage of PET

film.158  In response to the supply shortage, producers added capacity, which consequently led

to a situation of oversupply.159

C. Substitutability

The majority of producers, importers and purchasers reported that U.S.‐produced PET

film and subject imports were “always” or “frequently” interchangeable.160  Price remains an

important factor in purchasing decisions as well, as it is one of the top three factors that firms

consider in making these decisions.161

D. Other Conditions

As in the original investigations and first reviews, supplier certification is mandated.  All

10 responding purchasers require certification of all of the product they purchase.162  Also, as in

the original investigations and the first reviews, the manufacture of PET film is capital intensive.  

Plants must run at relatively high capacity utilization for sustained periods in order to remain

profitable.163

                                                      

153 Subject import market share was *** percent in 2008, *** percent in 2009, *** percent in

2010, *** percent in 2011, *** percent in 2012, and *** percent in 2013.  CR/PR at Table I‐9.

We note that India is subject to antidumping duties on PET film in ***.  CR at IV‐11, PR at IV‐7.

154 Nonsubject import market share was *** percent in 2008, *** percent in 2009, *** percent

in 2010, *** percent in 2011, *** percent in 2012, and *** percent in 2013.  CR/PR at Table I‐9.  The

United States imposed antidumping duty orders on imports of PET film from Brazil, China, Thailand, and

the UAE in November 2008.  CR at I‐5, PR at I‐4.

155 CR at II‐13, PR at II‐6.  In 2013, Mexico accounted for 26.4 percent of nonsubject imports,

Korea accounted for 16.1 percent and the UAE accounted for 12.5 percent.  Id. 156 CR at II‐15 – II‐16, PR at II‐8; see CR at IV‐25 – IV‐26, PR at IV‐11 – IV‐12.

157 CR at II‐15, PR at II‐8.

158 See CR at II‐16, PR at II‐8.

159 CR at IV‐25, PR at IV‐12.

160 CR at II‐28, PR at II‐15, CR/PR at Table II‐10.

161 CR at II‐20, PR at II‐11, CR/PR at Table II‐6.

162 CR at II‐23, PR at II‐12.

163 CR at I‐20, PR at I‐16.
26

Raw materials are an important consideration in the price of PET film, accounting for

between 48.3 and 60.1 percent of U.S. producers’ cost of goods sold during 2008‐13.  The basic

raw materials for producing PET film are (1) dimethyl terephthalate or purified terephthalic acid

and (2) monoethylene glycol, which come from xylene and ethylene, respectively.164  Domestic

producers reported that raw material costs are rising.165  Ethylene is usually manufactured from

natural gas, while xylene is a byproduct of oil refineries.  Thus, raw material costs are greatly

affected by crude oil and natural gas prices.  After peaking in 2008, natural gas and crude oil

prices declined greatly in 2009.  Natural gas prices have remained lower, with some

fluctuations, and were 32 percent lower in January 2014 than in January 2008.  Crude oil prices

trended upwards, increasing above their January 2008 levels by 2011, and have since fluctuated

within a narrow range.  ***, monoethylene glycol prices ***.166

VII. Revocation of the Antidumping and Countervailing Duty Orders on

Subject Imports from India and Taiwan Is Likely to Lead to the

Continuation or Recurrence of Material Injury to the Domestic Industry

within a Reasonably Foreseeable Time

A. Likely Volume of Subject Imports

As discussed above, under the discipline of the orders, there were relatively limited

volumes of U.S. shipments of subject imports during the current period of review, and they

declined over the period.167  Cumulated subject import market share, which was already low,

declined by *** over the course of the period to *** than what it was at the end of the first

reviews.168

The record indicates that subject producers have both the incentive and capability to

significantly increase shipments of subject merchandise to the U.S. market within a reasonably

foreseeable time if the orders are revoked.   Subject producers have increased capacity169 and

production170 over the period of these reviews, while capacity utilization171 has decreased

                                                      

164 CR/PR at V‐1.

165 Domestic Industry’s Prehearing Brief at 25.

166 CR/PR at V‐1.

167 Cumulated U.S. shipments of subject imports totaled *** pounds in 2008, *** pounds in

2009, *** pounds in 2010, *** pounds in 2011, *** pounds in 2012, and *** pounds in 2013.  CR/PR at

Table I‐8.

168 Cumulated subject import market share was *** percent in 2008, *** percent in 2009, ***

percent in 2010, *** percent in 2011, *** percent in 2012, and *** percent in 2013.  CR/PR at Table I‐9.  

Subject import market share was *** percent in 2006, the last year of the first review period.  CR/PR at

Table I‐1.

169 Cumulated subject import capacity totaled *** pounds in 2008, *** pounds in 2009, ***

pounds in 2010, *** pounds in 2011, and *** pounds in 2012 and 2013.  CR/PR at Table IV‐13.

170 Cumulated subject import production totaled *** pounds in 2008, *** pounds in 2009, ***

pounds in 2010, *** pounds in 2011, *** pounds in 2012 and *** pounds in 2013.  CR/PR at Table IV‐13.
27

overall.  The PET film industries in both India and Taiwan are export oriented,172 and exports

from these countries have increased overall during the period.173  Attractive prices in the U.S.

market present an incentive to ship subject product to the United States, as firms generally

reported that PET film prices in the U.S. market were higher or the same as prices in other

markets.174  The antidumping and countervailing duty orders imposed by the EU on PET film

from India, discussed above, provide the same incentive.  The United States also maintains

antidumping duty orders on imports of PET film from multiple other countries, including China,

which limits competition in the U.S. market and further increases its attractiveness compared

to other markets.

   We find that producers in the subject countries would likely direct significant

quantities of PET film to the U.S. market should the pertinent orders be revoked.  The United

States was the second largest world importer (after China) of PET film during the current review

period, accounting for 22 percent of global imports in 2013.175  The cumulated subject countries

exported substantial quantities of PET film during the period of review176 and, notwithstanding

the continuation of the orders pursuant to the first five‐year reviews, subject imports were

present in the U.S. market throughout the period, demonstrating continued interest in the U.S.

market.  This participation in the U.S. market also indicates that the subject producers have

ready access to U.S. distribution networks.   

Given the cumulated subject producers’ capacity and production increases, decreased

capacity utilization and overall export orientation, the size and relative attractiveness of the

U.S. market and the continued presence of the subject imports in the U.S. market, as well as

the orders in effect in third countries on imports of PET film from India, we conclude that

cumulated subject import volumes will likely be significant, both in absolute terms and relative

to U.S. consumption, upon revocation of the orders.177

                                                                                                                                                                              

(...Continued) 171 Cumulated subject import capacity utilization was *** percent in 2008, *** percent in 2009,

*** percent in 2010, *** percent in 2011, *** percent in 2012, and *** percent in 2013.  CR/PR at Table

IV‐13.

172 Cumulated subject exports as a share of total shipments was *** percent in 2008, ***

percent in 2009, *** percent in 2010, *** percent in 2011, *** percent in 2012, and *** percent in

2013.  CR/PR at Table IV‐13.   173 Cumulated subject exports totaled *** pounds in 2008, *** pounds in 2009, *** pounds in

2010, *** pounds in 2011, *** pounds in 2012, and *** pounds in 2013.  CR/PR at Table IV‐13. 174 CR at IV‐37, PR at IV‐20; see Domestic Industry’s Prehearing Brief, Exh. 2.

175 CR/PR at II‐1, Table IV‐15.

176 Nan Ya reported that it has ***.  CR at IV‐18, PR at IV‐10.  However, Nan Ya’s capacity ***

over the period of review.  CR/PR at Table IV‐11.  Moreover, given the large extent of the global

oversupply, the claimed ability of the Asian market to absorb Nan Ya’s likely increasing exports is not

realistic.  Global growth in capacity is expected to ***.  CR at IV‐27, PR at IV‐13. 177 We have also examined inventories in our analysis of the likely volume of subject imports.  

Reported end‐of‐period inventories of subject merchandise in India and Taiwan increased irregularly

over the period of review.  They totaled *** pounds in 2008, *** pounds in 2009, *** pounds in 2010,

*** pounds in 2011, *** pounds in 2012, and *** pounds in 2013.  CR/PR at Table IV‐13.  U.S. importers’

(Continued...)
28

B. Likely Price Effects  

As discussed above, domestically produced and imported PET film are highly

substitutable.  As in the first reviews, the majority of U.S. producers, importers and purchasers

reported that the domestic and imported products are always or frequently interchangeable.178

The general importance of price has not changed since the original investigations.  Price

remains one of the most important factors in purchasing decisions.179  As in the first reviews,

because of the high degree of interchangeability, price would likely be the principal factor

influencing purchasing decisions absent the orders, especially in the commodity portion of the

U.S. market, which is the largest.180

The Commission requested pricing data for eight PET film products.  However, price

comparisons in the current reviews are of limited probative value because of the low volume of

subject imports.  Nonetheless, the record indicates that underselling occurred in 57 of 136

quarterly comparisons despite the orders, with margins of underselling ranging from 0.1 to 69.6

percent.181

Given the underselling in these current reviews as well as the extensive underselling

during the first reviews and the original investigations, as well as our findings that the subject

imports would likely increase upon revocation, we find that significant underselling would likely

recur if the antidumping and countervailing duty orders were revoked.  Because of the

importance of price in purchasing decisions, this underselling would likely cause the domestic

industry to either reduce its prices or forgo price increases to maintain market share, especially

as commodity PET film comprises the majority of the U.S. market.182   

                                                                                                                                                                              

(...Continued)

end‐of‐period inventories from the subject countries decreased irregularly over the period.  They

totaled *** pounds in 2008, *** pounds in 2009, *** pounds in 2010, *** pounds in 2011, *** pounds

in 2012, and *** pounds in 2013.  CR/PR at Table IV‐4.    178 CR at II‐28, PR at II‐15, CR/PR at Table II‐10.

179 CR at II‐22, PR at II‐12; CR/PR at Table II‐7.

180 ***.  CR/PR at II‐1.

181 CR at V‐27, PR at V‐8; CR/PR at Table V‐12.

182 The pricing data show that domestic prices have been declining since 2011.  See

CR/PR at Tables V‐3 – V‐8.  The likely increased subject imports would likely exacerbate these

unfavorable trends, as well as the increasingly unfavorable ratio of COGS to net sales evident in

the latter part of the current period of review.  This ratio was 90.1 percent in 2008, 88.5

percent in 2009, 82.2 percent in 2010, 84.0 percent in 2011, 89.3 percent in 2012, and 91.2

percent in 2013.  CR/PR at Table III‐10.
29

C. Likely Impact183 184

Over the current period of review, most indicators of the domestic industry’s condition

declined, even after the recession ended in 2009.  Capacity decreased steadily.185  While

production fluctuated, it decreased overall.186  Capacity utilization also fluctuated, but

decreased by approximately 10 percentage points over the period of review.187  Shipments

                                                      

183 Under the statute, “the Commission may consider the magnitude of the margin of dumping”

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 a five‐year review 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.  Commerce expedited its determinations in its

reviews and made affirmative determinations.  With regard to the antidumping duty review on subject

imports from India, Commerce found likely dumping margins of 24.10 percent for Ester Industries, Ltd.;

3.02 percent for Polyplex Corporation Ltd.; and 13.17 percent for all others.  With regard to the

antidumping duty review on subject imports from Taiwan, Commerce found likely dumping margins of

8.99 percent for Nan Ya Plastics Corporation, Ltd.; 0.75 percent for Shinkong Synthetic Fibers

Corporation; and 4.37 percent for all others.  79 Fed. Reg. 12153, 12154 (Mar. 4, 2014).

With regard to the countervailing duty review on subject imports from India, Commerce found

likely subsidy rates of 27.37 percent for Ester Industries, Ltd.; 33.42 percent for Garware Polyester Ltd,;  

22.69 percent for Polyplex Corporation Ltd.; and 29.34 percent for all others.  78 Fed. Reg. 47276, 47277

(Aug. 5, 2013).

184 In addition, the statute provides that “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.”  19 U.S.C. § 1675a(6).  

In its unpublished Issues and Decision Memorandum issued in the review of the countervailing duty

order with respect to India, Commerce found that six programs fall within the definition of an export

subsidy under Article 3.1 of the WTO Subsidies Agreement:  (1) Pre‐Shipment and Post‐Shipment Export

Financing; (2) Duty Entitlement Passbook Scheme; (3) Duty Free Replenishment Scheme; (4) Export

Promotion of Capital Goods Scheme; (5) Advance License Program; and (6) Export Oriented Units.  

Commerce also found that it had insufficient information to determine whether the following four

programs fell within the meaning of Article 6.1 of the WTO Subsidies Agreement:  (1) State Sales Tax

Incentive Programs; (2) SOM Capital Incentive Scheme; (3) Waiving of Interest on Loan by SICOM

Limited; and (4) SOM Electricity Duty Exemption Scheme.  Issues and Decision Memorandum for the

Final Results of the Expedited Second Sunset Review of the Countervailing Duty Order on Polyethylene

Terephthalate (PET) Film, Sheet, and Strip from India (July 30, 2013).   185 Capacity totaled 720.1 million pounds in 2008, 702.7 million pounds in 2009, 701.0 million

pounds in 2010, 624.6 million pounds in 2011, 620.2 million pounds in 2012, and 710.0 million pounds in

2013.  CR/PR at Table III‐4.

186 Production totaled 620.2 million pounds in 2008, 550.7 million pounds in 2009, 602.7 million

pounds in 2010, 510.8 million pounds in 2011, 495.4 million pounds in 2012, and 543.0 million pounds in

2013.  CR/PR at Table III‐4.   187 Average capacity utilization was 86.1 percent in 2008, 78.4 percent in 2009, 86.0 percent in

2010, 81.8 percent in 2011, 79.9 percent in 2012, and 76.5 percent in 2013.  CR/PR at Table III‐4.
30

decreased over the period.188  Inventories relative to total shipments fluctuated somewhat, but

remained fairly steady over the period.189  The domestic industry’s market share fluctuated over

the period, but was approximately the same in 2013 as it was in 2008.190

Employment indicators declined overall during the period of review.  The number of

production and related workers decreased,191 as did the hours they worked192 and the wages

they were paid.193  Their productivity also declined.194

The domestic industry’s net sales, as measured by quantity, fluctuated, although they

decreased overall.195  Operating losses were sustained in 2008 and 2009, as well as in 2013.196  

The operating income margin followed the same trend.197  COGS fluctuated, but decreased

overall.198  Capital expenditures increased substantially,199 as two plants began operations in

                                                      

188 Total U.S. shipments were 582.0 million pounds in 2008, 516.7 million pounds in 2009, 547.1

million pounds in 2010, 478.0 million pounds in 2011, 454.6 million pounds in 2012, and 503.4 million

pounds in 2013.  CR/PR at Table III‐5.

189 Inventories relative to total shipments were 9.8 percent in 2008, 10.4 percent in 2009, 10.3

percent in 2010, 9.7 percent in 2011, 10.7 percent in 2012, and 9.3 percent in 2013.  CR/PR at Table III‐6.

190 U.S. producers’ share of the quantity of apparent U.S.  consumption was 77.7 percent in

2008, 79.6 percent in 2009, 75.3 percent in 2010, 71.8 percent in 2011, 69.9 percent in 2012, and 76.0

percent in 2013.  CR/PR at Table I‐9.

191 The number of production and related workers totaled 2,196 in 2008, 2,020 in 2009, 2,017 in

2010, 1,857 in 2011, 1,837 in 2012, and 1,935 in 2013.  CR/PR at Table III‐9.

192 Total hours worked totaled 4.4 million in 2008, 4.0 million in 2009, 4.0 million in 2010, 3.7

million in 2011, 3.8 million in 2012, and 3.9 million in 2013.  CR/PR at Table III‐9.

193 Wages paid totaled $149.4 million in 2008, $138.3 million in 2009, $134.1 million in 2010,

$133.9 million in 2011, $136.4 million in 2012, and $141.6 million in 2013.  CR/PR at Table III‐9.

194 Productivity, as measured by pounds per hour, totaled 142.1 in 2008, 138.5 in 2009, 151.3 in

2010, 136.7 in 2011, 131.9 in 2012, and 138.1 in 2013.  CR/PR at Table III‐9.

195 Total net sales were 614.7 million pounds in 2008, 545.2 million pounds in 2009, 592.1

million pounds in 2010, 517.4 million pounds in 2011, 489.5 million pounds in 2012, and 508.8 million

pounds in 2013.  CR/PR at Table III‐10.

196 Operating losses totaled $11.2 million in 2008, $1.3 million in 2009, and $6.7 million in 2013,

and operating income totaled $95.6 million in 2010, $90.8 million in 2011, and $19.8 million in 2012.  

CR/PR at Table III‐10.

197 The operating income margin was negative 1.0 percent in 2008, negative 0.1 percent in 2009,

8.3 percent in 2010, 7.6 percent in 2011, 1.9 percent in 2012, and negative 0.6 percent in 2013.  CR/PR

at Table III‐10.

198 Total COGS was $1.1 billion in 2008, $878.5 million in 2009, $951.4 million in 2010, $1.0

billion in 2011, $945.2 million in 2012, and $942.2 million in 2013.  CR/PR at Table III‐10.

199 Capital expenditures totaled $123.4 million in 2008, $40.3 million in 2009, $35.9 million in

2010, $59.0 million in 2011, $134.1 million in 2012, and $212.9 million in 2013.  CR/PR at Table III‐13.
31

2013.  Average research and development expenses also increased over the period.200  In view

of the foregoing, we find that the domestic industry is in a vulnerable condition.   

We have found above that the likely additional volumes of subject imports would likely

be priced in a manner that would undersell the domestic like product.  Consequently, the

domestic industry would need to respond either by forgoing sales and ceding market share or

by lowering or restraining its prices.  Under either circumstance, the domestic industry’s

revenues and financial performance would likely decline, resulting from declines in the

domestic industry’s production, shipments, market share, and employment or from lower

revenues.

We have also considered the role of nonsubject imports in the U.S. market.  The volume

of nonsubject imports fluctuated throughout the current period of review, but was not much

higher in 2013 than in 2008.201  Although nonsubject market share increased by approximately

*** percentage points between 2010 and 2012, the domestic industry recovered that increase

in 2013.202   We have found above that the volume of subject imports would likely be significant

upon revocation of the orders and that the subject producers are export oriented.  Under these

circumstances, we find that the domestic industry would more likely lose market share to the

likely high volume of aggressively priced subject imports than to nonsubject imports.  Further,

the domestic industry’s profitability would likely decline as it is forced to lower its prices to

compete with the increased volumes of lower‐priced subject imports.

Accordingly, in light of the likely significant volumes and likely adverse price effects, we

find that revocation of the antidumping and countervailing duty orders under review would

likely have a significant adverse impact on the domestic industry.

VIII. Conclusion

For the foregoing reasons, we determine that revocation of the countervailing duty

order on PET film from India and the antidumping duty orders on PET film from India and

Taiwan would be likely to lead to continuation or recurrence of material injury to an industry in

the United States within a reasonably foreseeable time.

                                                      

200 Average research and development expenses totaled $13.6 million in 2008, $12.6 million in

2009, $13.3 million in 2010, $15.1 million in 2011, $15.7 million in 2012, and $15.0 million in 2013.  

CR/PR at Table III‐13.

201 Shipments of nonsubject imports totaled *** million pounds in 2008, *** pounds in 2009,

*** pounds in 2010, *** pounds in 2011, *** pounds in 2012, and *** pounds in 2013.  CR/PR at Table

I‐8.

202 See CR/PR at Table I‐9.

I‐1

PART I: INTRODUCTION

BACKGROUND

On April 1, 2013, 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 reviews to determine whether revocation of the countervailing duty order on

polyethylene terephthalate film, sheet, and strip (“PET film”) from India and the antidumping

duty orders on PET film from India and Taiwan would likely lead to the continuation or

recurrence of material injury to a domestic industry.2 3 On July 5, 2013, the Commission

determined that it would conduct full reviews pursuant to section 751(c)(5) of the Act.4 The

following tabulation presents information relating to the background and schedule of this

proceeding:5  

                                                            

1 19 U.S.C. 1675(c). 2 Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan: Institution of Five‐Year

Reviews, 78 FR 19524, April 1, 2013. All interested parties were requested to respond to this notice by

submitting the information requested by the Commission.

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 reviews of the subject antidumping and countervailing duty

orders concurrently with the Commission’s notice of institution. Initiation of Five‐Year (“Sunset”)

Review, 78 FR 19647, April 2, 2013. 4

Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan: Notice of Commission

Determinations To Conduct Full Five‐Year Reviews, 78 FR 42105, July 15, 2013.  The Commission found

the domestic interested party group response to its notice of institution to be adequate and that the

respondent interested party group response with respect to Taiwan was adequate and decided to

conduct a full review with respect to the antidumping duty order concerning PET film from Taiwan.  The

Commission found that the respondent interested party group response with respect to the reviews on

the orders on PET film from India was inadequate.  However, the Commission determined to conduct

full reviews concerning the antidumping and countervailing duty orders on PET film from India to

promote administrative efficiency in light of its decision to conduct a full review with respect to the

order on PET film from Taiwan.   5 The Commission’s notice of institution, notice to conduct full reviews, scheduling notice, and

statement on adequacy are referenced 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 expedited or full

reviews may also be found at the web site.  
I‐2

Effective date Action

May 8, 2008

Commerce’s countervailing/antidumping duty orders on PET Film from India

and Taiwan (73 FR 26079 and 26080, May 8, 2008

April 1, 2013 Commission’s institution of five‐year reviews (78 FR 19524, April 1, 2013)

April 1, 2013 Commerce’s initiation of five‐year reviews (78 FR 19647, April 2, 2013)

July 5, 2013

Commission’s determinations to conduct full five‐year reviews (78 FR 42105,

July 15, 2013)

March 4, 2014

Commerce’s final results of full five‐year reviews of the antidumping duty

orders (79 FR 12153, March 4, 2013)

January 6, 2014 Commission’s scheduling of the reviews (79 FR 2883, January 16, 2014)

May 14, 2014  

Commission’s hearing cancelled by request of Domestic Interested Parties

(79 FR 28949, May 20, 2014)

June 27, 2014 Commission’s vote

July 16, 2014 Commission’s determination(s) and views

The original investigations

The original investigations resulted from petitions filed by DuPont Teijin Films (“DuPont

Teijin”), Wilmington, DE;  Mitsubishi Polyester Film of America, (“Mitsubishi”), Greer, SC;  and

Toray Plastics (America), Inc. (“Toray”), North Kensington, RI, on May 17, 2001, alleging that an

industry in the United States is materially injured and threatened with material injury by reason

of subsidized imports of PET film from India and less‐than‐fair‐value (“LTFV”) imports of PET

film from India and Taiwan. Following notification of a final determination by Commerce that

imports of PET film from India were being subsidized and that imports of PET film from India

and Taiwan were being sold at LTFV, the Commission determined in June 2002 that a domestic

industry was materially injured by reason of subsidized imports of PET film from India and LTFV

imports of PET film from India and Taiwan.6

  Commerce published the countervailing duty order

on subject imports of PET film from India on July 1, 2002.7 Commerce published the

antidumping duty orders on PET film from India on May 16, 2002 and on Taiwan on May 20,

2002.8

  

                                                            

6 Polyethylene Terephthalate Film, Sheet, and Strip from India and Taiwan, Inv. Nos. 701‐TA‐415 and

731‐TA‐933 and 934 (Final), USITC Publication 3518 (June 2002). USITC Determination, 67 FR 43340,

June 27, 2002. 7 Notice of Countervailing Duty Order:  Polyethylene Terephthalate Film, Sheet, and Strip (PET Film)

from India, 67 FR 44179, July 1, 2002.   8 Notice of Final Determination of Sales at Less Than Fair Value:  Polyethylene Terephthalate Film,

Sheet, and Strip (PET Film) from India, 67 FR 34899, May 16, 2002, as amended by 67 FR 44175, July 1,

2002.  Notice of Final Determination of Sales at Less Than Fair Value:  Polyethylene Terephthalate Film,

Sheet, and Strip (PET Film) from Taiwan, 67 FR 35474, May 20, 2002, as amended by 67 FR 44174, July 1,

2002.
I‐3

Subsequent five‐year reviews

  

In April 2008, the Commission completed full five‐year reviews of the subject orders and

determined that revocation of the countervailing duty order on PET film from India and the

antidumping duty orders on PET film from India and Taiwan would be likely to lead to

continuation or recurrence of material injury to an industry in the United States within a

reasonably foreseeable time.9 Following affirmative determinations in the first five‐year

reviews by Commerce and the Commission,10 Commerce issued a continuation of the

countervailing duty order on imports of PET film from India, effective May 8, 2008, and

antidumping duty orders on PET film from India and Taiwan, effective May 8, 2008.11

RELATED INVESTIGATIONS  

In 1990, the U.S. PET film industry filed for relief from alleged LTFV imports of PET film

from Korea, Japan, and Taiwan.12  The Commission made a negative determination with respect

to Taiwan in the preliminary investigations.13  The Commission published its affirmative final

determinations on imports of PET film from Japan and Korea in May 1991.14  Antidumping duty

orders covering imports of PET film from Japan and Korea15 were issued in 1991.  Commerce

revoked the order on PET film form Japan in 1995, after concluding that requirements for

revocation based on changed circumstances (i.e., the order no longer was of interest to

interested parties) were met.16

On July 1, 1999, Commerce initiated a five‐year “sunset” review of the antidumping duty

order on PET film from Korea.  Commerce subsequently determined that dumping would likely

                                                            

9 Polyethylene Terephthalate Film, Sheet, and Strip from India and Taiwan, Inv. Nos. 701‐TA‐415 and

731‐TA‐933 and 934 (Review), USITC Publication 3994 (April 2008).

10 Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan:  Determinations, 73 FR

25030, May 6, 2008; Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan:  Final

Results of the Expedited Sunset Reviews of the Antidumping Duty Orders, 72 FR 57297; and Final Results

of Expedited Five‐Year (Sunset) Review of the Countervailing Duty Order, 72 FR 57300, October 9, 2007.   11 Continuation of Countervailing Duty Orders on Polyethylene Terephthalate Film, Sheet, and Strip

from India, 73 FR 26080, May 8, 2008; Continuation of Antidumping Duty Orders on Polyethylene

Terephthalate Film, Sheet, and Strip from India and Taiwan, 73 FR 26079, May 8, 2008. 12 DuPont, Hoechst, and ICI were the petitioners.

13 Polyethylene Terephthalate Film, Sheet, and Strip from Japan, the Republic of Korea, and Taiwan,

Invs. Nos. 731‐TA‐458 through 460 (Preliminary), USITC Publication 2292, June 1990. 14 Polyethylene Terephthalate Film, Sheet, and Strip from Japan and the Republic of Korea, Invs. Nos.

731‐TA‐458 and 459 (Final), USITC Publication 2383, May 1991.

15 After conducting administrative reviews, Commerce revoked the antidumping duty order with

respect to product produced/exported by Korean firms Saehan (formerly Cheil Synthetics, Inc.), Kolon

Industries, and H.S. Industries (61 FR 35177, July 5, 1996, 61 FR 58374, November 14, 1996, and 66 FR

5717, November 15, 2001, respectively).

16 60 FR 52366, October 6, 1995.
I‐4

continue or recur if the order were revoked and the Commission determined that revocation of

the order would be likely to lead to continuation or recurrence of material injury to an industry

in the United states within a reasonably foreseeable time.17  As a result, Commerce continued

the order on PET film from Korea effective March 7, 2000.18  In 2005, pursuant to expedited

second reviews conducted by Commerce and the Commission, the order on PET film from

Korea was again continued, effective October 20, 2005.19  In 2011, pursuant to full third reviews

conducted by Commerce and the Commission, the order on PET film from Korea was revoked,

effective October 20, 2010.20

On September 28, 2007, the U.S. PET film industry filed for relief from alleged LTFV

imports of PET film from Brazil, China, Thailand, and the United Arab Emirates (“UAE”).21  The

Commission published its affirmative determinations of injury by reason of imports of PET film

from Brazil, China, Thailand, and the UAE and Commerce published its antidumping duty orders

in November 2008.22

SUMMARY DATA

Table I‐1 presents a summary of data from the original investigations and the current

full five‐year reviews.  

                                                            

17 See Polyethylene Terephthalate Film from Korea, Inv. No. 31‐TA‐459 (Review), USITC Publication

3278, February 2000.

18 65 FR 11984.

19 See Polyethylene Terephthalate Film from Korea, Inv. No. 31‐TA‐459 (Second Review), USITC

Publication 3800, September 2005, and 70 FR 61118, October 20, 2005.

20 See Polyethylene Terephthalate Film from Korea, Inv. No. 31‐TA‐459 (Third Review), USITC

Publication 4254, August 2011, and 76 FR 54791, September 2, 2011.  Polyethylene Terephthalate Film,

Sheet, and Strip from the Republic of Korea:  Revocation of Antidumping Duty Order, 76 FR September

16, 2011.

21 DuPont Teijin, Mitsubishi, and Toray were the petitioners. 22 See Polyethylene Terephthalate Film, Sheet, and Strip from Brazil, China, Thailand, and the United

Arab Emirates, USITC Publication 4040, October 2008, and 73 FR 66056, November 6, 2008.  

Polyethylene Terephthalate Film, Sheet, and Strip from Brazil, China, Thailand, and the United Arab

Emirates:  Antidumping Duty Orders and Amended Final Determination of Sales at Less Than Fair Value

for the United Arab Emirates, 73 FR 66595, November 10, 2008.    
I‐5

Table I-1 

PET film: Comparative data from the original investigations, first reviews, and current reviews, 

1999-2001, 2002-06, and 2008-13 

Item 

Original investigations First review 

1999 2000 2001 2002 2003 2004 2005 2006 

 Quantity (1,000 pounds) 

U.S. consumption quantity *** *** *** *** *** *** *** ***

 Share of quantity (percent) 

Share of U.S. consumption: 

 U.S. producers' share *** *** *** *** *** *** *** ***

U.S. importers' share: 

 India *** *** *** *** *** *** *** ***

Taiwan *** *** *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** *** *** ***

All other sources *** *** *** *** *** *** *** ***

Total imports *** *** *** *** *** *** *** ***

 Value (1,000 dollars) 

U.S. consumption *** *** *** *** *** *** *** ***

 Share of value (percent) 

Share of U.S. consumption: 

 U.S. producers' share *** *** *** *** *** *** *** ***

U.S. importers' share: 

 India *** *** *** *** *** *** *** ***

Taiwan *** *** *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** *** *** ***

All other sources *** *** *** *** *** *** *** ***

Total imports *** *** *** *** *** *** *** ***

 Quantity (1,000 pounds); Value (1,000 dollars); and Unit Value (dollars per pound) 

Shipments of U.S. imports from 

 India 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

 Taiwan 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

 Subject sources: 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

 Nonsubject sources: 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

 All countries: 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

 Table continued on next page. 
I‐6

Table I-1--Continued

PET film: Comparative data from the original investigations, first reviews, and current reviews, 

1999-2001, 2002-06, and 2008-13 

Item 

Second Reviews

2008 2009 2010 2011 2012 2013

 Quantity (1,000 pounds)

U.S. consumption quantity 749,184 649,422 726,370 665,488 649,954 662,050

 Share of quantity (percent) 

Share of U.S. consumption: 

 U.S. producers' share 77.7 79.6 75.3 71.8 69.9 76.0

U.S. importers' share: 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total imports 22.3 20.4 24.7 28.2 30.1 24.0

 Value (1,000 dollars)

U.S. consumption 1,386,701 1,124,771 1,348,009 1,437,022 1,243,991 1,207,212

 Share of quantity (percent) 

Share of U.S. consumption: 

 U.S. producers' share 79.6 83.1 77.6 73.2 75.8 79.8

U.S. importers' share: 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total imports 20.4 16.9 22.4 26.8 24.2 20.2

 Quantity (1,000 pounds); Value (1,000 dollars); and Unit Value (dollars per pound)

Shipments of U.S. imports from 

 India 

 Quantity *** *** *** *** *** ***

Value *** *** *** *** *** ***

Unit value *** *** *** *** *** ***

 Taiwan 

 Quantity *** *** *** *** *** ***

Value *** *** *** *** *** ***

Unit value *** *** *** *** *** ***

 Subject sources: 

 Quantity *** *** *** *** *** ***

Value *** *** *** *** *** ***

Unit value *** *** *** *** *** ***

 Nonsubject sources: 

 Quantity *** *** *** *** *** ***

Value *** *** *** *** *** ***

Unit value *** *** *** *** *** ***

 All countries: 

 Quantity 167,216 132,744 179,241 187,480 195,397 158,687

Value 282,423 190,378 302,553 384,737 301,599 243,696

Unit value $1.69 $1.43 $1.69 $2.05 $1.54 $1.54

 Table continued on next page. 
I‐7

Table I-1--Continued

PET film: Comparative data from the original investigations, first reviews, and current reviews, 

1999-2001, 2002-06, and 2008-13 

Item 

Original investigations First review 

1999 2000 2001 2002 2003 2004 2005 2006

 

Quantity (1,000 pounds); Value (1,000 dollars); and Unit Value (dollars per 

pound) 

U.S. industry: 

 Capacity (quantity) *** *** *** *** *** *** *** ***

Production (quantity) *** *** *** *** *** *** *** ***

Capacity utilization (percent) *** *** *** *** *** *** *** ***

U.S. shipments: 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

Ending inventory *** *** *** *** *** *** *** ***

Inventories/total shipments *** *** *** *** *** *** *** ***

Production workers *** *** *** *** *** *** *** ***

Hours worked (1,000) *** *** *** *** *** *** *** ***

Wages paid (1,000 dollars) *** *** *** *** *** *** *** ***

Hourly wages *** *** *** *** *** *** *** ***

Productivity (pounds per hour) *** *** *** *** *** *** *** ***

Financial data: 

 Net sales: 

 Quantity *** *** *** *** *** *** *** ***

Value *** *** *** *** *** *** *** ***

Unit value *** *** *** *** *** *** *** ***

Cost of goods sold (COGS) *** *** *** *** *** *** *** ***

Gross profit or (loss) *** *** *** *** *** *** *** ***

SG&A expense *** *** *** *** *** *** *** ***

Operating income or (loss) *** *** *** *** *** *** *** ***

Unit COGS *** *** *** *** *** *** *** ***

Unit operating income *** *** *** *** *** *** *** ***

COGS/ Sales (percent) *** *** *** *** *** *** *** ***

Operating income or (loss)/ 

 sales (percent) *** *** *** *** *** *** *** ***

 Table continued on next page. 
I‐8

Table I-1--Continued

PET film: Comparative data from the original investigations, first reviews, and current reviews, 

1999-2001, 2002-06, and 2008-13 

Item 

Second Reviews 

2008 2009 2010 2011 2012 2013

 

Quantity (1,000 pounds); Value (1,000 dollars); and Unit Value (dollars per 

pound) 

U.S. industry: 

 Capacity (quantity) 720,103 702,692 700,955 624,565 620,209 710,024

Production (quantity) 620,246 550,720 602,656 510,811 495,378 543,023

Capacity utilization (percent) 86.1 78.4 86.0 81.8 79.9 76.5

U.S. shipments: 

 Quantity 581,968 516,678 547,129 478,008 454,557 503,363

Value 1,104,278 934,393 1,045,456 1,052,285 942,392 963,516

Unit value 1.90 1.81 1.91 2.20 2.07 1.91

Ending inventory 60,547 56,657 61,019 50,201 52,158 49,840

Inventories/total shipments 9.8 10.4 10.3 9.7 10.7 9.3

Production workers 2,196 2,020 2,017 1,857 1,837 1,935

Hours worked (1,000) 4,366 3,977 3,982 3,736 3,756 3,933

Wages paid (1,000 dollars) 149,435 138,342 134,079 133,884 136,416 141,613

Hourly wages 34.23 34.79 33.67 35.84 36.32 36.01

Productivity (pounds per hour) 142.1 138.5 151.3 136.7 131.9 138.1

Financial data: 

 Net sales: 

 Quantity 614,691 545,179 592,062 517,366 489,458 508,794

Value 1,168,465 992,837 1,156,872 1,191,841 1,058,192 1,033,019

Unit value $1.90 $1.82 $1.95 $2.30 $2.16 $2.03

Cost of goods sold (COGS) 1,052,922 878,505 951,407 1,000,633 945,200 942,182

Gross profit or (loss) 115,543 114,332 205,465 191,208 112,992 90,837

SG&A expense 126,771 115,666 109,823 100,454 93,183 97,543

Operating income or (loss) (11,228) (1,334) 95,642 90,754 19,809 (6,706)

Unit COGS $1.71 $1.61 $1.61 $1.93 $1.93 $1.85

Unit operating income $(0.02) $(0.00) $0.16 $0.18 $0.04 $(0.01)

COGS/ Sales (percent) 90.1 88.5 82.2 84.0 89.3 91.2

Operating income or (loss)/sales 

 (percent) (1.0) (0.1) 8.3 7.6 1.9 (0.6)

Note:--Data for India and from all other countries in the original investigations (1999-01), and from all other countries 

with the exception of Brazil in the first five-year reviews (2002-06), are adjusted official import statistics rather than 

questionnaire shipments of imports data. All data for these current second five-year reviews were compiled from data 

submitted in response to Commission questionnaires and are shipments of imports data. 

Source: Compiled primarily from data submitted in response to Commission questionnaires in the original 

investigations and in the first five-year reviews and from adjusted official Commerce statistics (Canada, Mexico, and 

Oman excluded); Compiled from data submitted in response to Commission questionnaires for these current fiveyear reviews. 
I‐9

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.
I‐10

(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‐‐ 

(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 report

Information obtained during the course of the reviews that relates to the statutory

criteria is presented throughout this report. A summary of trade and financial data for PET film

as collected in the reviews is presented in appendix C.  U.S. industry data are based on the

questionnaire responses of 11 U.S. producers of PET film that are believed to have accounted

for 100 percent of domestic production of PET film in 2013. U.S. import data and related

information are based on the questionnaire responses of 21 U.S. importers of PET film that are

believed to have accounted for 93.8 percent of the value of total subject U.S. imports from

India and 61.4 percent of the value of total subject imports from Taiwan as reported in official

import statistics of the Department of Commerce during 2008‐13. Foreign industry data and

related information are based on the questionnaire responses of three producers of PET film.  
I‐11

One producer in India that accounted for an estimated *** percent of total capacity in India

and two producers in Taiwan that accounted for an estimated *** percent of total capacity in

Taiwan submitted questionnaire responses.23 Responses by U.S. producers, importers,

purchasers, and foreign producers of PET film to a series of questions concerning the

significance of the existing antidumping and countervailing duty orders and the likely effects of

revocation of such orders are presented in appendix D.  

COMMERCE’S REVIEWS

Administrative reviews24

Commerce has completed five administrative reviews of the outstanding countervailing

duty orders on PET film from India. Commerce has completed four administrative reviews of

the outstanding antidumping duty order on PET film from India and four administrative reviews

of the outstanding antidumping duty order on PET film from Taiwan.25 The results of the

administrative reviews are shown in tables I‐2a; I‐2b; and I‐2c.

Table I-2a 

PET film: Administrative reviews of the countervailing duty order for India 

Date results 

published 

Period of review Producer or exporter Margin (percent) 

73 FR 15135, 

March 21, 2008 

January 1, 2005-

December 31, 2005 

MTZ Polyfilms Ltd. 31.25

73 FR 75672, 

December 12, 2008 

January 1, 2006-

December 31, 2006 

MTZ Polyfilms Ltd. 65.59

75 FR 6634, 

February 10, 2010 

January 1, 2007-

December 31, 2007 

Jindal Poly Films 

Limited of India 

7.17

76 FR 76948, 

December 9, 2011 

January 1, 2009-

December 31, 2009 

Ester Industries Ltd. 11.81

79 FR 11412, 

February 28, 2014 

January 1, 2011-

December 31, 2011 

SRF 2.64

Source: Cited Federal Register notices. 

                                                            

23 Reported foreign producer 2013 production quantities as a percentage of 2012 Indian PET film

capacity (no production data for India for 2012) and 2012 Taiwan PET film production as reported in

***.  

24 Commerce has issued no duty absorption findings with respect to product from the subject

countries.   25 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‐12

Table I-2b 

PET film: Administrative reviews of the antidumping duty order for India 

Date results 

published 

Period of review Producer or exporter Margin (percent) 

73 FR 7252, 

February 7, 2008 

July 1, 2005- 

June 30, 2006 

MTZ Polyfilms Ltd. 0.00

76 FR 76943, 

December 9, 2011 

July 1, 2009- 

June 30, 2010 

Ester Industries Ltd. 6.81

78 FR 9670, 

February 11, 2013 

July 1, 2010- 

June 30, 2011 

SRF Limited 

Polyplex 

Jindal 

0.00

0.00

0.00

79 FR 11406, 

February 28, 2014 

July 1, 2011- 

June 30, 2012 

SRF 

Polyplex 

Jindal 

0.78

0.78

0.00

Source: Cited Federal Register notices. 

Table I-2c 

PET film: Administrative reviews of the antidumping duty order for Taiwan 

Date results 

published 

Period of review Producer or exporter Margin (percent) 

76 FR 9745, 

February 22 2011; 

76 FR 18519, 

April 4, 20111 

July 1, 2008- 

June 30, 2009 

Nan Ya 

Shinkong 

18.30

6.38

76 FR 76941, 

December 9, 2011 

July 1, 2009- 

June 30, 2010 

Nan Ya 

Shinkong 

74.34

6.98

78 FR 9668, 

February 11, 2013 

July 1, 2010- 

June 30, 2011 

Nan Ya 

Shinkong 

8.99

0.75

79 FR 11408, 

February 28, 2014 

July 1, 2011- 

June 30, 2012 

Shinkong 4.48

 1 76 FR 9745, Februrary 22, 2011 established rates of 20.76 for Nan Ya and 6.38 for Shinkong. 76 FR 18519, 

April 4, 2011, amended the rate for Nan Ya to 18.30 percent. 

 

Source: Cited Federal Register notices. 

New shipper reviews

Commerce has conducted one new shipper review with respect to PET film from India.  

On December 24, 2009, Commerce received timely requests for AD and CVD new shipper

reviews from SRF Limited (“SRF”), a producer and exporter in India of all the PET film it

exported to the United States.  On May 27, 2011, Commerce published its final results of the

countervailing duty new shipper review, a calculated individual ad valorem subsidy rate for SRF,

for the January 1, 2009, through December 31, 2009 of 3.04 percent ad valorem.26  

                                                            

26 Polyethylene Terephthalate Film, Sheet, and Strip From India:  Initiation of Antidumping Duty and

Countervailing Duty New Shipper Reviews, 75 FR 10758, March 9, 2010; Polyethylene Terephthalate Film,

Sheet, and Strip From India:  Final Results of Countervailing Duty New Shipper Review, 76 FR 30910, May

27, 2011.     
I‐13

Scope reviews

Commerce has conducted one scope review with respect to PET film from Taiwan.  On

May 31, 2011, Commerce published its final results of the scope review requested by Nan Ya

Plastics Corp. Ltd. and Hop Industries Corp.:  amorphous PET film that is not biaxially‐oriented is

not within the scope of the antidumping duty order.27

Five‐year reviews

Commerce has issued the final results of its expedited countervailing duty order review

with respect to India and full antidumping duty order reviews with respect to India and

Taiwan.28 Table I‐3 presents the countervailing duty margins for India calculated by Commerce

in its original investigation, first review, and current review.  Table I‐4 presents the antidumping

duty margins for India and Taiwan calculated by Commerce in its original investigations, first

reviews, and current reviews.

Table I-3 

Product: Commerce’s original, first five-year review, and current five-year review countervailing 

duty margins for producers/exporters in India 

Producer/exporter 

Original margin 

(percent ad 

valorem) 

First five-year 

review margin 

(percent ad 

valorem) 

Second five-year 

review margin 

(percent ad 

valorem) 

India

Ester Industries, Ltd. 18.43 27.39 27.37 

Garware Polyester Ltd. 24.48 33.44 33.42 

Polyplex Corp. Ltd. 18.66 22.71 22.69 

All others 20.40 29.36 29.34 

Source: Countervailing duty orders, 67 FR 44179, July 1, 2002; 73 FR 26080, May 8, 2008; Polyethylene 

Terephthalate (PET) Film, Sheet, and Strip from India: Final Results of the Expedited Second Sunset 

Review of the Countervailing Duty Order, 78 FR 47276, August 5, 2013. 

                                                            

27 Notice of Scope Rulings, 76 FR 31301, May 31, 2011.

28 Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan:  Final Results of the

Second Sunset Review of the Antidumping Duty Orders and Correction to the Preliminary Results, 79 FR

12153, March 4, 2014.
I‐14

Table I-4 

Product: Commerce’s original, first five-year review, and current five-year review dumping 

margins for producers/exporters in India and Taiwan 

Producer/exporter 

Original margin 

(percent ad 

valorem) 

First five-year 

review margin 

(percent ad 

valorem) 

Second five-year 

review margin 

(percent ad 

valorem) 

India1

Ester Industries, Ltd. 24.14 5.712 24.10 

Polyplex Corp. Ltd.3 10.34 0.0014 3.02 

All others 24.14 5.715 13.17 

Taiwan6

Nan Ya Plastics Corp., Ltd. 2.49 2.49 8.99 

Shinkong Synthetic Fibers Corp. 2.05 2.05 0.75 

All others 2.40 2.40 4.37 

 1 Antidumping duty order, 67, FR 34899, May 16, 2002, as amended by 67 FR 44175, July 2, 2002; Continuation 

order, 73, FR 26079, May 8, 2008; Final results of current full five-year review, 79 FR 12153, March 4, 2014. 

 2

 Ester’s rate was found to be 24.24 percent, which was adjusted to 5.71 percent to take into account the export 

subsidy rate found in the companion countervailing duty investigation. 

 3 Commerce initially excluded Polyplex from the antidumping duty order because the rate for Polyplex was zero 

after adjusting the dumping margin for the export subsidies in the companion countervailing duty investigation. 

However, as directed by the Court of International trade, Commerce redetermined to subject Polyplex to the 

antidumping duty order at the rate initially published in the order. Notice of Decision of the Court of International 

Trade, 69 FR 40352, July 2, 2004. 

 4

 Polyplex’ rate was found to be 10.34 percent, which was adjusted to 0.01 percent to take into account the export 

subsidy rate found in the companion countervailing duty investigation, and Polyplex was excluded from the 

antidumping duty order. Polyplex’ exclusion was subsequently reversed by a decision of the Court of International 

Trade. See Notice of Decision of the Court of International Trade: Polyethylene Terephthalate Film, Sheet, and Strip 

from India, 69 FR 40352, July 2, 2004. 

 5

 The “all others” rate established in the investigation was based on Ester’s rate. 

 6

 Antidumping duty order, as amended, 67 FR 44174, July 1, 2002; Continuation order, May 8, 2008; Final results 

of full review, 79 FR 12153, March 4, 2014. 

 

Source: Cited Federal Register Notices. 

THE SUBJECT MERCHANDISE

Commerce’s scope

Commerce has defined the scope of this investigation as follows:

All gauges of raw, pretreated, or primed PET film, whether extruded or

coextruded.  Excluded are metallized films and other finished films that have had

at least one of their surfaces modified by the application of a performance‐

enhancing resinous or inorganic layer of more than 0.00001 inches thick. Imports

of PET film are classifiable in the Harmonized Tariff Schedule of the United States

(HTSUS) under item number 3920.62.00.  HTSUS subheadings are provided for

convenience and customs purposes.  The written description of the scope of

these orders is dispositive.  Since these orders were published, there was one

scope determination for PET film from India, dated August 25, 2003.  In this

determination, requested by International Packaging Films Inc., the Department
I‐15

determined that tracing and drafting film is outside of the scope of the order on

PET film from India.29

Tariff treatment

PET film is classifiable in the Harmonized Tariff Schedule of the United States (“HTS”)

under subheading 3920.62.00 and reported for statistical purposes under statistical reporting

number 3920.62.0090. Current tariff rates for PET film are presented in the following

tabulation:

HTS provision 

Article description 

General1 Special2 Column 23

Rates (ad valorem) 

3920 

 3920.62.00 

 3920.62.0090 

Other plates, sheets, film, foil and strip, 

of plastics, noncellular and not 

reinforced, laminated, supported or 

similarly combined with other materials: 

 Of poly(ethylene terephthalate) 

 Other 

4.24 Free (A*, 

AU, BH, CA, 

CL, CO, E, 

IL, JO, MA, 

MX, OM, P, 

PA, PE, SG) 

25 

 1 Normal trade relations, formerly known as the most-favored-nation duty rate, applicable to India and Taiwan. 

 2

 Special rates apply to imports of PET film from certain trading partners of the United States as follows: A (GSP); 

AU (United States-Australia Free Trade Agreement); BH (United States Bahrain Free Trade Agreement 

Implementation Act); CA and MX (North American Free Trade Agreement); CL (United States-Chile Free Trade 

Agreement); CO (United States-Colombia Trade Promotion Agreement Implementation Act); E (Caribbean Basin 

Economic Recovery Act); IL (United States-Israel Free Trade Area); JO (United States-Jordan Free Trade Area 

Implementation Act); MA (United States-Morroco Free Trade Agreement Implementation Act); (P (Dominican 

Republic-Central America-United States Free Trade Agreement Implementation Act); PA (United States-Panama 

Trade Promotion Agreement Implementation Act); PE (United States-Peru Trade Promotion Agreement 

Implementation Act); SG (United States-Singapore Free Trade Agreement). GSP authority expired July 31, 2013. 

 3

 Applies to imports from a small number of countries that do not enjoy normal trade relations duty status. 

                                                            

29 Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan:  Final Results of the

Second Sunset Review of the Antidumping Duty Orders and Correction to the Preliminary Results, 79 FR

12153, March 4, 2014.  The scope published in the final results of the second sunset review of the

countervailing duty (“CVD”) order on India differs slightly from the final results of the second review of

the antidumping (“AD”) duty orders.  Specifically, the CVD final results cite the item number as the ten

digit statistical reporting number, 3920.62.00.90 and provide an explanation of changes made to the

HTS: “Effective July 1, 2003, the HTSUS subheading 3920.62.00.00 was divided into 3920.62.0010

(metallized PET film) and 3920.62.00.90 (non‐metallized PET film).” In addition, the CVD final results

made no mention of the scope determination cited in the AD scope.  Polyethylene Terephthalate Film,

Sheet, and Strip From India:  Final Results of the Expedited Second Sunset Review of the Countervailing

Duty Order, 78 FR 47276, August 5, 2013.
I‐16

 4 HTS heading 9902.25.76 reduces the duty on biaxially oriented polyethylene terephthalate film certified by the 

importer as intended for use in capacitors and as produced from solvent-washed low ash content (≤300 ppm) 

polymer resin (CAS No. 25038-59-9) (provided for in subheading 3920.62.00) to 3.4 percent for goods entered on or 

before December 31, 2009. 

 

THE PRODUCT30

Description and applications

PET film is a high‐performance, clear, flexible, and transparent or translucent material

that is produced from PET polymer, a linear, thermoplastic polyester resin.  It is generally more

expensive than other plastic films and is used typically only when its unique properties are

required.  Special properties imparted to PET film during the manufacturing process are integral

to its preferred use in a myriad of downstream commodity and specialty applications

encompassing the food packaging, industrial, electrical, imaging, and magnetics sectors.  

Domestic producers ship the majority of subject PET film by truck directly to converters who

apply thicker out‐of‐scope coatings and printing to produce salable merchandise.  PET film is

also sold through distributors. According to U.S. producers ***, subject PET film from both

domestic and foreign sources is basically interchangeable, generally of the same quality and

types across the board, although the relative product type distribution usually varies among

producers.31

  

Manufacturing processes

The basic PET film “sequential draw” production process is fundamentally standard

across the industry.  PET film operations are capital‐intensive, dictating that plants be run at

relatively high capacity utilization rates for sustainable periods to remain profitable.  Most

plants operate on a 24 hour‐per‐day, 7 day‐per‐week basis, with some allotted downtime for

maintenance and repairs.32  Each production line could cost anywhere between $50 million and

$100 million to produce 10,000 to 20,000 tons per year.33 34 The PET film production process is

conducted in a “clean room” environment to protect the finished film from microscopic

airborne contamination.  Sturdy equipment and vibratory control are essential to the

                                                            

     30 Unless otherwise noted, basic information is derived from the most recently concluded PET film

investigation, Polyethylene Terephthalate (PET) Film from Korea, Inv. No. 731‐TA‐459 (Third Review),

USITC Publication 4254, August 2011, pp. I‐14‐21.  Subject matter from producers’ questionnaire

responses and other industry information has been updated to reflect currently available information.

31 E‐mail correspondence from ***, April 16, 2014.

32 Producers’ questionnaire responses, section II‐6.

33 Hearing transcript, p. 23 (Byerson).

34 Flex Films started up a new grassroots state‐of‐the‐art flexible packaging PET film plant at

Elizabethtown, KY, in January 2013. The 8.7 meter wide film line is reported to be larger than any other

line operating in the United States and has an annual production capability of 36,000 metric tons per

year; a second 8.7 meter line is planned, http://www.flexfilm.com, retrieved April 14, 2014.
I‐17

production of PET films of uniform thickness and surface features.  The major producers of PET

film do not normally run other types of film on their PET film production lines unless necessary

owing to the intricacies of the process, and, therefore, do not normally employ production

workers for other purposes.35  Also, most PET film production lines are geared to the

production of products within specified gauge ranges (thin, intermediate, or thick) across end‐

use groups because of the exacting requirements of the process and variability in PET polymer

processing characteristics.  Therefore, the larger producers with more lines and sophisticated

surface modification and other technologies, together with the capability to generally produce

multiple polymer grades, tend to have the capability to provide a wider range of products to

each end‐use sector.36   

Most PET film manufacturers produce the majority of their own PET polymer using the

batch polymerization or continuous polymerization process, or a combination thereof. The

batch process allows the film producer to custom tailor PET polymer for specific end‐use

applications. PET film grade polymer can be manufactured from either purified terephthalic

acid (“PTA”) or dimethyl terephthalate (“DMT”) in combination with ethylene glycol (“MEG”),

feedstock products derived principally from petroleum.37 Producers tend to produce PET film

grade polymer from either PTA or DMT dependent upon process design and end product

property/quality perceptions. PTA reportedly has economic advantages compared to DMT.38 39

DMT, however, currently accounts for the *** feedstock used in the production of PET film.40   

A typical PET film production scheme is shown in the process flow diagram of figure I‐1.  

The basic process steps are polymerization, extrusion and film casting, drawing and biaxial

orientation, crystallization, cooling, winding, and finishing.  Sophisticated scanners and control

systems maintain optimal process conditions. Many value added in‐line film treatments may

also be applied to modify the film during routine processing, including antistatic agents applied

by running the film over microporous liquid coating drums, other chemical treatments, co‐

extrusion of other polyester substrates onto one or both sides of the film via melt phase

lamination processes to promote adhesion, introduction of fillers and pigments into the PET

polymer melt via masterbatch systems, and corona treatment for downstream converter

requirements.41 42

                                                            

35 Producers’ questionnaire responses, section II‐5.

36 Staff plant visit, DuPont Teijin, Hopewell, VA, August 26, 2008.

37 Producers’ questionnaire responses, section IV‐14.

38 *** producers’ questionnaire response, section III‐13.

39 Staff plant visit, DuPont Teijin, Hopewell, VA, August 26, 2008.

40 *** supplement response to producers’ questionnaire, section I‐8.   41 Staff plant visit, DuPont Teijin, Hopewell, VA, August 26, 2008.

42 Corona treatment is the act of exposing the surface of a material to a highly active electric field to

modify its surface energy.  The Global Association of Manufacturers of Polyester Film (AMPEF),

http://www.ampef.com/, retrieved April 14, 2014.
I‐18

Figure I‐1: Process flow diagram for PET film production  

Source: Obtained online at http://www.ampef.com/technology2.html  

In the sequential draw process, molten PET polymer is extruded under pressure through

a narrow slotted die which may vary from 18 inches to 6 feet in length.  The molten material

exits the die directly onto an ultra smooth casting drum which cools the melt and forms an

amorphous polymeric film.  From there, the film is stretched (drawn) in a longitudinal direction

over a series of precision motorized rollers.  The stretched film next enters a long heated

chamber called a stenter (or tenter) oven, where it is subjected to a transverse stretch

(sideways draw) to complete biaxial orientation.  Biaxial orientation aligns the polymeric chains

into a uniform structure which imparts strength, toughness, clarity, and all the other value‐
I‐19

added properties characteristic of PET film.  The finished film of the desired width and gauge

(nominally 1 micron (4 gauge) to 350 microns (1,400 gauge)) is wound into rolls for shipment to

the customer.43 44  PET film is typically slit into rolls ranging from 2 inches to 11 feet wide and

500 to 200,000 feet in length, and sold to downstream converters who apply various thicker

substrates to the film for ultimate nonsubject end‐use requirements.  Certain U.S. primary PET

film producers may also convert base film into nonsubject “equivalent PET film” on the same

equipment by applying coatings exceeding 0.254 microns (0.00001 inch; ca. 1 gauge) and sell

the value added film to downstream end users.45 46

Physical Characteristics and Uses

PET film has certain inherent desirable qualities such as brilliant optical clarity, high

tensile strength, good flexibility, and retention of physical properties over a wide temperature

range, excellent electrical insulation properties, durability, heat resistance, good gas‐barrier

properties, excellent dimensional stability, chemical inertness, and relatively low moisture

absorption.47 It is available commercially in a range of widths, thicknesses, and properties

depending upon the need of end users, and is generally more expensive than other plastic films

owing to its diverse and superior properties.  PET film can be made as a single layer or can be

coextruded with other polyester polymers, blended with pigments, and coated inline with

applied polymer and other agents into a multilayer film encompassing the desired

characteristics.   

There are five subject PET film end‐use categories generally recognized by the industry:

Packaging, Industrial and Specialties, Electrical, Imaging, and Magnetics.48 PET film is produced

and sold for a myriad of end‐uses in two major categories: general purpose commodity‐grade

films, and specialty‐grade films which generally command a price premium relative to the

commodity grades.  Depending on the producer and end use application, PET films are

characterized as thin films or thick films, with thin films generally but not exclusively ranging

from the 48 gauge commodity packaging markets up to 200 gauge for other thin film

commodity and specialty markets, and thicker films ranging above 200 gauge to around 1,400

                                                            

43 Staff plant visit, DuPont Teijin, Hopewell, VA, August 26, 2008. 44 The Global Association of PET Film Manufacturers (AMPEF), http://www.ampef.com/, retrieved

April 14, 2014.

45 *** produces nonsubject equivalent PET film interchangeably with subject PET film on the same

equipment; *** can make out‐of‐scope PET film on certain lines, but only changes if ***.  Producers’

questionnaire responses, sections II‐5‐7.

46 1 micron = 3.937 gauge (0.00004 inch); 100 gauge = 1 mil (0.001 inches). 47 Ibid., PET film has the widest service temperature range of any competing material (‐70°C to

150°C); the highest tensile and tear strength, and electrical insulation breakdown properties; together

with superior dimensional stability, oxygen barrier properties, and dielectric constant (electrical

resistivity).

48 The Global Association of Manufacturers of Polyester Film (AMPEF), http://www.ampef.com/,

retrieved April 15, 2014.  
I‐20

gauge towards the more value added industrial and specialty, and electrical markets.49  

Packaging and industrial and specialty applications are major volume and growth markets,

while imaging is reportedly declining and traditional magnetics applications have mostly

disappeared.50 51

Packaging film end use examples include general purpose food packaging, film for

flexible pouches, peel‐able seals, lids, snacks, barrier films, can laminations, and vacuum

insulation panels.  Industrial and specialties film applications include hot stamping foil, release

films, photo resist films, metallic yarns, adhesive tapes, plastic cards (including smart cards),

labels, lamination films, brightness enhancement films (computer screens), solar/safety window

films, medical test strips, and other miscellaneous uses. Electrical applications include motor

wire and cable, transformer insulation films, capacitors, thermal printing tapes, membrane

touch switches (computer and calculator keyboards), and flexible printed circuit films. Imaging

applications include microfilm, printing and pre‐press films, color proofing, printing plates,

drawing office drafting film, overhead transparencies, X‐ray films, instant photos, business

graphics, and wide format displays.  Magnetics end uses include videotape, audio cassette tape,

floppy disks, and advanced high‐density computer storage media.  Selected PET film product

types cited as manufactured by domestic producers include flexible packaging, window film and

solar window film, silicon release and other liners, industrial carrier web, pressure sensitive

label stock, printing plate and motors applications, optical films and optical display films (flat

panel TV), LCD, renewable energy films, photovoltaic cell, touch screen applications, imaging

and medical X‐ray, ***.52

DOMESTIC LIKE PRODUCT ISSUES

In its original determinations, the Commission defined a single like product coextensive

with the scope as defined by Commerce.53 In its notice of institution in these current five‐year

reviews, the Commission solicited comments from interested parties regarding the appropriate

domestic like product and domestic industry.54 No party requested that the Commission collect

data concerning other possible domestic like products in their comments on the Commission’s

draft questionnaires.  In these reviews, no party disagrees with the Commission’s definition of

the domestic like product as set forth in the original investigations.55  

                                                            

49 Pricing products definitions reflect *** for packaging/industrial markets; *** for

industrial/electrical markets. Producers’ questionnaire, section IV‐1.

50 Producers’ questionnaire responses, section IV‐11.

51 Demand for *** continues to decline. *** producer questionnaire response, section II‐3.

52 Producers’ questionnaire responses, sections II‐3; II‐15; IV‐10; and IV‐11.

53 Polyethylene Terephthalate Film, Sheet, and Strip from India and Taiwan, Inv. Nos. 701‐TA‐415 and

731‐TA‐933 and 934 (Final), USITC Publication 3518 (June 2002).   54 Polyethylene Terephthalate Film, Sheet, and Strip From India and Taiwan:  Institution of Five‐Year

Reviews, 78 FR 19524, April 1, 2013. 55 Domestic producers’ Response to Notice of Institution, p. 3‐4.  Nan Ya’s Response to Notice of

Institution, p. 15.
I‐21

In their aggregate (DuPont Teijin, Mitsubishi, and SKC) prehearing brief, domestic

interested parties agreed with the Commission’s definition of the domestic like product as set

forth in the original investigation and the first review, where the Commission defined the

domestic like product as being coextensive with the scope of the order as defined by the

Department of Commerce.56  

U.S. MARKET PARTICIPANTS

U.S. producers

During the original investigations, nine firms supplied the Commission with information

on their U.S. operations with respect to PET film. These firms accounted for 100 percent of U.S.

production of PET film in 2001.57 During the first five‐year reviews, eight firms supplied the

Commission with information on their U.S. operations with respect to PET film.58 These firms

accounted for 100 percent of U.S. production of PET film in 2006. In these current proceedings,

the Commission issued U.S. producers’ questionnaires to 11 firms, all of which provided the

Commission with information on their PET film operations. These firms are believed to account

for 100 percent of U.S. production of PET film in 2013. Presented in table I‐5 is a list of current

domestic producers of PET film and each company’s position on continuation of the orders,

production locations(s), and share of reported production of PET film for 2008‐2013.

                                                            

56 Domestic Interested Parties Prehearing Brief, p. 10. 57 The nine U.S. producers that supplied the Commission with usable questionnaire information

during the original investigations were:  3M; Agfa; Curwood; DuPont Teijin; Kodak; Mitsubishi; SKC;

Terphane; and Toray.  ***.

58 The eight U.S. producers that supplied the Commission with usable questionnaire information

during the first five‐year reviews were:  3M; Curwood; DuPont Teijin; Kodak; Mitsubishi; SKC; Terphane;

and Toray.
I‐22

Table I-5 

PET film: U.S. producers, positions on orders, U.S. production locations, related and/or affiliated 

firms, and shares of 2008-2013 reported U.S. production 

Firm Position on orders Production locations 

Share of production 

(percent) 

3M Company *** St. Paul, MN ***

Carestream *** Carestream, CO ***

Curwood *** Oshkosh, WI ***

DuPont Teijin Support Hopewell, VA ***

Kodak *** Rochester, NY ***

Flex USA Support Elizabethtown, KY ***

Mitsubishi Support Greer, SC ***

Polyplex USA *** Decatur, AL ***

SKC Support Covington, GA ***

Terphane Support Bloomfield, NY ***

Toray Support North Kingstown, RI ***

Total ***

 Source: Compiled from data submitted in response to Commission questionnaires. 

*** are related to foreign producers of the subject merchandise and are also related to

U.S. importers of the subject merchandise. Additionally, as discussed in greater detail in Part III,

*** U.S. producers directly import the subject merchandise and *** purchase the subject

merchandise from U.S. importers.

U.S. importers

In the original investigations, 22 U.S. importing firms supplied the Commission with

usable information on their operations involving the importation of PET film, accounting for ***

percent of U.S. imports of PET film from India and approximated official statistics from Taiwan

during 2001. Of the responding U.S. importers, six were domestic producers:  ***.  These

imports were exclusively from the U.S. producers’ related firms.59

During the first five‐year reviews, 32 U.S. importing firms supplied the Commission with

usable information on their operations involving the importation of PET film. All eight domestic

producers were among the responding U.S. importers.

In the current proceedings, the Commission issued U.S. importers’ questionnaires to 32

firms believed to be importers of PET film, as well as to all U.S. producers of PET film. Usable

questionnaire responses were received from 21 firms, representing *** percent of Commerce

official import statistics from India for the period examined and *** percent of Commerce

official import statistics from Taiwan for the period examined. Table I‐6 lists all responding U.S.

                                                            

59 Polyethylene Terephthalate Film, Sheet, and Strip from India and Taiwan Investigation Nos. 701‐TA‐

415 and 731‐TA‐933 and 934 (Final), USITC Publication 3518, June 2002, pp. IV‐1‐IV‐2.   
I‐23

importers of PET film from India, Taiwan, and other sources, their locations, and their shares of

U.S. imports for 2008‐13.

Table I-6 

PET film: U.S. importers, U.S. headquarters, sources and shares of imports, 2008-13 

Firm Headquarters 

Share of imports by source 

(percent) 

India Taiwan 

All other 

sources 

Bemis Company, Inc. Neenah, WI *** *** ***

Carestream Health, Inc. Rochester, NY *** *** ***

DuPont Teijin Films Hopewell, VA *** *** ***

Dynamic Polymers, LLC Columbus, OH *** *** ***

Eastman Kodak Company Rochester, NY *** *** ***

Flex America, Inc. Elizabethtown, KY *** *** ***

Forplax Los Angeles, LLC San Dimas, CA *** *** ***

Forplax, LLC Itasca, IL *** *** ***

Granwell Products, Inc. West Caldwell, NJ *** *** ***

International Packaging Films Inc. Norwood, NJ *** *** ***

Kolon USA, Inc. Ridgefield Park, NJ *** *** ***

Mitsubishi Polyester Film, Inc. Greer, SC *** *** ***

NOW Plastics, Inc. East Longmeadow, MA *** *** ***

Pilcher Hamilton Willowbrook, IL *** *** ***

Polyplex USA LLC Decatur, AL *** *** ***

Rocheux International, Inc. Piscataway, NJ *** *** ***

Sanyo Corporation of America New York, NY *** *** ***

SKC, Inc. Covington, GA *** *** ***

Smyrna International, Inc. Springfield, VA *** *** ***

Terphane, Inc. Bloomfield, NY *** *** ***

Toray Plastics (America), Inc. North Kingstown, RI *** *** ***

Total *** *** ***

 Source: Compiled from data submitted in response to Commission questionnaires. 

U.S. purchasers

The Commission received 14 questionnaire responses from firms that bought PET film

during 2008‐13 (table I‐7).60 These firms purchased 177 million pounds of PET film in 2013 (26.7

percent of U.S. apparent consumption). Ten responding purchasers are processors, three are

distributors, and three are end users. Responding U.S. purchasers are located mainly on the

East Coast and in the Midwest. The largest responding purchasers of PET film are ***.

                                                            

60 Of the 14 responding purchasers, 14 purchased domestically produced PET film, 4 purchased

imports from India, 2 purchased imports from Taiwan, and 11 purchased imports from other countries.
I‐24

Table I-7 

PET film: Purchaser names, location, purchaser type, applications, sources and purchases, 2013 

*            *            *            *            *            *            *

APPARENT U.S. CONSUMPTION

Data concerning apparent U.S. consumption of PET film during the period for which data

were collected in this proceeding are shown in table I‐8.

Table I-8 

PET film: U.S. shipments of domestic product, U.S. shipments of imports, and apparent U.S. 

consumption, 2008-13 

Item 

Calendar year

2008 2009 2010 2011 2012 2013

 Quantity (1,000 pounds) 

U.S. producers' U.S. shipments 581,968 516,678 547,129 478,008 454,557 503,363

U.S. importers' U.S. shipments of imports 

from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total shipments of U.S. imports 167,216 132,744 179,241 187,480 195,397 158,687

Apparent U.S. consumption 749,184 649,422 726,370 665,488 649,954 662,050

 Value (1,000 dollars) 

U.S. producers' U.S. shipments 1,104,278 934,393 1,045,456 1,052,285 942,392 963,516

U.S. importers' U.S. shipments of imports 

from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total shipments of U.S. imports 282,423 190,378 302,553 384,737 301,599 243,696

Apparent U.S. consumption 1,386,701 1,124,771 1,348,009 1,437,022 1,243,991 1,207,212

 Source: Compiled from data submitted in response to Commission questionnaires. 
I‐25

U.S. MARKET SHARES

U.S. market share data are presented in table I‐9.

Table I-9 

PET film: U.S. consumption and market shares, 2008-13 

Item 

Calendar year

2008 2009 2010 2011 2012 2013

 Quantity (1,000 pounds) 

Apparent U.S. consumption 749,184 649,422 726,370 665,488 649,954 662,050

 Share of quantity (percent) 

U.S. producers' U.S. shipments 77.7 79.6 75.3 71.8 69.9 76.0

U.S. importers' U.S. shipments of imports 

from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total shipments of U.S. imports 22.3 20.4 24.7 28.2 30.1 24.0

 Value (1,000 dollars) 

Apparent U.S. consumption 1,386,701 1,124,771 1,348,009 1,437,022 1,243,991 1,207,212

 Share of value (percent) 

U.S. producers' U.S. shipments 79.6 83.1 77.6 73.2 75.8 79.8

U.S. importers' U.S. shipments of imports 

from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total shipments of U.S. imports 20.4 16.9 22.4 26.8 24.2 20.2

 Source: Compiled from data submitted in response to Commission questionnaires. 

II‐1

PART II: CONDITIONS OF COMPETITION IN THE U.S. MARKET

U.S. MARKET CHARACTERISTICS

The United States was the second largest worldwide importer (after China) of PET film

during the review period, accounting for 22 percent of global imports in 2013 (see part IV).1 In

the first reviews, the U.S. market was described as consisting of five main end‐use segments:

packaging, industrial, electrical, imaging, and magnetics. Since then, the magnetic end use has

virtually disappeared. U.S. producer *** noted that PET film “has been reinventing itself for

many decades and new end uses will be developed.”

Within the larger segments, there are numerous sub‐segments. Each sub‐segment

consists of a particular type of PET film (defined by gauge, coatings, and other specifications)

that is often produced for that particular sub‐segment and sold to purchasers who participate

primarily in that sub‐segment. Different producers also have different specialties and emphases

across segments and sub‐segments. PET film types can be classified as commodity films, semi‐

specialty films, and specialty films. According to domestic interested parties, the majority of PET

film sold in the U.S. market is commodity films.2   

U.S. PET film producers fall into two categories, firms that produce primarily or solely for

the merchant market (DuPont Teijin, Flex USA, Mitsubishi, Polyplex USA, SKC, Terphane, and

Toray) and those that produce primarily or solely for captive consumption (Carestream,  

Curwood, Kodak, and 3M).3 The producers that captively consume the product tend to be

concentrated in large end‐use sub‐segments, such as photography and X‐rays, into which

merchant‐market producers rarely sell. Two new U.S. producers, Flex USA and Polyplex USA,

have entered the market since the first review.

*** described the PET film business cycle as short peaks followed by long bottoms and

stated that the peak years were 1995 and 2010. After a period of tight supply for PET film in

U.S. and world markets in 2010, additional production capacity has come on line in the United

States and in other countries.4

   

CHANNELS OF DISTRIBUTION

U.S. producers and importers sold mainly to end users (table II‐1). About one‐third of

U.S. production, as well as some imports, went to converters. Conversion activities include

coating, metallizing, and/or laminating PET film.5

 

1 Based on data from GTIS, which includes some out of scope products. 2 ***. Domestic interested parties’ prehearing brief, p. 21.   3 The portion of U.S. production that was internally consumed fell from *** percent in 2008 to ***

percent in 2013. 4 ***.   5 ***.
II‐2

Table II-1 

PET film: U.S. producers’ and importers’ share of reported U.S. shipments (percent), by sources 

and channels of distribution, 2008-13 

* * * * * * * 

Note: U.S. producers’ sales to converters are from ***.

 

Source: Compiled from data submitted in response to Commission questionnaires. 

GEOGRAPHIC DISTRIBUTION

U.S. producers reported selling PET film to all regions in the contiguous United States

(table II‐2). Importers also reported selling to all regions with the exception of the central

southwest for imports from Taiwan. For U.S. producers, the majority of sales were between 101

and 1,000 miles of their production facilities (table II‐3). Most importers’ sales were within 100

miles of their U.S. point of shipment.

Table II-2 

PET film: Geographic market areas in the United States served by U.S. producers and importers, 

by number of responding firms 

Region U.S. producers 

U.S. importers 

India Taiwan 

Northeast 8 2 5

Midwest 9 3 6

Southeast 9 3 4

Central Southwest 8 1 0

Mountains 6 1 1

Pacific Coast 9 2 2

Other1 0 0 0

All regions in the continental United 

States 5 0 0

 1 All other U.S. markets, including AK, HI, PR, and VI, among others. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Table II-3 

PET film: Distances shipped within the United States 

Distance shipped within the United 

States 

Share of commercial U.S. shipments (percent) 

U.S. producers 

U.S. importers U.S. importers 

India Taiwan 

Zero to 100 miles *** *** ***

101 miles to 1,000 miles *** *** ***

Over 1,000 miles *** *** ***

Source: Compiled from data submitted in response to Commission questionnaires.
II‐3

SUPPLY AND DEMAND CONSIDERATIONS

U.S. supply

Firms reported increased supply in the U.S. market from U.S. producers and from

imports during the review period, and that they expect supply to continue to increase as

additional capacity comes on line worldwide. Four of 10 producers and 8 of 17 importers

reported changes in factors related to U.S. supply. Firms cited new PET film capacity worldwide,

including in the United States (Flex USA and Polyplex USA), and in Mexico (Flex). One producer

reported a global glut of PET film in 2014 due to increased global capacity. U.S. producers also

noted changes in energy costs during the review period, with one producer noting “wildly”

fluctuating energy costs, particularly for natural gas. This producer also reported that increased

logistics charges would balance out the advantages of lower energy costs.

Some firms reported PET film shortages in 2010, specifically for 36g and 48g PET film.

One firm reported that by the third quarter of 2010 U.S. producers stopped making commodity

type 36g and 48g *** in favor of producing higher margin products creating a shortage until

Flex and Polyplex opened their U.S production facilities. ***reported that the supply of 48

gauge film decreased in 2009‐10 as producers worldwide shifted their capacity to make PET film

for the solar market, but that since then, new global capacity has come on line for 48 gauge

film. *** reported a global shortage of PET film in 2010‐11 due to the lack of added capacity

plus the explosion of the LCD TV market.  

U.S. producers (8 of 9) expect increased domestic supply from three new PET film lines

installed in 2013‐14 (by SKC, Polyflex USA, and Flex USA). In addition, ***.  

Some importers (6 of 16) anticipate increases in the supply of subject imports. ***

stated that producers in India and Taiwan are increasing capacity faster than demand in their

home and regional markets. *** also reported new capacity in India.  

Many firms (all 9 responding U.S. producers and 8 of 17 importers) also reported an

increase in the availability of nonsubject imports. Firms cited continuing capacity expansions in

2012 and 2013, particularly in Asia, despite global oversupply. One firm noted that since 2008,

there have been more than 20 new PET film lines installed worldwide. Firms cited an increase in  

U.S. imports from Bahrain, China, Dubai, Korea, Mexico, Thailand, Turkey, and UAE. Firms

specifically noted increased supply to the U.S. market from the Flex plant in Mexico; from JBF

plants in Bahrain and UAE (despite the antidumping order), and from new PET film lines in

China (despite the antidumping order).  

Two foreign producers reported no changes in factors affecting supply. However, ***.

No foreign producer anticipated any changes in subject import supply.

Domestic production

Based on available information, U.S. producers of PET film have the ability to respond to

changes in demand with moderate changes in the quantity of shipments of U.S.‐produced PET

film to the U.S. market. The main contributing factors to this degree of responsiveness of supply

are the availability of unused capacity and some inventories.
II‐4

Industry capacity

Domestic capacity utilization decreased over the period of review from *** percent to

*** percent, reflecting a slight decline in overall capacity and a larger decline in production. The

level of capacity utilization in 2013 was the lowest during any year since prior to 1999 (the first

year of the original investigation).6 This level of capacity utilization suggests that U.S. producers

may have some capacity to increase production of PET film in response to an increase in prices.  

Alternative markets

U.S. producers’ exports, as a percentage of total shipments, ranged from *** percent to

*** percent during the review period. Most U.S. producers stated that it would be difficult to

shift their shipments to other markets. Reasons cited include: high U.S. production costs (both

materials and manufacturing costs); logistical issues (long qualification times, wait period for

testing, high costs of entering new markets, and contract negotiations); and global oversupply

of commodity grades. One firm stated it could sell specialty grades to Europe but not in the

same volume as the U.S. market and another firm reported that it typically exports high‐end

specialty products. In addition, some firms reported that U.S. producers that produce for their

own internal consumption or that have production facilities abroad are unlikely to increase

exports of PET film. Only one U.S. producer reported barriers to trade in other markets: ***

reported higher tariffs in Europe (6 percent) and Brazil (16 percent).

Inventory levels

U.S. producers’ inventories were about *** percent of total shipments during the

review period. These inventory levels suggest that U.S. producers may have some ability to

respond to changes in demand with changes in the quantity shipped from inventories.

Production alternatives

None of the responding U.S. producers reported that they could switch production from

PET film to other products in response to a price change.7

  

Subject imports from India

Indian producers likely have the capability to respond to changes in demand with large

changes in the quantity shipped to the U.S. market. The main contributing factors to this degree

of responsiveness of supply are unused capacity and the existence of alternate markets.

 

6 *** reported that PET film production is highly capital intensive and requires producers to operate

at very high utilization rates. It stated that ***.   7 ***.
II‐5

Information in this section is primarily based on the questionnaire response of one foreign

producer, Polyplex, that accounted for an estimated *** percent of total capacity in India.8

  

Industry capacity

Polyplex’s capacity in India *** during the review period, with ***.9

  Capacity utilization

***. ***.10 Polyplex reported that there ***.

Alternative markets

Internal consumption accounted for *** of Polyplex’s shipments. Commercial shipments

to the Indian home market declined from *** percent of total shipments in 2008 to *** percent

in 2013. The ratio of exports to the ***, although exports to the ***. Polyplex reported that

***. Polyplex further reported that ***. It reported that it has ***.

In describing the Indian PET film market, Polyplex reported that ***. ***.

India was the sixth largest PET film exporter worldwide in 2013; its exports increased

from 92.4 million pounds in 2008 to 206.8 million pounds in 2013 (see part IV of this report).11

India’s major export markets in 2013 were Italy (16 percent), Bangladesh (7 percent), the

United States (6 percent), Germany (6 percent), and China (5 percent).

Inventory levels

The ratio of inventories to total shipments was less than *** percent during all but one

year during the review period.

Production alternatives

***.

Subject imports from Taiwan

Information in this section is based primarily on the questionnaire responses of two

foreign producers (Nan Ya and Vast) that are estimated to have accounted for *** percent of

PET film capacity in Taiwan in 2012 and *** percent of production in Taiwan in 2011.12 Based

on available information, producers of PET film from Taiwan have the ability to respond to

changes in demand with moderate changes in the quantity of shipments of PET film to the U.S.

market, with some possible variation depending on whether market conditions would support

 

8 Capacity based on 2012 data. ***.

9 ***.

10 ***. 11 Global Trade Atlas data presented in part IV of this report; data include some nonsubject products.   12 ***.
II‐6

transferring sales from Asia to the United States. The main contributing factors to this degree of

responsiveness of supply are the existence of alternate markets, but the lack of available

capacity and inventories.

Industry capacity

Producers in Taiwan reported capacity utilization rates of ***during 2008‐13. ***.13

***.  

Alternative markets

Home market shipments and internal consumption accounted for about *** of

shipments from Taiwan producers and exports to Asia accounted for ***. ***.14  

***.15 ***.  

Nan Ya reported that it supplies about *** percent of consumption in the Taiwan home

market, and that demand in its home market ***. Vast reported that ***.  

***.16  

Taiwan was the fifth largest exporter worldwide in 2013; its exports increased from 51.0

million pounds in 2008 to 214.5 million pounds in 2013 (see part IV of this report).17 Taiwan’s

major export markets were China (half of exports in 2013), and Japan (25 percent). Other

export markets include the United States, Malaysia, Canada, Germany, and Australia.

Inventory levels

Taiwan producers’ ratio of inventories to total shipments ranged from *** percent

during the period of review.

Production alternatives

***.

Nonsubject imports

The largest sources of nonsubject imports during 2008‐13 were Mexico, Korea, and UAE.

Mexico accounted for 26.4 percent of nonsubject imports during 2013, Korea accounted for

16.1 percent and UAE accounted for 12.5 percent.

 

13 ***. 14 ***. Exchange rate data are presented in part V of this report.

15 ***.   16 Nan Ya reported that ***. 17 Global Trade Atlas, data include some nonsubject products.  
II‐7

New suppliers

Seven of 10 purchasers indicated that new suppliers entered the U.S. market since 2008,

and 5 purchasers expect additional entrants. Purchasers cited new U.S. production by Flex USA

and Polyplex USA, and from new suppliers of product from India (Jindal, Garware, and Ester),

China (WanHua and Green Packaging, Dong Fang), UAE (JBF) and Mexico (Flex). Expected new

entrants include Middle Eastern and South American producers. One purchaser noted that the

foreign producers are attracted to the large size of the U.S. market.

U.S. demand

Based on available information, the overall demand for PET film is likely to experience

small to moderate changes in response to changes in price. The main contributing factors are  

the lack of substitute products tempered by PET film’s highly variable cost shares of final

products.

End uses

U.S. demand for PET film depends on the demand for U.S.‐produced downstream

products. As shown in the following tabulation, *** of U.S. producers’ shipments went to

industrial end uses, followed by packaging and then imaging. The vast majority of imports from

India were used in *** and most imports from Taiwan were used in ***.18

End use segment 

U.S. 

producers India Taiwan 

percent of shipments 

Electrical *** *** ***

Industrial *** *** ***

Imaging *** *** ***

Magnetics *** *** ***

Packaging *** *** ***

Total 100.0 100.0 100.0

Although most firms reported no changes in end uses, 6 of 9 responding U.S. producers,

4 of 17 importers, and 2 of 14 purchasers reported changes. Firms reported the following

changes: a decrease in PET film for LCD screens and imaging; disappearance of the magnetics

market; increase in touch screen applications; 10 percent annual growth globally in industrial  

and packaging; siliconized (in line chemically treated) taking market share from siliconized

paper; and imaging and magnetic markets moving from analog to digital technology. Some

 

18 Firms were asked to report based on their 2013 U.S. shipments; therefore this data does not

include firms that did not produce or import PET film in 2013. In addition, not all firms answered the

question; some noted that they did not know the end uses. For Taiwan, importers ***.
II‐8

firms reported increased PET film use in photovoltaic applications while at least one firm

reported that PET film use in this application had declined.   

Only 3 of 9 U.S. producers and 3 of 16 importers, and no purchasers anticipated changes

in end uses. Anticipated changes include PET film replacing other products such as oriented

polypropylene, higher gauge PET film, and the growing use of PET film in flexible printed

electronics.

Business cycles

Most producers, but a smaller percentage of importers and purchasers, indicated that

the PET film market was subject to business cycles.19 A minority of firms indicated that the PET

film market was subject to other conditions of competition distinctive to PET film.20  ***

reported that the PET film business cycle is typically 7 to 10 years. One firm reported that

seasonality varies between end use markets with higher demand in food packaging during the

growing seasons and around holidays, while another firm reported that demand is lowest in the

fourth quarter.  

Most responding firms (7 of 8 U.S. producers, 6 of 9 importers, and 5 of 7 purchasers)

reported changes since 2008 in business cycles or conditions of competition, often citing

capacity changes and wider economic conditions. *** reported it expects a prolonged

trough in the business cycle because of worldwide oversupply due to continuing capacity

expansions, particularly in China and India.  

*** reported a shortage of PET film in 2010 as Asian producers, responding to increased

demand in Asia for optical film, reduced exports and supplied local markets. *** also reported a

shortage in 2010, in which packaging film prices doubled as U.S. producers reduced production

of these films and increased production of thicker industrial films (for consumer electronics,

solar applications, and release films). It added that global and U.S. capacity additions in 2012

and 2013 lowered the prices and increased the availability of packaging films. *** reported that

global capacity utilization has dropped from almost sold out in 2010 to less than 70 percent

currently as new producers have entered the world market. *** reported that during the

recession, customers reduced inventories and as the economy has recovered, customers have

restocked but that pricing pressures have increased with continued imports and the installation

of new U.S. PET film lines.

*** reported that flat panel displays have become a large new segment as magnetics

have disappeared. ***reported more market volatility since the 2008 global financial crisis, and

that the rate of new capacity has not been consistent, creating supply/demand fluctuations.  

 

19 Of the responding firms, 7 of 10 U.S. producers, 7 of 17 importers, and 5 of 14 purchasers reported

that the market was subject to business cycles.

20 Of the responding firms, 3 of 10 U.S. producers, 4 of 17 importers, and 3 of 14 purchasers reported

that the PET film market was subject to other conditions of competition distinctive to PET film.
II‐9

Apparent consumption

Apparent U.S. consumption of PET film declined during 2008‐13; in 2013, it was 11.6

percent lower than in 2008. Apparent consumption fluctuated during the first four years of the

review period, with a decline from 2008 to 2009, recovery in 2010, another decline in 2011, and

then remained relatively stable in 2012 and 2013. In 2013, U.S. apparent consumption was

lower than during any year in the original investigations (1999‐2001) and first reviews (2002‐

06).  

Demand trends

Most firms reported an increase in U.S. demand for PET film since 2008 (table II‐4).

Firms were more mixed on their responses regarding future demand, although a plurality of

U.S. producers, importers, and purchasers expect demand to increase.

Table II-4 

PET film: Firms’ responses regarding U.S. demand, by number of responding firms 

Item 

Number of firms reporting 

Increase No change Decrease Fluctuate 

Demand inside the United States since 2008:

 U.S. producers 6 1 2 2

Importers 10 3 1 2

Purchasers 6 1 2 2

Foreign producers 2 0 0 1

Anticipated demand inside the United States:

 U.S. producers 5 2 2 2

Importers 7 4 1 4

Purchasers 5 1 2 2

Foreign producers 0 1 1 1

Demand for purchasers' final products since 

2008: 

 Purchasers 3 2 1 1

 Source: Compiled from data submitted in response to Commission questionnaires.

Substitute products

Substitutes for PET film are somewhat limited, although some firms (5 of 8 producers, 4

of 15 importers, and 8 of 14 purchasers) reported some substitutes.21 Substitutes listed by

purchasers include BOPP (bi‐axially oriented polypropylene film) and BOPA (bi‐axially oriented

polypropylene film) for food and other flexible packaging uses, certain laminating papers22 for

electrical insulation uses, and polycoated paper and polyolefin films for lamination and

 

21 The remaining firms reported that there were no substitutes. 22 The specific substitutes listed were 3M’s Tufquin and Cequin.
II‐10

conversion uses. Only one producer and one purchaser reported any changes or anticipated

changes in substitutes.

Cost share

Because PET film is used in a wide variety of end‐use products (which are themselves

often used in other downstream products), the percent of the final cost that is accounted for by

PET film varies widely across and within end uses. Reported cost shares for some end uses were

as follows (in percent): packaging (15 to 70, average of about 30), medical (12); optical films (15

to 20 ); motors (3); release liners (40 to 70); labels (10 to 50); industrial (40 to 68); solar window

films (15 to 50); metalized PET (75); packing tapes (50); laminated film (80); specialty films (16);

balloons (80); and reflective sheeting (10).

SUBSTITUTABILITY ISSUES

The degree of substitution between domestic and imported PET film depends upon such

factors as relative prices, quality (e.g., grade standards, reliability of supply, defect rates, etc.),

and conditions of sale (e.g., price discounts/rebates, lead times between order and delivery

dates, payment terms, product services, etc.). Based on available data, staff believes that there

is a high degree of substitutability between domestically produced PET film and PET film

imported from subject sources.  

Lead times

PET film is primarily produced‐to‐order. U.S. producers reported that 79 percent of their

commercial shipments were produced‐to‐order with lead times of 2 to 6 weeks.23 The

remaining 21 percent of their commercial shipments came from inventories, with lead times of

1 to 7 days. Importers reported that most PET film from Taiwan was also produced‐to‐order,

***, while about *** of product from India was sold from inventories. Importers’ reported lead

times were 1 to 7 days from U.S inventories, one month from foreign inventories, and generally

4 to 10 weeks for produced‐to‐order product.  

Knowledge of country sources

Twelve purchasers indicated they had marketing/pricing knowledge of domestic

product, two of Indian product, one of Taiwan product, and six of nonsubject countries.

As shown in table II‐5, a majority or plurality of purchasers and their customers

sometimes make purchasing decisions based on the producer, but a majority or plurality

reported that they never purchase based on the country of origin. Of the purchasers that

 

23 *** reported that during a peak business cycle in 2010, some lead times exceeded 4 to 6 weeks.

*** reported that competition in the U.S. market has reduced lead times from 30 days to 7 days.   
II‐11

reported that they always make decisions based on the manufacturer, ***. It also considers

service, quality, long term commitment to the U.S. market, and the overall risk of doing

business with a specific supplier. Other reasons cited for basing decision on producer including

specification, quality, qualification, delivery, service, price, and food safety requirements.

Reasons for always basing purchase on country of origin were service, customer turnaround

times, and a preference for domestic product while keeping one offshore supplier.

Table II-5 

PET film: Purchasing decisions based on producer and country of origin, by number of reporting 

firms 

Decision Always Usually Sometimes Never 

Purchaser makes decision based on producer 2 3 4 1

Purchaser’s customers make decision based 

on producer 0 3 6 1

Purchaser makes decision based on country 3 1 1 5

Purchaser’s customers make decision based 

on country 0 2 2 6

Source: Compiled from data submitted in response to Commission questionnaires. 

Factors affecting purchasing decisions

As shown in table II‐6, the most often cited top three factors firms consider in their

purchasing decisions for PET film were quality (9 firms), price (8 firms), availability and

delivery/lead time (3 firms each). Quality was the most frequently cited first most important

factor (cited by 5 firms), followed by price (3 firms); price was the most frequently reported

second most important factor (3 firms); and quality, price, and delivery/lead time were the

most frequently reported third most important factor (2 firms each). In addition firms listed

minimum order quantities, product range/specifications, capacity, reliability, service, quality

systems/history, and ease of supply chain as important considerations in their purchase

decisions for PET film.   

Table II-6 

PET film: Ranking of factors used in purchasing decisions as reported by U.S. purchasers, by 

number of reporting firms 

Factor First Second Third Total 

Quality 5 2 2 9 

Price 3 3 2 8 

Availability 0 2 1 3 

Delivery/lead time 0 1 2 3 

Other1 2 2 2 6 

1

 Other factors include specification and fit for use considerations as first factor; ease of supply chain and 

vendor strategic fit for second factor; reliability of supply and product range for third factor. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐12

The majority of purchasers (9 of 14) reported that they only sometimes or never

purchase the lowest‐priced product. Five of 13 purchasers reported that certain types of

product were only available from a single source.

When asked if they purchased PET film from one source although a comparable product

was available at a lower price from another source, 12 purchasers reported doing so, citing

reasons including lead times, delivery, supply reliability, ease of supply chain, and order size.

One purchaser stated it buys from ***, and that substituting a raw material can be very time

consuming and expensive. It stated that it may be willing to pay a higher price for U.S.‐

produced product due to shorter lead times and lower minimum order size.24 It also considers

the cost to qualify versus the expected benefits of changing sources (price, terms, leadtime,

service, etc). One purchaser stated it buys from ***because of ***. ***purchases from more

than one source, but among qualified producers, it purchases from the lowest price supplier

with sufficient capacity that consistently meets specifications. One firm noted that Korea and

Turkey require larger minimum order size and have a longer transit time.   

Importance of specified purchase factors

Purchasers were asked to rate the importance of 15 factors in their purchasing decisions

(table II‐7). All 14 responding purchasers rated the following factors as “very important”:  

availability, price, product consistency, quality meets industry standards and reliability of

supply. Other factors rated as “very important” by more than half of responding purchasers

were delivery terms and minimum quantity requirements (8 firms each).

Supplier certification

All 10 responding purchasers require that all of the product they purchase be certified.

Purchasers reported that the time to qualify a new supplier ranged from 60 to 365 days.25 Six of

10 purchasers reported that a foreign supplier had failed in its attempt to qualify product, or

had lost its approved status since 2008. Two firms listed Jindal (India) because of “specification”

and poor quality. One firm each listed Toyobo (China), SKC (Korea), Terphane (Brazil) for quality

issues for a particular grade, Kolon (Korea) for delivery delays on some grades, and a Russian

supplier for delivery problems and failed specifications.  

 

24 It reported that most offshore suppliers require a minimum order of a container (40,000 pounds).

25 Three purchasers reported 365 days and seven reported 60 to 210 days.  
II‐13

Table II-7 

PET film: Importance of purchase factors, as reported by U.S. purchasers, by number of 

responding firms 

Factor 

Number of firms reporting 

Very Somewhat Not 

Availability 14 0 0

Delivery terms 8 5 1

Delivery time 10 3 1

Discounts offered 2 8 4

Extension of credit 4 7 3

Minimum quantity requirements 8 5 1

Packaging 5 7 2

Price 14 0 0

Product consistency 14 0 0

Product range 6 5 3

Quality exceeds industry standards 4 6 4

Quality meets industry standards 14 0 0

Reliability of supply 14 0 0

Technical support/service 3 10 1

U.S. transportation costs 5 6 2

Source: Compiled from data submitted in response to Commission questionnaires. 

Changes in purchasing patterns

Purchasers were asked about changes in their purchases from different sources since

2008 (table II‐8). There was not a clear pattern for domestic purchases and purchases of Indian

product. Six purchasers reported increases in purchases of nonsubject imports and four

reported decreases in purchases of product from Taiwan. Reasons reported for decreased

purchases of domestic product included: tighter U.S. supply, reduced demand for end product,

addition of new supplier, country of origin changed by current supplier, temporary decrease in

2009 when Dupont Teijin stopped making domestic product, and U.S. producers’ unwillingness

to make PET film. Reasons reported for increasing domestic purchases included: new U.S.

capacity and suppliers, market growth, and the opening of Flex USA and Polyplex USA in 2013.

Table II-8 

PET film: Changes in relative purchases from U.S., subject, and nonsubject countries 

Source of purchases 

Did not 

purchase Decreased Increased Constant Fluctuated

United States 0 4 4 4 2

India 7 3 3 1 0

Taiwan 8 4 2 1 0

All other sources 2 2 6 1 2

Source: Compiled from data submitted in response to Commission questionnaires. 

For India, reasons for decreased purchases included decreased demand for a specific

PET film product, no need for imports since domestic product was available, and price; and

reasons for increased purchases were availability and to supplement loss of domestic supply.
II‐14

Among firms reporting decreased purchases from Taiwan, ***, one firm reported it is no longer

purchasing from Nan Ya, and one firm reported it substituted an alternative qualified firm.

Reasons for increasing purchases from nonsubject countries were to supplement loss of

domestic supply, capacity additions, added new supplier, source/price, and began purchasing

from UAE and Mexico. Reasons for decreasing purchases from nonsubject countries were that

the purchaser stopped buying from *** and that the purchaser substituted an alternative

qualified firm.  

Eight of 10 responding purchasers reported that they had changed suppliers since 2008.

Specifically, firms reported dropping or reducing purchases from the following suppliers (and

reasons, if stated): Jindal (quality), Polyplex (***), Shenda China (exited U.S. market in 2008 due

to antidumping duties), Terphane Brazil (exited U.S. market in 2008 due to antidumping duties),

Mitsubishi (unwillingness to supply in 2010), DuPont Teijin (unwillingness to supply in 2011),

Nan Ya (no longer competitive), and Rocheux (cost increases from antidumping order and

qualified a domestic supplier).  

Firms reported adding or increasing purchases from the following suppliers (and  

reasons, if stated): Flex USA (new capacity, quality, price, source of supply); Flex Mexico; JBF;

Polyplex USA; ***; SKC (added to our product portfolio); Smyrna International/Triton (unable to

obtain packaging films from domestic suppliers); and Toray (quality, price, and source of

supply). Firms also reported changes because of mill/vendor consolidation.  

Only two purchasers reported reasons for purchasing from one country only. ***

purchases from domestic suppliers because of quality and the cost of qualifying additional

suppliers, and *** purchases domestic only because of strict quality requirements.

Importance of purchasing domestic product

Purchasers reported that 14 percent of their 2013 PET film purchases required domestic

product. Specifically, for 8 percent of their purchases their customers required domestic

product, and for the remaining 6 percent, purchases of domestic product were required for

reasons other than their customers or laws/regulations. These other reasons cited for

preferring domestic product included: no other current source for product, product attributes,

timing/product design, and lean principles and better quality. Domestic product was not

required for the remaining 86 percent of their purchases.

Comparisons of domestic products, subject imports, and nonsubject imports

Purchasers were asked to compare PET film produced in the United States, subject

countries, and nonsubject countries on the same 15 factors (table II‐9) for which they were

asked to rate the importance.  

A majority of purchasers reported that U.S. and all imported products were comparable

on seven of the factors (discounts offered, extension of credit, packaging, price, quality exceeds

industry standards, quality meets industry standards, and U.S. transportation costs). Most

purchasers reported that PET film from India, Taiwan, and nonsubject countries were

comparable on all factors.
II‐15

Purchasers rated the U.S. product as superior to that from India, Taiwan, and nonsubject

imports on availability, delivery terms, delivery time, and technical support/service. In addition,

firms rated the domestic product as superior to imports from India and nonsubject imports on

minimum quantity requirements, product range, and reliability of supply. On two of these

factors, minimum quantity requirements and reliability of supply, equal numbers of firms rated

the U.S. product as superior to that from Taiwan and comparable to that from Taiwan. For

product consistency, an equal number of purchasers rated the U.S. product as superior to that

from India and comparable to that from India.

Comparison of U.S.‐produced and imported PET film

In order to determine whether U.S.‐produced PET film can generally be used in the

same applications as imports from India and Taiwan, U.S. producers, importers, and purchasers

were asked whether the products can “always,” “frequently,” “sometimes,” or “never” be used

interchangeably. As shown in table II‐10, the majority of responding firms reported that U.S.‐

produced PET film and imported PET film from India, Taiwan, and other countries “always” or

“frequently” can be used interchangeably.

As can be seen from table II‐11, 9 of 13 responding purchasers reported that

domestically‐produced product “always” met minimum quality specifications. 2 of 8 responding

purchasers reported that PET film from India “always” met minimum quality specifications and

4 of 7 responding purchasers reported that PET film from Taiwan “always” met minimum

quality specifications.

In addition, producers, importers, and purchasers were asked to assess how often

differences other than price were significant in sales of PET film from the United States, subject,

or nonsubject countries. As seen in table II‐12, most producers and importers reported that

such differences were “sometimes” or “never” significant. On the other hand, most purchasers

reported that such differences between domestic product and that from India and Taiwan were

“always” or “frequently” significant.   
II‐16

Table II-9 

PET film: Purchasers’ comparisons between U.S.-produced and imported product 

Factor 

Number of firms reporting 

U.S. vs. India U.S. vs. Taiwan India vs. Taiwan

S C I S C I S C I

Availability 9 3 0 6 4 1 0 6 2

Delivery terms 7 5 0 6 4 1 0 7 1

Delivery time 10 2 0 7 3 1 0 7 1

Discounts offered 3 9 0 1 9 1 0 7 1

Extension of credit 4 8 0 2 8 1 0 7 1

Minimum quantity requirements 8 4 0 5 5 1 0 7 1

Packaging 4 8 0 2 8 1 0 6 2

Price1 1 10 1 2 8 1 0 8 0

Product consistency 6 6 0 3 7 1 0 6 2

Product range 7 5 0 4 5 2 0 6 2

Quality exceeds industry standards 5 7 0 3 7 1 0 7 1

Quality meets industry standards 4 8 0 3 7 1 0 7 1

Reliability of supply 7 5 0 5 5 0 0 6 1

Technical support/service 8 4 0 5 4 2 0 6 2

U.S. transportation costs 1 5 7 0 4 6 1 0 7 1

Factor 

Number of firms reporting 

U.S. vs. Nonsubject India vs. Nonsubject Taiwan vs. Nonsubject

S C I S C I S C I

Availability 8 5 0 1 7 1 0 7 1

Delivery terms 7 6 0 0 8 1 0 7 1

Delivery time 9 4 0 1 6 2 0 7 1

Discounts offered 3 10 0 1 7 1 0 7 1

Extension of credit 5 8 0 0 8 1 0 7 1

Minimum quantity requirements 7 6 0 1 7 1 0 7 1

Packaging 3 10 0 0 7 2 0 7 1

Price1 1 11 1 0 9 0 0 7 1

Product consistency 4 9 0 0 8 1 0 7 1

Product range 7 6 0 0 7 2 0 7 1

Quality exceeds industry standards 5 7 1 0 8 1 0 7 1

Quality meets industry standards 4 9 0 0 7 2 0 7 1

Reliability of supply 7 5 1 0 7 2 0 7 1

Technical support/service 8 5 0 1 6 2 0 7 1

U.S. transportation costs 1 4 9 0 0 8 1 0 7 1

 1 A rating of superior means that price/U.S. transportation costs is generally lower. For example, if a firm 

reported “U.S. superior,” it meant that the U.S. product was generally priced lower than the imported 

product. 

Note: S=first listed country’s product is superior; C=both countries’ products are comparable; I=first list 

country’s product is inferior. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐17

Table II-10 

PET film: Interchangeability between PET film produced in the United States and in other 

countries, by country pairs 

Country pair 

U.S. producers U.S. importers 

U.S. 

purchasers

A F S N A F S N A F S N

United States vs. India 5 3 1 0 5 6 0 0 1 6 3 1

United States vs. Taiwan 5 3 0 0 7 4 1 1 1 5 1 2

India vs. Taiwan 4 2 1 0 4 4 0 1 1 5 1 1

United States vs. Other 5 3 1 0 5 6 1 0 1 6 2 0

India vs. Other 4 2 1 0 4 5 0 0 1 3 1 0

Taiwan vs. Other 4 3 0 0 3 4 0 0 1 4 0 0

 Note.—A=Always, F=Frequently, S=Sometimes, N=Never.

Source: Compiled from data submitted in response to Commission questionnaires. 

Table II-11 

PET film: Ability to meet minimum quality specifications, by source and number of reporting 

firms1 

Source Always Usually Sometimes Rarely or never 

United States 9 4 0 0

India 2 4 2 0

Taiwan 4 1 2 0

1

 Purchasers were asked how often domestically produced or imported PET film meets minimum quality 

specifications for their own or their customers’ uses.

Source: Compiled from data submitted in response to Commission questionnaires. 

Table II-12 

PET film: Significance of differences other than price between PET film produced in the United 

States and in other countries, by country pair 

Country pair 

U.S. producers U.S. importers U.S. purchasers 

A F S N A F S N A F S N 

United States vs. India 1 0 5 3 0 2 4 4 3 3 4 1

United States vs. Taiwan 1 1 4 3 0 1 7 4 3 3 2 1

India vs. Taiwan 0 0 5 2 0 1 4 3 1 2 3 2

United States vs. Other 1 1 5 3 0 2 6 4 2 2 4 1

India vs. Other 0 0 5 2 0 2 4 3 1 1 4 1

Taiwan vs. Other 0 1 4 2 0 1 4 3 1 1 3 1

Note.--A = Always, F = Frequently, S = Sometimes, N = Never. 

Source: Compiled from data submitted in response to Commission questionnaires. 
II‐18

ELASTICITY ESTIMATES

This section discusses elasticity estimates. Parties did not comment on the estimates.

U.S. supply elasticity

The domestic supply elasticity26 for PET film measures the sensitivity of the quantity

supplied by U.S. producers to changes in the U.S. market price of PET film. The elasticity of

domestic supply depends on several factors including the level of excess capacity, the ease with

which producers can alter capacity, producers’ ability to shift to production of other products,

the existence of inventories, and the availability of alternate markets for U.S.‐produced PET

film. Analysis of these factors earlier indicates that the U.S. industry is likely to be able to

moderately increase or decrease shipments to the U.S. market; an estimate in the range of 2 to

5 is suggested.  

U.S. demand elasticity

The U.S. demand elasticity for PET film measures the sensitivity of the overall quantity

demanded to a change in the U.S. market price of PET film. This estimate depends on factors

discussed earlier such as the existence, availability, and commercial viability of substitute

products, as well as the component share of PET film in the production of any downstream

products. Based on the available information, the aggregate demand for PET film is likely to be

moderately inelastic; a range of ‐0.5 to ‐1.0 is suggested.  

Substitution elasticity

The elasticity of substitution depends upon the extent of product differentiation

between the domestic and imported products.27 Product differentiation, in turn, depends upon

such factors as quality (e.g., chemistry, appearance, etc.) and conditions of sale (e.g.,

availability, sales terms/ discounts/ promotions, etc.). Based on available information, the

elasticity of substitution between U.S.‐produced PET film and imported PET film is likely to be in

the range of 3 to 6.

 

26 A supply function is not defined in the case of a non‐competitive market.

27 The substitution elasticity measures the responsiveness of the relative U.S. consumption levels of

the subject imports and the domestic like products to changes in their relative prices. This reflects how

easily purchasers switch from the U.S. product to the subject products (or vice versa) when prices

change.
III‐1

PART III: CONDITION OF THE U.S. INDUSTRY

OVERVIEW

The information in this section of the report was compiled from the responses of eleven

firms, which accounted for all of U.S. production of PET film during the period of these current

five‐year reviews, and supplied information on their operations in these reviews and other

proceedings on PET film.1 Important industry events that occurred during the period of these

current five‐year reviews are presented in table III‐1.

Table III-1 

PET film: Important industry events, 2008-13 

Flex USA *** 

Polyplex USA *** 

Terphane *** 

Source: ***. 

Changes experienced by the industry

  

Domestic producers were asked to indicate whether their firm had experienced any

plant openings, relocations, expansions, acquisitions, consolidations, closures, or prolonged

shutdowns because of strikes or equipment failure; curtailment of production because of

shortages of materials or other reasons, including revision of labor agreements; or any other

change in the character of their operations or organization relating to the production of PET

film since 2008.  *** of the 11 domestic producers indicated that they had experienced such

changes; their responses are presented in table III‐2.

 

1 The eleven responding U.S. producers are:  3M Co. (“3M”); Carestream (“Carestream”); Curwood,

Inc. (“Curwood”); DuPont Teijin Films (“DuPont Teijin”); Eastman Kodak Co. (“Kodak”); Flex Films (USA)

Inc. (“Flex USA”); Mitsubishi Polyester Film, Inc. (“Mitsubishi”); Polyplex USA LLC (“Polyplex USA”); SKC

Inc. (“SKC”); Terphane Inc. (“Terphane”); and Toray Plastics (America), Inc. (“Toray”).
III‐2

Table III-2 

PET film: Changes in the character of U.S. operations since January 1, 2008 

Firm Production 

facility location 

Capacity 

(1,000 pounds) 

Operational changes 

3M St. Paul MN 

Decatur, AL 

Greenville, SC 

*** *** 

*** 

*** 

*** 

Carestream Rochester, NY *** *** 

Curwood Oshkosh, WI *** *** 

DuPont Teijin Hopewell, VA 

Circleville, OH 

Florence, SC 

Fayetteville, NC 

*** *** 

*** 

*** 

*** 

*** 

Flex USA Elizabethtown, 

KY 

*** *** 

Kodak Rochester, NY *** *** 

Mitsubishi Greer, SC *** *** 

*** 

*** 

Polyplex USA Decatur, AL *** *** 

*** 

SKC Covington, GA *** *** 

Terphane Bloomfield, NY *** *** 

Toray North 

Kingstown, RI 

*** *** 

Source: Compiled from data submitted in response to Commission questionnaires (U.S. producer questionnaire 

responses, section II-2). 

Anticipated changes in operations

The Commission asked domestic producers to report anticipated changes in the

character of their operations relating to the production of PET film. Their responses appear in

table III‐3.

Table III-3 

PET film: Anticipated changes in the character of U.S. operations

* * * * * * * 

U.S. PRODUCTION, CAPACITY, AND CAPACITY UTILIZATION

Several responding U.S. producers have foreign affiliations and/or production facilities.

DuPont Teijin is *** owned by Teijin Holdings USA, Inc., New York, NY, and *** owned by E.I.

DuPont de Nemours & Co., Wilmington, DE.  DuPont also ***.  Flex USA is ***.  Mitsubishi is
III‐3

***.  Polyplex USA reported that it is ***.  SKC reported that it is ***.  Terphane  reported  that

it ***.  Toray reported that it is related to ***.2

The Commission asked U.S. producers whether the production equipment and the

production and related workers (“PRWs”) employed in the production of PET film were used to

produce other products.  ***.  ***.   ***.3

Table III‐4 presents U.S. producers’ production, capacity, and capacity utilization, by

firm.  

 

2 U.S. producers’ questionnaire responses (section I‐4, section I‐6, and section I‐7).

3 U.S. producer questionnaire responses (section II‐5).  
III‐4

Table III-4 

PET film: U.S. producers’ production, capacity, and capacity utilization, by firm, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Capacity (1,000 pounds) 

3M Company *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

 Total 720,103 702,692 700,955 624,565 620,209 710,024

 Production (1,000 pounds) 

3M Company *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

 Total 620,246 550,720 602,656 510,811 495,378 543,023

 Capacity utilization (percent) 

3M Company *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

 Average 86.1 78.4 86.0 81.8 79.9 76.5

  Source: Compiled from data submitted in response to Commission questionnaires.
III‐5

Constraints on capacity

*** of the 11 responding U.S. producers reported constraints in the manufacturing

process.  Most frequently cited constraints were ***.  Reported constraints are presented in

the tabulation that follows.

* * * * * * * 

U.S. PRODUCERS’ U.S. SHIPMENTS AND EXPORTS

Table III‐5 presents U.S. producers’ U.S. shipments, export shipments, and total

shipments.  U.S. commercial shipments fluctuated downward during 2008‐13.  *** U.S.

producers, ***, accounted for *** percent of U.S. commercial shipment quantity during the

period of these current five‐year reviews.  Internal consumption decreased over the period.  

Certain U.S. producers consume *** of their production captively; however, *** report any

internal consumption of PET film.  No U.S. producers reported transfers to related forms during

the period of these current 5‐year reviews.  Nine firms reported export shipments during all or

a portion of the period of the current five‐year reviews.  *** firms accounted for an  

aggregated *** percent of U.S. exports during 2008‐13:  ***.  *** export shipments.  Export

markets reported for U.S.‐produced PET film were:  ***.4

  

Captive consumption (internal shipments) accounted for volumes of U.S. producers’ U.S.

shipments for the period of these current five‐year reviews that ranged between ***.      

 

4 U.S. producers’ questionnaire responses (section II‐8, fn. 3).
III‐6

Table III-5 

PET film: U.S. producers’ U.S. shipments, exports shipments, and total shipments, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

Commercial U.S. shipments 400,977 346,265 398,097 346,602 349,209 399,676

Internal consumption 180,991 170,413 149,032 131,406 105,348 103,687

Subtotal, U.S. shipments 581,968 516,678 547,129 478,008 454,557 503,363

Export shipments 32,723 28,501 44,933 39,359 34,901 33,803

Total shipments 614,691 545,179 592,062 517,367 489,458 537,166

 Value (1,000 dollars) 

Commercial U.S. shipments 727,053 583,760 744,606 769,075 714,645 748,889

Internal consumption 377,225 350,633 300,850 283,210 227,747 214,627

Subtotal, U.S. shipments 1,104,278 934,393 1,045,456 1,052,285 942,392 963,516

Export shipments 64,187 58,444 111,416 139,557 115,800 104,660

Total shipments 1,168,465 992,837 1,156,872 1,191,842 1,058,192 1,068,176

 Unit value (dollars per pound) 

Commercial U.S. shipments 1.81 1.69 1.87 2.22 2.05 1.87

Internal consumption 2.08 2.06 2.02 2.16 2.16 2.07

Subtotal, U.S. shipments 1.90 1.81 1.91 2.20 2.07 1.91

Export shipments 1.96 2.05 2.48 3.55 3.32 3.10

Total shipments 1.90 1.82 1.95 2.30 2.16 1.99

 Share of quantity (percent) 

Commercial U.S. shipments 65.2 63.5 67.2 67.0 71.3 74.4

Internal consumption 29.4 31.3 25.2 25.4 21.5 19.3

Subtotal, U.S. shipments 94.7 94.8 92.4 92.4 92.9 93.7

Export shipments 5.3 5.2 7.6 7.6 7.1 6.3

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

 Share of value (percent) 

Commercial U.S. shipments 62.2 58.8 64.4 64.5 67.5 70.1

Internal consumption 32.3 35.3 26.0 23.8 21.5 20.1

Subtotal, U.S. shipments 94.5 94.1 90.4 88.3 89.1 90.2

Export shipments 5.5 5.9 9.6 11.7 10.9 9.8

Total shipments 100.0 100.0 100.0 100.0 100.0 100.0

 Source: Compiled from data submitted in response to Commission questionnaires. 
III‐7

U.S. PRODUCERS’ INVENTORIES

Table III‐6 presents U.S. producers’ end‐of‐period inventories and the ratio of these

inventories to U.S. producers’ production, U.S. shipments, and total shipments over the period

examined.

Table III-6 

PET film: U.S. producers’ inventories, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

U.S. producers' end-of-period 

inventories 60,547 56,657 61,019 50,201 52,158 49,840

 Ratio (percent) 

Ratio of inventories to.-- 

 U.S. production 9.8 10.3 10.1 9.8 10.5 9.2

U.S. shipments 10.4 11.0 11.2 10.5 11.5 9.9

Total shipments 9.8 10.4 10.3 9.7 10.7 9.3

 Source: Compiled from data submitted in response to Commission questionnaires. 

U.S. PRODUCERS’ IMPORTS AND PURCHASES

Table III‐7 presents data on individual U.S. producers’ U.S. production and U.S imports of

PET film, and the ratio of imports to U.S. production over the period examined.   

Table III-7 

PET film: U.S. producers’ U.S. production, imports, and import ratios to U.S. production, 2008-13 

* * * * * * * 

*** U.S. producers ***.   

Table III‐8 presents data on individual U.S. producers’ reported purchases of PET film

imported from subject sources over the period for which data were gathered.   ***.

Table III-8 

PET film: U.S. producers’ U.S. production and purchases of imports, 2008-13 

* * * * * * * 
III‐8

U.S. EMPLOYMENT, WAGES, AND PRODUCTIVITY

Table III‐9 shows U.S. producers’ employment‐related data during the period examined.  

Aggregate number of PRWs decreased irregularly by 11.9 percent during the period for which

data were gathered.  However, several firms exhibited opposing employment trends.  

Specifically, *** producers, while *** during the period of these current five‐year reviews.  

Additionally, industry *** affected the number of PRWs.  Specifically, ***.  Therefore, overall

the PET film industry *** for a *** PRWs during 2008‐13.   

Table III-9 

PET film: Average number of production and related workers, hours worked, wages paid to such 

employees, hourly wages, productivity, and unit labor costs, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

Production-Related Workers (PRWs) 

(number) 2,196 2,020 2,017 1,857 1,837 1,935

Total hours worked (1,000 hours) 4,366 3,977 3,982 3,736 3,756 3,933

Hours worked per PRW (hours) 1,988 1,969 1,974 2,012 2,045 2,033

Wages paid ($1,000) 149,435 138,342 134,079 133,884 136,416 141,613

Hourly wages (dollars per hour) $34.23 $34.79 $33.67 $35.84 $36.32 $36.01

Productivity (pounds per hour) 142.1 138.5 151.3 136.7 131.9 138.1

Unit labor costs (dollars per pound) $0.24 $0.25 $0.22 $0.26 $0.28 $0.26

 Source: Compiled from data submitted in response to Commission questionnaires. 
III-9 

PART III: FINANCIAL EXPERIENCE OF U.S. PRODUCERS

Background

Eleven U.S. producers provided useable financial data on their operations producing PET

film.5 Internal consumption of PET film by *** accounted for a declining share of U.S.

producers’ total sales, from *** percent by quantity and *** percent by value in 2008 to ***

percent by quantity and *** percent by value in 2013. All of the firms reported that their

installed equipment is dedicated to the production of PET film; the *** on the same equipment.

Operations on PET Film

Table III‐10 presents aggregated data on U.S. producers’ operations in relation to PET

film over the fiscal years, 2008‐13, examined while table III‐11 presents selected company‐

specific financial data. In brief, the quantity and value of total sales declined from 2008 through

2013. Operating income and net income before taxes increased from a loss in 2008 to a profit‐

high point in 2010, and fell from that year to a loss in 2013. Likewise, the number of firms

reporting operating losses decreased from 2008 to 2010‐2011 and increased in 2012 and 2013.

Cash flow increased from 2008 to a high in 2010, falling thereafter through 2013. 

 

5 These firms were:  3M, Curwood, Carestream, DuPont Teijin, Kodak, Flex USA, Mitsubishi, Polyplex

USA, SKC, Terphane, and Toray. Each firm, ***, reported on a calendar year basis. ***. Transfers to

related firms were reported by *** classified them as exports in the trade section of the Commission’s

questionnaire.
III-10 

Table III-10 

PET film: Results of operations of U.S. producers, fiscal years, 2008-13 

 Item 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Quantity (1,000 pounds) 

Commercial sales 433,096 371,704 435,224 371,680 367,676 391,398 

Internal consumption1 *** *** *** *** *** ***

Transfers to related firms2 *** *** *** *** *** ***

Total net sales 614,691 545,179 592,062 517,366 489,458 508,794 

 Value (1,000 dollars) 

Commercial sales 789,234 630,735 824,589 835,720 761,694 763,439 

Internal consumption1 *** *** *** *** *** ***

Transfers to related firms2 *** *** *** *** *** ***

Total net sales 1,168,465 992,837 1,156,872 1,191,841 1,058,192 1,033,019 

Cost of goods sold 

(COGS): 

 Raw materials 579,597 424,267 503,604 600,990 550,400 534,555 

 Direct labor 161,242 150,657 144,069 148,531 148,735 154,425 

 Other factory costs 312,083 303,581 303,734 251,112 246,065 253,202 

 Total COGS 1,052,922 878,505 951,407 1,000,633 945,200 942,182 

Gross profit 115,543 114,332 205,465 191,208 112,992 90,837 

SG&A expenses 126,771 115,666 109,823 100,454 93,183 97,543 

Operating income or (loss) (11,228) (1,334) 95,642 90,754 19,809 (6,706)

Other income or 

(expense), net3 (34,003) (36,425) (12,734) (8,388) (14,304) (21,099)

Net income or (loss) (45,231) (37,759) 82,908 82,366 5,505 (27,805)

Depreciation/amortization 102,524 108,072 110,877 76,950 77,781 62,812 

Cash flow 57,293 70,313 193,785 159,316 83,286 35,007 

 Number of firms 

Reporting operating 

losses4

 5 6 *** *** 4 6 

Reporting data (sales) 9 9 9 9 9 10 

Table continued on the next page. 
III-11 

Table III-10--Continued

PET film: Results of operations of U.S. producers, fiscal years, 2008-13 

Item 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Ratio to total net sales (percent) 

COGS: 

 Raw materials 49.6 42.7 43.5 50.4 52.0 51.7 

 Direct labor 13.8 15.2 12.5 12.5 14.1 14.9 

 Other factory costs 26.7 30.6 26.3 21.1 23.3 24.5 

 Total COGS 90.1 88.5 82.2 84.0 89.3 91.2 

Gross profit 9.9 11.5 17.8 16.0 10.7 8.8 

SG&A expenses 10.8 11.7 9.5 8.4 8.8 9.4 

Operating income or 

(loss) (1.0) (0.1) 8.3 7.6 1.9 (0.6)

Net income or (loss) (3.9) (3.8) 7.2 6.9 0.5 (2.7)

 Unit value (dollars per pound) 

Commercial sales 1.82 1.70 1.89 2.25 2.07 1.95 

Internal consumption *** *** *** *** *** ***

Transfers to related firms *** *** *** *** *** ***

Total net sales 1.90 1.82 1.95 2.30 2.16 2.03 

COGS: 

 Raw materials 0.94 0.78 0.85 1.16 1.12 1.05 

 Direct labor 0.26 0.28 0.24 0.29 0.30 0.30 

 Other factory costs 0.51 0.56 0.51 0.49 0.50 0.50 

 Total COGS 1.71 1.61 1.61 1.93 1.93 1.85 

Gross profit 0.19 0.21 0.35 0.37 0.23 0.18 

SG&A expenses 0.21 0.21 0.19 0.19 0.19 0.19 

Operating income or 

(loss) (0.02) (5

) 0.16 0.18 0.04 (0.01)

Net income or (loss) (0.07) (0.07) 0.14 0.16 0.01 (0.05)

1

 Internal consumption was reported by ***. 

2

 Transfers to related firms was reported by ***. 

3

 Other income/(expense) consists mostly of interest expense. Other expenses, reported by ***. 4

 Firms reported operating losses were: ***. 

5 Less than $0.005, but negative. 

Note.—See table C-2 for a calculation of the industry’s merchant market sales and costs. 

Source: Compiled from data submitted in response to Commission questionnaires. 
III-12 

Table III-11 

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Total net sales quantity (1,000 pounds) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 614,691 545,179 592,062 517,366 489,458 508,794 

 Total net sales value (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 1,168,465 992,837 1,156,872 1,191,841 1,058,192 1,033,019 

 Total COGS (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 1,052,922 878,505 951,407 1,000,633 945,200 942,182 

Table continued on the next page. 
III-13 

Table III-11--Continued

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Gross profit or (loss) (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 115,543 114,332 205,465 191,208 112,992 90,837 

 Total SG&A expenses (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 126,771 115,666 109,823 100,454 93,183 97,543 

Operating income or (loss) (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms (11,228) (1,334) 95,642 90,754 19,809 (6,706)

Table continued on the next page. 
III-14 

Table III-11--Continued

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Raw material costs as a ratio to net sales (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 49.6 42.7 43.5 50.4 52.0 51.7 

 Direct labor costs as a ratio to net sales (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 13.8 15.2 12.5 12.5 14.1 14.9 

 Other factory costs as a ratio to net sales (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 26.7 30.6 26.3 21.1 23.3 24.5 

Table continued on the next page. 
III-15 

Table III-11--Continued

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Total COGS as a ratio to net sales (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 90.1 88.5 82.2 84.0 89.3 91.2 

 Total SG&A expenses as a ratio to net sales (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 10.8 11.7 9.5 8.4 8.8 9.4 

 Operating income or (loss) as a ratio to net sales (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms (1.0) (0.1) 8.3 7.6 1.9 (0.6)

Table continued on the next page. 

 
III-16 

Table III-11--Continued

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Unit total net sales (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 1.90 1.82 1.95 2.30 2.16 2.03 

Unit raw material costs (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 0.94 0.78 0.85 1.16 1.12 1.05 

 Unit direct labor costs (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 0.26 0.28 0.24 0.29 0.30 0.30 

Table continued on the next page.
III-17 

Table III-11--Continued

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

 Unit other factory costs (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 0.51 0.56 0.51 0.49 0.50 0.50 

Unit total COGS (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 1.71 1.61 1.61 1.93 1.93 1.85 

Table continued on the next page. 
III-18 

Table III-11--Continued

PET film: Results of operations of U.S. producers, by firm, fiscal years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

 Unit total SG&A expenses (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms 0.21 0.21 0.19 0.19 0.19 0.19 

 Unit operating income or (loss) (dollars per pound) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

All firms (0.02) (

3

) 0.16 0.18 0.04 (0.01)

1

 Not applicable (***). 

2

 ***. 

3

 ***. 

Note.—***. 

Source: Compiled from data submitted in response to Commission questionnaires 
III-19 

Total net sales

As shown in table III‐10, total net sales include commercial sales, internal consumption,

and transfers to related firms. Total sales irregularly declined from 2008 to 2013 in terms of

quantity and value; the average unit value of total sales increased from 2008 to 2011 and then

declined from 2011 to 2013. The quantity reported for internal consumption declined while the

quantity reported for transfers irregularly increased from 2008 to 2013. The value of internal

consumption fell from 2008 through 2013 while the value of transfers increased irregularly

during the same period; the value and average unit value of transfers reached a high point in

2011, like commercial sales.

Table III‐11 shows that the sales experience was mixed: *** in 2013. In terms of

quantity, five others experienced a decrease in sales from 2008 to 2013 while three other firms

increased sales between the two years. In terms of value, four firms reported lower sales in

2013 compared with 2008 while four reported higher sales between the two years. With regard

to commercial sales quantity and value, three firms (***) reported lower sales in 2013 than in

2008 while four other firms (***) reported higher sales. The average unit value of commercial

sales of each of the companies increased between 2008 and 2013, ***.6  

Costs and expenses

As shown in table III‐10, raw material costs represent the single largest component of

overall COGS, averaging approximately 55.3 percent of total COGS on a cumulative basis during

2008‐13 (ranging from 48.3 percent in 2009 to 60.1 percent in 2011). Raw material costs as a

percentage of total net sales value ranged from 42.7 percent in 2009 to 52.0 percent in 2012

and irregularly increased from 2008 to 2013. As shown in table III‐11, average raw material

costs, direct labor, and other factory costs (i.e., conversion costs) vary from company to

company. These costs generally reflect underlying differences in input costs and conversion

costs (labor and overhead). The highest average raw material costs as a ratio to sales were

reported by *** while ***.  

After raw materials, the largest component of reported COGS is other factory costs,

which as a ratio to sales irregularly declined from 26.7 percent to 24.5 percent (and from $0.51

per pound of sales to $0.50 per pound of sales) from 2008 to 2013. Direct labor costs, the

smallest component of COGS, also rose irregularly between 2008 and 2013 as a ratio to sales

and on a per‐unit basis. Both other factory costs and direct labor have more of a fixed cost

component than do raw material costs (which have more of a variable cost component). With

the decline in production and capacity utilization, other factory costs rose on a per‐unit basis

from 2011 to 2013 while direct labor costs fluctuated and were the same in 2013 as in 2012.7

  

 

6 This does not include ***. 7 The cost structure of ***.
III-20 

SG&A expenses were lower in absolute dollars, as a ratio to sales, and on a per‐unit

basis in 2013 than in 2008. Of eight reporting firms (***), SG&A expenses were lower for three

and higher for five in 2013 than in 2008.8

  

Profitability

Table III‐10 shows that the industry’s gross profit, on an absolute and relative basis, rose

substantially from 2008 to 2010 but fell dramatically from 2010 through 2013. Operating

income rose from a loss in both 2008 and 2009 to substantially higher and profitable levels in

2010 and 2011, falling thereafter to a loss in 2013. The number of firms reporting operating

losses fell as the industry’s profitability improved from 2009 to 2010 and 2011 and the number

increased as the industry’s profitability fell in 2012 and 2013. The experience of individual firms

is depicted in table III‐11. Net income before taxes and cash flow generally followed the trend

of operating income/(loss) for the industry and for each firm.9

Variance analysis

A variance analysis for the operations of U.S. producers of PET film is presented in table

III‐12.10 The information for this variance analysis is derived from table III‐10. The information

differs in that while table III‐10 presents data for commercial sales, internal consumption, and

transfers to related firms, table III‐12 presents only the total net sales variance. As the data

depict, operating income increased between 2008 and 2013, attributable to a favorable price

variance (unit prices increased between the periods) that was greater than the unfavorable net

cost/expense variance (unit costs increased). Between 2011‐12 and 2012‐13 operating income

fell because the unfavorable price variance (unit prices fell) was greater than a favorable net

cost/expense variance (unit costs and expenses decreased).

 

8 ***.

9 ***.

10 The Commission’s variance analysis is calculated in three parts:  Sales variance, cost of sales

variance (COGS variance), and SG&A expense variance.  Each part consists of a price variance (in the

case of the sales variance) or a cost or expense variance (in the case of the COGS and SG&A expense

variance), and a volume variance.  The sales or cost/expense variance is calculated as the change in unit

price or per‐unit cost/expense times the new volume, while the volume variance is calculated as the

change in volume times the old unit price or per‐unit cost/expense.  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 components of the

net sales, COGS, and SG&A expense variances.  The overall volume component of the variance analysis is

generally small.
III-21 

Table III-12 

PET film: Variance analysis on the operations of U.S. producers, fiscal years, 2008-13 

Item 

Between fiscal years 

2008-13 2008-09 2009-10 2010-11 2011-12 2012-13 

Value (1,000 dollars) 

Total net sales: 

 Price variance 65,853 (43,493) 78,655 180,923 (69,358) (66,977)

Volume variance (201,299) (132,135) 85,380 (145,954) (64,291) 41,804 

Total net sales variance (135,446) (175,628) 164,035 34,969 (133,649) (25,173)

Cost of sales: 

 Cost/expense variance (70,654) 55,348 2,646 (169,258) 1,456 40,358 

Volume variance 181,394 119,069 (75,548) 120,032 53,977 (37,340)

Total cost of sales 

variance 110,740 174,417 (72,902) (49,226) 55,433 3,018 

Gross profit vairance (24,706) (1,211) 91,133 (14,257) (78,216) (22,155)

SG&A expenses: 

 Cost/expense variance 7,388 (3,231) 15,790 (4,487) 1,852 (679)

Volume variance 21,840 14,336 (9,947) 13,856 5,419 (3,681)

Total SG&A expense 

variance 29,228 11,105 5,843 9,369 7,271 (4,360)

Operating income 

variance 4,522 9,894 96,976 (4,888) (70,945) (26,515)

Summarized as: 

 Price variance 65,853 (43,493) 78,655 180,923 (69,358) (66,977)

Net cost/expense 

variance (63,266) 52,117 18,435 (173,744) 3,309 39,679 

 Net volume variance 1,934 1,270 (115) (12,066) (4,895) 783 

Note.—Unfavorable variances are shown in parentheses; all others are favorable. The data are 

comparable to changes in operating income as presented in table III-10. 

Source: Compiled from data submitted in response to Commission questionnaires. 

Capital expenditures and research and development expenses

Table III‐13 presents data on capital expenditures and research and development

(“R&D”) expenses by firm. Capital expenditures, which were at a high level in 2008 (***)

irregularly declined through 2010; they increased in 2011, 2012, and in 2013, attributable to

***. Five firms reported that they incurred R&D expenses, which irregularly increased from

2008 to 2013.
III-22 

Table III-13 

PET film: Capital expenditures and research and development expenses of U.S. producers, fiscal 

years, 2008-13 

Firm 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Capital expenditures (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

Total 123,403 40,342 35,933 59,041 134,075 212,905 

 R&D expenses (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane *** *** *** *** *** ***

Toray *** *** *** *** *** ***

Average 13,576 12,573 13,276 15,134 15,694 15,017 

Source: Compiled from data submitted in response to Commission questionnaires. 

The Commission’s questionnaire asked firms to describe the nature of their capital

expenditures. Their responses are shown in the tabulation below:
III-23 

Firm Nature or focus of the firm’s capital expenditures 

DuPont Teijin . . . . . . . . . ***. 

Mitsubishi . . . . . . . . . . . . ***. 

SKC . . . . . . . . . . . . . . . . . ***. 

Kodak . . . . . . . . . . . . . . . ***. 

Terphane . . . . . . . . . . . . . ***. 

Toray . . . . . . . . . . . . . . . . ***. 

3M . . . . . . . . . . . . . . . . . . ***. 

Carestream . . . . . . . . . . . ***. 

Flex USA . . . . . . . . . . . . . ***. 

Assets and return on investment

Table III‐14 presents data on the U.S. producers’ total net assets related to PET film and

their return on investment (“ROI”). In general, the total value of net assets increased between

2008 and 2013 due to the ***. ROI, calculated as the reported operating income divided by net

assets, increased (the operating loss lessened) between the two years.
III-24 

Table III-14 

PET film: U.S. producers’ total assets and return on investment, fiscal years, 2008-13 

Item 

Fiscal years 

2008 2009 2010 2011 2012 2013 

Total net assets (1,000 dollars) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane1 *** *** *** *** *** ***

Toray *** *** *** *** *** ***

Total 1,191,453 1,063,368 1,024,962 1,079,306 1,098,011 1,240,456 

 Return on investment ratio (percent) 

3M *** *** *** *** *** ***

Carestream *** *** *** *** *** ***

Curwood *** *** *** *** *** ***

DuPont Teijin *** *** *** *** *** ***

Flex USA *** *** *** *** *** ***

Kodak *** *** *** *** *** ***

Mitsubishi *** *** *** *** *** ***

Polyplex USA *** *** *** *** *** ***

SKC *** *** *** *** *** ***

Terphane1 *** *** *** *** *** ***

Toray *** *** *** *** *** ***

Average (0.9) (0.1) 9.3 8.4 1.8 (0.5)

1

 ***. 

2

 Not applicable: (***). 

3 ***. 

 Source: Compiled from data submitted in response to Commission questionnaires. 
IV‐1

PART IV: U.S. IMPORTS AND THE FOREIGN INDUSTRIES

U.S. IMPORTS

Overview

The Commission issued questionnaires to 32 firms believed to have imported PET film

between 2008 and 2013. Twenty‐one firms provided data and information in response to the

questionnaires, while four firms indicated that they had not imported product within the scope

of these reviews during the period for which data were collected.1 Based on official Commerce

statistics for imports of PET film (less Canada and Oman), based on quantity, importers’

questionnaire data accounted for 83.3 percent of total U.S. imports during 2008‐13 and 67.8

percent of total subject imports during 2008‐13. Firms responding to the Commission’s

questionnaire accounted for the following shares of individual subject country’s subject imports

(as a share of official import statistics, by value) during the period examined.

 93.8 percent of the subject imports from India during 2008‐13

 61.4 percent of the subject imports from Taiwan during 2008‐13

Official Commerce statistics for PET film imported under statistical reporting number

3920.62.00.90 may be overstated as they include nonsubject products, e.g. “equivalent PET

film,” and possibly amorphous (“APET”) and crystalline (“CPET”) PET film.  Further, as discussed

in Part I of this report, there have been two scope reviews concerning PET film, one excluding

tracing and drafting film from India; the second excluding amorphous PET film that is not  

biaxially oriented.  Therefore, in light of the data coverage by the Commission’s questionnaires,

possible overstatement of Commerce statistics, and scope exclusions, the PET film import data

in this report are based on questionnaire responses.

  

Imports from subject and nonsubject countries

Table IV‐1 present information on U.S. imports of PET film from India, Taiwan and all

other sources over the period examined.   Three U.S. importers accounted for an aggregate ***

percent of U.S. imports of PET film from India *** during the 2008‐13 period of review.  ***.

With respect to U.S. imports from Taiwan, three importers accounted for an aggregate

*** percent *** of U.S. imports of PET film from Taiwan during the 2008‐13 period of review.  

U.S. importers from Taiwan ***.    

                                                      

1 ***.
IV‐2

Table IV-1 

PET film: U.S. imports by source, 2008-13 

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

U.S. Imports from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total U.S. imports 172,274 128,498 180,979 188,342 195,302 153,777 

 Value (1,000 dollars)1

U.S. Imports from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total U.S. imports 268,097 166,932 286,102 362,080 284,007 216,230 

 Unit value (dollars per pound) 

U.S. Imports from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total U.S. imports 1.56 1.30 1.58 1.92 1.45 1.41 

 Share of quantity (percent) 

U.S. Imports from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0 

 Share of value (percent) 

U.S. Imports from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total U.S. imports 100.0 100.0 100.0 100.0 100.0 100.0 

 Ratio to U.S. production (percent) 

U.S. Imports from.-- 

 India *** *** *** *** *** ***

Taiwan *** *** *** *** *** ***

Subtotal, subject sources *** *** *** *** *** ***

All other sources *** *** *** *** *** ***

Total U.S. imports 27.8 23.3 30.0 36.9 39.4 28.3 

1 Landed duty paid. 

Source: Compiled from data submitted in response to Commission questionnaires. 
IV‐3

Table IV‐2 presents information based on official Commerce statistics for U.S. imports of

PET film from major nonsubject countries.

   

Table IV-2 

PET film: U.S. imports from major nonsubject sources, by source, 2008-13

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

Nonsubject U.S. imports from.-- 

 China 11,732 5,484 14,643 13,479 8,999 12,409 

Germany 4,103 3,492 4,113 4,593 5,208 6,234 

Indonesia 2,100 1,079 6,495 9,335 10,646 10,327 

Korea 59,161 43,287 45,987 38,010 31,139 34,182 

Mexico 3,757 17,466 38,136 51,830 78,375 56,084 

Thailand 11,848 5,795 10,521 15,965 18,902 17,943 

Turkey 12,977 11,426 18,654 20,978 21,631 10,018 

United Arab Emirates 14,705 5,992 24,097 30,412 35,904 26,551 

All other sources 31,163 20,833 19,237 16,851 17,627 19,976 

Total U.S. imports from 

 nonsubject sources 151,545 114,855 181,884 201,452 228,431 193,724 

 Value (1,000 dollars)1

Nonsubject U.S. imports from.-- 

 China 13,906 6,951 22,268 29,447 15,006 17,433 

Germany 11,609 10,926 11,717 16,029 19,000 19,923 

Indonesia 2,943 1,406 8,380 16,138 13,276 12,448 

Korea 75,984 51,365 68,653 74,648 52,987 59,719 

Mexico 4,601 17,595 52,100 85,357 100,233 72,297 

Thailand 13,690 5,898 12,231 26,513 22,187 20,187 

Turkey 15,557 10,646 23,303 33,745 24,382 10,644 

United Arab Emirates 17,387 6,166 33,217 56,424 41,220 28,465 

All other sources 95,118 67,799 87,022 99,050 84,904 87,072 

Total U.S. imports from 

 nonsubject sources 250,796 178,752 318,892 437,351 373,196 328,187 

 Unit value (dollars per pound) 

Nonsubject U.S. imports from.-- 

 China 1.19 1.27 1.52 2.18 1.67 1.40 

Germany 2.83 3.13 2.85 3.49 3.65 3.20 

Indonesia 1.40 1.30 1.29 1.73 1.25 1.21 

Korea 1.28 1.19 1.49 1.96 1.70 1.75 

Mexico 1.22 1.01 1.37 1.65 1.28 1.29 

Thailand 1.16 1.02 1.16 1.66 1.17 1.13 

Turkey 1.20 0.93 1.25 1.61 1.13 1.06 

United Arab Emirates 1.18 1.03 1.38 1.86 1.15 1.07 

All other sources 3.05 3.25 4.52 5.88 4.82 4.36 

Total U.S. imports from 

 nonsubject sources 1.65 1.56 1.75 2.17 1.63 1.69 

  Table continued on next page. 

 
IV‐4

Table IV-2--Continued 

PET film: U.S. imports from major nonsubject sources, by source, 2008-13

Item 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Share of total U.S. imports based on quantity (percent) 

Nonsubject U.S. imports 

from.-- 

 China 6.6 3.9 6.9 5.8 3.6 5.8 

Germany 2.3 2.5 1.9 2.0 2.1 2.9 

Indonesia 1.2 0.8 3.1 4.0 4.3 4.9 

Korea 33.3 30.8 21.8 16.5 12.5 16.1 

Mexico 2.1 12.4 18.1 22.5 31.4 26.4 

Thailand 6.7 4.1 5.0 6.9 7.6 8.4 

Turkey 7.3 8.1 8.8 9.1 8.7 4.7 

United Arab Emirates 8.3 4.3 11.4 13.2 14.4 12.5 

All other sources 17.5 14.8 9.1 7.3 7.1 9.4 

Total 85.2 81.8 86.2 87.3 91.4 91.0 

 1 Landed duty paid. 

Source: Compiled from official import statistics for HTS statistical reporting number 3920.62.00.90 excluding data 

imported from Canada and Oman as out-of-scope merchandise.

The three top nonsubject countries for U.S. imports of PET film accounted for an

aggregated 60.3 percent of nonsubject U.S. imports of PET film in 2013:  Mexico ( 29.0 percent),

Korea (17.6 percent), and the United Arab Emirates (13.7 percent).  ***.2

   Although Korea and

the United Arab Emirates are nonsubject countries for these current five‐year reviews, both

countries are subject to antidumping duty orders as a result of other investigations as

mentioned earlier in this report.

U.S. importers’ imports subsequent to December 31, 2013

The Commission requested importers to indicate whether they had imported or

arranged for the importation of PET film from India and/or Taiwan for delivery after December

31, 2013.  Table IV‐3 presents the U.S. import quantities U.S. firms contracted for delivery after

December 31, 2013.

Table IV-3 

PET film: U.S. importers’ orders for delivery subsequent to December 31, 2013

*            *            *            *            *            *            *

 

   

                                                      

2 Staff interview with ***, April 29, 2014.
IV‐5

U.S. IMPORTERS’ INVENTORIES

Table IV‐4 presents data for inventories of U.S. imports of PET film from India, Taiwan,

and all other sources held in the United States.  The majority of end‐of‐period inventories of

U.S. imports of PET film from India were held by ***.  Significant end‐of‐period inventories of

U.S. imports of PET film from Taiwan were held by ***.  With respect to of end‐of‐period

inventories of U.S. imports of PET film from all other sources, ***.

Table IV-4 

PET film: U.S. importers’ end-of-period inventories of imports, by source, 2008-13

*            *            *            *            *            *            * 

CUMULATION CONSIDERATIONS

In assessing whether imports should be cumulated, the Commission determines

whether U.S. imports from the subject countries compete with each other and with the

domestic like product and has generally considered four factors: (1) fungibility, (2) presence of

sales or offers to sell in the same geographical markets, (3) common or similar channels of

distribution, and (4) simultaneous presence in the market. Additional information concerning

fungibility, geographical markets, and simultaneous presence in the market is presented below.

Fungibility

The Commission asked if PET film produced in the United States and in other countries

were interchangeable (i.e., can they be physically used in the same applications).  With respect

to interchangeability of PET film produced in the United States., India, and Taiwan, the majority

of responding firms reported that U.S‐produced PET film and PET film imported from India and

Taiwan “always” or “frequently” can be used interchangeably (table II‐10).

Presence in the market

Imports generally have been simultaneously present in the U.S. market throughout the

period examined.  Imports of PET film from both India and Taiwan entered the United States in

all 72 months of the 2008‐13 period of review.

Geographical markets

Table IV‐5 presents U.S. imports of PET film by subject country source and customs

district of entry, 2008‐13. PET film from both India and Taiwan compete for users without

regard to geographical location in the United States.  While U.S. imports of PET film from India

and Taiwan may enter select customs districts, the product is then generally sold nationwide.  

For the 2008‐13 period of these current five‐year reviews, imports of PET film from India

principally entered through the customs districts of the East and the Mid West; whereas, U.S.
IV‐6

imports of PET film from Taiwan principally entered through the customs districts of the East

and West.

Table IV-5 

PET film: Subject U.S. imports by source and Customs District of entry, 2008-13 

Region 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Share of total quantity (percent) 

U.S. imports from India: 

 East1

 48.7 45.6 56.8 40.0 57.4 45.2

 South2 13.7 28.8 12.7 9.3 7.3 8.7

 Mid West3 30.5 15.8 22.1 44.1 28.3 43.3

 West4 7.2 9.8 8.3 6.5 7.0 2.9

 Total 100.0 100.0 100.0 100.0 100.0 100.0

U.S. imports from Taiwan: 

 East1

 57.1 61.7 60.6 59.2 39.4 52.2

 South2 0.6 0.4 0.4 0.3 2.0 2.3

 Mid West3 28.1 20.9 15.3 9.2 5.4 0.9

 West4 14.2 17.0 23.7 31.2 53.2 44.6

 Total 100.0 100.0 100.0 100.0 100.0 100.0

 1

 Includes Baltimore, MD; Boston, MA; Buffalo, NY; Charleston, SC; Charlotte, NC; New York, NY; Norfolk, VA; 

Ogdensburg, NY; Philadelphia, PA; Savannah, GA; Washington, DC. 2

 Includes Dallas-Fort Worth, TX; Houston-Galveston, TX; Laredo, TX; Miami, FL; Mobile, AL; New Orleans, LA; San 

Juan, PR; Tampa, FL. 

3

 Includes Chicago, IL; Cleveland, OH; Detroit, MI; Milwaukee, WI; Minneapolis, MN; St. Louis, MO. 4

 Includes Anchorage, AK; Columbia-Snake, OR; Great Falls, MT; Honolulu, HI; Los Angeles, CA; San Diego, CA; 

San Francisco, CA; Seattle, WA. 

 Source: Compiled from official statistics of the Department of Commerce. 

SUBJECT COUNTRY PRODUCERS

According to industry sources, installed PET film capacity in India is *** PET film capacity

in Taiwan (table IV‐6).

   

Table IV-6 

PET film: India and Taiwan capacity, 2012

*            *            *            *            *            *            *

Trade balances for India and Taiwan are presented in table IV‐7.

 
IV‐7

Table IV-7 

PET film: India and Taiwan exports, imports, and trade balances, 2008-13

Reporting country 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

Subject: 

 India: 

 Exports 92,398 50,301 122,315 211,527 197,373 206,833 

Imports 4,052 18,034 20,596 15,686 9,923 32,320 

Trade balance 88,346 32,267 101,719 195,841 187,450 174,513 

 Taiwan: 

 Exports 50,975 50,124 70,607 168,124 210,184 214,492 

Imports 43,235 53,043 72,380 71,926 70,438 79,031 

Trade balance 7,740 (2,919) (1,773) 96,199 139,746 135,461 

Note:-- Export and import figures for HTS subheading 3920.62 include nonsubject products, e.g. metallized PET film, 

“equivalent PET film,” and possibly amorphous (“APET”) and crystalline (“CPET”) film. 

Source: Global Trade Atlas, accessed April 4, 2014. 

Other than in the United States, India is subject to antidumping duties on PET film from

***.3

THE INDUSTRY IN INDIA

Overview

The *** producers of PET film in India are presented earlier in table IV‐6.

Operations on PET film

Industry sources indicated ten producers of PET film in India for the period of these

current five‐year reviews;4 whereas, there were eight producers during the period of the first

five‐year reviews and six producers during the original investigation.  Six producers responded

to the Commission questionnaires both in the original investigation and for the period of the

first five‐year review (Ester, Garware, Jindal, MTZ, SRF, and Uflex).  Only one producer, Polyplex  

India, related to the U.S. producer Polyplex USA, responded to the Commission questionnaire

for the period of these current five‐year reviews.  Polyplex India reported an estimate of ***

percent of total production of PET film in India accounted for by its production  in 2013 and an

estimated *** percent of total exports to the United States of PET film from India accounted for

by its exports in 2013.  Polyplex India indicated that the firm’s total sales accounted for by

                                                      

3 Foreign producer questionnaire response, section II‐10.  South Korean antidumping duties on PET

film from India were extended for three years effective May 2012.  Domestic Interested Parties

Prehearing Brief, p. 16 and exh. 3. 4 ***.
IV‐8

PET film in their most recent fiscal year was *** percent.5

    PET film capacity, production,

shipments, and inventories in India, 2008‐13, are presented in table IV‐8.

  

Table IV-8 

PET film: India capacity, production, shipments, and inventories, 2008-13

*            *            *            *            *            *            *

 

Polyplex India further reported that ***,6 it had ***.7

Polyplex India reported that it ***.8  No *** for PET film.9

According to industry sources, ***.10  

Table IV‐9 presents export country destinations for PET film produced in India.   

Table IV-9 

PET film: Indian export destinations, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

World 92,398 50,301 122,315 211,527 197,373 206,833 

Italy 25,752 10,752 12,694 17,009 27,370 33,043 

Bangladesh 2,291 2,639 3,545 8,131 11,938 14,901 

United States 3,616 1,920 11,263 24,176 17,624 13,327 

Germany 507 276 3,704 3,627 8,605 12,236 

China 4,312 6,056 10,639 11,118 8,944 11,191 

Malaysia 849 320 170 3,840 3,441 7,895 

South Africa 1,276 472 2,917 6,290 7,427 6,609 

Thailand 1,448 1,722 4,330 6,255 8,746 6,601 

United Arab Emirates 4,881 507 6,281 8,973 4,436 6,056 

Nigeria 3,982 1,400 2,549 4,297 4,383 5,787 

All Other 43,486 24,238 64,227 117,819 94,468 89,181 

 Note:-- Export and import figures for HTS subheading 3920.62 include nonsubject products, e.g. metallized PET 

film, “equivalent PET film,” and possibly amorphous (“APET”) and crystalline (“CPET”) film. 

Source: Global Trade Atlas, accessed April 4, 2014. 

   

                                                      

5 Foreign producer questionnaire response, section II‐8.

6 Foreign producer questionnaire response, section II‐14 and section II‐4. 7 Foreign producer questionnaire response, section II‐11.

8 Foreign producer questionnaire response, section II‐2.

9 Foreign producer questionnaire response, section II‐6.

10 ***.
IV‐9

Reported *** include the following:

 ***

 ***

 ***11  

According to industry sources, PET film consumption in India is ***.12

THE INDUSTRY IN TAIWAN

Overview

A summary of PET film supply and demand in Taiwan is presented in table IV‐10.

Table IV-10 

PET film: Taiwan capacity, production, imports, exports, and consumption, 2011

*            *            *            *            *            *            *

According to industry sources, Taiwan has ***.13

    

Operations on PET Film

Industry sources indicated there were two producers of PET film in Taiwan for the

period of these current five‐year reviews.14  One producer, Nan Ya, responded to the

Commission’s questionnaires for the period of the first five‐year review; whereas, two

producers, Nan Ya and Vast Plastic Corp. (“Vast”), responded to the Commission’s

questionnaires for the period of the current five‐year reviews.

Nan Ya reported an estimate of *** percent of total production of PET film in Taiwan

accounted for by its production in 2013 and an estimated *** percent of total exports to the

United States of PET film from Taiwan accounted for by its exports in 2013.  Nan Ya indicated

that the firm’s total sales accounted for by PET film in their most recent fiscal year was ***

percent.15  Vast’s estimated percentage of production of PET film in Taiwan is calculated as ***

percent and Vast’s estimated percentage of exports to the United States from Taiwan in 2013 is

calculated as *** percent.16  Vast indicated that the firm’s total sales accounted for by PET film in

their most recent fiscal year was *** percent.17

                                                      

11 ***. 12 ***.

13 ***. 14 ***.

15 Nan Ya’s Foreign producer questionnaire response, section II‐8.

16 ***.  Vast’s foreign producer questionnaire response, section II‐14.   
IV‐10

Nan Ya further reported that, ***.18   With respect to constraints on production, Nan Ya

reported that it ***.19   ***.20     

Nan Ya reported that it has ***.21  

Nan Ya further indicated that ***.22     

In addition, Nan Ya reported that ***.23  Nan Ya reported *** barriers to trade in any

countries other than the United States, *** on its exports of PET film other than the United

States.24  

Vast reported that its plant ***.25 Vast further reported that its constraints on capacity

were ***.26   Vast further reported ***.27

Table IV‐11 presents PET film capacity, production, shipments, and inventories in

Taiwan.   Nan Ya identified its principal export markets as ***.  Vast identified its principal

export markets as ***.28  

Table IV-11 

PET film: Taiwan capacity, production, shipments, and inventories, 2008-13

*            *            *            *            *            *            * 

Table IV‐12 presents export country destinations for PET film produced in Taiwan.   

 

                                                            

(...continued) 17 Vast’s foreign producer questionnaire response, section II‐8.

18 Nan Ya’s Foreign producer questionnaire response, section II‐3.

19 Nan Ya’s Foreign producer questionnaire response, section II‐6.

20 Nan Ya’s Foreign producer questionnaire response, section II‐7. 21 Nan Ya’s Foreign producer questionnaire response, section II‐11. 22 Ibid.

23 Ibid.

24 Nan Ya’s foreign producer questionnaire response, section II‐10

25 Vast’s foreign producer questionnaire response, section II‐2.

26 Vast’s foreign producer questionnaire response, section II‐6.

27 Vast’s foreign producer questionnaire response, sections II‐3, II‐5, II‐7, II‐9, and II‐10.

28 Foreign producer questionnaire responses, section II‐14.
IV‐11

Table IV-12 

PET film: Taiwan export destinations, 2008-13 

Destination 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

World 50,964 50,122 70,610 168,127 210,184 214,494 

China 13,250 13,448 24,535 58,063 104,757 107,916 

Japan 10,373 10,013 9,771 60,435 47,476 53,361 

Hong Kong 6,422 7,075 12,185 15,097 18,775 14,458 

United States 8,056 7,652 9,409 13,633 11,993 12,289 

Malaysia 1,261 1,711 2,917 3,045 3,494 4,092 

Canada 1,878 1,744 1,958 2,648 3,856 3,056 

Germany 97 13 77 1,548 3,086 2,758 

Australia 1,497 1,711 1,843 2,392 2,485 2,266 

New Zealand 1,166 1,230 2,161 2,260 2,231 2,119 

Philippines 871 514 291 1,803 2,511 2,108 

All Other 6,094 5,011 5,463 7,202 9,520 10,073 

Note:-- Export and import figures for HTS subheading 3920.62 include nonsubject products, e.g. metallized PET film, 

“equivalent PET film,” and possibly amorphous (“APET”) and crystalline (“CPET”) film. 

Source: Global Trade Atlas, accessed April 4, 2014. 

THE INDUSTRIES IN INDIA AND TAIWAN COMBINED   

Table IV‐13 presents reported data on the PET film industries in India and Taiwan

combined.

Table IV‐13

PET film:  India’s and Taiwan’s capacity, production, shipments, and inventories, 2008‐13

*            *            *            *            *            *            * 

GLOBAL MARKET  

The PET film industry is global in nature with operations on virtually every continent.

Asia dominates, followed by North America (U.S. and Mexico), Europe, and the Middle East, in

order, accounting for the majority of the current global PET film annual supply capability of

roughly *** million metric tons.29 30   

Typical of many growth industries, the global PET film industry which grew at an average

annual growth of *** percent31 appears conceptually to be cyclical in nature owing to the

                                                      

29 *** supplement response to producers’ questionnaire, section I‐8.

30 ***.

31 Ibid, footnotes 27 and 28.
IV‐12

fundamental laws of supply and demand. As supply and demand head towards balance at the

top of a given cycle, profitability generally increases and many producers are encouraged to

plan new capacity which, in turn, usually leads to an uncertain downward period of oversupply

and reduced profitability.  During periods of oversupply, producers depending upon their

particular market situation may choose to rationalize or idle more obsolete capacity, throttle

back more competitive capacity and ride out the lower periods of the downturn, or plan to

capitalize on exports of certain available surplus capacity.  Certain producers may also opt to

import commodity films of lower margin potential to maximize profitability in higher valued

films.32  A myriad of external factors may prove to affect the duration of fundamental PET film

supply and demand cycles, including the global economic climate, exchange rate fluctuations,

petroleum and natural gas prices, demographics and geopolitics.33   

In 2010, the global PET film industry operated at an effective capacity utilization rate of

*** percent owing to pent up consumer demand in association with recovery from the

recessionary period of 2008‐09.  Producers’ inventories were drawn down34 on top of near full

capacity operations as consumers rebuilt inventories and demanded additional supplies to

satisfy recovering consumer demand.35 36 The growth in emerging markets for optical and

photovoltaic applications was reportedly a major driver of market demand together with the

return of industrial and electrical applications.  Industrial and electrical applications were

reported to be more strongly affected during the recession compared to packaging applications

which are related to less discretionary food consumption. Even though demand contracted

somewhat during the recessionary period, supply and demand reportedly remained reasonably

balanced because of the lack of capacity additions and the closure of old lines during the

previous years.  The consequent higher prices and margins following the tight supply demand

situation of 2010 reportedly attracted interest in a new round of global capacity expansion

during the 2011‐13 period.37 38

  

Production capacity and domestic consumption

Global PET film capacity in the 2012‐13 period was estimated to approximate ***

million metric tons. The Asian countries dominate global PET film production capability, and

command some *** percent of global capacity, followed by North America ***, Europe ***,

the Middle East ***, and other regions, South America and Africa *** in aggregate.  China

alone, accounts for about *** percent of global capacity and some *** percent of Asian

capacity.  Korean capacity comprises about *** percent of global capacity and *** percent of

                                                      

32 ***  Importers’ questionnaire response, section II‐4.   33 Commission staff research and questionnaire responses.

34 *** producers’ questionnaire response, section II‐4.

35 *** producers’ questionnaire, section I‐8.   36 ***.

37 Ibid.   38 PET film prices *** in 2010. *** producers’ questionnaire, section I‐8.  
IV‐13

Asian capacity; India, *** percent of global and *** percent of Asian; Japan, *** percent of

global, and *** percent of Asian; and Taiwan, *** percent of global, and *** percent of Asian.     

Global PET film domestic consumption patterns in the 2012‐13 period generally track

that of production capability patterns, but differ somewhat considering trade patterns.  Asia

accounts for *** percent of total global consumption, North America, *** percent, Europe, ***

percent, the Middle East, *** percent and Africa and South America, *** percent in

aggregate.39  

Global supply and demand patterns 2012‐17

Available data suggest that both global PET film supply capability and demand will ***

during the five year period encompassing 2012‐17, and that *** will be available during this

period.  The three forecasts currently available to the Commission in general indicate that

capacity growth will *** when capacity is expected to *** while demand continues to *** at a

compound annual rate of *** percent.40 41  Demand is reported to be growing faster in ***

than globally, at an annual rate of around *** percent, but supply demand ***.42    

Global consumption of PET film by major end‐use markets is expected to continue to

experience positive average annual growth of *** percent in aggregate.  Packaging, the ***

global end‐use market ***, is expected to grow at an average annual rate of *** percent;

Industrial and Specialties, ***, *** percent annual growth; Electrical/Electronic, ***, ***

percent annual growth; Imaging and Magnetic Media, *** and *** percent annual growth

respectively.43  

Global Trade

The following tables present global data trends of the leading exporting and importing

countries of PET film during the five year period 2008‐13, together with corresponding country

trade balances.  Data were sourced from information available on the Global Trade Atlas (GTIS)

database at the 6‐digit HTS level (3920.62) as subject PET film under international conventions

is not definitively broken out at the 10‐digit level (3920.62.0090) applicable to U.S. trade

statistics.  Thus, the individual country trade data reported at the 6‐digit level potentially

contain nonsubject sources of PET film, although the data as reported are believed to be

indicative of individual country trends in the trade of subject PET films.  The trade data tables

which follow are reported on a volume basis in thousands of pounds and are ranked on a high

to low basis by country on calendar year 2013.       

   

                                                      

39 ***.

40 Ibid, ***. 41 *** supplement responses to producers’ questionnaires, section I‐8.

42 *** supplement response to producers’ questionnaire, section I ‐8.

43 *** supplemental response to producers’ questionnaire, section I‐8.
IV‐14

Table IV‐14 details leading global exporting countries of PET film.  European Union (EU‐

28) external export trade is also reported.  

Table IV-14 

PET film: Top exporting countries and regions, 2008-13

Reporting country 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

China 203,848 139,167 359,421 310,371 332,510 403,831 

Korea 334,403 284,952 311,484 330,067 325,706 346,037 

Japan 261,486 271,907 384,338 340,294 329,708 315,064 

Germany 213,912 197,091 239,558 243,092 228,813 251,781 

Taiwan 50,975 50,124 70,607 168,124 210,184 214,492 

India 92,398 50,301 122,315 211,527 197,373 206,833 

United States 185,115 168,671 212,794 177,236 168,166 172,584 

United Arab Emirates 81,416 119,443 210,517 194,649 212,775 163,943 

Netherlands 49,295 20,677 87,396 21,746 58,308 157,251 

Thailand 87,856 90,054 98,804 115,791 104,016 137,401 

Italy 88,213 80,951 105,099 93,970 87,140 104,479 

Belgium 46,372 69,428 97,319 97,925 98,646 102,971 

Poland 19,630 22,304 33,872 34,743 53,890 95,952 

Portugal 56,573 76,117 87,900 96,091 100,866 89,075 

Indonesia 66,161 56,756 69,646 73,271 75,092 82,369 

Malaysia 95,110 71,829 95,101 87,832 81,311 80,264 

Hong Kong 72,490 82,047 80,045 70,550 71,509 80,065 

 Total (countries shown) 2,005,253 1,851,818 2,666,217 2,667,278 2,736,011 3,004,393 

Regions: 

 EU28 (External Trade) 139,253 124,065 162,780 164,974 164,343 182,975 

 Note:--Ranked on calendar year 2013. Export figures for HTS subheading 3920.62 include nonsubject products, 

e.g. metallized PET film, “equivalent PET film,” and possibly amorphous (“APET”) and crystalline (“CPET”) film. 

Note:--UAE exports are derived from partner country GTA import data. 

Source: Global Trade Atlas, accessed April 4, 2014.   

Of the 17 exporting countries shown, 6 countries accounted for about 58 percent of the

aggregate total in 2013. The leading countries in order were China, Korea, Japan and Germany,

together with the countries subject to this investigation, Taiwan, and India.  China, Korea, Japan

and Germany also import significant quantities of PET film product.  Exporting countries

included in this listing that are currently subject to dumping orders but nonsubject to this

investigation are China, and the United Arab Emirates (UAE).  Brazil, a nonsubject country

falling outside the top 17 global exporting countries, is also subject to dumping orders.  

According to the data reported, total exports of the 17 leading exporting countries experienced

a compound annual growth rate of 8.5 percent during the 5 year period 2008‐13, and 4.2

percent for the 3 year period 2010‐13.  The higher growth rate calculated over the 5 year

period may have been influenced by downward volume pressure experienced during the global

recession of 2008‐09.     
IV‐15

The leading 16 global importing countries of PET film are detailed in table IV‐15 along

with EU‐28 external import trade.  

Table IV-15 

PET film: Top importing countries and regions, 2008-13

Reporting country 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

China 276,909 315,666 465,192 521,163 610,737 676,291 

United States 294,599 281,592 422,978 442,725 546,151 534,570 

Japan 254,151 207,173 292,483 341,760 279,034 290,873 

Germany 194,822 166,815 239,104 250,579 218,372 261,073 

Italy 164,317 135,467 200,887 173,475 182,463 201,396 

United Kingdom 131,885 133,443 184,249 170,080 167,035 147,571 

Belgium 71,895 83,022 106,990 104,303 130,602 122,736 

France 103,509 90,222 107,389 115,798 122,290 122,352 

South Korea 47,814 55,473 109,900 87,918 81,132 102,402 

Spain 77,863 85,489 205,316 91,150 80,563 80,605 

Taiwan 43,235 53,043 72,380 71,926 70,438 79,031 

Canada 72,609 72,942 84,530 77,874 81,844 75,768 

Indonesia 15,933 19,429 36,755 36,934 62,327 73,277 

Switzerland 52,318 49,730 64,002 65,032 64,285 68,028 

Poland 27,128 31,691 41,196 43,195 59,194 67,369 

Mexico 48,363 40,259 75,167 69,448 60,096 62,887 

 Total of countries shown 1,877,350 1,821,456 2,708,518 2,663,360 2,816,563 2,966,229

Regions: 

 EU28 (External Trade) 312,262 290,428 469,516 428,009 465,439 475,953 

 

Note:--Ranked on 2013 after the United States. Export figures for HTS subheading 3920.62 include nonsubject 

products, e.g. metallized PET film, “equivalent PET film,” and possibly amorphous (“APET”) and crystalline (“CPET”) 

film. 

Source: Global Trade Atlas, accessed April 4, 2014. 

   

Five countries, China, the United States,44 Japan, Germany, and Italy, in order,

accounted for 66 percent of the total accountable PET film imports of the top 16 importing

countries.  Imports of PET film by EU‐28 countries from outside the region were also significant.

The large majority of China’s and Japan’s leading imports were confined to other Asian

countries. China’s imports were largely confined to Korea, Taiwan, and Japan, while Japan’s

                                                      

44 U.S. imports of PET film at the 6‐digit HTS level are overstated relative to subject PET film at the 10‐

digit level, and in 2013 by approximately 280 million pounds.  This is due to the inclusion of 235 million

pounds of nonsubject amorphous (APET) sheet from Oman, and 43 million pounds of APET from Canada.  

The corrected aggregate share for the five countries cited would be reduced 3 percentage points to 63

percent.  
IV‐16

imports were largely confined to Korea, Taiwan, Malaysia, Indonesia, and China.  German and

Italian imports were mostly from other European countries and Asia.  According to available

data, Imports of the 16 leading importing countries in aggregate grew at an average compound

rate of 9.0 percent during the 5 year period, 2008‐13, and at 3.1 percent during the 2011‐13

period.

Trade balances refer to the calculated difference between exports and imports, and

thus provide a relative gage of various countries’ export capability or import dependency trends

as shown in table IV‐16.  Some countries, however, have a propensity to engage in both

relatively significant export and import activities for various reasons.

 
IV‐17

Table IV-16 

PET film: Subject- and nonsubject-country exports, imports, and trade balances, 2008-13

Reporting country 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

Subject: 

 India: 

 Exports 92,398 50,301 122,315 211,527 197,373 206,833 

Imports 4,052 18,034 20,596 15,686 9,923 32,320 

Trade balance 88,346 32,267 101,719 195,841 187,450 174,513 

 Taiwan: 

 Exports 50,975 50,124 70,607 168,124 210,184 214,492 

Imports 43,235 53,043 72,380 71,926 70,438 79,031 

Trade balance 7,740 (2,919) (1,773) 96,199 139,746 135,461 

Nonsubject: 

 Korea: 

 Exports 334,403 284,952 311,484 330,067 325,706 346,037 

Imports 47,814 55,473 109,900 87,918 81,132 102,402 

Trade balance 286,590 229,479 201,584 242,149 244,574 243,635 

 United Arab Emirates: 

 Exports 81,416 119,443 210,517 194,649 212,775 163,943 

Imports 12,573 5,886 13,159 15,728 14,431 11,413 

Trade balance 68,843 113,557 197,358 178,921 198,344 152,530 

 Netherlands: 

 Exports 49,295 20,677 87,396 21,746 58,308 157,251 

Imports 52,111 46,264 62,847 17,280 48,400 43,535 

Trade balance (2,815) (25,587) 24,548 4,467 9,908 113,717 

 Thailand: 

 Exports 87,856 90,054 98,804 115,791 104,016 137,401 

Imports 3,746 7,152 13,124 16,420 25,845 33,532 

Trade balance 84,111 82,903 85,680 99,371 78,171 103,868 

 Portugal: 

 Exports 56,573 76,117 87,900 96,091 100,866 89,075 

Imports 11,261 9,780 10,384 11,387 10,787 11,660 

Trade balance 45,312 66,337 77,517 84,704 90,079 77,415 

 Poland: 

 Exports 19,630 22,304 33,872 34,743 53,890 95,952 

Imports 27,128 31,691 41,196 43,195 59,194 67,369 

Trade balance (7,498) (9,387) (7,324) (8,453) (5,304) 28,583 

 Table continued on next page. 
IV‐18

Table IV-16--Continued 

PET film: Subject- and nonsubject-country exports, imports, and trade balances, 2008-13

Reporting country 

Calendar year 

2008 2009 2010 2011 2012 2013 

 Quantity (1,000 pounds) 

 Japan: 

 Exports 261,486 271,907 384,338 340,294 329,708 315,064 

Imports 254,151 207,173 292,483 341,760 279,034 290,873 

Trade balance 7,335 64,734 91,855 (1,466) 50,673 24,191 

 Indonesia: 

 Exports 66,161 56,756 69,646 73,271 75,092 82,369 

Imports 15,933 19,429 36,755 36,934 62,327 73,277 

Trade balance 50,228 37,326 32,891 36,337 12,765 9,092 

 Germany: 

 Exports 213,912 197,091 239,558 243,092 228,813 251,781 

Imports 194,822 166,815 239,104 250,579 218,372 261,073 

Trade balance 19,090 30,276 454 (7,487) 10,441 (9,292)

 Belgium: 

 Exports 46,372 69,428 97,319 97,925 98,646 102,971 

Imports 71,895 83,022 106,990 104,303 130,602 122,736 

Trade balance (25,523) (13,594) (9,672) (6,378) (31,956) (19,764)

 United Kingdom: 

 Exports 72,788 61,906 86,170 59,922 53,762 61,703 

Imports 131,885 133,443 184,249 170,080 167,035 147,571 

Trade balance (59,097) (71,538) (98,079) (110,158) (113,273) (85,868)

 Italy: 

 Exports 88,213 80,951 105,099 93,970 87,140 104,479 

Imports 164,317 135,467 200,887 173,475 182,463 201,396 

Trade balance (76,103) (54,516) (95,789) (79,505) (95,323) (96,917)

 China: 

 Exports 203,848 139,167 359,421 310,371 332,510 403,831 

Imports 276,909 315,666 465,192 521,163 610,737 676,291 

Trade balance (73,061) (176,500) (105,771) (210,793) (278,227) (272,460)

 United States: 

 Exports 185,115 168,671 212,794 177,236 168,166 172,584 

Imports 294,599 281,592 422,978 442,725 546,151 534,570 

Trade balance (109,484) (112,921) (210,184) (265,489) (377,984) (361,985)

 

Note:-- Export and import figures for HTS subheading 3920.62 include nonsubject products, e.g. metallized PET film, 

“equivalent PET film,” and possibly amorphous (“APET”) and crystalline (“CPET”) film. 

Source: Global Trade Atlas, accessed April 4, 2014. 
IV‐19

Korea, the UAE, Thailand, the Netherlands, and the subject countries of India and

Taiwan are examples of countries which typically demonstrate merchant tendencies and

experience relatively significant positive trade balances.  Japan is a good example of a country

which exports and imports relatively large, balanced volumes of PET film, while China

experiences a relatively significant trade deficit but at the same time also imports and exports

large volumes of PET film.  China, the U.S., and the United Kingdom have traditionally

experienced trade deficits and thus are net importers of PET film. The EU‐28 countries overall

display a significant trade deficit with countries from outside the region.  China and the UAE are

each nonsubject countries currently subject to dumping orders.

Foreign demand

Firms’ responses regarding PET film demand outside the United States since 2008 and

anticipated future demand are summarized in table IV‐17. Most firms reported that demand

outside of the United States has increased since 2008 and most anticipated that demand would

continue to increase.

Table IV-17 

PET film: Firms’ responses regarding demand outside of the United States 

Item 

Number of firms reporting 

Increase No change Decrease Fluctuate 

Demand outside the United States 

since 2008: 

 U.S. producers 7 0 1 2

Importers 10 2 1 2

Purchasers 8 1 1 0

Foreign producers 3 0 0 0

Demand in home market since 2008: 

 Foreign producers 2 0 1 0

Anticipated demand outside the 

United States: 

 U.S. producers 6 1 1 2

Importers 7 3 1 4

Purchasers 7 1 1 1

Foreign producers 2 1 0 0

Anticipated demand in home market: 

 Foreign producers 2 0 0 0

Source: Compiled from data submitted in response to Commission questionnaires. 

Firms cited demand growth in developing countries particularly in Asia (including China)

and South America. One firm stated that demand is expected to grow faster greater than GDP

in emerging markets and to pace GDP in mature markets. Firms reported increased growth in

packaging applications with population growth and as consumers demand more convenient

packaging options. Firms also cited increased PET film demand in other applications including

optical films, flexible printed electronics, and solar applications.  
IV‐20

On the other hand, *** stated that “demand has increased in Asia and South America

through 2011 but is weak throughout the world,” and *** noted a decline in demand for

imaging films.

*** reported decreased demand in the Taiwan home market because of price

competition, and increased demand in Australia and New Zealand. *** reported that the

majority of demand in Taiwan is for packaging applications and that such demand was not

affected by the global economic crisis, and that demand is expected to increase over the next

two years due to the economic recovery. *** reported that demand has increased in the Asia

Pacific region because of growth in population, consumption trends, and changing lifestyle.  

***.45 ***.

Prices

In comparing prices of PET film in U.S. and foreign markets, firms generally reported

that PET film prices in the U.S. market were the higher or the same as prices in other markets.

Among U.S. producers, three firms reported that prices were lower in Asia than in the United

States, with one firm estimating that prices in Asia were about 10 percent lower compared to

prices in other regions. *** reported that in the first quarter of 2014 pricing were $0.30 to

$0.40 per pound higher in the U.S. market than in China and in Europe. Another producer

reported that U.S. prices were $1.45 per pound compared to $1.24 per pound in Mexico.

Among importers, one reported that prices in Japan are higher than in the United States

and one reported that prices in the U.S. market are a little higher than European prices, similar

to prices in the United Kingdom (not including freight), and similar to prices in Canada. *** and

that there are no significant price differences in the markets in North America, South America,

Europe, and Asia. Foreign producer *** reported that it sells PET film for the same base price in

all markets, with additional fees for sea freight, import duties, and trucking fees.  

                                                      

45 ***.
V‐1

PART V: PRICING DATA

FACTORS AFFECTING PRICES

Raw material costs

Raw materials are an important consideration in the price of PET film, accounting for

between 48.3 and 60.1 percent of U.S. producers’ costs of goods sold during 2008‐13. The basic

raw materials for producing PET film are (1) dimethyl terephthalate (“DMT”) –or purified

terephthalic acid (“PTA”) and (2) monoethylene glycol (“MEG”), which come from xylene and

ethylene, respectively. 1 Ethylene usually is manufactured from natural gas while xylene is a

byproduct from oil refineries. Thus, raw material costs are greatly affected by crude oil and

natural gas prices. After peaking in 2008, natural gas and crude oil prices declined greatly in

2009 (figure V‐1). Natural gas prices have remained lower, with some fluctuations, and were 32

percent lower in January 2014 than in January 2008. Crude oil prices trended upwards,

increasing above their January 2008 levels by 2011 and have since fluctuated within a narrow

range. ***, MEG prices ***.2  

U.S. producers were asked to describe how changes in the prices of their raw materials

had changed their selling prices for PET film since 2008. Firms reported that there is a lag of 3 to

6 months when raw material price changes affect selling prices for PET film and that the selling

price changes monthly based on market prices of paraxylene and ethylene glycol. Firms also

noted that oil prices fluctuated wildly during the recession then increased, affecting PET film

prices. Most producers (8 of 10) anticipate changes in raw material pricing including higher

costs due to global political events, global supply and demand issues, and increased prices for

oil due to the U.S. economic expansion. ***.3  

Transportation costs to the U.S. market

Transportation costs for PET film shipped from subject countries to the United States

were 7.8 percent for India and 5.3 percent for Taiwan. These estimates are derived from official

import data and represent the transportation and other charges on imports.4

                                                      

1 ***. Domestic interested parties’ posthearing brief, p. 11. 2 See graph presented in Domestic interested parties’ posthearing brief, p. 11. ***. They further state

that “domestic producers have little ability to adjust prices to reflect fluctuations in raw materials

prices.” Domestic interested parties’ posthearing brief, p. 11‐12.

3 Polyplex is setting up a PET resin plant in Decatur, AL. Polyplex’s website,

http://www.polyplex.com/about‐us/global‐presence/polyplex‐usa, retrieved Apr. 24, 2014. 4 The estimated transportation costs were obtained by subtracting the customs value from the c.i.f.

value of the imports for 2013 and then dividing by the customs value based on HTS 3920.62.0090.  
V‐2

Figure V-1 

Raw materials: Crude oil and natural gas price indices, January 2008-February 2014 

Source: U.S. Energy Information Administration, www.eia.gov, retrieved April 22, 2014 

Five importers reported that they arranged international transportation to the customer

while 12 reported that the exporter arranged such transportation. Transportation costs from

Taiwan to the United States reported by importers equate to *** percent of the import value.5

Among foreign producers, ***.6 ***.7

U.S. inland transportation costs

Eight of nine responding U.S. producers and 11 of 12 importers reported that they

typically arrange transportation to their customers. U.S. producers reported that their U.S.

inland transportation costs ranged from 3 to 7 percent. Importers reported a wider range of

costs, with five firms reporting 1 to 8 percent and three reporting 10 to 35 percent.

                                                      

5 Three importers reported transportation costs from Taiwan ***. The average unit value of PET film

imports from Taiwan in 2013 was $2,826 per short ton (landed duty‐paid value based on official import

statistics); transportation costs of *** per short ton equate to *** percent of the landed duty‐paid

value. No importer reported transportation costs from India.

6 ***.

7 ***. The average unit value of PET film imports from India in 2013 was $2,699 per short ton (landed

duty‐paid value based on official import statistics); transportation costs of *** per short ton equate to

*** percent of the landed duty‐paid value.

0

20

40

60

80

100

120

140

160

180

2008 2009 2010 2011 2012 2013 2014

January 2008=100

Crude oil Natural gas
V‐3

Exchange rates

Nominal and real exchange rates for the currencies of India and Taiwan in relation to the

U.S. dollar during January 2008‐March 2014 are presented in figure V‐2.8 The Indian rupee has

depreciated substantially against the U.S. dollar in nominal terms, although less so in real

terms. The New Taiwan (NT) dollar has been mostly stable against the U.S. dollar over the same

period, appreciating slightly in nominal terms and declining slightly in real terms.

Figure V-2 

Exchange rates: Quarterly indices of the nominal and real exchange rates of the currencies of 

India and Taiwan relative to the U.S. dollar, January 2008-March 2014 

Note: India real exchange rate data are not available for first quarter of 2014. 

Source: IMF International Financial Statistics at http://www.imfstatistics.org/, Federal Reserve Bank of St. 

Louis at http://stlouisfed.org/, and National Statistics, Republic of China (Taiwan) at http://eng.stat.gov.tw, 

retrieved May 30, 2014. 

                                                      

8 As noted in part II, ***.  

0.0

20.0

40.0

60.0

80.0

100.0

120.0

2008 2009 2010 2011 2012 2013 2014

Index (2008=100)

India

Nominal Real

0.0

20.0

40.0

60.0

80.0

100.0

120.0

2008 2009 2010 2011 2012 2013 2014

Index (2008=100)

Taiwan

Nominal Real
V‐4

PRICING PRACTICES

Pricing methods

U.S. producers and importers sell on a transaction‐by‐transaction basis and also through

contracts (table V‐1).  

Table V-1 

PET film: U.S. producers and importers reported price setting methods, by number of responding 

firms1 

Method U.S. producers U.S. importers 

Transaction-by-transaction 9 14

Contract 7 8

Set price list 3 3

Other 1 3

 1 The sum of responses down may not add up to the total number of responding firms as each firm was 

instructed to check all applicable price setting methods employed.

Source: Compiled from data submitted in response to Commission questionnaires.

Over half of U.S. producers’ sales in 2013 were on a contract basis (table V‐2); 31

percent of total sales were subject to long term contracts and 26 percent were subject to short

term contracts. Most importers’ sales were on a short term contract basis. U.S. producers’ short

term contracts are typically for one year and their long term contracts are for two to four years.

Importers’ contracts are typically shorter in length, from 3 months to one year. Most U.S.

producers and importers reported that prices can be renegotiated during the contract and that

contracts contain meet‐or‐release provisions.

Table V-2 

PET film: U.S. producers’ and importers’ shares of U.S. commercial shipments by type of sale, 

2013 

Type of sale 

Share of commercial U.S. shipments (percent) 

U.S. producers 

U.S. importers U.S. importers 

India Taiwan 

Long-term contracts 31.3 *** ***

Short-term contracts 25.6 *** ***

Spot sales 43.1 *** ***

 Note.--Because of rounding, figures may not add to the totals shown. 

Source: Compiled from data submitted in response to Commission questionnaires.

Four purchasers reported that they purchase product daily, two weekly, and three

monthly. No purchaser reported that they expect their purchasing patterns to change in the

next two years. Most (6 of 9) purchasers contact one to three suppliers before making a

purchase.
V‐5

Sales terms and discounts

Five producers reported quoting delivered prices and four reported quoting f.o.b. prices.

Most importers (11 of 16) quote prices on a delivered basis.

Some producers and importers offer quantity and/or total volume discounts while

others do not offer discounts. Of 10 responding producers, five producers offer no discounts, 4

offer quantity discounts, 6 offer total volume discounts, and 2 offer other discounts. Seven of

17 responding importers offer no discounts, 3 offer quantity discounts, 7 offer total volume

discounts, and 4 offer other discounts (such as for advanced payments). Some producers and

importers reported that they offer discounts or rebates for certain customers, particularly large

accounts.

The most common sales terms are net 30 days. Nine producers reported sales terms of

net 30, although producers also reported net 60 (3 firms), 2/10 net 30 (3 firms), and other

terms. Twelve importers reported net 30, but importers also reported net 60 (6 firms), 2/10 net

30 (3 firms), and other terms.

Price leadership

Purchasers reported that the following suppliers were price leaders in the PET film

market: Dupont Teijin (listed by 6 purchasers), Mitsubishi (5), and SKC (3). In addition, one firm

listed Toray and Flex, and one firm reported that there are currently no price leaders and that

the market is oversupplied.

PRICE DATA

The Commission requested U.S. producers and importers to provide quarterly data for

the total quantity and f.o.b. value of the following PET film products shipped to unrelated U.S.

customers during 2008‐13.

Product 1.‐‐ 48 gauge plain film for packaging/industrial markets

Product 2.‐‐ 48 gauge corona‐treated film for packaging/industrial markets

Product 3.‐‐ 48 gauge chemically treated film for packaging/industrial markets (includes

films that are treated with chemicals post‐extrusion, as well as films that are chemically

treated via coextrusion)

Product 4.‐‐ 92 gauge plain film for packaging/industrial markets

Product 5.‐‐ 120 gauge plain film for packaging/industrial markets

Product 6.‐‐ 500‐1000 gauge plain film for industrial/electrical markets
V‐6

Product 7.‐‐ 400‐700 gauge chemically treated film for printing plate markets

Product 8.‐‐ 1000‐1400 gauge plain film for motors/insulation markets

Nine U.S. producers, 3 importers from India, and 6 importers from Taiwan provided

usable pricing data for sales of the requested products, although not all firms reported pricing

for all products for all quarters. Pricing data reported by these firms accounted for 31.6 percent

of U.S. producers’ U.S. commercial shipments of PET film, 91.0 percent of U.S. commercial

shipments of subject imports from India, and 90.3 percent of U.S. commercial shipments of

imports from Taiwan during 2008‐13.

Price data for products 1‐8 are presented in tables V‐3 to V‐10 and figures V‐1 to V‐8. 9

Table V-3 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 1 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-4 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 2 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-5 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 3 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-6 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 4 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

                                                      

9 ***.
V‐7

Table V-7 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 5 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-8 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 61

 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-9 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 71

 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Table V-10 

PET film: Weighted-average f.o.b. prices and quantities of domestic and imported product 81 and 

margins of underselling/(overselling), by quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Figure V-1 

PET film: Weighted-average prices and quantities of domestic and imported products 1-8, by 

quarters, 2008-2013 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Price trends

Prices generally increased from 2008 through 2011 and then declined. Prices for

products 7 and 8, smaller volume products, showed different trends, with product 7 prices  

generally declining in 2011 and 2012 and then increasing in 2013 and product 8 prices showing
V‐8

an overall increase over the period. Table V‐11 summarizes the price trends, by country and by

product. ***.10

Table V-11 

PET film: Summary of weighted-average f.o.b. prices for products 1-8 from the United States, 

India, and Taiwan 

* * * * * * * 

Source: Compiled from data submitted in response to Commission questionnaires.

Price comparisons

As shown in table V‐12, prices for PET film imported from India were below those for

U.S.‐produced product in 22 of 42 instances; margins of underselling ranged from 0.6 to 28.0

percent. In the remaining 20 instances, prices for PET film from India were between 2.5 and

92.3 percent above prices for the domestic product. Prices for PET film imported from Taiwan

were below those for U.S.‐produced product in 35 of 94 instances; margins of underselling

ranged from 0.1 to 69.6 percent. In the remaining 59 instances, prices for PET film from Taiwan

were between 0.3 and 78.7 percent above prices for the domestic product.  

Table V-12 

PET film: Instances of underselling/overselling and the range and average of margins, by country, 

2008-2013 

Source 

Underselling Overselling 

Number of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

Number of 

instances 

Range 

(percent) 

Average 

margin 

(percent) 

India 22 0.6 to 28.0 13.3 20 (2.5) to (92.3) (23.9)

Taiwan 35 0.1 to 69.6 11.1 59 (0.3) to (78.7) (25.8)

Total 57 0.1 to 69.6 12.0 79 (0.3) to (92.3) (25.3)

 Source: Compiled from data submitted in response to Commission questionnaires. 

                                                      

10 ***.
A‐1

APPENDIX A

FEDERAL REGISTER NOTICES  

A‐3

The Commission makes available notices relevant to its investigations and reviews on its

website, www.usitc.gov. In addition, the following tabulation presents, in chronological order,

Federal Register notices issued by the Commission and Commerce during the current

proceeding.  

Citation Title Link

78 FR 19524,

April 1, 2013

Polyethylene Terephthalate Film,

Sheet, and Strip From India and

Taiwan:  Institution of Five‐Year

Reviews

https://www.federalregister.gov/articles/

2013/04/01/2013‐07328/polyethylene‐

terephthalate‐film‐sheet‐and‐strip‐from‐

india‐and‐taiwan‐institution‐of‐five‐year  

78 FR 19647,

April 2, 2013

Initiation of Five‐Year (“Sunset”)

Review  

https://www.federalregister.gov/articles/

2013/04/02/2013‐07550/initiation‐of‐

five‐year‐sunset‐review  

78 FR 42105,

July 15, 2013

Polyethylene Terephthalate Film,

Sheet, and Strip From India and

Taiwan:  Notice of Commission

Determinations To Conduct Full

Five‐Year Reviews

https://www.federalregister.gov/articles/

2013/07/15/2013‐16869/polyethylene‐

terephthalate‐film‐sheet‐and‐strip‐from‐

india‐and‐taiwan‐notice‐of‐commission  

78 FR 47276,

August 5, 2013

Polyethylene Terephthalate Film,

Sheet, and Strip From India:  Final

Results of the Expedited Second

Sunset Review of the

Countervailing Duty Order

https://www.federalregister.gov/articles/

2013/08/05/2013‐18834/polyethylene‐

terephthalate‐pet‐film‐sheet‐and‐strip‐

from‐india‐final‐results‐of‐the‐expedited‐

second  

79 FR 2883,

January 16,

2014

Polyethylene Terephthalate Film,

Sheet, and Strip From India and

Taiwan:  Scheduling of Full Five‐

Year Reviews Concerning the

Countervailing Duty Order on

Polyethylene Terephthalate Film,

Sheet, and Strip (“PET Film”)From

India and the Antidumping Duty

Orders on PET film From India

and  Taiwan

https://www.federalregister.gov/articles/

2014/01/16/2014‐00728/polyethylene‐

terephthalate‐film‐sheet‐and‐strip‐from‐

india‐and‐taiwan‐scheduling‐of‐full‐five‐

year  

 
A‐4

79 FR 12153,

March 4, 2014

Polyethylene Terephthalate Film,

Sheet, and Strip From India and

Taiwan:  Final Results of the

Second Sunset Review of the

Antidumping Duty Orders and

Correction to the Preliminary

Results

https://www.federalregister.gov/articles/

2014/03/04/2014‐04748/polyethylene‐

terephthalate‐film‐sheet‐and‐strip‐from‐

india‐and‐taiwan‐final‐results‐of‐the‐

second  

79 FR 28949,

May 20, 2014

Polyethylene Terephthalate Film,

Sheet, and Strip From India and

Taiwan:  Revised Schedule for the

Subject Reviews

https://www.federalregister.gov/articles/201

4/05/20/2014‐11580/polyethylene‐

terephthalate‐film‐sheet‐and‐strip‐from‐

india‐and‐taiwan‐revised‐schedule‐for‐the

Note.–The press release announcing the Commission’s determinations concerning adequacy

and the conduct of a full or expedited review can be found at

http://usitc.gov/press_room/news_release/2012/er0409kk1.htm.  A summary of the

Commission’s votes concerning adequacy and the conduct of a full or expedited review can be

found at http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11452.  The

Commission’s explanation of its determinations can be found at

http://pubapps2.usitc.gov/sunset/caseProfSuppAttmnt/download/11453.
B-1 

APPENDIX B

LIST OF HEARING WITNESSES  

B-3 

The public hearing in connection with these reviews, scheduled to begin at 9:30 A.M. on

May 20, 2014, at the U.S. International Trade Commission Building, was cancelled at the

request of Domestic Interested Parties (79 FR 28949, May 20, 2014).

C‐1

APPENDIX C

SUMMARY DATA

Table C-1

PET Film: Summary data concerning the U.S. market, 2008-13

2008 2009 2010 2011 2012 2013 2008-13 2008-09 2009-10 2010-11 2011-12 2012-13

U.S. consumption quantity:

Amount............................................................. 749,184 649,422 726,370 665,488 649,954 662,050 (11.6) (13.3) 11.8 (8.4) (2.3) 1.9

Producers' share (1).......................................... 77.7 79.6 75.3 71.8 69.9 76.0 (2.1) 2.4 (5.3) (4.6) (2.6) 8.7

Importers' share (1):

India.............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Taiwan........................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Subject sources.......................................... *** *** *** *** *** *** *** *** *** *** *** ***

All others sources, nonsubject........................ *** *** *** *** *** *** *** *** *** *** *** ***

Total imports........................................... 22.3 20.4 24.7 28.2 30.1 24.0 7.4 (8.4) 20.7 14.2 6.7 (20.3)

U.S. consumption value:

Amount............................................................. 1,386,701 1,124,771 1,348,009 1,437,022 1,243,991 1,207,212 (12.9) (18.9) 19.8 6.6 (13.4) (3.0)

Producers' share (1).......................................... 79.6 83.1 77.6 73.2 75.8 79.8 0.2 4.3 (6.6) (5.6) 3.5 5.4

Importers' share (1):

India.............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Taiwan........................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Subject sources.......................................... *** *** *** *** *** *** *** *** *** *** *** ***

All others sources, nonsubject........................ *** *** *** *** *** *** *** *** *** *** *** ***

Total imports........................................... 20.4 16.9 22.4 26.8 24.2 20.2 (0.9) (16.9) 32.6 19.3 (9.4) (16.7)

U.S. shipments of imports from:

India:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

Taiwan:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

Subject sources:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

All other sources:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

Total imports:

Quantity......................................................... 167,216 132,744 179,241 187,480 195,397 158,687 (5.1) (20.6) 35.0 4.6 4.2 (18.8)

Value............................................................. 282,423 190,378 302,553 384,737 301,599 243,696 (13.7) (32.6) 58.9 27.2 (21.6) (19.2)

Unit value...................................................... $1.69 $1.43 $1.69 $2.05 $1.54 $1.54 (9.1) (15.1) 17.7 21.6 (24.8) (0.5)

Ending inventory quantity............................... 21,288 15,990 16,481 19,674 17,461 12,290 (42.3) (24.9) 3.1 19.4 (11.2) (29.6)

U.S. producers':

Average capacity quantity................................. 720,103 702,692 700,955 624,565 620,209 710,024 (1.4) (2.4) (0.2) (10.9) (0.7) 14.5

Production quantity........................................... 620,246 550,720 602,656 510,811 495,378 543,023 (12.5) (11.2) 9.4 (15.2) (3.0) 9.6

Capacity utilization (1)...................................... 86.1 78.4 86.0 81.8 79.9 76.5 (9.7) (7.8) 7.6 (4.2) (1.9) (3.4)

U.S. shipments:

Quantity......................................................... 581,968 516,678 547,129 478,008 454,557 503,363 (13.5) (11.2) 5.9 (12.6) (4.9) 10.7

Value............................................................. 1,104,278 934,393 1,045,456 1,052,285 942,392 963,516 (12.7) (15.4) 11.9 0.7 (10.4) 2.2

Unit value...................................................... $1.90 $1.81 $1.91 $2.20 $2.07 $1.91 0.9 (4.7) 5.7 15.2 (5.8) (7.7)

Export shipments:

Quantity......................................................... 32,723 28,501 44,933 39,359 34,901 33,803 3.3 (12.9) 57.7 (12.4) (11.3) (3.1)

Value............................................................. 64,187 58,444 111,416 139,557 115,800 104,660 63.1 (8.9) 90.6 25.3 (17.0) (9.6)

Unit value...................................................... $1.96 $2.05 $2.48 $3.55 $3.32 $3.10 57.8 4.5 20.9 43.0 (6.4) (6.7)

Ending inventory quantity.................................. 60,547 56,657 61,019 50,201 52,158 49,840 (17.7) (6.4) 7.7 (17.7) 3.9 (4.4)

Inventories/total shipments (1).......................... 9.8 10.4 10.3 9.7 10.7 9.3 (0.6) 0.5 (0.1) (0.6) 1.0 (1.4)

Production workers........................................... 2,196 2,020 2,017 1,857 1,837 1,935 (11.9) (8.0) (0.1) (7.9) (1.1) 5.3

Hours worked (1,000s)...................................... 4,366 3,977 3,982 3,736 3,756 3,933 (9.9) (8.9) 0.1 (6.2) 0.5 4.7

Wages paid ($1,000)........................................ 149,435 138,342 134,079 133,884 136,416 141,613 (5.2) (7.4) (3.1) (0.1) 1.9 3.8

Productivity (pounds per hour).......................... 142.1 138.5 151.3 136.7 131.9 138.1 (2.8) (2.5) 9.3 (9.7) (3.5) 4.7

Unit labor costs................................................. $0.24 $0.25 $0.22 $0.26 $0.28 $0.26 8.2 4.3 (11.4) 17.8 5.1 (5.3)

Net Sales:

Quantity......................................................... 614,691 545,179 592,062 517,366 489,458 508,794 (17.2) (11.3) 8.6 (12.6) (5.4) 4.0

Value............................................................. 1,168,465 992,837 1,156,872 1,191,841 1,058,192 1,033,019 (11.6) (15.0) 16.5 3.0 (11.2) (2.4)

Unit value...................................................... $1.90 $1.82 $1.95 $2.30 $2.16 $2.03 6.8 (4.2) 7.3 17.9 (6.2) (6.1)

Cost of goods sold (COGS).............................. 1,052,922 878,505 951,407 1,000,633 945,200 942,182 (10.5) (16.6) 8.3 5.2 (5.5) (0.3)

Gross profit of (loss)......................................... 115,543 114,332 205,465 191,208 112,992 90,837 (21.4) (1.0) 79.7 (6.9) (40.9) (19.6)

SG&A expenses................................................ 126,771 115,666 109,823 100,454 93,183 97,543 (23.1) (8.8) (5.1) (8.5) (7.2) 4.7

Operating income or (loss)................................ (11,228) (1,334) 95,642 90,754 19,809 (6,706) (40.3) (88.1) (2) (5.1) (78.2) (2)

Capital expenditures......................................... 123,403 40,342 35,933 59,041 134,075 212,905 72.5 (67.3) (10.9) 64.3 127.1 58.8

Unit COGS....................................................... $1.71 $1.61 $1.61 $1.93 $1.93 $1.85 (5.9) (0.3) 20.4 (0.2) (4.1)

Unit SG&A expenses......................................... $0.21 $0.21 $0.19 $0.19 $0.19 $0.19 (7.0) 2.9 (12.6) 4.7 (1.9) 0.7

Unit operating income or (loss)......................... ($0.02) ($0.00) $0.16 $0.18 $0.04 ($0.01) (27.8) (86.6) (2) 8.6 (76.9) fn2

COGS/sales (1)................................................ 90.1 88.5 82.2 84.0 89.3 91.2 1.1 (1.6) (6.2) 1.7 5.4 1.9

Operating income or (loss)/sales (1)................. (1.0) (0.1) 8.3 7.6 1.9 (0.6) 0.3 0.8 8.4 (0.7) (5.7) (2.5)

Notes:

1

 Report data are in percent and period changes are in percentage points.

2

 Undefined. 

(Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted)

Report data Period changes

Calendar year Calendar year comparisons

C-3
Table C-2

PET Film: Summary data concerning the U.S. merchant market, 2008-13

2008 2009 2010 2011 2012 2013 2008-13 2008-09 2009-10 2010-11 2011-12 2012-13

U.S. consumption quantity: (1)

Amount............................................................. 568,193 479,009 577,338 534,082 544,606 558,363 (1.7) (15.7) 20.5 (7.5) 2.0 2.5

Producers' share (2).......................................... 70.6 72.3 69.0 64.9 64.1 71.6 1.4 2.4 (4.6) (5.9) (1.2) 11.6

Importers' share (2):

India.............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Taiwan........................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Subject sources.......................................... *** *** *** *** *** *** *** *** *** *** *** ***

All others sources, nonsubject........................ *** *** *** *** *** *** *** *** *** *** *** ***

Total imports........................................... 29.4 27.7 31.0 35.1 35.9 28.4 (3.4) (5.8) 12.0 13.1 2.2 (20.8)

U.S. consumption value:

Amount............................................................. 1,009,476 774,138 1,047,159 1,153,812 1,016,244 992,585 (1.7) (23.3) 35.3 10.2 (11.9) (2.3)

Producers' share (2).......................................... 72.0 75.4 71.1 66.7 70.3 75.4 4.8 4.7 (5.7) (6.3) 5.5 7.3

Importers' share (2):

India.............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Taiwan........................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Subject sources.......................................... *** *** *** *** *** *** *** *** *** *** *** ***

All others sources, nonsubject........................ *** *** *** *** *** *** *** *** *** *** *** ***

Total imports........................................... 28.0 24.6 28.9 33.3 29.7 24.6 (12.2) (12.1) 17.5 15.4 (11.0) (17.3)

U.S. shipments of imports from:

India:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

Taiwan:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

Subject sources:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

All other sources:

Quantity......................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Value............................................................. *** *** *** *** *** *** *** *** *** *** *** ***

Unit value...................................................... *** *** *** *** *** *** *** *** *** *** *** ***

Ending inventory quantity............................... *** *** *** *** *** *** *** *** *** *** *** ***

Total imports:

Quantity......................................................... 167,216 132,744 179,241 187,480 195,397 158,687 (5.1) (20.6) 35.0 4.6 4.2 (18.8)

Value............................................................. 282,423 190,378 302,553 384,737 301,599 243,696 (13.7) (32.6) 58.9 27.2 (21.6) (19.2)

Unit value...................................................... $1.69 $1.43 $1.69 $2.05 $1.54 $1.54 (9.1) (15.1) 17.7 21.6 (24.8) (0.5)

Ending inventory quantity............................... 21,288 15,990 16,481 19,674 17,461 12,290 (42.3) (24.9) 3.1 19.4 (11.2) (29.6)

U.S. producers': (1)

Average capacity quantity................................. 510,423 498,370 472,292 415,361 415,123 533,450 4.5 (2.4) (5.2) (12.1) (0.1) 28.5

Production quantity........................................... 448,972 383,964 438,500 360,512 366,588 431,020 (4.0) (14.5) 14.2 (17.8) 1.7 17.6

Capacity utilization (2)...................................... 88.0 77.0 92.8 86.8 88.3 80.8 (7.2) (10.9) 15.8 (6.1) 1.5 (7.5)

Commercial U.S. shipments:

Quantity......................................................... 400,977 346,265 398,097 346,602 349,209 399,676 (0.3) (13.6) 15.0 (12.9) 0.8 14.5

Value............................................................. 727,053 583,760 744,606 769,075 714,645 748,889 3.0 (19.7) 27.6 3.3 (7.1) 4.8

Unit value...................................................... $1.81 $1.69 $1.87 $2.22 $2.05 $1.87 3.3 (7.0) 10.9 18.6 (7.8) (8.4)

Export shipments:

Quantity......................................................... 32,123 25,801 37,633 24,688 17,874 20,230 (37.0) (19.7) 45.9 (34.4) (27.6) 13.2

Value............................................................. 62,187 47,444 80,516 65,848 45,739 49,201 (20.9) (23.7) 69.7 (18.2) (30.5) 7.6

Unit value...................................................... $1.94 $1.84 $2.14 $2.67 $2.56 $2.43 25.6 (5.0) 16.4 24.7 (4.1) (5.0)

Ending inventory quantity.................................. 51,006 47,530 46,517 34,886 38,786 39,029 (23.5) (6.8) (2.1) (25.0) 11.2 0.6

Inventories/total shipments (2).......................... 11.6 12.6 10.7 9.5 10.8 9.2 (2.3) 1.0 (1.8) (1.3) 1.3 (1.6)

Production workers........................................... 1,625 1,456 1,430 1,329 1,362 1,491 (8.2) (10.4) (1.8) (7.1) 2.5 9.5

Hours worked (1,000s)...................................... 3,284 2,917 2,868 2,747 2,846 3,080 (6.2) (11.2) (1.7) (4.2) 3.6 8.2

Wages paid ($1,000)........................................ 107,378 101,106 96,836 93,595 99,418 107,186 (0.2) (5.8) (4.2) (3.3) 6.2 7.8

Productivity (pounds per hour).......................... 136.7 131.6 152.9 131.2 128.8 139.9 2.4 (3.7) 16.2 (14.2) (1.9) 8.6

Unit labor costs................................................. $0.24 $0.26 $0.22 $0.26 $0.27 $0.25 4.0 10.1 (16.1) 17.6 4.5 (8.3)

Net Sales:

Quantity......................................................... 433,096 371,704 435,224 371,680 367,676 391,398 (9.6) (14.2) 17.1 (14.6) (1.1) 6.5

Value............................................................. 789,234 630,735 824,589 835,720 761,694 763,439 (3.3) (20.1) 30.7 1.3 (8.9) 0.2

Unit value...................................................... $1.82 $1.70 $1.89 $2.25 $2.07 $1.95 7.0 (6.9) 11.7 18.7 (7.9) (5.8)

Cost of goods sold (COGS).............................. 725,295 574,017 664,808 683,032 662,997 670,231 (7.6) (20.9) 15.8 2.7 (2.9) 1.1

Gross profit of (loss)......................................... 63,939 56,718 159,781 152,688 98,697 93,208 45.8 (11.3) 181.7 (4.4) (35.4) (5.6)

SG&A expenses................................................ 80,269 72,168 75,978 72,954 74,432 79,854 (0.5) (10.1) 5.3 (4.0) 2.0 7.3

Operating income or (loss)................................ (16,330) (15,450) 83,804 79,734 24,265 13,354 (3) (5.4) (3) (4.9) (69.6) (45.0)

Capital expenditures......................................... 25,632 19,451 25,861 38,227 39,194 175,947 586.4 (24.1) 33.0 47.8 2.5 348.9

Unit COGS....................................................... $1.67 $1.54 $1.53 $1.84 $1.80 $1.71 2.3 (7.8) (1.1) 20.3 (1.9) (5.0)

Unit SG&A expenses......................................... $0.19 $0.19 $0.17 $0.20 $0.20 $0.20 10.1 4.8 (10.1) 12.4 3.1 0.8

Unit operating income or (loss)......................... ($0.04) ($0.04) $0.19 $0.21 $0.07 $0.03 (3) 10.2 (3) 11.4 (69.2) (48.3)

COGS/sales (2)................................................ 91.9 91.0 80.6 81.7 87.0 87.8 (4.1) (0.9) (10.4) 1.1 5.3 0.7

Operating income or (loss)/sales (2)................. (2.1) (2.4) 10.2 9.5 3.2 1.7 3.8 (0.4) 12.6 (0.6) (6.4) (1.4)

Notes:

fn2.--Report data are in percent and period changes are in percentage points.

fn3.--Undefined. 

fn1.--Since production, capacity, employment were not gathered on U.S. merchant market operations separate from overall U.S. operations in this review, for the purposes of this table the firms who primarily internally consumed their production 

of PET film have been removed from the compilation. The firms generally excluded were [***]. The data for [***]'s commercial shipments were added back into the data on U.S. producers' commercial U.S. shipments and therefore into the 

calculation of apparent U.S. consumption. Separately, for the merchant market financial data presented COGS were allocated to commercial shipments on the basis of quantity of PET film commercially sold out of total and SG&A on the basis 

of the value of PET firm commercially sold at the firm level. Data for the overall merchant market financial operations therefore reflects the Commission's estimate of the financial operations on a merchant market basis.

C-4

(Quantity=1,000 pounds; Value=1,000 dollars; Unit values, unit labor costs, and unit expenses=dollars per pound; Period changes=percent--exceptions noted)

Report data Period changes

Calendar year Calendar year comparisons
D‐1

APPENDIX D

COMMENTS ON THE SIGNIFICANCE OF THE EXISTING ANTIDUMPING AND

COUNTERVAILING DUTY ORDERS AND THE LIKELY EFFECTS OF REVOCATION

D-3 

Appendix D is business proprietary in its entirety