All of the transition orders had antidumping margins calculated by Commerce methodologies and practices since outlawed for unfairness by the URAA pursuant to the WTO Antidumping Agreement. The Department's use of margins determined under pre-URAA law in sunset reviews would derogate these reforms and be inconsistent with the United States' WTO obligations. In providing information to the Commission, the Administration does not intend that Commerce calculate future dumping margins or net countervailable subsidies, because such an exercise would involve undue speculation regarding future selling prices, costs of production, selling expenses, exchange rates, and sales and production volumes. SAA at 891. The SAA is correct.
Commerce is unable to reliably calculate margins following revocation without undue speculation.
For the same reasons expressed in the SAA, Commerce is unable to state with any reliability that the margins found in investigations or reviews are likely to prevail after revocation. To aid in the Commission in making sound sunset determinations, Commerce should so advise the Commission of this fact when reporting margins to the Commission. It should also advise the Commission that its reported margins have no predictive value concerning likely changes in import prices following revocation. As the Department well knows, margins have as much to do with foreign market value, the happenstance of model matching, cost and expense allocations, sales and production volumes, the Departments' informational and verification demands, and exchange rates as they do with U.S. prices. The Department's margins and U.S. prices following revocation have no predictive correlation.