[Federal Register Volume 60, Number 38 (Monday, February 27, 1995)]
[Notices]
[Pages 10564-10569]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 95-4721]



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DEPARTMENT OF COMMERCE.
[C-533-812]


Final Affirmative Countervailing Duty Determination: Certain 
Carbon Steel Butt-Weld Pipe Fittings From India

AGENCY: Import Administration, International Trade Administration, 
Department of Commerce.

EFFECTIVE DATE: February 27, 1995.

FOR FURTHER INFORMATION CONTACT: Susan M. Strumbel, Office of 
[[Page 10565]] Countervailing Investigations, Import Administration, 
U.S. Department of Commerce, Room 3099, 14th Street and Constitution 
Avenue, N.W., Washington, D.C. 20230; telephone (202) 482-1442.

Final Determination

    The Department of Commerce (``the Department'') determines that 
benefits which constitute subsidies within the meaning of section 701 
of the Tariff Act of 1930, as amended (``the Act''), are being provided 
to manufacturers, producers, or exporters in India of certain carbon 
steel butt-weld pipe fittings. For information on the estimated net 
subsidies, please see the Suspension of Liquidation section of this 
notice.

Case History

    Since the publication of the preliminary determination in the 
Federal Register, 59 FR 28337 (June 1, 1994), the following events have 
occurred.
    On June 27, 1994, at petitioner's request, we extended the final 
determination in this investigation to coincide with the final 
determination in the companion antidumping investigation (59 FR 32955).
    On June 30, 1994, petitioner requested that the Department postpone 
its preliminary determination in the antidumping investigation. 
Therefore, on July 26, 1994, the Department published in the Federal 
Register a notice postponing the preliminary antidumping determination 
and, therefore, also the final countervailing duty determination (59 FR 
37961).
    On October 5, 1994, respondents requested that the Department 
postpone the final antidumping and countervailing duty determinations. 
Therefore, on November 14, 1994, the Department published in the 
Federal Register a notice postponing the final antidumping and 
countervailing duty determinations until no later than February 16, 
1995 (59 FR 56461).
    We conducted verification of the responses submitted on behalf of 
the Government of India (GOI), Karmen Steels of India (Karmen) and 
Sivanandha Pipe Fittings Ltd. (Sivanandha) from November 4 through 
November 7, 1994. We received case briefs on January 24 from petitioner 
and respondents, and received rebuttal briefs from petitioner on 
January 31, 1995.

Scope of Investigation

    The products covered by this investigation are certain carbon steel 
butt-weld pipe fittings (``pipe fittings'') having an inside diameter 
of less than fourteen inches (355 millimeters), imported in either 
finished or unfinished condition. Pipe fittings are formed or forged 
steel products used to join pipe sections in piping systems where 
conditions require permanent welded connections, as distinguished from 
fittings based on other methods of fastening (e.g., threaded, grooved, 
or bolted fittings). Butt-weld fittings come in a variety of shapes 
which include ``elbows,'' ``tees,'' ``caps,'' and ``reducers.'' The 
edges of finished pipe fittings are beveled, so that when a fitting is 
placed against the end of a pipe (the ends of which have also been 
beveled), a shallow channel is created to accommodate the ``bead'' of 
the weld which joins the fitting to the pipe. These pipe fittings are 
currently classifiable under subheading 7307.93.3000 of the Harmonized 
Tariff Schedule of the United States (``HTSUS'').
    Although the HTSUS subheading is provided for convenience and 
customs purposes, our written description of the scope of this 
proceeding is dispositive.

Applicable Statue 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. References to the Countervailing Duties: 
Notice of Proposed Rulemaking and Request for Public Comments, 54 FR 
23366 (May 31, 1989) (Proposed Regulations), are provided solely for 
further explanation of the Department's CVD practice. Although the 
Department has withdrawn the particular rulemaking proceeding pursuant 
to which the Proposed Regulations were issued, the subject matter of 
these regulations is being considered in connection with an ongoing 
rulemaking proceeding which, among other things, is intended to conform 
the Department's regulations to the Uruguay Round Agreements Act. See 
60 FR 80 (January 3, 1995).
Injury Test

    Because India is a ``country under the Agreement'' within the 
meaning of section 701(b) of the Act, the U.S. International Trade 
Commission (``ITC'') is required to determine whether imports of pipe 
fittings from India materially injure, or threaten material injury to, 
a U.S. industry. On April 20, 1994, the ITC preliminarily determined 
that there is a reasonable indication that an industry in the United 
States is being materially injured or threatened with material injury 
by reason of imports from India of the subject merchandise (59 FR 
18825).

Period of Investigation

    For purposes of this final determination, the period for which we 
are measuring subsidies (the period of investigation (``POI'')) is the 
respondents' fiscal year: April 1, 1993 to March 31, 1994.

Non-Responding Company

    Since Tata did not respond to our countervailing duty 
questionnaire, we have used best information available (``BIA'') in 
accordance with section 355.37(a) of the Department's regulations. As 
BIA, we have used information provided in the petition except where we 
have calculated a rate for a given program in a previous countervailing 
duty investigation or administrative review for India which is higher 
than that provided in the petition. We did not include in the BIA 
subsidy rate for Tata programs for which we have no basis to calculate 
a benefit (i.e., programs for which rates are not calculated in the 
petition, programs not previously investigated, or programs previously 
found not used). Based on this approach, we calculated a BIA rate for 
Tata of 61.56 percent ad valorem.

Calculation of Country-Wide Rate

    In determining the benefits to the subject merchandise from the 
various programs described below, we used the following calculation 
methodology. We first calculated a country-wide rate for each program. 
This rate comprised the ad valorem benefit received by each firm 
weighted by each firm's share of exports of the subject merchandise to 
the United States. The program rates were then added together to arrive 
at the country-wide rate.
    Pursuant to 19 CFR 355.20(d) of the Department's regulations, we 
compared the total ad valorem benefit received by each firm to the 
country-wide rate for all programs. The rates for Karmen, Sivanandha 
and Tata were significantly different from the country-wide rate. 
Therefore, all three companies received company-specific rates. The 
country-wide rate will be assigned to all other manufacturers, 
producers and exporters.

Karmen's Exports of Refurbished Pipe Fittings

    Karmen has an arrangement with a Singaporean company, under which 
the Singaporean company supplies Karmen with rusty pipe fittings. 
Karmen reconditions and refurbishes these pipe fittings and ships them 
directly to the Singaporean company's U.S. customer. For purposes of 
the preliminary determination, we considered this refurbished 
merchandise to be covered by this proceeding. However, we stated 
[[Page 10566]] that we would seek additional information concerning: 
(1) The nature and extent of the processing operation, and (2) the 
extent to which the refurbished pipe fittings are being subsidized.
    For purposes of this final determination, we are treating the 
``sales'' of Singaporean pipe as outside of the scope of our 
investigation and, hence, not subject to any potential countervailing 
duty order on butt-weld pipe fittings from India. Karmen essentially 
performs a tolling service for its Singaporean customer. Moreover, 
Karmen does not ``substantially transform'' these pipe fittings. 
Substantial transformation generally refers to a degree of processing 
or manufacturing resulting in a new and different article. Through that 
transformation, the new article becomes a product of the country in 
which it was processed or manufactured. See Cold-Rolled Steel from 
Argentina, 58 FR 37062, 37065 (1993) (Appendix I). The Department makes 
these determinations on a case-by-case-basis. See, e.g., Certain Fresh 
Cut Flowers from Colombia, 55 FR 20491, 20299 (1990); Limousines from 
Canada, 55 FR 11036, 11040 (1990).
    In determining whether Karmen substantially transformed these pipe 
fittings, we examined whether the degree of processing or manufacturing 
resulted in a new and different article. Karmen receives rusty pipe 
fittings from Singapore, it removes the rust, paints the fitting, and 
forwards it to the Singaporean company's customer. We do not consider 
this refurbishing process as substantially transforming the subject 
merchandise because it remains a pipe fitting after refurbishment. 
Therefore, because Karmen does not substantially transform the 
merchandise, we do not consider it as falling within the scope of this 
investigation.
    However, we have also determined that the benefits received by 
Karmen under two of the countervailable export subsidy programs 
discussed below (pre-shipment financing and income tax deductions under 
80HHC) cannot be limited exclusively to Karmen's export sales of new 
pipe fittings (i.e., all Karmen's export sales excluding the 
Singaporean transactions). In neither instance is there any indication 
that Karmen is precluded from receiving these benefits on its 
refurbishing operations. Therefore, we have included the fee Karmen 
receives for refurbishing the Singaporean pipe fittings as part of the 
denominator for calculating the ad valorem subsidy rate. This is 
consistent with past practice. When we cannot specifically tie the 
receipt of an export subsidy to a subset of export sales, such as 
exports of the subject merchandise, we divide the total value of the 
export subsidy received by the total value of exports. (See, e.g., 
Final Results of Countervailing Duty Administrative Review: Certain 
Iron-Metal Castings from India, 56 FR 52521, (October 21, 1991), Final 
Affirmative Countervailing Duty Determination; Certain Electrical 
Conductor Aluminum Redraw Rod from Venezuela, 53 FR 24763, 24767 (June 
30, 1988) (Redraw Rod)). (For a further discussion of this issue, 
please refer to the Interested Party Comments section of this notice).
Analysis of Programs

    Based upon our analysis of the petition, the responses to our 
questionnaires, verification and comments made by interested parties, 
we determine the following:

A. Programs Determined To Be Countervailable

1. Preferential Pre-Shipment Financing
    Pre-shipment financing is extended to exporters prior to shipment 
as working capital for purchasing raw materials, processing, packing, 
warehousing, transporting and shipping. Any exporter showing a 
confirmed export order or a letter of credit is eligible for this 
program. Generally, the loans are extended for 180 days. We verified 
that both Karmen and Sivanandha had loans on which interest was paid 
during the POI under this program.
    Because only exporters are eligible for loans under this program, 
we determine that they are countervailable to the extent they are 
provided at a preferential interest rate. See, e.g., Redraw Rod. As our 
commercial benchmark interest rate, we used 16.50 percent, which is the 
rate reported by the GOI as the annual average commercial interest rate 
on short-term financing during the POI. We compared this benchmark rate 
to the interest rate charged on pre-shipment loans and found that the 
interest rate charged was lower than the benchmark rate. Therefore, we 
determine that loans provided under this program are countervailable.
    To calculate the benefit, we followed the short-term loan 
methodology which has been applied consistently in our past 
determinations and is described in more detail in the Subsidies 
Appendix accompanying Cold-Rolled Carbon Steel Flat-Rolled Products 
from Argentina: Final Affirmative Countervailing Duty Determination and 
Countervailing Duty Order, 49 FR 18006 (April 26, 1984); see also, 
Alhambra Foundry v. United States, 626 F. Supp. 402 (CIT 1985).
    We compared the amount of interest paid during the POI to the 
amount of interest that would have been paid at the benchmark rate. The 
difference between these two amounts is the benefit. We then divided 
the benefit by total exports. On this basis, we determine the estimated 
net subsidy from this program to be 0.47 percent ad valorem for Karmen, 
0.44 percent ad valorem for Sivanandha and 5.27 percent ad valorem for 
Tata.
2. Income Tax Deductions Under Section 80HHC
    Income tax benefits are available to exporters in India under 
Section 80HHC of the Income Tax Act of 1961. This program allows 
exporters to reduce their taxable income by the profits or export 
subsidies earned on exports. Both Karmen and Sivanandha claimed 
deductions under this program on their income tax returns filed in the 
POI.
    Since tax deductions under Section 80HHC are available only to 
exporters, we determine that this program is countervailable. To 
calculate the benefit, we multiplied the amount of the deduction 
claimed by each company by the corporate income tax rate and divided 
the result by total exports. On this basis, we determine the estimated 
net subsidy from this program to be 2.10 percent ad valorem for Karmen, 
2.73 percent ad valorem Sivanandha and 15.82 percent ad valorem for 
Tata.
3. International Price Reimbursement Scheme
    The International Price Reimbursement Scheme (``IPRS'') was 
established to compensate Indian exporters for the difference between 
the domestic price of inputs and their world market price. We verified 
that, as of April 1, 1993, the input product used in the production of 
pipe fittings (seamless carbon steel pipe), was no longer eligible for 
IPRS benefits. However, residual benefits could be received after that 
date and, in fact, Karmen received residual benefits under this program 
during the POI for exports of pipe fittings shipped prior to the POI.
    Respondents maintain that the IPRS program is permissible within 
the framework of Item (d) of the Illustrative List of Export Subsidies 
annexed to the Agreement on the Interpretation and Application of 
Article VI, XVI and XXIII of the General Agreement on Tariffs and Trade 
(Subsidies Code), (1979). Pursuant to the remand determination in Final 
Results of Redetermination Pursuant to Court Remand, Creswell Trading 
Company, Inc., et al. v. United [[Page 10567]] States, Slip. Op. 94-65 
(Creswell Trading), the IPRS program must be examined in light of Item 
(d).
    To conduct the analysis with respect to Item (d) of the 
Illustrative List, we examined whether the IPRS program involves a 
consistently applied calculation methodology for determining the 
difference between the higher domestic and lower international price of 
a product available to exporters and whether the pricing and other data 
used in this methodology are regularly updated to reflect accurately 
the price differential at the time of the purchase of the product.
    We verified that India's IPRS program utilizes a clearly defined 
and consistently applied methodology for calculating the difference 
between the higher domestic and lower international price of seamless 
carbon steel pipe available to their exporters. We also verified that 
the price schedules for both domestic and international prices are 
updated periodically. Therefore, we determine that the basic terms and 
conditions of the provision of carbon steel pipe under the IPRS program 
are not ``more favourable than those commercially available on world 
markets'' to Indian exporters. However, we have also determined that 
the IPRS rebate is ``excessive,'' because the government failed to 
include ocean freight in its calculation of the world market price.
    Item (d) is concerned with the government's provision of goods to 
exporters on terms more favorable than those ``commercially available 
on world markets to their exporters.'' Indian exporters who purchase 
seamless carbon steel pipe on the world market would necessarily also 
incur the cost of delivering the pipe to India. Therefore, the 
commercially available alternative is the price of seamless carbon 
steel pipe itself, from sources outside of India, plus a delivery 
charge to India.
    The international prices used by the GOI in its calculations of 
IPRS rebates are stated in F.O.B. (port of origination) terms and, 
thus, do not reflect the delivery of foreign seamless carbon steel pipe 
to India. Consequently, we added delivery costs to the price of 
foreign-sourced seamless carbon steel pipe and compared the delivered 
domestic price to a delivered world market price. On this basis, we 
determine that the IPRS rebates received by the Indian pipe fittings 
producers are excessive in the amount of the delivery charges necessary 
to transport carbon steel pipe to India. The excess amount is a 
countervailable subsidy because the rebate enabled the pipe fittings 
exporters to pay a lower price for carbon steel pipe than that 
commercially available on world markets.
    To calculate Karmen's benefit, we divided the amount of ocean 
freight necessary to ship seamless carbon steel pipe to India by 
Karmen's total exports of pipe fittings. We did not include in the 
denominator the fees Karmen receives for refurbishing Singaporean pipe 
because refurbished pipe fittings are not eligible for the IPRS. On 
this basis, we determine the estimated net subsidy from this program to 
be 7.05 percent ad valorem for Karmen, 0.00 percent ad valorem for 
Sivanandha and 32.66 percent ad valorem for Tata.

B. Programs Determined not to Provide Benefits During the POI Advance 
Licenses and Advance Customs Clearance Permits (``ACCP's'')

    Under the GOI's Duty Exemption Scheme, inputs used in the 
production of exports may enter the country duty-free. Two mechanisms 
under the Duty Exemption Scheme are Advance Licenses and Advance Custom 
Clearance Permits (``ACCPs''). Sivanandha used Advance Licenses to 
import seamless carbon steel pipes in the POI. Advance Licenses permit 
the importation of goods duty free provided that the imports are used 
in the production of merchandise subsequently exported.
    Karmen used ACCPs during the POI. ACCPs allow exporters to import 
merchandise duty free for the purpose of jobbing, restoration, 
reconditioning and other servicing, provided that such merchandise is 
re-exported. Karmen used its ACCPs to import the aforementioned pipe 
fittings from Singapore.
    We consider the use of Advance Licenses and ACCP's to be the 
equivalent of a duty-drawback program (see Final Affirmative 
Countervailing Duty Determination: Steel Wire Rope from India, 56 FR 
46292 (September 11, 1991)). Under Sec. 355.44(i)(4)(1) of the 
Department's proposed regulations (see Countervailing Duties; Notice of 
Proposed Rulemaking and Request for Public Comments, 54 FR 23366 (May 
31, 1989), the non-excessive drawback of import duties is not 
countervailable if the imported products are physically incorporated 
into exported products. According to the questionnaire responses and 
verification, the products imported under Advance Licenses are 
physically incorporated into pipe fittings which are subsequently re-
exported. The products imported under the ACCP's were refurbished and 
also re-exported. Therefore, we determine that Advance Licenses and 
ACCP's did not provide a countervailable benefit in the POI.
C. Programs Determined To Be Not Used

    We established at verification that the following programs were not 
used during the POI.

A. Preferential Post-Shipment Financing
B. Additional and Replenishment Licenses
C. Market Development Assistance
D. Export Promotion, Capital Goods Scheme
E. Benefits for 100 Percent Export-Oriented Units
F. Benefits Provided to Export Processing Zones

Interested Party Comments

    Comment 1: Karmen argues that it would be inappropriate to subtract 
the fees received for its refurbishing operations from the denominator 
but to leave the subsidies resulting from the refurbishing in the 
numerator. Karmen argues that the job-working fees received for the 
Singaporean transactions must be included in the denominator to 
calculate its subsidy rate. Karmen contends that the benefits from the 
two subsidies we preliminarily found countervailable, the 80HHC tax 
program and the pre-shipment export financing, resulted significantly 
from the transactions involving Singaporean pipe.
    Petitioner argues that the transactions involving the refurbished 
pipe fittings do not constitute a sale for the purposes of this 
investigation. Furthermore, petitioner disagrees that the refurbished 
pipe fittings contributed to Karmen's benefits under either of the 
above-mentioned programs.
    DOC's Position: As noted above, we have determined that the 
benefits from the pre-shipment export financing and 80HHC programs 
cannot be tied solely to Karmen's export sales, exclusive of the income 
received for refurbishing Singaporean pipe. During verification, we 
were told by Karmen officials that they did not use pre-shipment export 
financing for shipments of refurbished pipe fittings, but based on our 
analysis of the information submitted regarding this program, there is 
no reason to believe that Karmen could not have used the financing for 
these shipments. We do not typically narrow our export subsidy 
denominator to less than total exports unless the benefits provided can 
be exclusively linked to a smaller subset of export sales. Therefore, 
consistent with our past practice, we divided the benefit amount by the 
value of Karmen's total exports, including the fees it received for 
refurbishing. [[Page 10568]] 
    With respect to the 80HHC program, our past practice has been to 
divide the value of the benefits by total exports in the POI. Pursuant 
to our general tax methodology, we consider tax benefits to be 
``received'' when a company files the return. Consequently, the benefit 
used in our calculation usually relates to sales activity in the year 
prior to the POI. As a result, the sales denominator we use in our 
subsidy calculation is rarely, if ever, the sales from the same fiscal 
year covered by the tax return. The only basis to exclude sales from 
the denominator is to determine that they are incapable of generating 
the tax benefit in question. The only issue then, in this 
investigation, is whether the fees Karmen receives for its refurbishing 
operations can generate 80HHC benefits.
    The 80HHC benefits Karmen claimed on the tax return filed during 
the POI (covering a pre-POI period) were not generated by Karmen's 
refurbishing operations because Karmen did not refurbish any 
Singaporean pipe during the fiscal year covered by the tax return. 
However, we verified that the fees received by Karmen for its 
refurbishing operations during the POI did generate 80HHC benefits on 
the tax return which covers the POI. It is clear that the refurbishing 
fees received by Karmen qualify for 80HHC benefits. The only reason 
80HHC benefits generated by the refurbishing operations are not in the 
80HHC subsidy calculation in this investigation is the Department's tax 
methodology which mandates the use of the tax return filed during the 
POI.
    Comment 2: Respondents argue that the benchmark interest rate of 
16.5 percent used in the Department's preliminary determination is the 
appropriate benchmark rate and should also be used in the Department's 
final determination. They state that this interest rate is the national 
average commercial rate for comparable loans. They contend that the 
18.75 percent interest rate listed in the Department's verification 
reports is a company-specific rate and therefore should not be used. 
They further state that the 18.75 percent interest rate is for a loan 
that has a one year term while pre-shipment financing has a much 
shorter term. Finally, they argue that pre-shipment export financing is 
a low risk form of credit because the exporter has to show a purchase 
order prior to receiving financing.
    DOC's Position: We agree that the 18.75 percent interest rate is a 
company-specific rate. When selecting a short-term interest rate 
benchmark the Department's first choice is a national average rate 
rather than a company-specific rate. See, Subsidies Appendix. The 
questionnaire response of the GOI stated that the annual average 
interest rate on short-term financing in India during the POI was 16.5 
percent. According to the Reserve Bank of India, the minimum commercial 
short-term rate on loans above 200,000 rupees in India during the POI 
was 15.00 percent. Information from the May 1994 edition of 
International Financial Statistics indicates that the average short- 
and medium-term interest rate in India during the POI was approximately 
15.59 percent. Given the information on the record, we used as our 
benchmark the rate provided by the GOI.
    Comment 3: Respondents argue that the Department should uphold its 
preliminary finding that the IPRS program is non-countervailable.
    DOC's Position: Based on verification and the recent remand 
determination in Creswell Trading, we have determined that the IPRS 
program provided a countervailable benefit during the POI.
Verification

    In accordance with section 776(b) of the Act, we verified the 
information used in making our final determination. We followed 
standard verification procedures, including meeting with government and 
company officials, examination of relevant accounting records and 
examination of original source documents. Our verification results are 
outlined in detail in the public versions of the verification reports, 
which are on file in the Central Records Unit (Room B-99 of the Main 
Commerce Building).

Suspension of Liquidation

    In accordance with our affirmative preliminary determination, we 
instructed the U.S. Customs Service to suspend liquidation of all 
entries of butt-weld pipe fittings from India, which were entered or 
withdrawn from warehouse for consumption, on or after June 1, 1994, the 
date our preliminary determination was published in the Federal 
Register.
    After the preliminary determination, this final countervailing duty 
determination was aligned with the final antidumping duty determination 
on certain carbon steel butt-weld pipe fittings from India, pursuant to 
section 606 of the Trade and Tariff Act of 1984 (section 705(a)(1) of 
the Act).
    Under article 5, paragraph 3 of the Subsidies Code, provisional 
measures cannot be imposed for more than 120 days without final 
affirmative determinations of subsidization and injury. Therefore, we 
instructed the U.S. Customs Service to discontinue the suspension of 
liquidation on the subject merchandise on or after September 30, 1994, 
but to continue the suspension of liquidation of all entries, or 
withdrawals from warehouse, for consumption of the subject merchandise 
entered between June 1, 1994, and September 29, 1994. We will reinstate 
the suspension of liquidation, under section 703(d) of the Act, if the 
ITC issues a final affirmative injury determination, and will require a 
cash deposit of estimated countervailing duties in the amounts 
indicated below:

Karmen Steels of India: 9.62 percent ad valorem
Sivanandha Pipe Fittings Ltd.: 3.16 percent ad valorem
Tata Iron & Steel Limited: 61.56 percent ad valorem
All-Others: 29.40 percent ad valorem

ITC Notification

    In accordance with section 705(d) of the Act, we will notify the 
ITC of our determination. In addition, pursuant to section 705(c) we 
are making available to the ITC all nonprivileged and nonproprietary 
information relating to this investigation. We will allow the ITC 
access to all privileged and business proprietary information in our 
files, provided the ITC confirms that it will not disclose such 
information, either publicly or under an administrative protective 
order, without the written consent of the Deputy Assistant Secretary 
for Investigations, Import Administration.
    If the ITC determines that material injury, or threat of material 
injury, does not exist, these proceedings will be terminated and all 
estimated duties deposited or securities posted as a result of the 
suspension of liquidation will be refunded or cancelled. If, however, 
the ITC determines that such injury does exist, we will issue a 
countervailing duty order directing Customs officers to assess 
countervailing duties on butt-weld pipe fittings from India.

Return of Destruction of Proprietary Information

    This notice serves as the only reminder to parties subject to 
Administrative Protective Order (APO) of their responsibility 
concerning the return or destruction of proprietary information 
disclosed under APO in accordance with 19 CFR 355.34(d). Failure to 
comply is a violation of the APO.
    This determination is published pursuant to section 705(d) of the 
Act and 19 CFR 355.20(a)(4).

    [[Page 10569]] Dated: February 16, 1995.
Barbara S. Stafford,
Acting Assistant Secretary for Import Administration.
[FR Doc. 95-4721 Filed 2-24-95; 8:45 am]
BILLING CODE 3510-DS-P