UNITED STATES – LAWS, REGULATIONS AND METHODOLOGY FOR CALCULATING DUMPING MARGINS ("ZEROING")
Document: Request for Consultations by the European Communities Addendum
Date: 15 September 2003
Document codes: WT/DS294/1/Add.1; G/L/630/Add.1; G/ADP/D49/1/Add.1
Complainant: EU
Respondent: U.S.
Third parties: Argentina, Brazil, China, Taiwan, Hong Kong, India, Japan, South Korea, Mexico, Norway, Thailand, Turkey
Dispute stage: Implementation & Compliance
Agreements cited: Art. 1, 2.1, 2.4, 5.8, 9.1, 9.3, 9.5, 11  Anti-dumpingArt. VI  GATT 1994Art. 18.4  Anti-dumpingArt. XVI:4  Agreement Establishing the World Trade OrganizationArt. 3  Anti-dumping

UNITED STATES – LAWS, REGULATIONS AND METHODOLOGY
FOR CALCULATING DUMPING MARGINS ("ZEROING")
Request for Consultations by the European Communities
Addendum
The following communication, dated 8 September 2003, from the Permanent Delegation of
the European Commission to the Permanent Mission of the United States and to the Chairman of the
Dispute Settlement Body, is circulated in accordance with Article 4.4 of the DSU.
The European Communities refers to the consultations held on 17 July 2003 concerning the
United States of America's laws, regulations and methodology for calculating dumping margins
("zeroing") as applied in a number of new anti-dumping investigations and reviews, as set out in the
European Communities' request for consultations dated 12 June 2003 (, ,
). The European Communities hereby requests further consultations with the
Government of the United States of America.
Further to the first round of consultations, the European Communities has identified
additional investigations in which the US DOC ap plied the "zeroing" methodology in calculating the
margin of dumping. The cases concerned are listed in the Annex attached hereto. For the sake of
convenience, the Annex continues the numbering of Annex II of the original request for consultations
and therefore starts at number 22.
This request is with respect to the determinat ions of dumping by the DOC, the determination
of injury by the United States International Trade Commission and the DOC notice for the imposition
of the anti-dumping duty in the cases listed in Annex.
The matters, which the EC would like to raise in the course of the additional consultations
include, but are not limited to, the following:
(1) the zeroing of negative dumping margins when comparing export prices and normal values on
a weighted average to weighted average basis;
(2) the impact of zeroing negative dumping margins in the determination of the "dumped
imports" in the injury investigation;
(3) the determination of dumping margins above de minimis level as a result of zeroing negative
dumping margins and the consequent imposition of an anti-dumping duty;

(4) the level of the dumping margins in the absence of zeroing in the cases listed in Annex.
The EC is concerned that the determinations in the listed cases appear to be, in several
respects, not in conformity with the obligations of the United States under the GATT, and the
Agreement on implementation of Article VI of the General Agreement on Tariffs and Trade 1994 (the
"ADA"), in particular under:
– Articles 1, 2.4 (including 2.4.2), 3, 5.8 and 18.3 of the ADA,
– Articles VI:1 and VI:2 of the GATT,
– Article XVI:4 of the Marrakech Agreement establishing the WTO and Article 18.4 of the
ADA.
We reserve the right to raise additional claims and legal matters regarding the legislation and
practice during the course of the consultations.
We look forward to receiving your reply to this request and to fixing a mutually acceptable
date for consultations.

ANNEX 1
ANTI-DUMPING DUTIES
Product MS DOC Case
Number
DOC Final Determination ITC Case
Number
ITC Determination AD Order
22.Stainless Steel
Wire Rod
SW A-401-806 63 FR40449,
July 29,1998
A-774 September 1998 63 FR49329,
September 15, 1998
23.Stainless Steel
Wire Rod
E A-469-807 63 FR40391,
July 29,1998
A-773 September 1998 63 FR 49330,
September 15, 1998
24.Stainless Steel
Wire Rod
I A-475-820 63 FR40422,
July 29,1998
A-770 September 1998 63 FR 49327,
September 15, 1998
25.Certain Stainless
Steel Plate in Coils
B A-423-808 64 FR15476,
March 31, 1999
A-788 May 1999 64 FR 27756,
May 21, 1999 (amended by 68
FR 20114 April 24, 2003)
26.Stainless Steel
Sheet and Strip in
Coils
F A-427-814 64 FR30820,
June 8, 1999
A-797 July 1999 64 FR 40562,
July 27, 1999
27.Stainless Steel
Sheet and Strip in
Coils
I A-475-824 64 FR30750,
June 8, 1999
A-799 July 1999 64 FR 40567,
July 27, 1999
28.Stainless Steel
Sheet and Strip in
Coils
UK A-412-818 64 FR30688,
June 8,1999
A-804 July 1999 64 FR 40555,
July 27,1999
29.Certain Cut-to-
Length Carbon-
Quality Steel Plate
F A-427-816 64 FR73143,
December 29,1999
A-816 February 2000 65 FR 6585,
February 10, 2000
30.Certain Cut-to-
Length Carbon-
Quality Steel Plate
I A-475-826 64 FR73234,
December 29,1999
A-819 February 2000 65 FR 6585,
February 10, 2000
31.Certain Pasta I A-475-818 61 FR30326,
June 14, 1996
(amended by 66 FR65889,
December 21,2001)
A-734 July 1996 61 FR38547
July 24, 1996

United States- Anti-dumping duties on Imports of Stainless Steel Wire Rod from Sweden
Specific Case No. 22
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Wire Rod from
Sweden (US case number A-401-806, 63 FR 49329 of 15 September 1998). The rate of the ad
valorem anti-dumping duty was 5.71% for Fagersta Stainless AB and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Wire Rod
from Sweden, the Department of Commerce (DOC ) utilised the same “zeroing” methodology as
described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 5.71%
for Fagersta Stainless AB while without the zeroing methodology (i.e. with the negative unit margins
included), the dumping margin would have been [-…%] (negative) and the case would have been
terminated with respect to this exporter.
United States- Anti-dumping duties on Imports of Stainless Steel Wire Rod from Spain
Specific Case No. 23
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Wire Rod from
Spain (US case number A-469-807, 63 FR 49330 of 15 September 1998). The rate of the ad valorem
anti-dumping duty was 4.73% for Roldán SA and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Wire Rod
from Spain, the Department of Commerce (DOC) utilised the same “zeroing” methodology as
described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 4.73%
for Roldán SA while without the zeroing methodology (i.e. with the negative unit margins included),
the dumping margin would have been [ …%] (lower)

United States- Anti-dumping duties on Imports of Stainless Steel Wire Rod from Italy
Specific Case No. 24
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Wire Rod from
Italy (US case number A-475-820, 63 FR 49327 of 15 September 1998). The rate of the ad valorem
anti-dumping duty was 12.72% for Cogne Acciai Speciali Srl and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Wire Rod
from Italy, the Department of Commerce (DOC ) utilised the same “zeroing” methodology as
described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 12.72%
for Cogne Acciai Speciali Srl while without the zeroing methodology (i.e. with the negative unit
margins included), the dumping margin would have been [ …%] (lower)
United States- Anti-dumping duties on Imports of Stainless Steel Plate in Coils from
Belgium
Specific Case No. 25
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Plate in Coils
from Belgium (US case number A-423-808, 64 FR 27756 of 21 May 1999, amended by 68 FR 20114
of 24 April 2003). The rate of the ad valorem anti-dumping duty was 3.84% for ALZ and 9.86% for
all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Plate in Coils
from Belgium, the Department of Commerce (DOC ) utilised the same “zeroing” methodology as
described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 3.84%
for ALZ while without the zeroing methodology (i.e. with the negative unit margins included), the
dumping margin would have been [ ..%] (lower)

United States- Anti-dumping duties on Imports of Stainless Steel Sheet and Strip in Coils
from France
Specific Case No. 26
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Sheet and Strip
in Coils from France (US case number A-427-814, 64 FR 40562 of 27 July 1999). The rate of the ad
valorem anti-dumping duty was 9.38% for Usinor and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Sheet and
Strip in Coils from France, the Department of Commerce (DOC) utilised the same “zeroing”
methodology as described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 9.38%
for Usinor while without the zeroing methodology (i.e. with the negative unit margins included), the
dumping margin would have been [ …%] (lower)
United States- Anti-dumping duties on Imports of Stainless Steel Sheet and Strip in Coils
from Italy
Specific Case No. 27
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Sheet and Strip
in Coils from Italy (US case number A-475-824, 64 FR 40567 of 27 July 1999). The rate of the ad
valorem anti-dumping duty was 11.23% for Acciai Spaciali Terni SpA and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Sheet and
Strip in Coils from Italy, the Department of Commerce (DOC) utilised the same “zeroing”
methodology as described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 11.23%
for Acciai Spaciali Terni SpA while without the zeroing methodology (i.e. with the negative unit
margins included), the dumping margin would have been [..%] (lower)

United States- Anti-dumping duties on Imports of Stainless Steel Sheet and Strip in Coils
from the UK
Specific Case No. 28
The measure
This case concerns the imposition of Anti-dumping duties on Stainless Steel Sheet and Strip
in Coils from the UK (US case number A-412-818, 64 FR 40555 of 27 July 1999). The rate of the ad
valorem anti-dumping duty was 14.84% for Avesta Sheffield and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Stainless Steel Sheet and
Strip in Coils from the UK, the Department of Commerce (DOC) utilised the same “zeroing”
methodology as described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 14.84%
for Avesta Sheffield while without the zeroing methodology (i.e. with the negative unit margins
included), the dumping margin would have been [ ..%] (lower)
United States- Anti-dumping duties on Imports of Certain Cut-to-Length Carbon-Quality
Steel Plate from France
Specific Case No. 29
The measure
This case concerns the imposition of Anti-dumping duties on Certain Cut-to-Length Carbon-
Quality Steel Plate from France (US case number A-427-816, 65 FR 6585 of 10 February 2000). The
rate of the ad valorem anti-dumping duty was 10.41% for Usinor and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Certain Cut-to-Length
Carbon-Quality Steel Plate from France, the Department of Commerce (DOC) utilised the same
“zeroing” methodology as described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 10.41%
for Usinor while without the zeroing methodology (i.e. with the negative unit margins included), the
dumping margin would have been […%] (lower)

United States- Anti-dumping duties on Imports of Certain Cut-to-Length Carbon-Quality
Steel Plate from Italy
Specific Case No. 30
The measure
This case concerns the imposition of Anti-dumping duties on Certain Cut-to-Length Carbon-
Quality Steel Plate from Italy (US case number A-475-826, 65 FR 6585 of 10 February 2000). The
rate of the ad valorem anti-dumping duty was 7.85% for Palini and Bertoli SpA and all others.
Use of zeroing
In the United States Department of Commerce’s investigation of Certain Cut-to-Length
Carbon-Quality Steel Plate from Italy, the Department of Commerce (DOC) utilised the same
“zeroing” methodology as described under Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin of 7.85%
for Palini and Bertoli SpA while without the zeroing methodology (i.e. with the negative unit margins
included), the dumping margin would have been [ ..%] (lower)
United States- Anti-dumping duties on Imports of Certain Pasta from Italy
Specific Case No. 31
The measure
This case concerns the imposition of Anti-dumping duties on Certain Pasta from Italy (US
case number A-475-818, 61 FR 38547 of 24 July 1996). The rates of the ad valorem anti-dumping
duty were 21.34% for Italpasta , 14.78% for La Molisana, 12.41% for Liguori, 18.30% for Pagani and
12.09% for all others.
Use of zeroing
In the United States Department of Commerce’s investigation Certain Pasta from Italy, the
Department of Commerce (DOC) utilised the sa me “zeroing” methodology as described under
Specific Case No. 1.
Dumping margin without zeroing
In particular, by using the above methodology, DOC calculated a dumping margin:
- of 21.34% for Italpasta . Without the zeroing methodology (i.e. with the negative unit margins
included), the dumping margin would have been [..%] (lower).

- of 14.78% for La Molisana. Without the zeroin g methodology, the dumping margin would have
been of [..%] (lower)
- of 12.41% for Liguori. Without the zeroing me thodology the dumping margin would have been
.[..%] (lower).
- of 18.30% for Pagani. Without the zeroing methodology the dumping margin would have been [..%]
(lower).