UNITED STATES – LAWS, REGULATIONS AND METHODOLOGY FOR CALCULATING DUMPING MARGINS ("ZEROING")
Document: Request for Consultations by the European Communities
Date: 19 June 2003
Document codes: WT/DS294/1; G/L/630; G/ADP/D49/1
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
The following communication, dated 12 June 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.
On behalf of the European Communities (the "EC"), I hereby request consultations with the
United States of America pursuant to Article 4 of the Understanding on Rules and Procedures
Governing the Settlement of Disputes, Article XXII:1 of the General Agreement on Tariffs and Trade
1994 (the "GATT") and Article 17 of the Agreement on implementation of Article VI of the General
Agreement on Tariffs and Trade 1994 (the "ADA").
This request is with respect to:
– the Tariff Act of 1930 (the "Act"), in particular sections 751, 771(35)(A) and
771(35)(B),
– the implementing regulation
1 of the United States Department of Commerce (the
"DOC"), in particular section 351.414(c)(2),
– the methodology of the DOC for determining the dumping margin in new
investigations on the basis of the comparison of a weighted average normal value
with a weighted average export price,
– the methodology of the DOC for determ ining the dumping margin in reviews,
– the determinations 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 I,
– and the final results of the anti-dumping administrative reviews listed in Annex II.
The matters, which the EC would like to raise in the course of the consultations include, but
are not limited to, the following:

1 19 CFR Section 351.

(1) in new investigations, the zeroing of negative dumping margins when comparing export
prices and normal values on a weighted average to weighted average basis;
(2) in reviews, the comparison of export prices and normal values on a weighted average to
transaction basis and the zeroing of negative dumping margins in circumstances other than
those specified in Article 2.4.2 of the ADA;
(3) the impact of zeroing negative dumping margins in the determination of the "dumped
imports" in the injury investigation;
(4) the determination of dumping margins above de minimis level as a result of zeroing negative
dumping margins and the consequent imposition, continuation or collection of an anti-
dumping duty;
(5) the level of the dumping margins in the absenc e of zeroing in the cases listed in Annex I and
Annex II
The EC is concerned that the Act, related regulations, US methodologies and determinations
in the listed cases appear to be, in several respec ts, not in conformity with the obligations of the
United States under the GATT, and the ADA, in particular under:
– Articles 1, 2.4 (including 2.4.2), 3, 5.8, 9.3, 9.5, 11 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 to setting a mutually convenient date
for these consultations.

ANNEX I
IMPOSITION OF ANTI-DUMPING DUTY
Product MS DOC Case
Number DOC Final Determination ITC Case
Number ITC Determination AD Order
1. Certain hot-rolled carbon steel NL A-421-807 66 FR 50408, October 3, 2001
(amended: 66 FR 55637,
November 2, 2001)
A-903 November 2001 66 FR 59565,
November 29, 2001
2. Stainless steel bar F A-427-820 67 FR 3143, January 23, 2002 A-913 February 2002 67 FR 10385,
March 7, 2002
3. Stainless steel bar G A-428-830 67 FR 3159, January 23, 2002
(amended: 67 FR 10382,
March 7, 2002)
A-914 February 2002 67 FR 10382,
March 7, 2002
4. Stainless steel bar I A-475-829 67 FR 3155, January 23, 2002
(amended: 67 FR 8228,
February 22, 2002)
A-915 February 2002 67 FR 10384,
March 7, 2002
5. Stainless steel bar UK A-412-822 67 FR 3146, January 23, 2002 A-918 February 2002 67 FR 10381,
March 7, 2002

United States – Anti-Dumping duties on Imports of Certain Hot-Rolled
Carbon Steel Flat Products from the Netherlands
Specific Case No. l
The measure
This case concerns the imposition of anti-dumping duties on Certain Hot-Rolled Carbon Steel
Flat products from the Netherlands (US case number A-421-807, 66 FR 59565 of 29 November 2001).
The rate of the ad valorem anti-dumping duty was 2.59% for Corus Staal BV and all others.
Use of zeroing
In the United States Department of Commerce's investigation of Hot-Rolled Carbon Steel Flat
Products from the Netherlands ("Hot-Rolled Steel"), the Department of Commerce (DOC) utilised a
methodology commonly referred to as "zeroing".
The practice of "zeroing", as applied in this case by the DOC, can briefly be described as
follows.
First, the DOC identified a number of different "models" or "types" of Hot-Rolled Steel,
called connums.
Next, the DOC calculated, for each of these models, a weighted average normal value and a
weighted average export price. Then, the DOC compared the weighted average normal value with the
weighted average export price for each model. For some models, normal value was higher than export
price; by subtracting export price from normal value for these models, the DOC established a "positive
dumping margin" for each model. For other models, normal value was lower than export price; by
subtracting export price from normal value for these other models, DOC established a " negative
dumping margin" for each model. Thus, there is a "positive dumping margin" where there is dumping,
and a "negative dumping margin" where there is not. The "positives" and "negatives" of the amounts
in this calculation are an indication of precisely how much the export price is above or below the
normal value.
Having made this calculation, the DOC then added up the amounts it had calculated as
"dumping margins" for each model of the product in order to determine an overall dumping margin for
the product as a whole . However, in doing so, the DOC treated any "negative dumping margin" as
zero – hence the use of the word "zeroing". Then, finally, having added up the "positive dumping
margins" and the zeroes, the DOC divided this sum by the cumulative total value of all the export
transactions involving all types and models of that product. In this way, the DOC obtained an overall
margin of dumping for the product under investigation.
This methodology is identical to the methodology that was held in breach of the WTO
Anti-Dumping Agreement in European Communities - Anti-Dumpi ng Duties on Imports of Cotton-
Type Bed Linen from India , (Panel Report, WT/DS141/R and Appellate Body Report,
WT/DS141/AB/R, adopted 12 March 2001).

Dumping margin without zeroing
By using the above methodology, DOC calcula ted a dumping margin of 2.59% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- ..%] (negative) and the case would have been terminated.
United States – Anti-Dumping Duties on Imports of Stainless Steel Bar from France
Specific Case No. 2
The measure
This case concerns the imposition of anti-dumping duties on Stainless Steel Bar from France
(US case number A-427-820, 67 FR 10385 of 7 March 2002). The rates of the ad valorem
anti-dumping duty were 71.83% for Aubert & Duval S.A, 3.90% for Ugine-Savoie Imphy and all
others.
Use of zeroing
In the United States Department of Commerce's investigation of Stainless Steel Bar from
France, the Department of Commerce (DOC) utilise d 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 3.90%
for Ugine-Savoie Imphy SA 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 Bar from Germany
Specific Case No. 3
The measure
This case concerns the imposition of anti-dumping duties on Stainless Steel Bar from
Germany (US case number A-428-830, 67 FR 10382 of 7 March 2002). The rates of the ad valorem
anti-dumping duty were 13.63% for BGH, 4.17% for Einsal, 15.40% for EWK, 32.32% for KEP and
16.96% for all others.
Use of zeroing
In the United States Department of Commerce's investigation of Stainless Steel Bar from
Germany , 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 13.63% for BGH. Without the zeroing methodology (i.e. with the negative unit margins
included), the dumping margin would have been [..%] (lower).
– of 4.17% for Einsal. Without the zeroing methodology, the dumping margin would have been
of [..%] (de minimis) and the case would have been terminated with respect to this exporter.
– of 15.40% for EWK. Without the zeroing met hodology the dumping margin would have been
[..%] (lower).
– of 32.32% for KEP. Without the zeroing methodology the dumping margin would have been
[..%] (lower).
United States – Anti-Dumping Duties on Imports of Stainless Steel Bar from Italy
Specific Case No. 4
The measure
This case concerns the imposition of anti-dumping duties on Stainless Steel Bar from Italy
(US case number A-475-829, 67 FR 10384 of 7 March 2002). The rates of the ad valorem
anti-dumping duty were 2.50% for Acciaierie Va lbruna Srl/Acciaierie Bo lzano D.p.A, 7.07% for
Acciaiera Foroni SpA, 3.83% for Rodacciai S.p.A, 33% for Cogne Acciai Speciali Srl and 3.81% for
all others.
Use of zeroing
In the United States Department of Commerce's investigation of Stainless Steel Bar 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 2.50% for Acciaierie Valbruna Srl/Accia ierie Bolzano S.p.A. 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.
– of 7.07% for Acciaiera Foroni Spa. Without the zeroing methodology the dumping margin
would have been [..%] (lower).
– of 3.83% for Rodacciai SpA. Without the zeroing methodology the dumping margin would
have been [...%] (lower).

United States – Anti-Dumping Duties on Imports of Stainless Steel Bar from the United Kingdom
Specific Case No. 5
The measure
This case concerns the imposition of anti-dumping duties on Stainless Steel Bar from the
United Kingdom (US case number A-412-822, 67 FR 10381 of 7 March 2002). The rates of the
ad valorem anti-dumping duty were 4.48% for Corus Engineering Steels, Ltd, 125.77% for
Crownridge Stainless Steel, Ltd/Valkia Ltd and Firth Rixson Special Steels, Ltd and 4.48% for all
others.
Use of zeroing
In the United States Department of Commerce's investigation of stainless steel bar from the
United Kingdom, 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 4.48%
for Corus Engineering Steels, Ltd 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.

ANNEX II
ADMINISTRATIVE REVIEWS
Product MS No Case Final Results Amended Final
Results Company Dumping
Margin
Period covered by the
Review
6. Industrial Nitrocellulose F A-427-009 66 FR 54213,
October 26, 2001
Bergerac NC 3.26% 1 August 99-31 July 00
7. Industrial Nitrocellulose UK A-412-803 67 FR 77747,
December 19, 2002
Imperial Chemical
Industries
3.06% 1 July 00-30 June 01
8. Stainless steel plate in coils B A-423-808 67 FR 64352,
October 18, 2002
ALZ NV &
TrefilARBED
(affiliated US
importer)
3.84% 1 May 00-30 April 01
9. Certain pasta I A-475-818 66 FR 300,
January 3, 2002
67 FR 5088,
February 4, 2002
Ferrara
Pallante
PAM
1.25%
1.78%
4.10%
1 July 99-30 June 00
10. Certain pasta I A-475-818 68 FR 6882,
February 11, 2003
Pastifi Garofalo 0.55% 1 July 00-30 June 01
11. Stainless steel sheet strip
coils
I A-475-824 67 FR 1715,
January 14, 2002
Acciai Speciali
Terni SpA
0.66% 4 January 99-30 June 00
12. Stainless steel sheet strip
coils
I A-475-824 68 FR 6719,
February 10, 2003
Acciai Speciali
Terni SpA
5.84% 1 July 00-30 June 01
13. Granular
polytetrafluoenthylene
I A-475-703 67 FR 1960,
January 15, 2002
Ausimont SpA 2.15% 1 August 99-31 July 00
14. Granular
polytetrafluoenthylene
I A-475-703 68 FR 2007,
January 15, 2003
Ausimont SpA 12.08% 1 August 00-31 July 01
15. Stainless steel sheet strip
coils
F A-427-814 67 FR 6493,
February 12, 2002
67 FR 12522,
March 19, 2002
Ugine 3.00% 4 January 99-30 June 00

16. Stainless steel sheet strip
coils
F A-427-814 67 FR 78773,
December 26, 2002
68 FR 4171,
January 28, 2003
Ugine 1.44% 1 July 00-30 June 01
17. Stainless steel sheet strip
coils
G A-428-825 67 FR 7668,
February 20, 2002
67 FR 15178,
March 29, 2002
KTN 2.61% 4 January 99-30 June 00
18. Stainless steel sheet strip
coils
G A-428-825 68 FR 6716,
February 10, 2003
TKN 4.77% 1 July 00-30 June 01
19. Ball bearings F A-427-801 67 FR 55780,
August 30, 2002
SKF France SA and
Sarma
8.51% 1 May 00-30 April 01
20. Ball bearings I A-475-801 67 FR 55780,
August 30, 2002
FAG Italia SpA
SKF Industrie SpA
1.42%
3.70%
1 May 00-30 April 01
21. Ball bearings UK A-412-801 67 FR 55780,
August 30, 2002
NSK Bearings
Europe Ltd
The Barden
Corporation UK
16.87%
3.87%
1 May 00-30 April 01

United States – Anti-Dumping Administrative Review on Imports
of Industrial Nitrocellulose from France
Specific Case No.6
The administrative review
This case concerns the administrative review of anti-dumping duties on Industrial
Nitrocellulose from France, produced and exported by Bergerac NC. (US case number A-427-009,
66 FR 54213 of 26 October 2001). The period of review is 1 August 1999 through 31 July 2000 and
the rate of anti-dumping duty for Bergerac NC was 3.26% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, can briefly be described as
follows. First, the DOC identified with respect to the product under investigation a certain number of
different "models" or "types" of that product, what it calls Connum.- a common practice for both
investigations and administrative reviews-.
Then, unlike in a new investigation, in an administrative review the DOC does not compare
the average US price (export price) to the averag e home market price (normal value) for the whole
investigation period. Instead, the DOC’s practice is to compare the US net price for each individual
US transaction to the most contemporaneous monthly average normal value.
The total value of the dumping margin is then calculated by aggregating only the transaction-
specific positive dumped values and then multiplying the quantity sold in the US market for each
model by the unit dumped value to arrive at the total dollars dumped. Comparisons of individual US
transactions to weighted-average monthly normal value that yield negative margins are ignored
(effectively treated as zero). Th e DOC applies this methodology in circumstances other than those
specified in Article 2.4.2 of the ADA.
Because DOC determines margins on a transaction-specific basis in administrative reviews,
no offsetting of negative margins is performed at either the Connum-specific or aggregate level. The
DOC’s methodology of aggregating the values of only the positive dumping margins based on the
individual transactions means that there is no offset against the positive values at any stage.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 3.26%. while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [...%] (lower).

United States – Anti-Dumping Administrative Review on Imports
of Industrial Nitrocellulose from the United Kingdom
Specific Case No.7
The administrative review
This case concerns the administrative review of anti-dumping duties on Industrial
Nitrocellulose from the United Kingdom, produced and exported by Imperial Chemical Industries
PLC. (US case number A-412-803, 67 FR 77747 of 19 December 2002). The period of review is
1 July 2000 through 30 June 2001 and the rate of anti -dumping duty for Imperial Chemical Industries
was 3.06% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 3.06% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- …%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Plate in Coils from Belgium
Specific Case No.8
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Plate
in Coils from Belgium, produced and exported by ALZ NV (US case number A-423-808,
67 FR 64352 of 18 October 2002). The period of review is 1 May 2000 through 30 April 2001 and the
rate of anti-dumping duty for ALZ NV was 3.84% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 3.84% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- ..%] (negative) and no anti-dumping duty would have been collected.

United States – Anti-Dumping Administrative Review on Certain Pasta from Italy
Specific Case No.9
The administrative review
This case concerns the administrative review of anti-dumping duties on Certain Pasta from
Italy, produced and exported by Pastificio Guido Ferr ara S.r.L. (Ferrara), Pastificio Antonio Pallante
S.r.L. (Pallante) and PAM S.r.L. (PAM). (US case number A-475-818, 66 FR 300 of 3 January 2002,
67 FR 5088 of 4 February 2002). The period of review is 1 July 1999 through 30 June 2000 and the
rate of anti-dumping duty was, ad valorem, 1.25% for Ferrara, 1.78% for Pallante, 4.10% for PAM.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated for Ferrara a dumping margin of 1.25%
while without the zeroing methodology (i.e. with the negative unit margins included), the dumping
margin would have been [...%] (lower).
As for Pallante, DOC calculated a dumping margin of 1.78%, while without the zeroing
methodology (i.e. the negative unit margins included), the dumping margin would have been [...%]
(lower).
As for PAM, DOC calculated a dumping margin of 4.10%, while without the zeroing
methodology (i.e. the negative unit margins included), the dumping margin would have been
de minimis.
United States – Anti-Dumping Administrative Review on Certain Pasta from Italy
Specific Case No.10
The administrative review
This case concerns the administrative review of anti-dumping duties on Certain Pasta from
Italy, produced and exported by Pastificio Garofalo S.p.A. (US case number A-475-818, 68 FR 6882
of 11 February 2003). The period of review is 1 July 2000 through 30 June 2001 and the rate of anti-
dumping duty was 0.55% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.

Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 0.55% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [...%] (lower).
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Sheet Strip in Coils from Italy
Specific Case No.11
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Sheet
Strip in Coils from Italy, produced and exported by Acciai Speciali Terni SpA (US case number
A-475-824, 67 FR 1715 of 14 January 2002). The period of review is 4 January 1999 through 30 June
2000 and the rate of anti-dumping duty for Acciai Speciali Terni SpA was 0.66% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 0.66% while without
the zeroing methodology (i.e. with the negative uni t margins included), the dumping margin would
have been [-…%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Sheet Strip in Coils from Italy
Specific Case No.12
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Sheet
Strip in Coils from Italy, produced and exported by Acciai Speciali Terni SpA (US case number
A-475-824, 68 FR 6719 of 10 February 2003). The period of review is 1 July 2000 through 30 June
2001 and the rate of anti-dumping duty for Acciai Speciali Terni SpA was 5.84% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.

Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 5.84% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- …%] (negative).
United States – Anti-dumping Administrative Review on Imports
of Granular Polytetrafluoroenthylene Resin from Italy
Specific Case No.13
The administrative review
This case concerns the administrative review of anti-dumping duties on Granular
Polytetrafluoroenthylene resin from Italy, produced and exported by Ausimont SpA. (US case number
A-475-703, 67 FR 1960 of 15 January 2002). The period of review is 1 August 1999 through
31 July 2000 and the rate of anti-dumping duty for Ausimont SpA SA was 2.15% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 2.15% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [...%] (lower).
United States – Anti-Dumping Administrative Review on Imports
of Granular Polytetrafluoroenthylene Resin from Italy
Specific Case No.14
The administrative review
This case concerns the administrative review of anti-dumping duties on Granular
Polytetrafluoroenthylene Resin from Italy, produced and exported by Ausimont SpA. (US case
number A-475-703, 68 FR 2007 of 15 January 2003). The period of review is 1 August 2000 through
31 July 2001 and the rate of anti-dumping duty for Ausimont SpA SA was 12.08% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.

Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 12.08% while
without the zeroing methodology (i.e. with the ne gative unit margins included), the dumping margin
would have been [...%] (lower).
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Sheet and Strip in Coils from France
Specific Case No.15
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Sheet
and Strip in Coils from France, produced and exported by Ugine (US case number A-427-814,
67 FR 6493 of 12 February 2002, 67 FR 12522 of 19 March 2002). The period of review is 4 January
1999 through 30 June 2000 and the rate of anti-dumping duty for Ugine was 3.00% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 3.00% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- …%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Sheet and Strip in Coils from France
Specific Case No.16
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Sheet
and Strip in Coils from France, produced and exported by Ugine SA (US case number A-427-814,
67 FR 78773 of 26 December 2002, 68 FR 4171 of 28 January 2003). The period of review is 1 July
2000 through 30 June 2001 and the rate of anti-dumping duty for Ugine SA was 1.44% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.

Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 1.44% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- …%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Sheet and Strip in Coils from Germany
Specific Case No.17
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Sheet
and Strip in Coils from Germany, produced and exported by KTN (US case number A-428-825,
67 FR 7668 of 20 February 2002, 67 FR 15178 of 29 March 2002). The period of review is 4 January
1999 through 30 June 2000 and the rate of anti-dumping duty for KTN was 2.61% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 2.61% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [- ..%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Stainless Steel Sheet and Strip in Coils from Germany
Specific Case No.18
The administrative review
This case concerns the administrative review of anti-dumping duties on Stainless Steel Sheet
and Strip in Coils from Germany, produced and exported by TKN (US case number A-428-825,
68 FR 6716 of 10 February 2003). The period of review is 1 July 2000 through 30 June 2001 and the
rate of anti-dumping duty for TKN was 4.77% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.

Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 4.77% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [– ..%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Ball Bearings from France
Specific Case No.19
The administrative review
This case concerns the administrative review of anti-dumping duties on Ball Bearings from
France, produced and exported by SKF France SA and Sarma (US case number A-427-801,
67 FR 55780of 30 August 2002). The period of review is 1 May 2000 through 30 April 2001 and the
rate of anti-dumping duty for SKF France SA and Sarma was 8.51% ad valorem.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin of 8.51% while without
the zeroing methodology (i.e. with the negative un it margins included), the dumping margin would
have been [-..%] (negative) and no anti-dumping duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Ball Bearings from Italy
Specific Case No.20
The administrative review
This case concerns the administrative review of anti-dumping duties on Ball Bearings from
Italy, produced and exported by SKF Industrie SpA and FAG Italia SpA (US case number A-475-801,
67 FR 55780 of 30 August 2002). The period of review is 1 May 2000 through 30 April 2001 and the
rate of anti-dumping duty was, ad valorem, 3.70% for SKF Industrie SpAand 1.42% for FAG Italia
SpA.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.

Dumping margin without zeroing
By using the above methodology, DOC calculated a dumping margin for SKF Industrie SpA
of 3.70% while without the zeroing methodology (i.e. with the negative unit margins included), the
dumping margin would have been [–..%] (negat ive) and no anti-dumping duty would have been
collected.
As for FAG Italia SpA, DOC calculated a dumping margin of 1.42% while without the
zeroing methodology the dumping margin would have been [– ..%] (negative) and no anti-dumping
duty would have been collected.
United States – Anti-Dumping Administrative Review on Imports
of Ball Bearings from the United Kingdom
Specific Case No.21
The administrative review
This case concerns the administrative review of anti-dumping duties on Ball Bearings from
the United Kingdom, produced and exported by NSK Bearings Europe Ltd and the Barden
Corporation UK (US case number A-412-801, 67 FR 55780 of 30 August 2002). The period of review
is 1 May 2000 through 30 April 2001 and the rate of anti-dumping duty was, ad valorem, 16.87% for
NSK Bearings Europe Ltd and 3.87% for the Barden Corporation UK.
Methodology
The practice of "zeroing", as applied in this case by the DOC, is the same as the practice
described under Specific Case No. 6.
Dumping margin without zeroing
By using the above methodology, DOC calculated for NSK Bearings Europe Ltd a dumping
margin of 16.87% while without the zeroing methodology (i.e. with the negative unit margins
included), the dumping margin would have been [- …%] (negative) and no anti-dumping duty would
have been collected.
As for the Barden Corporation UK, DOC calculated a dumping margin of 3.87%, while
without the zeroing methodology (i.e. with the ne gative unit margins included), the dumping margin
would have been [– ..%] (negative) and no anti-dumping duty would have been collected.