[Federal Register Volume 66, Number 246 (Friday, December 21, 2001)]
[Notices]
[Pages 65889-65893]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 01-31514]


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DEPARTMENT OF COMMERCE

International Trade Administration

[A-583-837]


Notice of Preliminary Determination of Sales at Less Than Fair 
Value and Postponement of Final Determination: Polyethylene 
Terephthalate Film, Sheet, and Strip (PET Film) From Taiwan

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

EFFECTIVE DATE: December 21, 2001.

FOR FURTHER INFORMATION: Ron Trentham or Tom Futtner at (202) 482-6320 
and (202) 482-3814, respectively; AD/CVD Enforcement Office IV, Group 
II, Import Administration, Room 1870, International Trade 
Administration, U.S. Department of Commerce, 14th Street and 
Constitution Avenue, NW., Washington, DC 20230.

The Applicable Statute and Regulations

    Unless otherwise indicated, all citations to the statute are 
references to the provisions effective January 1, 1995, the effective 
date of the amendments made to the Tariff Act of 1930 (the Act) by the 
Uruguay Round Agreements Act (URAA). In addition, unless otherwise 
indicated, all citations to the Department of Commerce (the Department) 
regulations refer to the regulations codified at 19 CFR part 351 (April 
2001).

[[Page 65890]]

Preliminary Determination

    We preliminarily determine that polyethylene terephthalate film, 
sheet, and strip (PET Film) from Taiwan is being sold, or is likely to 
be sold, in the United States at less than fair value (LTFV), as 
provided in section 733 of the Act. The estimated margins of sales at 
LTFV are shown in the Suspension of Liquidation section of this notice.

Case History

    The investigation was initiated on June 6, 2001.\1\ See Notice of 
Initiation of Antidumping Duty Investigation: Polyethylene 
Terephthalate Film, Sheet, and Strip (PET Film) from India and Taiwan, 
66 FR 31888 (June 13, 2001) (Initiation Notice). Since the initiation 
of the investigation, the following events have occurred.
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    \1\ The petitioners in this investigation are DuPont Teijin 
Films, Mitsubishi Polyester Film of America and Toray Plastics 
(America), Inc.
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    The Department set aside a period for all interested parties to 
raise issues regarding product coverage. See Initiation Notice, at 66 
FR 31889. We received no comments from any parties on this matter.
    On July 2, 2001 the United States International Trade Commission 
(ITC) transmitted to the Department its preliminarily determination 
that there is a reasonable indication that an industry in the United 
States is materially injured by reason of imports from Taiwan of PET 
film that are alleged to be sold in the United States at LTFV. See 
Polyethylene Terephthalate Film, Sheet, and Strip and Taiwan, 66 FR 
36296 (July 11, 2001).
    On July 3, 2001 the Department issued the antidumping duty 
questionnaire \2\ to Nan Ya Plastics Corporation, Ltd. (Nan Ya) and 
Shinkong Synthetic Fibers Corporation (Shinkong). See Selection of 
Respondents section below. We received responses to our questionnaire 
from both respondents. We issued supplemental questionnaires, 
pertaining to sections A, B, C, and D of the antidumping questionnaire, 
to Nan Ya and Shinkong in September, October and November 2001. Nan Ya 
and Shinkong responded to these supplemental questionnaires in 
September, October, November, and December 2001.
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    \2\ Section A of the questionnaire requests general information 
concerning a company's corporate structure and business practices, 
the merchandise under investigation that it sells, and the manner in 
which it sells that merchandise in all of its markets. Section B 
requests a complete listing of all home market sales, or, if the 
home market is not viable, of sales in the most appropriate third-
country market (this section is not applicable to respondents in 
non-market economy (NME) cases). Section C requests a complete 
listing of U.S. sales. Section D requests information on the cost of 
production (COP) of the foreign like product and the constructed 
value (CV) of the merchandise under investigation. Section E 
requests information on further manufacturing.
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    On October 4, 2001, pursuant to section 733(c)(1)(B) of the Act, 
the Department postponed the preliminary determination of this 
investigation 50 days, from October 24, 2001 until December 13, 2001. 
See Polyethylene Terephthalate Film, Sheet, and Strip from India and 
Taiwan: Notice of Postponement of Preliminary Antidumping Duty 
Determinations; 66 FR 52108 (October 12, 2001).
    During the course of this investigation, questions have arisen 
concerning affiliation between Nan Ya and its U.S. customers. Nan Ya 
has claimed that it is not affiliated with its U.S. customers. The 
petitioners have argued that Nan Ya is affiliated with several of its 
U.S. customers through a family grouping that includes collateral 
relatives. The Department has examined this issue by requesting and 
receiving information from Nan Ya and analyzing publicly available 
information. For these preliminary results, we are not treating Nan Ya 
as affiliated with its U.S. customers. We are still collecting and 
analyzing information on this matter and will determine whether these 
transactions are considered affiliated under the statute for purposes 
of the final results of this investigation. Interested parties are 
invited to submit comments on this specific issue, especially with 
regard to affiliation through a family group.

Postponement of the Final Determination

    Section 735(a)(2) of the Act provides that a final determination 
may be postponed until not later than 135 days after the date of the 
publication of the preliminary determination if, in the event of an 
affirmative preliminary determination, a request for such postponement 
is made by exporters who account for a significant proportion of 
exports of the subject merchandise, or in the event of a negative 
preliminary determination, a request for such postponement is made by 
the petitioners. The Department's regulations, at 19 CFR 351.210(e)(2), 
require that requests by respondents for postponement of a final 
determination be accompanied by a request for extension of provisional 
measures from a four-month period to not more than six months.
    On November 30, 2001 Shinkong requested that, in the event of an 
affirmative preliminary determination in this investigation, the 
Department postpone its final determination until 135 days after the 
publication of the preliminary determination. Shinkong also included a 
request to extend the provisional measures to not more than 135 days 
after the publication of the preliminary determination. Accordingly, 
since we have made an affirmative preliminary determination, and the 
requesting party accounts for a significant proportion of exports of 
the subject merchandise, we have postponed the final determination 
until not later than 135 days after the date of the publication of the 
preliminary determination.

Period of Investigation (POI)

    The POI is April 1, 2000 through March 31, 2001. This period 
corresponds to the four most recent fiscal quarters prior to the month 
of the filing of the petition (i.e., May 2001).

Scope of Investigation

    For purposes of these investigations, the products covered are 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 this 
proceeding is dispositive.

Selection of Respondents

    Section 777A(c)(1) of the Act directs the Department to calculate 
individual dumping margins for each known exporter and producer of the 
subject merchandise. Where it is not practicable to examine all known 
producers/exporters of subject merchandise, section 777A(c)(2) of the 
Act permits the Department to investigate either (1) a sample of 
exporters, producers, or types of products that is statistically valid 
based on the information available at the time of selection, or (2) 
exporters and producers accounting for the largest volume of the 
subject merchandise from the exporting country that can reasonably be 
examined. The petition identified two producers (Nan Ya and Shinkong) 
of PET film in Taiwan that export to the United States. Information on 
the record indicates that Nan Ya and Shinkong were the two largest 
producer/exporters of PET film from Taiwan to the United States during 
the POI. Due to limited resources we

[[Page 65891]]

determined that we could investigate only the two largest producers/
exporters, accounting for nearly 70 percent of total exports to the 
United States during the POI. See Memorandum regarding Selection of 
Respondents, dated June 22, 2001. Therefore, we designated Nan Ya and 
Shinkong as mandatory respondents and sent them the antidumping 
questionnaire.

Product Comparisons

    In accordance with section 771(16) of the Act, all products 
produced by the respondents covered by the description in the Scope of 
Investigation section, above, and sold in Taiwan during the POI are 
considered to be foreign like products for purposes of determining 
appropriate product comparisons to U.S. sales. We have relied upon 
product type, product application, product thickness, and product grade 
to match U.S. sales of subject merchandise to comparison-market sales 
of the foreign like product or constructed value (CV). Where there were 
no sales of identical merchandise in the home market to compare to U.S. 
sales, we compared U.S. sales to the next most similar foreign like 
product on the basis of the characteristics listed above.

Fair Value Comparisons

    During the POI, U.S. sales by the Taiwanese respondents were export 
price (EP) sales. To determine whether sales of PET Film were made in 
the United States at LTFV, we compared EP to the normal value (NV), as 
described in the EP and NV sections of this notice. In accordance with 
section 777A(d)(1)(A)(i) of the Act, we calculated weighted-average EPs 
and compared these to weighted-average home market prices during the 
POI.

Export Price

    For the price to the United States, we used EP, in accordance with 
section 772(a) of the Act, because Nan Ya and Shinkong reported that 
they sold the merchandise directly to unaffiliated U.S. customers or 
sold the merchandise to unaffiliated trading companies in Taiwan with 
knowledge that these companies in turn sold the merchandise to U.S. 
customers, and constructed export price was not otherwise warranted for 
these transactions. For both Nan Ya and Shinkong, we calculated EP 
using the packed prices charged to the unaffiliated trading companies 
or the first unaffiliated customer in the United States (the starting 
price).
    We deducted from the starting price, where applicable, amounts for 
movement expenses in accordance with section 772(c)(2)(A) of the Act. 
In this case, movement expenses include foreign inland freight, 
international freight, brokerage and handling charges, marine 
insurance, harbor duties and U.S. inland freight.

Normal Value

A. Selection of Comparison Market
    Section 773(a)(1) of the Act directs that NV be based on the price 
at which the foreign like product is sold in the home market, provided 
that the merchandise is sold in sufficient quantities (or has 
sufficient aggregate value, if quantity is inappropriate) and that 
there is no particular market situation in the home market that 
prevents a proper comparison with the EP or CEP transaction. The 
statute contemplates that quantities (or value) will normally be 
considered insufficient if they are less than five percent of the 
aggregate quantity (or value) of sales of the subject merchandise to 
the United States.
    For this investigation, we found that Nan Ya and Shinkong each had 
a viable home market for PET film. Thus, the home market is the 
appropriate comparison market in this investigation, and we used the 
respondents' submitted home market sales data for purposes of 
calculating NV.
    In deriving NV, we made adjustments as detailed in the Calculation 
of NV Based on Home Market Prices section below.
B. Cost of Production Analysis
    On September 19 and September 26, 2001 the petitioners alleged that 
sales of PET Film in the home market were made at prices below the 
fully absorbed cost of production (COP) with regard to Shinkong and Nan 
Ya, respectively. Accordingly, the petitioners requested that the 
Department conduct company-specific sales-below-cost investigations. 
Based upon the comparison of adjusted prices for the foreign like 
product to COP, and in accordance with section 773(b)(2)(A)(i) of the 
Act, we found reasonable grounds to believe or suspect that sales of 
PET film produced in Taiwan were made at prices below the COP with 
regard to both respondents. As a result, the Department has conducted 
an investigation to determine whether the respondents made sales in the 
home market at prices below their respective COPs during the POI within 
the meaning of section 773(b) of the Act. The COP analysis the 
Department performed is described below. See Memorandum to Holly A. 
Kuga ``Petitioner's Allegation of Sales Below the Cost of Production 
for Shinkong Synthetic Fibers Corporation, (September 28, 2001); 
Memorandum to Holly A. Kuga ``Petitioner's Allegation of Sales Below 
the Cost of Production for Nan Ya Plastics Corporation, Ltd. (October 
2, 2001), both on file in the CRU.
1. Calculation of COP
    In accordance with section 773(b)(3) of the Act, we calculated a 
weighted-average COP for each respondent based on the sum of the cost 
of materials and fabrication for the foreign like product, plus amounts 
for the home market general and administrative (G&A) expenses, 
including interest expenses. We relied on the COP data submitted by 
Shinkong and Nan Ya in their cost questionnaire responses, except, as 
noted below, in specific instances where the submitted costs were not 
appropriately quantified or valued.

Shinkong

    We recalculated Shinkong's total cost of manufacture to include a 
portion for ``Other Production-CPA adjust'' attributable to subject 
merchandise. See Calculation Memorandum of the Preliminary 
Determination of the Investigation of Shinkong Synthetic Fibers 
Corporation, dated December 12, 2001.

Nan Ya

    In accordance with sections 773(f)(2) and (3) of the Act, we 
recalculated Nan Ya's reported material adjustment to reflect the 
highest of the transfer price, COP, or market price of the inputs 
received from affiliated suppliers. In addition, we included a portion 
of ``cost difference'' and ``stop loss'' expenses attributable to Nan 
Ya's reported cost. See Memorandum from Ernest Gziryan, dated December 
13, 2001.
2. Test of Home Market Sales Prices
    On a model-specific basis, we compared the reported COP to the home 
market prices, adjusted for any applicable discounts and rebates, 
movement charges, selling expenses, and packing. We then compared the 
adjusted weighted-average COP for Shinkong and Nan Ya to the adjusted 
home market sales prices of the foreign like product, as required under 
section 773(b) of the Act, in order to determine whether these sales 
had been made at prices below the COP in substantial quantities within 
an extended period of time (i.e., a period of one year), and, whether 
below-cost prices were sufficient to permit the recovery of all costs 
within a reasonable period of time.

[[Page 65892]]

3. Results of the COP Test
    Pursuant to section 773(b)(2)(C) of the Act, where less than 20 
percent of a respondent's sales of a given product during the POI are 
at prices less than the COP, we do not disregard any below-cost sales 
of that product because we determine that the below-cost sales were not 
made in ``substantial quantities'' within an extended period of time. 
Where 20 percent or more of a respondent's sales of a given product 
during the POI are at prices less than the COP, we determine such sales 
to have been made in ``substantial quantities'' within an extended 
period of time in accordance with sections 773(b)(2)(B) and 
773(b)(2)(C) of the Act. In such cases, because we compare prices to 
POI average costs, we also determine that such sales were not made at 
prices that would permit recovery of all costs within a reasonable 
period of time, in accordance with section 773(b)(2)(D) of the Act.
    In this case, we found that, for certain specific products, more 
than 20 percent of Shinkong's and Nan Ya's home market sales, within an 
extended period of time, were at prices less than the COP in accordance 
with section 773(b)(1)(A) of the Act. For these certain specific 
products we compared Shinkong's and Nan Ya's home market prices to POI 
average costs and determined that such sales were not made at prices 
that would permit recovery of all costs within a reasonable period of 
time pursuant to section 773(b)(2)(B) of the Act. We therefore excluded 
these sales and used the remaining sales as the basis for determining 
NV, in accordance with section 773(b)(1) of the Act.
C. Calculation of NV Based on Home Market Prices
    We based home market prices on the packed prices to unaffiliated 
purchasers in Taiwan. We adjusted, where applicable, the starting price 
for discounts and rebates. We made adjustments for any differences in 
packing, in accordance with sections 773(a)(6)(A) and 773(a)(6)(B)(i) 
of the Act, and we deducted movement expenses pursuant to section 
773(a)(6)(B)(ii) of the Act. In addition, where applicable, we made 
adjustments for differences in circumstances of sale (COS) pursuant to 
section 773(a)(6)(C)(iii) of the Act by deducting direct selling 
expenses (credit expense) incurred for home market sales, and adding 
U.S. direct selling expenses (credit expenses). No other adjustments to 
NV were claimed or allowed.
D. Level of Trade (LOT)/Constructed Export Price (CEP) Offset
    In accordance with section 773(a)(1)(B)(i) of the Act, to the 
extent practicable, we determine NV based on sales in the comparison 
market at the same LOT as the EP or CEP transactions as appropriate. 
The NV LOT is that of the starting-price of sales in the comparison 
market or, when NV is based on CV, that of the sales from which we 
derive selling, general, and administrative (SG&A) expenses and profit. 
For EP sales, the U.S. LOT is also the level of the starting-price 
sale, which is usually from exporter to importer. For CEP, it is the 
level of the constructed sale from the exporter to an affiliated 
importer after the deductions required under section 772(d) of the Act. 
In this case, both Nan Ya and Shinkong had only EP sales.
    To determine whether NV sales are at a different LOT than EP or CEP 
transactions, we examine stages in the marketing process and selling 
functions along the chain of distribution between the producer and the 
unaffiliated customer. If the comparison market sales are at a 
different LOT and the difference affects price comparability, as 
manifested in a pattern of consistent price differences between the 
sales on which NV is based and comparison market sales at the LOT of 
the export transaction, we make a LOT adjustment under section 
773(a)(7)(A) of the Act.
    We obtained information from the respondents about the marketing 
stages involved in the reported U.S. and home market sales, including a 
description of the selling activities performed by the respondents for 
each channel of distribution. In identifying LOTs for EP and home 
market sales, we considered the selling functions reflected in the 
starting price before any adjustments. We expect that, if claimed LOTs 
are the same, the functions and activities of the seller should be 
similar. Conversely, if a party claims that LOTs are different for 
different groups of sales, the functions and activities of the seller 
should be dissimilar. In this investigation, none of the respondents 
requested a LOT adjustment.
    Shinkong reported that it made EP sales of subject merchandise to a 
single type of customer through a single channel of distribution in the 
U.S. market. Further, Shinkong indicated that it performed certain 
types of selling functions (freight and delivery arrangements, and 
warranty services) for the U.S. customers. Because there is only one 
type of customer, a single channel of distribution, and the same 
selling functions are performed for every customer, we preliminarily 
determine that there is a single LOT with respect to Shinkong's EP 
sales. In the home market, Shinkong reported that it sold subject 
merchandise to two types of customers (distributors and end-users). 
Further, it indicated that, for each of the two reported channels of 
distribution, it provided the same types of selling functions (freight 
and delivery arrangements and warranty services) in the same degree for 
each of the two types of customers. Because these selling functions are 
provided in equal degrees to all home market customers, we preliminary 
find that there is only one LOT in the home market.
    Upon review of the record, we found that Shinkong performed the 
same selling functions for EP sales as compared to home market sales. 
As such, we preliminarily find that there is no difference in the 
number, type, and degree of selling functions that Shinkong performs in 
the home market as compared to its EP sales. Because EP sales are made 
at the same LOT as home market sales, no LOT adjustment is warranted 
and we have not made a LOT adjustment for Shinkong's sales. See 
Memorandum to the File Re: Level of Trade Analysis for Shinkong 
Synthetic Fibers Corporation, dated December 13, 2001.
    Nan Ya reported that it sold subject merchandise to two types of 
customers (distributors and end-users) in the home market. Further, it 
indicated that, for each of the two reported channels of distribution, 
it provided the same types of selling functions in the same degree for 
each of the two types of customers. Because these selling functions are 
provided in equal degrees to all home market customers, we 
preliminarily find that there is only one LOT in the home market.
    Nan Ya reported that it sold subject merchandise to two types of 
customers (distributors and end-users) in the United States. Further, 
it indicated that, for each of the two reported channels of 
distribution, it provided the same types of selling functions in the 
same degree for each of the two types of customers. Because these 
selling functions are provided in equal degrees to all U.S. customers, 
we preliminarily find that there is only one LOT in the U.S. market.
    Upon review of the record we find that Nan Ya performed 
substantially similar selling functions for EP sales as compared to 
home market sales. The record indicates that there are minor 
differences between the selling functions performed for EP sales and 
home market sales. For example, Nan Ya provided some technical service 
for

[[Page 65893]]

home market customers but not EP customers. However the information on 
the record indicates that there is insufficient qualitative differences 
in the selling functions performed by Nan Ya in making sales in the 
home market and United States to find them to be distinct LOTs. 
Therefore, using the information on the record, we preliminarily 
determine that Nan Ya makes home market and EP sales at the same LOT.
    Because Nan Ya's EP sales are made at the same LOT as home market 
sales, we did not make a LOT adjustment for any sales of subject 
merchandise by Nan Ya. See Memorandum to the File Re: Level of Trade 
Analysis for Nan Ya Plastics Corporation, Ltd., dated December 13, 
2001.

Currency Conversions

    We made currency conversions into U.S. dollars in accordance with 
section 773A of the Act based on exchange rates in effect on the dates 
of the U.S. sales, as obtained from the Federal Reserve Bank, the 
Department's preferred source for exchange rates.

Verification

    In accordance with section 782(i) of the Act, we intend to verify 
all information relied upon in making our final determination.

All Others Rate

    Section 735(c)(5)(A) of the Act provides for the use of an ``all 
others'' rate, which is applied to non-investigated firms. See 
Statement of Administrative Actions, Uruguay Round Agreements Act, Pub. 
L. 103-465, 103rd Cong. 2d Sess., H. Doc. 103-316, vol. I (1994) (SAA) 
at 873. This section states that the all others rate shall generally be 
an amount equal to the weighted average of the weighted-average dumping 
margins established for exporters and producers individually 
investigated, excluding any zero and de minimis margins, and any 
margins based entirely upon the facts available. Therefore, since Nan 
Ya has a de minimis margin, we have preliminarily assigned to all other 
exporters of PET Film from Taiwan, a margin that is based on the 
weighted-average margin calculated for Shinkong.

Suspension of Liquidation

    In accordance with section 733(d) of the Act, we are directing the 
U.S. Customs Service to suspend liquidation of all entries of PET Film 
from Taiwan, except for exports by Nan Ya, that are entered, or 
withdrawn from warehouse, for consumption on or after the date of 
publication of this notice in the Federal Register. Because the 
estimated weighted-average dumping margin for Nan Ya is de minimis, we 
are not directing the Customs Service to suspend liquidation of entries 
of merchandise from this company from Taiwan. We are also instructing 
the Customs Service to require a cash deposit or the posting of a bond 
equal to the dumping margin for all entries of PET Film from Taiwan, 
except for exports by Nan Ya.

------------------------------------------------------------------------
                                                                 Margin
                                                               (percent)
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Manufacturer/exporter:
  Shinkong Synthetic Fibers Corporation......................       9.19
  Nan Ya Plastics Corporation, Ltd...........................       1.70
  All Others.................................................       9.19
------------------------------------------------------------------------

Disclosure

    The Department will disclose calculations performed within five 
days of the date of publication of this notice to the parties to the 
proceeding in accordance with 19 CFR 351.224(b).

International Trade Commission Notification

    In accordance with section 733(f) of the Act, we have notified the 
ITC of our sales at LTFV determination. If our final antidumping 
determination is affirmative, the ITC will determine whether the 
imports covered by that determination are materially injuring, or 
threatening material injury to, the U.S. industry. The deadline for 
that ITC determination would be the later of 120 days after the date of 
this preliminary determination or 45 days after the date of our final 
determination.

Public Comment

    Case briefs for this investigation must be submitted no later than 
one week after the issuance of the last verification report. Rebuttal 
briefs must be filed within five days after the deadline for submission 
of case briefs. A list of authorities used, a table of contents, and an 
executive summary of issues should accompany any briefs submitted to 
the Department. Executive summaries should be limited to five pages 
total, including footnotes. Further, we would appreciate it if parties 
submitting written comments would provide the Department with an 
additional copy of the public version of any such comments on diskette.
    Section 774 of the Act provides that the Department will hold a 
hearing to afford interested parties an opportunity to comment on 
arguments raised in case or rebuttal briefs, provided that such a 
hearing is requested by an interested party. If a request for a hearing 
is made in an investigation, the hearing normally will be held two days 
after the deadline for submission of the rebuttal briefs, at the U.S. 
Department of Commerce, 14th Street and Constitution Avenue, NW., 
Washington, DC 20230. In the event that the Department receives 
requests for hearings from parties to more than one PET film case, the 
Department may schedule a single hearing to encompass all those cases. 
Parties should confirm by telephone the time, date, and place of the 
hearing 48 hours before the scheduled time.
    Interested parties who wish to request a hearing, or to participate 
if one is requested, must submit a written request within 30 days of 
the publication of this notice. Requests should specify the number of 
participants and provide a list of the issues to be discussed. Oral 
presentations will be limited to issues raised in the briefs.
    As noted above, the final determination will be issued within 135 
days after the date of the publication of the preliminary 
determination.
    This determination is issued and published pursuant to sections 
733(f) and 777(i)(1) of the Act.

    Dated: December 13, 2001.
Faryar Shirzad,
Assistant Secretary for Import Administration.
[FR Doc. 01-31514 Filed 12-20-01; 8:45 am]
BILLING CODE 3510-DS-P