Federal Register / Vol. 60, No. 235 / Thursday, December 7, 1995 / Notices 62813

the manufacturer is, the cash deposit

rate will be the rate established for the

most recent period for the manufacturer

of the merchandise; and (4) for all other

producers and/or exporters of this

merchandise, the cash deposit rate shall

be 24 percent, the rate established in the

first notice of final results of

administrative review published by the

Department (47 FR 10268, March 10,

1982). These deposit requirements shall

remain in effect until publication of the

final results of the next administrative

review.

This notice serves as a final reminder

to importers of their responsibility

under 19 CFR 353.26 to file a certificate

regarding the reimbursement of

antidumping duties prior to liquidation

of the relevant entries during this

review period. Failure to comply with

this requirement could result in the

Secretary’s presumption that

reimbursement of antidumping duties

occurred and subsequent assessment of

double antidumping duties.

Notification to Interested Parties

This notice also serves as a reminder

to parties subject to administrative

protective order (APO) of their

responsibility concerning the

disposition of proprietary information

disclosed under APO in accordance

with 19 CFR 353.34(d). Timely written

notification of return/destruction of

APO materials or conversion to judicial

protective order is hereby requested.

Failure to comply with the regulations

and the terms of an APO is a

sanctionable violation.

This administrative review and notice

are in accordance with section 751(a)(1)

of the Tariff Act (19 U.S.C. 1675(a)(1))

and 19 CFR 353.22.

Dated: November 30, 1995.

Paul L. Joffe,

Deputy Assistant Secretary for Import

Administration.

[FR Doc. 95–29887 Filed 12–6–95; 8:45 am]

BILLING CODE 3510–DS–P

[A–475–801]

Antifriction Bearings (Other Than

Tapered Roller Bearings) and Parts

Thereof From Italy; Preliminary Results

of Antidumping Duty Administrative

Reviews

AGENCY: Import Administration,

International Trade Administration,

Department of Commerce.

ACTION: Notice of preliminary results of

antidumping duty administrative

reviews.

SUMMARY: In response to requests from

interested parties, the Department of

Commerce (the Department) is

conducting administrative reviews of

the antidumping duty orders on

antifriction bearings (other than tapered

roller bearings) and parts thereof from

Italy. The classes or kinds of

merchandise covered by these orders are

ball bearings and cylindrical roller

bearings. The reviews cover 3

manufacturers/exporters. The period of

review (the POR) is May 1, 1993,

through April 30, 1994.

We have preliminarily determined

that sales have been made below foreign

market value (FMV). If these

preliminary results are adopted in our

final results of the administrative

review, we will instruct U.S. Customs to

assess antidumping duties equal to the

difference between the United States

price (USP) and the FMV. We invite

interested parties to comment on these

preliminary results.

EFFECTIVE DATE: December 7, 1995.

FOR FURTHER INFORMATION CONTACT: The

appropriate case analyst, for the various

respondent firms listed below, at the

Office of Antidumping Compliance,

International Trade Administration,

U.S. Department of Commerce,

Washington, D.C. 20230; telephone:

(202) 482–4733.

Davina Hashmi (Meter), Michael

Rausher (FAG), Thomas Schauer (SKF),

Michael Rill, or Richard Rimlinger.

SUPPLEMENTARY INFORMATION:

Applicable Statute and Regulations

Unless otherwise indicated, all

citations to the statute and to the

Department’s regulations are references

to the provisions as they existed on

December 31, 1994.

Background

On May 15, 1989, the Department

published in the Federal Register (54

FR 20909) the antidumping duty orders

on ball bearings (BBs) and cylindrical

roller bearings (CRBs) and parts thereof

from Italy. On June 22, 1994, and July

15, 1994, in accordance with 19 CFR

353.22(c) (1994), we initiated

administrative reviews of those orders

for the period May 1, 1993, through

April 30, 1994 (59 FR 32180 and 59 FR

36160). The Department is now

conducting these administrative reviews

in accordance with section 751 of the

Tariff Act of 1930, as amended (the

Tariff Act).

Scope of Reviews

The products covered by these

reviews are antifriction bearings (other

than tapered roller bearings) and parts

thereof (AFBs), and constitute the

following classes or kinds of

merchandise:

1. Ball Bearings and Parts Thereof:

These products include all antifriction

bearings that employ balls as the rolling

element. Imports of these products are

classified under the following

categories: antifriction balls, ball

bearings with integral shafts, ball

bearings (including radial ball bearings)

and parts thereof, and housed or

mounted ball bearing units and parts

thereof.

Imports of these products are

classified under the following

Harmonized Tariff Schedules (HTS)

subheadings: 3926.90.45, 4016.93.00,

4016.93.10, 4016.93.50, 6909.19.5010,

8431.20.00, 8431.39.0010, 8482.10.10,

8482.10.50, 8482.80.00, 8482.91.00,

8482.99.05, 8482.99.10, 8482.99.35,

8482.99.6590, 8482.99.70, 8483.20.40,

8483.20.80, 8483.50.8040, 8483.50.90,

8483.90.20, 8483.90.30, 8483.90.70,

8708.50.50, 8708.60.50, 8708.60.80,

8708.70.6060, 8708.70.8050, 8708.93.30,

8708.93.5000, 8708.93.6000, 8708.93.75,

8708.99.06, 8708.99.31, 8708.99.4960,

8708.99.50, 8708.99.5800, 8708.99.8080,

8803.10.00, 8803.20.00, 8803.30.00,

8803.90.30, 8803.90.90.

2. Cylindrical Roller Bearings and

Parts Thereof: These products include

all AFBs that employ cylindrical rollers

as the rolling element. Imports of these

products are classified under the

following categories: antifriction rollers,

all cylindrical roller bearings (including

split cylindrical roller bearings) and

parts thereof, and housed or mounted

cylindrical roller bearing units and parts

thereof.

Imports of these products are

classified under the following HTS

subheadings: 3926.90.45, 4016.93.00,

4016.93.10, 4016.93.50, 6909.19.5010,

8431.20.00, 8431.39.0010, 8482.40.00,

8482.50.00, 8482.80.00, 8482.91.00,

8482.99.25, 8482.99.35, 8482.99.6530,

8482.99.6560, 8482.99.6590, 8482.99.70,

8483.20.40, 8483.20.80, 8483.50.8040,

8483.90.20, 8483.90.30, 8483.90.70,

8708.50.50, 8708.60.50, 8708.93.5000,

8708.99.4000, 8708.99.4960, 8708.99.50,

8708.99.8080, 8803.10.00, 8803.20.00,

8803.30.00, 8803.90.30, 8803.90.90.

The size or precision grade of a

bearing does not influence whether the

bearing is covered by the order. For a

further discussion of the scope of the

orders being reviewed, including recent

scope determinations, see Antifriction

Bearings (Other Than Tapered Roller

Bearings) and Parts Thereof from Italy;

Final Results of Antidumping Duty

Administrative Reviews and Revocation

in Part of an Antidumping Duty Order,

60 FR 10959 (February 28, 1995). The

HTS item numbers are provided for
62814 Federal Register / Vol. 60, No. 235 / Thursday, December 7, 1995 / Notices

convenience and Customs purposes.

The written descriptions remain

dispositive.

These reviews cover the following

firms and classes or kinds of

merchandise:

Name of firm Class or kind

FAG Italia S.p.A .................... BBs, CRBs.

Meter, S.p.A .......................... BBs.

SKF Industrie S.p.A .............. BBs, CRBs.

United States Price

In calculating United States price

(USP), the Department used purchase

price or exporter’s sales price (ESP), as

defined in section 772 of the Tariff Act,

as appropriate.

Due to the extremely large number of

transactions that occurred during the

POR and the resulting administrative

burden involved in calculating

individual margins for all of these

transactions, we sampled sales to

calculate USP, in accordance with

section 777A of the Tariff Act. When a

firm made more than 2,000 ESP sales

transactions to the United States for a

particular class or kind of merchandise,

we reviewed ESP sales which occurred

during sample weeks. We selected one

week from each two-month period in

the review period, for a total of six

weeks, and analyzed each transaction

made in those six weeks. The sample

weeks included June 27–July 3, 1993,

July 4–10, 1993, October 10–16, 1993,

November 7–13, 1993, February 13–19,

1994, and April 24–30, 1994. We

reviewed all purchase price sales

transactions during the POR because

there were few purchase price sales.

USP was based on the packed f.o.b.,

c.i.f., or delivered price to unrelated

purchasers in, or for exportation to, the

United States. We made deductions, as

appropriate, from purchase price and

ESP for movement expenses, discounts

and rebates.

We made additional deductions from

ESP for direct selling expenses, indirect

selling expenses, and repacking in the

United States.

In light of the Federal Circuit’s

decision in Federal Mogul v. United

States, CAFC No. 94–1097, the

Department has changed its treatment of

home market consumption taxes. Where

merchandise exported to the United

States is exempt from the consumption

tax, the Department will add to the U.S.

price the absolute amount of such taxes

charged on the comparison sales in the

home market. This is the same

methodology that the Department

adopted following the decision of the

Federal Circuit in Zenith v. United

States, 988 F. 2d 1573, 1582 (1993), and

which was suggested by that court in

footnote 4 of its decision. The Court of

International Trade (CIT) overturned

this methodology in Federal Mogul v.

United States, 834 F. Supp. 1391 (1993),

and the Department acquiesced in the

CIT’s decision. The Department then

followed the CIT’s preferred

methodology, which was to calculate

the tax to be added to U.S. price by

multiplying the adjusted U.S. price by

the foreign market tax rate; the

Department made adjustments to this

amount so that the tax adjustment

would not alter a ‘‘zero’’ pre-tax

dumping assessment.

The foreign exporters in the Federal

Mogul case, however, appealed that

decision to the Federal Circuit, which

reversed the CIT and held that the

statute did not preclude the Department

from using the ‘‘Zenith footnote 4’’

methodology to calculate tax-neutral

dumping assessments (i.e., assessments

that are unaffected by the existence or

amount of home market consumption

taxes). Moreover, the Federal Circuit

recognized that certain international

agreements of the United States, in

particular the General Agreement on

Tariffs and Trade (GATT) and the Tokyo

Round Antidumping Code, required the

calculation of tax-neutral dumping

assessments. The Federal Circuit

remanded the case to the CIT with

instructions to direct the Department to

determine which tax methodology it

will employ.

The Department has determined that

the ‘‘Zenith footnote 4’’ methodology

should be used. First, as the Department

has explained in numerous

administrative determinations and court

filings over the past decade, and as the

Federal Circuit has now recognized,

Article VI of the GATT and Article 2 of

the Tokyo Round Antidumping Code

required that dumping assessments be

tax-neutral. This requirement continues

under the new Agreement on

Implementation of Article VI of the

General Agreement on Tariffs and

Trade. Second, the Uruguay Round

Agreements Act (URAA) explicitly

amended the antidumping law to

remove consumption taxes from the

home market price and to eliminate the

addition of taxes to U.S. price, so that

no consumption tax is included in the

price in either market. The Statement of

Administrative Action (p. 159)

explicitly states that this change was

intended to result in tax neutrality.

While the ‘‘Zenith footnote 4’’

methodology is slightly different from

the URAA methodology, in that section

772(d)(1)(C) of the pre-URAA law

required that the tax be added to U.S.

price rather than subtracted from home

market price, it does result in taxneutral duty assessments. In sum, the

Department has elected to treat

consumption taxes in a manner

consistent with its longstanding policy

of tax-neutrality and with the GATT.

With respect to subject merchandise

to which value was added in the United

States prior to sale to unrelated U.S.

customers, e.g., parts of bearings that

were imported and further processed

into finished bearings by U.S. affiliates

of foreign exporters, we deducted any

increased value in accordance with

section 772(e)(3) of the Tariff Act.

Those bearings which are otherwise

subject to the order that are imported

into the United States and incorporated

into nonbearing products by or for the

exporter, and which collectively

comprise less than one percent of the

value of the finished products sold to

unrelated customers in the United

States are not subject to the assessment

of antidumping duties (see Antifriction

Bearings (Other Than Tapered Roller

Bearings) and Parts Thereof from the

Federal Republic of Germany; Final

Results of Antidumping Duty

Administrative Review, 56 FR 31694

(July 11, 1991). In Roller Chain, Other

Than Bicycle, from Japan 48 FR 51801

(November 14, 1983), roller chain,

which was subject to an antidumping

duty finding, was imported by a related

party and incorporated into finished

motorcycles. The finished motorcycles

were the first products sold by the

exporter to unrelated purchasers in the

United States. Because the roller chain

did not constitute a significant

percentage of the value of the completed

product, the Department found that a

USP could not reasonably be

determined for the roller chain. The

Department, therefore, did not assess

antidumping duties on these

transactions. We have applied this same

principle to these reviews.

Foreign Market Value

The home markets were viable for all

companies and all classes or kinds of

merchandise pursuant to 19 C.F.R.

353.48. The Department used home

market prices or constructed value (CV),

as defined in section 773 of the Tariff

Act, as appropriate, to calculate foreign

market value (FMV).

Due to the extremely large number of

transactions that occurred during the

POR and the resulting administrative

burden involved in examining all of

these transactions, we sampled sales to

calculate FMV, in accordance with

section 777A of the Tariff Act. When a

firm had more than 2,000 home market

sales transactions for a particular class

or kind of merchandise, we used sales
Federal Register / Vol. 60, No. 235 / Thursday, December 7, 1995 / Notices 62815

from sample months that corresponded

to the sample weeks selected for U.S.

sales sampling plus one

contemporaneous month prior to the

POR and one following the POR. The

sample months included April, June,

July, October, and November of 1993,

and February, April, and May of 1994.

In general, the Department relies on

monthly weighted-average prices in the

calculation of FMV in administrative

reviews. Because of the significant

volume of home market sales involved

in these reviews, we examined whether

it was appropriate to average, in

accordance with section 777A of the

Tariff Act, all of each respondent’s

home market sales on an annual basis.

In this case, the use of POR weightedaverage prices results in significant time

and resource savings for the

Department. To determine whether a

POR weighted-average price was

representative of the transactions under

consideration, we performed a threestep test.

We first compared each monthly

weighted-average home market price for

each model with the weighted-average

POR price of that model. We calculated

the proportion of each model’s sales

whose POR weighted-average price did

not vary meaningfully (i.e., was within

plus or minus 10 percent) from the

monthly weighted-average prices. We

did this for each model within each

class or kind of merchandise. We then

compared the volume of sales of all

models within each class or kind of

merchandise whose POR weightedaverage price did not vary meaningfully

from the monthly weighted-average

price with the total volume of sales of

that class or kind of merchandise. If the

POR weighted-average price of at least

90 percent of sales in each class or kind

of merchandise did not vary

meaningfully from the monthly

weighted-average price, we considered

the POR weighted-average prices to be

representative of the transactions under

consideration. Finally, we tested

whether there was any correlation

between fluctuations in price and time

for the home market sales. Where the

absolute value of the correlation

coefficient was less than 0.05 (where a

coefficient approaching 1.0 means a

direct relation between price and time,

i.e., that prices consistently rise from

month to month, and a coefficient

approaching zero means no relation

between prices and time), we concluded

that there was no significant relation

between price and time. We calculated

a weighted-average POR FMV only for

those classes or kinds that satisfied our

three-step test for the factors of price,

volume, and time.

We compared U.S. sales with sales of

such or similar merchandise in the

home market. We considered all nonidentical products within a bearing

family to be equally similar. As defined

in the questionnaire, a bearing family

consists of all bearings within a class or

kind of merchandise that are the same

in the following physical characteristics:

load direction, bearing design, number

of rows of rolling elements, precision

rating, dynamic load rating, outer

diameter, inner diameter, and width.

Home market prices were based on

the packed, ex-factory or delivered

prices to related or unrelated purchasers

in the home market. Where applicable,

we made adjustments for movement

expenses, differences in cost attributable

to differences in physical characteristics

of the merchandise pursuant to

773(a)(4)(C) of the Tariff Act, and

differences in packing. We also made

adjustments for differences in

circumstances of sale in accordance

with 19 C.F.R. 353.56. For comparisons

to purchase price sales, we deducted

home market direct selling expenses

and added U.S. direct selling expenses.

For comparisons to ESP sales, we

deducted home market direct selling

expenses. We also made adjustments,

where applicable, for home market

indirect selling expenses to offset U.S.

commissions in purchase price and ESP

calculations and to offset U.S. indirect

selling expenses deducted in ESP

calculations, but not exceeding the

amount of the indirect U.S. expenses.

For comparisons to both ESP and

purchase price sales, we adjusted FMV

for taxes consistent with our change in

practice as stated above.

We used sales to related customers

only where we determined such sales

were made at arm’s-length prices, i.e., at

prices comparable to prices at which the

firm sold identical merchandise to

unrelated customers.

Where we found home market sales

below the cost of production in the

1991–1992 administrative reviews, we

concluded that reasonable grounds exist

to believe or suspect that home market

sales during the POR were made at

prices below the cost of production, and

we initiated cost investigations.

In accordance with section 773(b) of

the Tariff Act, in determining whether

to disregard home market sales made at

prices below the cost of production, we

examined whether such sales were

made in substantial quantities over an

extended period of time. When less than

10 percent of the home market sales of

a particular model were at prices below

the cost of production, we found that

there were not substantial quantities of

that model sold below cost and did not

disregard any sales of that model. When

10 percent or more, but not more than

90 percent, of the home market sales of

a particular model were determined to

be below cost, we determined that

substantial quantities of that model

were sold below cost and excluded the

below-cost home market sales from our

calculation of FMV, provided that these

below-cost sales were made over an

extended period of time. When more

than 90 percent of the home market

sales of a particular model were made

below cost over an extended period of

time, we disregarded all home market

sales of that model from our calculation

of FMV and used CV (see Polyethylene

Terephthalate Film, Sheet, and Strip

from Korea, 56 FR 16306 (1991)).

To determine if sales below cost had

been made over an extended period of

time, we compared the number of

months in which sales below cost had

occurred for a particular model to the

number of months in which the model

was sold. If the model was sold in three

or fewer months, we did not find that

below-cost sales were made over an

extended period of time unless there

were sales below cost of that model in

each month. If a model was sold in more

than three months, we did not find that

below-cost sales were made over an

extended period of time unless there

were sales below cost in at least three

of the months in which the model was

sold (see Final Results of Antidumping

Duty Administrative Reviews; Tapered

Roller Bearings and Parts Thereof,

Finished and Unfinished, From Japan

and Tapered Roller Bearings, Four

Inches or Less in Outside Diameter, and

Components Thereof, From Japan, 58 FR

64729 (December 9, 1993)).

Since none of the respondents has

submitted information indicating that

any of its sales below cost were at prices

which would have permitted ‘‘recovery

of all costs within a reasonable period

of time in the normal course of trade’’

within the meaning of section 773(b)(2)

of the Tariff Act, we were unable to

conclude that the costs of production of

such sales were recovered within a

reasonable period of time. As a result,

we disregarded below-cost sales when

the conditions described above were

met.

In accordance with sections 773(a)(1)

and 773(b)(2) of the Tariff Act, we used

CV as the basis for FMV when there

were no usable sales of such or similar

merchandise for comparison.

We calculated CV in accordance with

section 773(e) of the Tariff Act. We

included the cost of materials,

fabrication, general expenses, profit, and

packing. To calculate CV we used: (1)

Actual general expenses or the statutory
62816 Federal Register / Vol. 60, No. 235 / Thursday, December 7, 1995 / Notices

minimum of 10 percent of materials and

fabrication, whichever was greater; (2)

actual profit or the statutory minimum

of 8 percent of materials, fabrication

costs and general expenses, whichever

was greater; and (3) packing costs for

merchandise exported to the United

States. Where appropriate, we made

adjustments to CV in accordance with

19 C.F.R. 353.56 for differences in

circumstances of sale. For comparisons

to purchase price sales, we deducted

home market direct selling expenses

and added U.S. direct selling expenses.

For comparisons to ESP sales, we

deducted home market direct selling

expenses. We also made adjustments,

where applicable, for home market

indirect selling expenses to offset U.S.

commissions in purchase price and ESP

calculations. For comparisons involving

ESP transactions, we made further

deductions for CV for indirect selling

expenses in the home market, capped by

the indirect selling expenses incurred

on ESP sales in accordance with 19

C.F.R. 353.56(b)(2).

Preliminary Results of Reviews

As a result of our reviews, we

preliminarily determine the weightedaverage dumping margins (in percent)

for the period May 1, 1993, through

April 30, 1994 to be:

Company BBs CRBs

FAG .................................. 2.23 0.00

Meter ................................. 3.75 (1)

SKF ................................... 3.26 (2)

1 No review requested.

2Order partially revoked with respect to this

company.

Parties to this proceeding may request

disclosure within 5 days of the date of

publication of this notice. Any

interested party may request a hearing

within 10 days of the date of publication

of this notice. A general issues hearing,

if requested, and any hearings regarding

issues related solely to specific

countries, if requested, will be held in

accordance with the following schedule

and at the indicated locations in the

main Commerce building:

Date Time Room

No.

General issues.Jan. 22,

1996.

10 a.m . 1412

Italy .......... Jan. 22,

1996.

2 p.m ... 1412

Issues raised in hearings will be

limited to those raised in the respective

briefs or written comments, and rebuttal

briefs or rebuttals to written comments.

Briefs or written comments from

interested parties, and rebuttal briefs or

rebuttals to written comments, limited

to the issues raised in the respective

case briefs and comments, may be

submitted not later than the dates

shown below for general issues and the

respective country-specific cases. The

Department will subsequently publish

the final results of these administrative

reviews, including the results of its

analysis of issues raised in any such

written comments or hearings.

Case Briefs/comments due Rebuttals due

General issues.Jan. 8, 1996 Jan. 16, 1996

Italy ............. Jan. 8, 1996 Jan. 16, 1996

The Department shall determine, and

the Customs Service shall assess,

antidumping duties on all appropriate

entries. Because sampling prevents

calculation of duties on an entry-byentry basis, we will calculate an

importer-specific ad valorem duty

assessment rate for each class or kind of

merchandise based on the ratio of the

total value of antidumping duties

calculated for the examined sales made

during the POR to the total customs

value of the sales used to calculate those

duties. This rate will be assessed

uniformly on all entries of that

particular importer made during the

POR. (This is equivalent to dividing the

total value of antidumping duties,

which are calculated by taking the

difference between statutory FMV and

statutory USP, by the total statutory USP

value of the sales compared, and

adjusting the result by the average

difference between USP and customs

value for all merchandise examined

during the POR.)

In some cases such as purchase price

situations, the respondent does not

know the entered value of the

merchandise. Then, we will either

calculate an approximate entered value

or we will calculate an average per-unit

dollar amount of antidumping duty

based on all sales examined during the

POR. See AFBs I at 31694. The

Department will issue appropriate

appraisement instructions directly to

the Customs Service upon completion of

these reviews.

Furthermore, the following deposit

requirements will be effective for all

shipments of the subject merchandise

entered, or withdrawn from warehouse,

for consumption on or after the

publication date of the final results of

these administrative reviews, as

provided by section 751(a)(1) of the

Tariff Act: (1) The cash deposit rates for

the reviewed companies will be those

rates established in the final results of

these reviews (except that no deposit

will be required for firms with zero or

de minimis margins; i.e., margins less

than 0.5 percent); (2) for previously

reviewed or investigated companies not

listed above, the cash deposit rate will

continue to be the company-specific rate

published for the most recent period; (3)

if the exporter is not a firm covered in

this review, a prior review, or the

original LTFV investigation, but the

manufacturer is, the cash deposit rate

will be the rate established for the most

recent period for the manufacturer of

the merchandise; and (4) the cash

deposit rate for all other manufacturers

or exporters will continue to be the ‘‘all

others’’ rate made effective by the final

results of the 1991–92 administrative

reviews of these orders (see Final

Results of Antidumping Duty

Administrative Reviews and Revocation

in Part of an Antidumping Duty Order,

58 FR 39729 (July 26, 1993)). As noted

in those previous final results, these

rates are the ‘‘all others’’ rates from the

relevant LTFV investigations. These

deposit requirements, when imposed,

shall remain in effect until publication

of the final results of the next

administrative reviews.

This notice also serves as a

preliminary reminder to importers of

their responsibility under 19 C.F.R.

353.26 to file a certificate regarding the

reimbursement of antidumping duties

prior to liquidation of the relevant

entries during this review period.

Failure to comply with this requirement

could result in the Secretary’s

presumption that reimbursement of

antidumping duties occurred and the

subsequent assessment of double

antidumping duties.

These administrative reviews and

notice are in accordance with section

751(a)(1) of the Tariff Act (19 U.S.C.

1675(a)(1)) and 19 C.F.R. 353.22(c)(5).

Dated: November 30, 1995.

Paul L. Joffe,

Deputy Assistant Secretary for Import

Administration.

[FR Doc. 95–29888 Filed 12–6–95; 8:45 am]

BILLING CODE 3510–DS–P