UNITED STATES – CERTAIN METHODOLOGIES AND THEIR APPLICATION TO ANTI-DUMPING PROCEEDINGS INVOLVING CHINA RECOURSE TO ARTICLE 22.6 OF THE DSU BY THE UNITED STATES DECISION BY THE ARBITRATOR
Document: Addendum BCI redacted, as indicated [[***]]
Date: 1 November 2019
Document codes: WT/DS471/ARB/Add.1; WT/DS471/ARB.
Complainant: China
Respondent: U.S.
Third parties: Brazil, Canada, EU, India, Japan, South Korea, Norway, Russia, Saudi Arabia, Ukraine, Vietnam, Turkey, Taiwan
Dispute stage: Implementation & Compliance
Agreements cited: Art. VI:2  GATT 1994Art. 6.10, 9.2, 9.4, 2.4.2, 6.8, Annex II, 6.1  Anti-dumping

UNITED STATES – CERTAIN METHODOLOGIES AND THEIR APPLICATION
TO ANTI-DUMPING PROCEEDINGS INVOLVING CHINA
RECOURSE TO ARTICLE 22.6 OF THE DSU BY THE UNITED STATES
DECISION BY THE ARBITRATOR
Addendum
BCI redacted, as indicated [[***]]
This addendum contains Annexes A to E to the Decision of the Arbitrator to be found in document

LIST OF ANNEXES
ANNEX A
WORKING PROCEDURES OF THE ARBITRATOR
Contents Page
Annex A-1 Working Procedures of the Arbitrator 5
Annex A-2 Additional Working Procedures of the Arbitrator concerning Business
Confidential Information
10
ANNEX B
ARGUMENTS OF THE PARTIES
Contents Page
Annex B-1 Executive summary of the arguments of the United States 12
Annex B-2 Executive summary of the arguments of China 23
ANNEX C
PROCEDURAL RULING OF THE ARBITRATOR
Contents Page
Annex C-1 Procedural Ruling on the United States' Request to Partially Open the
Arbitrator's Meeting to Public Observation
34
ANNEX D
GRAPHICAL ILLUSTRATIONS AND FIGURES CONCERNING THE PARTIES' PROPOSED CALCULATION
METHODOLOGIES
Contents Page
Annex D-1 China's proposed DID tabular approach: Graphical illustrations of the failure
to meet the parallel trends assumption provided by the United States
38
Annex D-2 United States' proposed Armington model: Relationship between the change
in the market share of Chinese exporters within the PRC -wide entity and the
duration of the anti-dumping orders
39
Annex D-3 United States' proposed Armington model: Relationship between the change
in the market share of Chinese exporters within the PRC -wide entity and the
level of the WTO-inconsistent PRC-wide duty rates
40
ANNEX E
DATA INPUTS AND CALCULATIONS OF THE ARBITRATOR
Contents Page
Annex E-1 Data inputs for US market values in the year prior to the imposition of the
anti-dumping orders
42
Annex E-2 Data inputs for the share of US imports from China covered by different
Chinese exporters in the year prior to the imposition of the anti -dumping
orders
49
Annex E-3 List of Chinese exporters outside the PRC -wide entity used to estimate the
share of different Chinese exporters for six anti-dumping orders
57

Contents Page
Annex E-4 List of Chinese exporters subject to the WA -T duty rates and other Chinese
exporters outside the PRC-wide entity used to estimate the share of different
Chinese exporters for three anti-dumping orders
70
Annex E-5 Data inputs for elasticities 74
Annex E-6 Data inputs for the actual anti-dumping duty rates 76
Annex E-7 List of anti-dumping duty rates used for two anti-dumping orders 81
Annex E-8 Data inputs for US market values in 2017 85
Annex E-9 Code and text version of the Armington model 91
Annex E-10 Data inputs used to implement the Armington model under the two steps 96
Annex E-11 Results of implementing the Armington model under the first step 99

ANNEX A
WORKING PROCEDURES OF THE ARBITRATOR
Contents Page
Annex A-1 Working Procedures of the Arbitrator 5
Annex A-2 Additional Working Procedures of the Arbitrator concerning Business
Confidential Information
10

ANNEX A-1
WORKING PROCEDURES OF THE ARBITRATOR

Adopted on 15 November 2018

Amended on 13 February 2019

General

1. (1) In this proceeding, the Arbitrator shall follow the relevant provisions of the
Understanding on Rules and Procedures Governing the Settlement of Disputes ("DSU"). In
addition, the following Working Procedures apply.
(2) The Arbitrator reserves the right to modify these procedures as necessary, after
consultation with the parties.
Confidentiality
2. (1) The deliberations of the Arbitrator and the documents submitted to it shall be kept
confidential. Members shall treat as confidential information that is submitted to the Arbitrator
by another Member which the submitting Member has designated as confidential.
(2) Nothing in the DSU or in these Working Procedures shall preclude a party from disclosing
statements of its own positions to the public.
(3) If a party submits a confidential version of its written submissions to the Arbitrator, it
shall also, upon request of a Member, provide a non-confidential summary of the information
contained in its submissions that could be disclosed to the public. Non-confidential summaries
shall be submitted no later than ten days after the written submission in question is presented
to the Arbitrator, unless a different deadline is est ablished by the Arbitrator upon written
request of a party showing good cause.
(4) Upon request, the Arbitrator may adopt appropriate additional procedures for the
treatment and handling of confidential information after consultation with the parties.
Submissions
3. (1) Before the substantive meeting of the Arbitrator with the parties, China shall transmit
to the Arbitrator and to the United States a communication explaining the basis for its request,
including the methodology and data supporting it, in a ccordance with the timetable adopted
by the Arbitrator.
(2) Each party to the dispute shall also transmit to the Arbitrator a written submission in
which it presents the facts of the case and its arguments as well as the economic and legal
basis supporting them, if any, in accordance with the timetable adopted by the Arbitrator.
(3) The Arbitrator may invite the parties to make additional submissions during the
proceeding, including with respect to requests for preliminary rulings in accordance with
paragraph 4 below.
Preliminary rulings
4. (1) If the United States considers that the Arbitrator should make a ruling before the
issuance of the Decision that certain measures, claims or issues are not properly before the
Arbitrator, the following procedure applies. Exceptions to this procedure shall be granted upon
a showing of good cause.

a. The United States shall submit any such request for a preliminary ruling at the earliest
possible opportunity. China shall submit its response to the request at a time to be
determined by the Arbitrator in light of the request.
b. The Arbitrator may issue a preliminary ruling on the issues raised in such a preliminary
ruling request before, during or after the substantive meeting, or the Arbitrator may defer
a ruling on the issues raised by a preliminary ruling until it issues its Decision to the parties.
c. If the Arbitrator finds it appropriate to issue a preliminary ruling before the issuance of its
Decision, the Arbitrator may provide reasons for the ruling at the time that the ruling is
made, or subsequently in its Decision.
(2) This procedure is without prejudice to the pa rties' right to request other types of
preliminary or procedural rulings during the proceeding, and to the procedures that the
Arbitrator may follow with respect to such requests.
Evidence
5. (1) Each party shall submit all evidence to the Arbitrator no later than the substantive
meeting, except evidence necessary for purposes of rebuttal, or evidence necessary for
answers to questions or comments on answers provided by the other party. Additional
exceptions may be granted upon a showing of good cause.
(2) If any new evidence has been admitted upon a showing of good cause, the Arbitrator
shall accord the other party an appropriate period of time to comment on the new evidence
submitted.
6. (1) If the original language of an exhibit or portion thereof is not a WTO working language,
the submitting party shall simultaneously submit a translation of the exhibit or relevant portion
into the WTO working language of the submission . The Arbitrator may grant reasonable
extensions of time for the translation of exhibits upon a showing of good cause.
(2) Any objection as to the accuracy of a translation should be raised promptly in writing,
preferably no later than the next filing or the meeting (whichever occurs earlier) following the
submission which contains the translation in question. Any objection shall be accompanied by
a detailed explanation of the grounds for the objection and an alternative translation.
7. (1) To facilitate the maintenance of the record of the dispute and maximize the clarity of
submissions, each party shall sequentially number its exhibits throughout the course of the
dispute, indicating the submitting Member and the number of each exhibit on its cover page.
Exhibits submitted by China should be numbered CHN -1, CHN-2, etc. Exhibits submitted by
the United States should be numbered USA -1, USA-2, etc. If the last exhibit in connection
with a submission was numbered CHN-5, the first exhibit in connection with the next
submission thus would be numbered CHN-6.

(2) Each party shall provide an updated list of exhibits (in Word or Excel format) together
with each of its submissions, oral statements, and responses to questions.
(3) If a party submits a document that has already been submitted as an exhibit by the
other party, it should explain why it is submitting that document again.
(4) Insofar as a party cons iders that the Arbitrator should take into account a document
already submitte d as an exhibit in the prior panel proceeding s, it should resubmit that
document as an exhibit for the purpose of this proceeding. In its list of exhibits, it should refer
to the number of the original exhibit in the original panel proceeding (OP) , if applicable
(example: USA-1 (USA-21-OP)).
(5) If a party includes a hyperlink to the content of a website in a submission, and intends
that the cited content form part of the official record, the cited content of the website shall be
provided in the form of an exhibit.

Editorial Guide
8. In order to facilitate the work of the Arbitrator, each party is invited on a voluntary basis to
make its submissions in accordance with the WTO Editorial Guide for Submissio ns (electronic copy
provided).
Questions

9. The Arbitrator may pose questions to the parties at any time, including:
a. Before the meeting, the Arbitrator may send written questions, in ad dition to written
questions already specified in the timetable, or a list of topics it intends to pursue in
questioning orally or in writing during the meeting. The Arbitrator may ask different or
additional questions at the meeting.
b. The Arbitrator may put questions to the parties orally or in writing during the meeting,
and in writing following the meeting, as provided for in paragraph 16 below.
Substantive meeting

10. The Arbitrator shall meet in closed session.
11. The parties shall be present at the meetings only when invited by the Arbitrator to appear
before it.
12. (1) Each party has the right to determine the composition of its own delegation when
meeting with the Arbitrator.
(2) Each party shall have the responsibility for al l members of its delegation and shall
ensure that each member of its delegation acts in accordance with the DSU and these Working
Procedures, particularly with regard to the confidentiality of the proceeding and the
submissions of the parties.
13. Each party shall provide to the Arbitrator the list of members of its delegation no later than
5.00 p.m. (Geneva time) three working days before the first day of each meeting with the Arbitrator.
14. A request for interpretation by any party should be made to the Arbitrator as early as possible,
preferably at the organizational stage, to allow sufficient time to ensure availability of interpreters.
15. There shall be one substantive meeting with the parties.
16. The substantive meeting of the Arbitrator with the parties shall be conducted as follows:
a. The Arbitrator shall invite the United States to make an opening statement to present
its case first. Subsequently, the Arbitrator shall invite China to present its point of view. Before
each party takes the floor, it shall provide the Arbitrator with a provisional written version of
its statement, including any visual presentations. If interpretation is needed, each party shall
provide additional copies for the interpreters.
b. Each party should avoid lengthy repetition of the arguments in its submissions. Each
party is invited to limit the duration of its opening statement to not more than 60 minutes. If
either party considers that it requires more time for its opening statement, it should inform
the Arbitrator and the other party at least 10 days prior to the meeting, together with an
estimate of the expected duration of its statement. The Arbitrator will accord equal time to
the other party.
c. After the conclusion of the opening statements, the Arbitrator shall give each party the
opportunity to make comments or ask the other party questions.
d. The Arbitrator may subsequently pose questions to the parties.

e. Once the questioning has concluded, the Arbitrator shall afford each party an
opportunity to present a brief closing statement, with the United States presenting its
statement first. Before each party takes the floor, it shall provide the Arbitrator and other
participants at the meeting with a provisional written version of its closing statement, if
available.
f. Following the meeting:
i. Each party shall submit a final written version of its opening statement no later than
5.00 p.m. (Geneva time) on the first working day following the meeting. At the same
time, each party should also submit a final written version of any prepared closing
statement that it delivered at the meeting.
ii. Each party shall send in writing, within the timeframe establ ished by the Arbitrator
before the end of the meeting, any questions to the other party to which it wishes to
receive a response in writing.
iii. The Arbitrator shall send in writing, within the timeframe established by the Arbitrator
before the end of the meeting, any questions to the parties to which it wishes to receive
a response in writing.
iv. Each party shall respond in writing to the questions from the Arbitrator, and to any
questions posed by the other party, within the time-frame established by the Arbitrator
before the end of the meeting. The parties may be given time to comment on the other
party's responses.
Descriptive part and executive summaries

17. The description of the arguments of the parties in the Decision of the Arbitrator shall consist
of executive summaries provided by the parties, which shall be annexed as addenda to the Decision.
These executive summaries shall not in any way serve as a substitute for the submissions of the
parties in the Arbitrator's examination of the case.
18. Each party shall submit one integrated executive summary, which shall summarize the facts
and arguments as presented to the Arbitrator in the party's submissions and statements , and if
possible, its responses to questions and comments thereon following the substantive meeting.
19. Each integrated executive summary shall be limited to no more than 15 pages.
20. The Arbitrator may request the parties to provide executive summaries of facts and arguments
presented in any other submissions to the Arbitrator for which a deadline may not be specified in
the timetable.
Service of documents

21. The following procedures regarding service of documents apply to all documents submitted by
parties during the proceeding:
a. Each party shall submit all documents to the Arbitrator by submitting them with the
DS Registry (office No. 2047).
b. Each party shall submit 2 paper copies of all documents it submits to the Arbitrator by
5.00 p.m. (Geneva time) on the due dates established by the Arbitrator. The DS Registrar
shall stamp the documents with the date and time of submission. The paper version
submitted to the DS Registry shall constitute the official version for the purposes of
submission deadlines and the record of the dispute. If any documents are in a format that
is impractical to submit as a paper copy, then the party may submit such documents to
the DS Registrar by email or on a CD-ROM, DVD or USB key only.
c. Each party shall also send an email to the DS Registry, at the same time that it submits
the paper versions, attaching an electronic copy of all documents that it submits to the

Arbitrator, preferably in both Microsoft Word and PDF format. All such emai ls to the
Arbitrator shall be addressed to DSRegistry@wto.org, and copied to other WTO Secretariat
staff whose email addresses have been provided to the parties during the proceeding. If
it is not possible to attach all the Exhibits to one email, the submitting party shall provide
the DS Registry with four copies of the Exhibits in electronic form on USB keys, CD-ROMs
or DVDs.
d. In addition, each party is invited to submit all documents through the Digital Dispute
Settlement Registry (DDSR) within 24 hours following the deadline for the submission of
the paper versions. If the parties have any questions or technical difficulties relating to
the DDSR, they are invited to consult the DDSR User Guide (electronic copy provided) or
contact the DS Registry at DSRegistry@wto.org.
e. Each party shall serve any document submitted to the Arbitrator directly on the other
party. A party may submit its documents to another party by email or on a CD -ROM or a
DVD, unless the recipient party has previously requested a paper copy. Each party shall
confirm, in writing, that copies have been served on the parties, as appropriate, at the
time it provides each document to the Arbitrator.
f. Each party shall submit its documents with the DS Registry and serve copies on the other
party by 5.00 p.m. (Geneva time) on the due dates established by the Arbitrator.
g. All communications from the Arbitrator to the parties will be via email.
Correction of clerical errors in submissions
22. The Arbitrator may grant leave to a party to correct clerical errors in any of its submissions
(including paragraph numbering and typographical mistakes). Any such request should identify the
nature of the errors to be corrected, and should be made promptly following the filing of the
submission in question.

ANNEX A-2
ADDITIONAL WORKING PROCEDURES OF THE ARBITRATOR CONCERNING
BUSINESS CONFIDENTIAL INFORMATION

Adopted on 15 November 2018

1. These procedures apply to any business confidential information (BCI) that a party wishes to
submit to the Arbitrator, including BCI that was previously treated by the U.S. Department of
Commerce as confidential or proprietary information protected by Administrative Protective Order in
the course of the anti-dumping duty proceedings relevant to this dispute. However, these procedures
do not apply to information that is available in the public domain. In addition, these procedures do
not apply to any BCI if the person who provided the information in the course of the relevant
proceedings agrees in writing to make the information publicly available.
2. The first time that a party submits to the Arbitrator BCI, as defined above, from an entity that
submitted that information in one of the relevant proceedings, the party shall also provide, with a
copy to the other party, an authorizing letter from the entity. That letter shall authorize both China
and the United States to submit in this dispute, in accordance with these procedures, any confidential
information submitted by that entity in the course of those proceedings.
3. If an entity refuses to grant the authorization letter, a party may bring the situation to the
attention of the Arbitrator. The Arbitrator shall consider what steps to take, which may include
requesting information pursuant to Article 13 of the DSU.
4. No person may have access to BCI except a member of the Secretariat or the Arbitrator, an
employee of a party, and an outside advisor for the purposes of this dispute to a party. An outside
advisor may include a person providing to a party advice on any matter related to the dispute.
However, an outside advisor is not permitted access to BCI if that advisor is an officer or employee
of an enterprise engaged in the production, export, or import of the products that were the subject
of the proceedings relevant to this dispute.
5. A party having access to BCI shall treat it as confidential, i.e., shall not disclose that
information other than to those persons authorized to receive it pursuant to these procedures. Each
party shall have responsibility in this regard for its employees as well as any outside advisors used
for the purposes of this dispute. BCI obtained under these procedures may be used only for the
purpose of providing information and argumentation in this arbitration and for no other purpose.
6. The party submitting BCI shall mark the cover and/or first page of the document containing
BCI, and each page of the document, to indicate the presence of such information. The specific
information in question shall be placed between double brackets, as follows: [[xx,xxx.xx]]. The first
page or cover of the document shall state “Contains business confidential information on pages
xxxxxx”, and each page of the document shall contain the notice “Contains Business Confidential
Information” at the top of the page.
7. Where a party submits a document containing BCI to the Arbitrator, the other party referring
to that BCI in its documents, including written submissions and oral statements, shall clearly identify
all such information in those documents. All such documents shall be marked as described in
paragraph 6. In the case of an oral statement containing BCI, the party making such a statement
shall inform the Arbitrator before making it that the statement will contain BCI, and the Arbitrator
will ensure that only persons authorized to have access to BCI pursuant to these procedures are in
the room to hear that statement.
8. The Arbitrator will not disclose BCI, in its decision or in any other way, to persons not
authorized under these procedures to have access to BCI. The Arbitrator may, however, make
statements of conclusion drawn from such information. Before the Arbitrator circulates its final
decision to the Members, the Arbitrator will give each party an opportunity to review the decision
to ensure that it does not contain any information that the party has designated as BCI.

ANNEX B
ARGUMENTS OF THE PARTIES
Contents Page
Annex B-1 Executive summary of the arguments of the United States 12
Annex B-2 Executive summary of the arguments of China 23

ANNEX B-1
EXECUTIVE SUMMARY OF THE ARGUMENTS OF THE UNITED STATES
I. INTRODUCTION
1. Contrary to the requirements of the Understanding on Rules and Procedures Governing the
Settlement of Disputes ("DSU"), the level of suspension of concessions that China has requested is
not equivalent to the level of nullification or impairment.
2. Pursuant to Article 22.7 of the DSU, the task of an arbitrator is to determine whether the
requested level of suspension of concessions or other obligations is equivalent to the level o f
nullification or impairment of benefits accruing to the complaining party under the relevant covered
agreement(s). The starting point in any analysis of a request for authorization to suspend
concessions is to determine the extent to which the Member's WTO-inconsistent measure that is the
subject of the Dispute Settlement Body 's ("DSB") recommendations nullifies or impairs benefits
accruing to the complaining party. Thus, an analysis of the level of nullification or impairment must
focus on the benefit allegedly nullified or impaired as a result of the breach found by the DSB. Due
to conceptual flaws and methodological errors, however, China has not provided a calculation that
is equivalent to the level of nullification or impairment.
3. This proceeding requires that each of the 25 antidumping duty determinations specifically
identified in China's methodology paper be separately analyzed to determine the most appropriate
methodology to calculate the level of nullification or impairment. China appears to agree. Yet, China
proposes a one-size-fits-all approach to estimating its requested level of suspension of concessions.
China's proposed methodology is of no use to the Arbitrator for it cannot capture the impact of
antidumping duty margins on trade flo ws, which is the key issue in this proceeding. China
compounds its methodological error by relying on false assumptions and incorrect data to implement
its approach.
4. Furthermore, China's methodology paper contains errors sufficient by themselves to establish
that China 's proposal is fundamentally flawed. For instance, China proposes an incorrect
counterfactual, applies an economic method that is completely inappropriate, and makes numerous
errors when compiling the data inputs it uses to estimate the level of nullification or impairment. As
a result, China overestimates the level of nullification or impairment attributable to the maintenance
following the expiration of the reasonable period of time ("RPT") of the U.S. antidumping measures
about which the DSB adopted recommendations.
5. China bases its request on the assertion that the Arbitrator must use a counterfactual that
assumes the complete remov al of the U.S. antidumping duty measures following the expiration of
the RPT, even U.S. antidumping duty measures that have not been found to be WTO -inconsistent.
China's proposal is contrary to the DSU and results in a gross overestimation of the level o f
nullification or impairment. The proper counterfactual to be applied for the purpose of this
proceeding is the elimination of the WTO -inconsistent aspects of the U.S. antidumping duty
measures, not the revocation or complete removal of the antidumping duty orders themselves.
6. In response to the flawed one-size-fits-all methodology proposed by China, the United States
proposes three approaches that accurately estimate the trade effects of the WTO -inconsistent U.S.
antidumping duty measures following the expiration of the RPT.
II. APPROPRIATE CALCULATION OF THE LEVEL OF NULLIFICATION OR
 IMPAIRMENT
A. Article 22 of the DSU Requires that the Proposed Level of Suspension Be
 Equivalent to the Level of Nullification or Impairment
7. Pursuant to Article 22.4 of the DSU, the DSB is not to authorize the suspension of concessions
or other obligations unless "the level" of suspension is "equivalent" to the level of nullification or

impairment. Article 22.7 of the DSU further provides that where a matter is referred to arbitration,
the arbitrator "shall determine whether the level of . . . suspension is equivalent to the level of
nullification or impairment." The starting point in the analysis of a suspension request is to
determine the extent to which any WTO -inconsistent measure maintained following the expiration
of the RPT nullifies or impairs benefits accruing to the complaining Member under the relevant
covered agreement(s).
8. Thus, an ana lysis of the level of nullification or impairment must focus on the "benefit"
accruing to the complaining Member under a covered agreement that is allegedly nullified or
impaired as a result of the breach found by the DSB. Arbitrators in past proceedings have uniformly
based their determinations on hard evidence and have refused to "accept claims that are 'too
remote', 'too speculative', or 'not meaningfully quantified. '" As the arbitrators in EC – Hormones
(US) (Article 22.6 – EC) and EC – Hormones (Canada) (Article 22.6 – EC) found, "we need to guard
against claims of lost opportunities where the causal link with the inconsistent [measure] is less than
apparent, i.e., where exports are allegedly foregone not because of the [inconsistent measure] but
due to other circumstances."
9. In previous Article 22.6 proceedings, the arbitrator has compared the level of trade for the
complaining party under the WTO -inconsistent measure to what the complaining party 's level of
trade would be expected to be where the Member concerned has brought the WTO -inconsistent
measure into conformity following the expiration of the RPT. The situation in which the Member
concerned has removed the WTO inconsistency is referred to as the "counterfactual." The difference
in the lev el of trade under these two situations typically represents the level of nullification or
impairment. Other Article 22.6 arbitrators have recognized that a counterfactual was an appropriate
method in those proceedings to calculate a level of nullification or impairment, and China itself
proposes the use of a counterfactual in this proceeding. China, however, has proposed an incorrect
counterfactual.
10. The appropriate analysis requires consideration of the present trading relationship between
China and the United States (as represented by the 2017 baseline), as well as what that relationship
would be if the U.S. measures had been brought into compliance with the DSB recommendations
following the expiration of the RPT (the counterfactual). As described below, the trade differential
will be the level of nullification or impairment attributable to the maintenance of the U.S. measures.
B. The Appropriate Counterfactual Eliminates the WTO -Inconsistent Aspects
 of the U.S. Antidumping Duty Measures
China's Counterfactual Has No Support in the DSU
11. China proposes to estimate the level of nullification or impairment based on assuming the
withdrawal of all of the U.S. antidumping duty orders, even parts of the U.S. antidumping duty
measures that are not subject to the DSB's recommendations.
12. Article 22.1 of the DSU provides that compensation and the suspension of concessions is
available in the "event that the recommendations" of the DSB "are not implemented within a
reasonable period of time." Thus, Article 22.1 of the DSU directs an arbitrator to base an Article
22.6 decision on the "recommendations" of the DSB. Similarly, Article 22.2 of the DSU, which is
explicitly referenced in the first sentence of Article 22.6, limits the role of an arbitrator to assessing
the effects of the WTO-inconsistent U.S. antidumping duty measures in accordance with the DSB 's
recommendations. To go beyond the DSB recommendations, as China proposes, would be contrary
to the DSU.
13. The DSB recommendations at issue in this proceeding relate to the use by the U.S. Department
of Commerce ("USDOC") of the Single Rate Presumption ("SRP"), as well as the use in certain
proceedings of an alternative, average -to-transaction comparison methodology and "zeroing" in
conjunction with that alternative comparison methodology. To determine the equivalent level of
nullification or impairment in this proceeding, it is necessary to correctly understand the findings
adopted by the DSB. The DSB findings of WTO inconsistency relate t o certain aspects of the U.S.
antidumping measures, but other aspects of the U.S. antidumping measures have not been found
to be WTO-inconsistent. As the United States will discuss in the following section, the antidumping

duty rates that apply to Chinese imports at issue in this proceeding can be broken down into four
categories.
14. Similarly, for the three investigations and one administrative review for which the panel made
findings concerning the USDOC 's use of the alternative, average -to-transaction comparison
methodology and "zeroing," only certain companies were assigned antidumping duty rates found to
be WTO -inconsistent. Those rates can be isolated and the level of nullification or impairment
resulting from their maintenance following the expir ation of the RPT can be estimated accurately
without incorrectly assuming, as China does, the total withdrawal of the U.S. antidumping duty
measures.
The Correct Counterfactual is Modification of the WTO -Inconsistent
U.S. Antidumping Duty Measures To El iminate the WTO -
Inconsistencies Found by the DSB , Not the Total Withdrawal of the
Antidumping Duty Measures
15. In this proceeding, the correct counterfactual is the estimated value of exports of relevant
products from China to the United States if the WTO -inconsistent U.S. antidumping duty measures
were brought into compliance with U.S. WTO obligations, holding all other factors constant. The
level of "nullification or impairment" to China is the difference between the value of China's exports
to the United States as reflected in the 2017 trade data, and the estimated export value under the
counterfactual scenario.
16. In other words, the question is: for each of the 13 products subject to "as applied" findings
and for each of the 12 products China has i dentified in connection with the "as such" findings, how
many additional exports from China would enter the United States under the separate duty rate (the
rate that applies to what the United States calls Group 2) if the presumption of a China-government
entity were eliminated. As discussed above, China's methodology paper applies an incorrect
counterfactual. The key assumption in China 's counterfactual is the removal of all antidumping
duties, even the U.S. antidumping duties that were not found to be W TO-inconsistent. Under the
correct counterfactual, however, those firms that are subject to the China -government entity rate
and did not fail to cooperate would, instead, be assigned the separate duty rate. The correct
estimate of the level of nullification or impairment is the difference in the value of trade that would
be induced by changing —if, in fact, there were a difference between the rate assigned the China
government entity and separate -rate respondents—the rate for these firms only. For most ca ses,
this represents a small share of imports from China at any given period. To illustrate, Chinese
imports are divided into four groups:
Group 1: Chinese imports from firms to which individual duty rates
apply;
Group 2: Chinese imports from firms that were not individually
examined yet received what is labeled as a "separate duty rate"
(that is, a rate separate from the rate assigned to the China -
government entity);
Group 3: Chinese imports from firms that are subject to the China-
government entity antidumping duty rate for which there is evidence
that they failed to cooperate with the USDOC 's investigation, such
that a rate based on facts available could have applied even if they
were not part of the China-government entity; and
Group 4: Chinese imports from firms that are subject to the China-
government entity antidumping duty rate for whi ch there is no
evidence that they failed to cooperate with the USDOC 's
investigation.
17. Under the correct counterfactual, the only modification is that duties on Group 4 imports are
changed from the rate assigned to the China -government entity to a separate duty rate. With the
exception of certain antidumping duty rates determined using the alternative, average -to-

transaction comparison methodology with "zeroing," all other antidumping duties would remain
unchanged.
C. The Correct Methodology for Deter mining the Level of Nullification or
 Impairment Must Be Determined Case by Case
Complying with the DSB Recommendations Concerning U.S.
Antidumping Duty Measures on Corrosion -Resistant Steel and
Diamond Sawblades Would Not Result in Any Increase in the Value
of Exports of Those Products from China to the United States; the
Level of Nullification or Impairment is Zero
a. The DSU Permits the Arbitrator to Find that a Measure Causes
No Nullification or Impairment
18. Article 3.8 of the DSU plainly provides for the possibility that the Member concerned may
rebut the presumption of the existence of nullification or impairment by putting forth evidence that
a breach of WTO obligations does not have an adverse impact on the complaining party. Additionally,
nothing in Article 3.8 of the DSU, which is one of the "General Provisions" of the DSU, limits the
opportunity of the Member concerned to make such a rebuttal only during the original panel phase
of a dispute settlement proceeding. The more logical time for a Member concerned to make such a
rebuttal would be in the context of an arbitration under Article 22.6 of the DSU, wherein the question
of the level of nullification or impairment – and indeed, the question of the existence of any level of
nullification or impairment at all following the expiration of the RPT – is placed squarely before the
decision maker that is tasked by the DSU with evaluating that question and the question of the level
of suspension – i.e., the DS U Article 22.6 arbitrator. If no trade is foregone due to a WTO -
inconsistent measure's continuing existence beyond the expiration of the RPT, i.e., if the estimate
of the trade foregone is zero, then the correct conclusion is that the level of nullificati on or
impairment is zero.
19. Furthermore, the factual circumstances related to a WTO -inconsistent measure's impact on
the complaining party might change over time, including after a panel report is circulated and before
a suspension request is made under Article 22.2 of the DSU. In an arbitration under Article 22.6 of
the DSU, it is incumbent upon the arbitrator to establish the level of nullification or impairment
following the end of the RPT, so as to ensure that the level of suspension authorized by th e DSB
does not exceed the level of nullification or impairment.
20. Accordingly, it is necessary for the Arbitrator to determine in this proceeding the ongoing trade
effects of the U.S. antidumping duty measures on corrosion-resistant steel and diamond sawblades
from China (using 2017 as the baseline for the counterfactual). China suggests in its methodology
paper that the "question that must be answered [in this proceeding] is what would have been the
value of imports from China in 2017 'but for' the United States continued imposition of the WTO
inconsistent measures." By this, China uses 2017 as a proxy (presumably for reasons of data
availability) for the ongoing trade effects caused by the maintenance of WTO-inconsistent measures
beyond the expiry of the RPT in August 2018. For purposes of the counterfactual, the United States
has also used 2017 data.
b. The Evidence Demonstrates that the Level of Nullification or
Impairment from the Antidumping Duty Measures on
Corrosion-Resistant Steel and Diamond Sawblades is Zero
21. The evidence demonstrates that bringing the U.S. antidumping duty measures on corrosion -
resistant steel and diamond sawblades from China into compliance would result in no increase at all
in the value of corrosion -resistant steel or diamond sawblades exported from China to the United
States.
22. In cases where the China -entity rate and a separate duty rate are the same, the level of
nullification or impairment is zero because the counterfactual scenario in which the USDOC
undertook a redetermination and changed the WTO -inconsistent rate for companies that form part
of the China-government entity—an entity based on a presumption found to be WTO-inconsistent—
from the China-government entity rate to the separate duty rate determined for those separate-rate

respondents subject to the relevant proceeding, would, in these cases, not result in any reduction
of the antidumping duty rate. In Corrosion-Resistant Steel, the China -government entity rate is
199.43 percent and the separate rate is also 199.43 percent. In Diamond Sawblades, in 2017, the
China-government entity rate was 82.03 percent and the separate rate also was 82.03 percent.
Accordingly, the level of nullification or impairment is zero.
An Armington-Based Imperfect S ubstitutes Partial Equilibrium
Model is the Appropriate Method for Estimating the Level of
Nullification or Impairment Resulting from the Maintenance
Following the Expiration of the RPT of the WTO -Inconsistent U.S.
Antidumping Duty Measures on Aluminum Extrusions, Shrimp, Steel
Cylinders, Woven Ribbons, PET Film, Carrier Bags, Coated Paper,
Steel Line and Pressure Pipe, Welded Carbon Steel Pipe, Welded
Carbon Steel Line Pipe, Steel Nails, Stainless Steel Sheet and Strip,
Cast Iron Pipe Fittings, Copper Pipe and Tube, Cold Rolled Steel Flat
Products, Truck Tires, and Washers
23. China recognizes that an "elasticities style trade model" or "a partial equilibrium model" "could
be used for calculating" the level of nullification or impairment. Indeed, China ch aracterizes such
an approach as "an excellent short-run quantitative model."
24. Despite China's suggestion that "many policies have been found to be inconsistent with WTO
rules" and "various and complicating issues" support the use of China's flawed approach – discussed
further below – the analysis required in this proceeding actually is quite simple. Antidumping duty
measures are tariffs. The simplest description of the correct counterfactual scenario here is that the
tariffs imposed by the United States are assumed to be reduced. Partial equilibrium analysis is, to
use China's term, an "excellent" tool for modeling the trade effects of a tariff reduction.
25. Under correct economic theory, the effect of the reduction or removal of the WTO-inconsistent
U.S. antidumping duties applied to aluminum extrusions, shrimp, steel cylinders, woven ribbons,
PET film, carrier bags, coated paper, steel line and pressure pipe, welded carbon steel, welded carbon
steel line pipe, steel nails, stainless steel sheet and strip, cast iron pipe fittings, copper pipe and
tube, cold rolled steel flat products, truck tires, and washers from China depends on the
substitutability between (1) the domestic like product (the product made in the United States), (2)
subject imports (the product imported from China that is subject to the WTO -inconsistent
antidumping duty), (3) non -subject imports from China (the product imported from China that is
not subject to the WTO-inconsistent antidumping duty), and (4) non-subject imports from the rest
of the world (the product imported from countries other than China). To properly measure the effect
of the reduction of the antidumping duties on aluminum extrusions, shrimp, steel cylinders, woven
ribbons, PET film, carrier bags, coated paper, steel line and pressure pipe, welded carbon steel,
welded carbon steel line pipe, steel nails, stainless steel sheet and strip, cast iron pipe fittings,
copper pipe and tube, cold rolled steel flat products, truck tires, and washers from China, one would
need to use for each product an economic model that accounts for the substitution effects on all four
of these varieties.
26. An example of such a model – an Armington-based imperfect substitutes partial equilibrium
model – that would be appropriate to use can be found in a 2017 paper by Ross Hallren and David
Riker. The Hallren and Riker paper provides a convenient framework to undertake a partial
equilibrium analysis of the trade effects of modifying import tariffs where the imported and domestic
goods are imperfect substitutes. Indeed, the Hallren and Riker paper provides as an "illustrative
application" an example of modeling the effects of "a reduction in the impo rt ad -valorem tariff
applied to subject imports from 5 to 0 percent," which corresponds to the modification of duties for
purposes of this discussion. The partial equilibrium model in the Hallren and Riker paper is based
on the Armington approach to trade , where products are differentiated by source countries and
consumers view products from different countries as imperfect substitutes. As explained in A
Practical Guide to Trade Policy Analysis , "most simulation models use the 'Armington assumption'
whereby varieties of goods are differentiated by country of origin (Armington, 1969)."
27. The U.S. version of the model assumes that there are four varieties of products in the industry
that are imperfect substitutes in demand. The four varieties are the domestic product, non-subject
imports from rest of world, non -subject imports from China, and subject imports from China. As
the Hallren and Riker paper explains, all source varieties are imperfect substitutes and consumers

substitute between each variety at a constant rate, which is the Armington elasticity. The Hallren
and Riker paper points out that the Armington elasticity "is a key element in the model" because it
tells how sensitive consumers are to changes in the relative prices of each of the source varieties.
28. The model detailed in the Hallren and Riker paper permits the estimation of the magnitudes
of the changes in the prices of the four varieties of products, the industry's overall price index, and
the quantities of the products as a result of a reduction in the ad valorem tariff on subject imports.
The goal of the analysis is to quantify these changes given information on the duties and the initial
values of trade and market shares in the respective industries in this proceeding.
a. Reduction of Tariff Rates on Subject Imports from the China-
Entity Rate to the Separate Duty Rate
29. To use the four-country model, one first needs to define 2017 imports from subject imports
versus non-subject imports from China. U.S. Customs and Border Protection ("CBP") is able to
compile U.S. import data for all products subject to an antidumping order. The United States has
provided a table with CBP-sourced data for each of the 13 products subject to "as applied" findings
and for each of the 12 prod ucts subject to "as such" findings that are discussed in China 's
methodology paper. This CBP data is separated into total imports subject to an antidumping duty
order as well as total imports subject to the China-government entity rate.
30. Finally, we note that the Armington model, like all other standard trade models, relies on the
observed value of imports as a share of the market to characterize an entity's relative competiveness
given the conditions in the market, including the imposition of duties. In this context, an appropriate
minimal trade share for subject China imports is at least one percent of total U.S. imports from
China. If the share is lower than one percent, the United States uses a formula-based approach to
calculate the level of nullification or impairment.
b. Correct Data Inputs that Would Be Used in Applying an
Armington-Based Imperfect Substitutes Partial Equilibrium
Model
31. The Hallren and Riker paper explains that the following data inputs would be used in applying
the Armin gton-based imperfect substitutes partial equilibrium model that the paper describes:
domestic shipments of domestic producers; trade value of subject imports from China; trade value
of non-subject imports from China; trade value of non-subject imports from rest of world ("ROW");
supply elasticity for domestic producers; supply elasticity for subject imports from China; supply
elasticity for non-subject imports from China; supply elasticity for non -subject imports from ROW;
elasticity of substitution within the industry; price elasticity of total demand; change in tariff rates
on subject imports.
c. Results of Armington-Based Model
32. As a result of applying the Armington -based model, the level of nullification or impairment
from the maintenance following the expiration of the RPT of the U.S. antidumping duty measures on
aluminum extrusions, shrimp, steel cylinders, woven ribbons , PET film, carrier bags, coated paper,
steel line and pressure pipe, welded carbon steel, welded carbon steel line pipe, steel nails, stainless
steel sheet and strip, cast iron pipe fittings, copper pipe and tube, cold rolled steel flat products,
truck tires, and washers from China is no more than $ 24.03 million per year. For these same
products, China's one-size-fits-all approach estimated the level of nullification or impairment to be
$8,638 billion annually.
A Formula-Based Approach is the Appropriate Method for Estimating
the Level of Nullification or Impairment from the U.S. Antidumping
Duty Measures on Wood Flooring, OCTG, CSPV Cells, and Off -the-
Road Tires
33. Total U.S. imports under the China -government entity rate as a share of total U.S. imports
from China under the order for wood flooring, OCTG, CSPV cells, off -the-road tires, and bedroom
furniture was less than one percent in 2017. That being the case, an Armington-based imperfect

substitutes partial equilibrium model cannot reliably be used to estimate the level of nullification or
impairment for these products.
34. In light of the facts of these ca ses and the evidence available, the most appropriate
methodology to estimate the level of nullification or impairment for wood flooring, OCTG, CSPV cells,
off-the-road tires, and bedroom furniture is a formula-based approach. A formula-based approach
examines China's historical import share of the U.S. market for Group 4 companies for the five
products prior to the imposition of the WTO-inconsistent antidumping duty measure and applies that
market share to the total value of imports of the goods from China in 2017. The United States
observes that this approach reflects trade distorted by dumping and thus overestimates the level of
nullification or impairment. Nevertheless, this approach is consistent with the approach taken by
arbitrators in past Article 22.6 proceedings and fits well with the evidence on record for these five
products.
35. Where the relevant data were available, previous Article 22.6 arbitrators have used historical
export or import levels to determine the level of nullification or impairment caused by a measure.
In EC – Hormones, for example, the arbitrator calculated the level of nullification or impairment in
respect of edible beef offal by: (1) considering average U.S. exports of the covered product in the
three years preceding the import ban at issue; (2) making a downward adjustment based on
changing preferences; (3) multiplying the estimated figure by the estimated price of the products;
and (4) deducting the value of current imports. In EC – Bananas III, the arbitrator calculated the
effect of the EU measure based on the level of Ecuador 's "best-ever exports," which occurred the
year before the measure was enacted. In US – Gambling, the arbitrator used the difference between
the complaining Member's revenues from supplying the services affected by the challenged measure
the year before the measure came into effect an d the average actual annual revenue in the years
following to calculate the level of nullification or impairment.
36. A similar formula-based approach is appropriate in this proceeding because historical levels of
U.S. imports of the five Chinese products are indicative of the level of nullification or impairment
caused by the U.S. antidumping duty measures.
37. The United States starts with the maximum share of imports that may have been assigned
the China-government entity rate during the period of investigation.
38. The United States calculated the level of trade during the period of investigation for the
relevant U.S. Harmonized Tariff Schedule (HTS) codes. It then calculated the share of trade covered
by the mandatory respondents and the separate rate respondents. The remainder would be the
maximum share of imports covered by the China -government entity rate. The maximum or
estimated share is then applied to U.S. imports from China for the specified product in 2017 to
determine the level of nullification or impairment. Next, the United States calculated the share of
companies that did not respond to the USDOC quantity and value questionnaire and would have
correctly been assigned a rate based on facts available, which was the basis on wh ich the China-
government entity rate was determined. The maximum share was then reduced by this amount.
39. The level of nullification or impairment resulting from the U.S. antidumping duty measures on
wood flooring, OCTG, CSPV cells, and off -the-road tir es from China is no more than $176.733
million. This contrasts with China's estimate of $6.036 billion for these four products.
Estimating the Level of Nullification or Impairment Related to
Recommendations Adopted by the DSB Concerning the USDOC's Use
of the Alternative, Average-to-Transaction Comparison Methodology
and "Zeroing" in Certain Proceedings
40. In the original dispute, China challenged, and the DSB adopted "as applied" recommendations
concerning, the use of the alternative, average -to-transaction comparison methodology and
"zeroing" in only three original investigations ( OCTG, Steel Cylinders, and Coated Paper) and one
administrative review (PET Film). The other antidumping proceedings at issue in this arbitration are
not implicated by th e findings related to the use of the alternative, average -to-transaction
comparison methodology and "zeroing," so there can be no nullification or impairment related to
those other proceedings as a result of the findings on the average -to-transaction compa rison
methodology and "zeroing."

a. Steel Cylinders
41. The level of nullification or impairment related to the USDOC's use of the alternative, average-
to-transaction comparison methodology and "zeroing" during the original antidumping investigation
of steel cylinders from China is zero. With respect to the Steel Cylinders antidumping investigation,
China only challenged the USDOC 's use of the alternative, average -to-transaction comparison
methodology and "zeroing" with respect to the margin of dumping determined for BTIC, and BTIC is
the only company for which there was an "as applied" finding concerning the use of the alternative,
average-to-transaction comparison methodology and "zeroing." In response to a decision of the
U.S. Court of International Trade, the USDOC revoked the antidumping duty measure with respect
to BTIC effective August 27, 2017. The USDOC took thi s action prior to the expiration of the RPT
and there is nothing else for the United States to do to implement the DSB's recommendations with
respect to the findings related to the USDOC 's use of the alternative, average -to-transaction
comparison methodology and "zeroing" to determine the margin of dumping for BTIC in the Steel
Cylinders antidumping investigation. Therefore, there is no nullification or impairment to China
related to this finding.
b. PET Film Administrative Review
42. The level of nullif ication or impairment related to the USDOC 's use of "zeroing" during the
third administrative review of the antidumping order on PET film from China is zero. With respect
to the third administrative review of PET film, China only challenged the USDOC 's use of "zeroing"
with respect to the margin of dumping determined for the DuPont Group, and the DuPont Group is
the only entity for which there was an "as applied" finding concerning the use of "zeroing." However,
the results of the third administrative review of PET film have been succeeded by the results of the
fourth administrative review of PET film, which were published on July 2, 2014. In the fourth
administrative review, the USDOC assigned the DuPont Group a margin of dumping that was not
determined using "zeroing." The antidumping rate applicable to the DuPont Group at the end of
the RPT (and during the baseline year 2017) would not be changed as a result of any redetermination
of the results of the third administrative review that are the subject of findings adopted by the DSB.
Therefore, there can be no nullification or impairment following the expiration of the RPT related to
this finding.
c. Coated Paper
43. In the Coated Paper antidumping duty investigation, the USDOC found that the average -to-
transaction rate in the investigation for APP China was 7.62 percent, and the average -to-average
rate (without "zeroing") would have been de minimis ([[***]] percent). Thus, there would not have
been an antidumping duty imposed for APP China. The separ ate rate assigned by the USDOC was
the APP China rate, which was determined using "zeroing." That rate was applied as a separate rate
in 2017.
44. The level of nullification or impairment resulting from the maintenance of the antidumping
duty rate deter mined using the average -to-transaction comparison methodology and "zeroing"
following the expiration of the RPT can be estimated using the Armington -based imperfect
substitutes partial equilibrium model. Specifically, the model can be used to estimate the trade
effect of a reduction from the WTO -inconsistent rate of 7.62 percent to zero percent for the non -
China-government entity imports in 2017, and to model a reduction of the China -government rate
to zero for the China-government entity shipments. The result provides the level of nullification or
impairment related to this finding, which is no more than $0.19 million.
45. If the USDOC assigned facts available to any Chinese firms due to non -cooperation, this
approach may overstate the level of nullification or impairment.
d. OCTG
46. In the OCTG antidumping duty investigation, the USDOC found that, for Chinese respondent
TPCO, the margin of dumping calculated using the average -to-average comparison methodology
was [[ ***]] percent, while the margin of dum ping calculated using the average -to-transaction
comparison methodology with "zeroing," which is the WTO-inconsistent aspect of the measure, was
32.07 percent. Thus, there still would have been an antidumping duty imposed for TPCO. The

separate rate assigned by the USDOC was the TPCO rate, which was determined using "zeroing."
That rate appears to have been applied as the separate rate in 2017.
47. There is not a sufficient level of subject imports from China in 2017 for the United States to
apply the Armington-based model for this product. Nevertheless, given that the tariff modification
that would apply in the counterfactual scenario is less than [[ ***]], the impact would be so small
that it cannot be "meaningfully quantified." An estimati on of zero as the level of nullification or
impairment is thus reasonable and plausible in this situation.
III. THE LEVEL OF SU SPENSION OF CONCESSI ONS OR OTHER OBLIGAT IONS
 PROPOSED BY CHINA F AR EXCEEDS THE LEVEL OF NULLIFICATION OR
 IMPAIRMENT
A. China Grossly Overstates the Level of Nullification or Impairment Because
 China's Proposed Approach Is Not Appropriate, It Is Premised on False
 Assumptions, and It Is Based on Incorrect Data Inputs
China's DID Tabular Methodology is Not Appropriate
48. China justifies using Differences -in-Differences (DID) tabular analysis by alluding to its
"simplicity." While simplicity can be a virtue, it does not justify using the tabular DID methodology
in this proceeding. The tabular DID methodology cannot capture the impact of different antidumping
duty margins on trade flows, which is the key issue to estimate any nullification or impairment in
this proceeding. China 's tabular DID methodology is only able to estimate termination of all
antidumping duties on China, including WTO -consistent duties on imports from China (Group 1,
Group 2, and Group 3).
49. Thus, it is not possible, as a legal matter, to use China's tabular DID analysis, because it would
necessarily overestimate the level of nullification or impa irment by including in the estimate the
removal of WTO-consistent duties.
50. The United States observes that there is no support in the economics literature for using DID
tabular analysis to estimate the effects of antidumping duties on imports. After an extensive search
of the economics literature, the United States did not find any academic studies using DID tabular
analysis to estimate the effects of antidumping duties or tariffs on imports.
China's Methodology is Premised on False Assumptions and Is
Fundamentally Flawed as a Result
51. China's tabular DID methodology cannot provide accurate estimates of the level of nullification
or impairment because it is premised on false assumptions. According to economic literature, the
following three key assumptions must hold in a tabular DID analysis: (1) parallel trends (the
comparison group is composed of exports that would be expected to follow the same trends as
China's exports of the subject products in the absence of antidumping duties); (2) stabi lity (the
treated and comparison exports must remain the same over time); and (3) uniformity (the treatment
or lack thereof ( i.e., antidumping duties) must be the same for all exports that comprise the
treatment and control groups, respectively).
52. Together, the assumptions of parallel trends, stability, and uniformity mean that an
appropriate comparison group must be comparable enough that its exports could reasonably be
expected to follow the same trend as those from China without the "treatment" o f the WTO -
inconsistent U.S. antidumping duties, but distinct enough that the effects of imposing U.S.
antidumping duties on China 's imports will not "spillover" on their exports. If these three key
assumptions do not hold, China 's tabular DID methodology will produce estimates that are
inaccurate. In this proceeding, all three assumptions do not hold in the comparison groups
constructed by China.
53. In its methodology paper, China acknowledges the importance of the parallel trends
assumption, and asserts that it made a "considerable effort" to demonstrate that the parallel trends
assumption holds for its control groups. While China 's methodology paper provides a considerable

amount of discussion on the parallel trends assumption, China fails to demonstrate that the parallel
trends assumption, in fact, holds in its control groups.
54. China entirely disregards the second (stability) and third (uniformity) assumptions. The
stability assumption has two implications in this context. First, stability requ ires that the set of
"treated" and "comparison" exports remains unchanged between the initial period and 2017.
However, China 's analysis incorrectly relies on HTS codes to define imports subject to each
antidumping duty order, and in some significant cases (for example, Aluminum Extrusions), the set
of HTS codes to which antidumping duties are applied in the initial period is not the same in 2017.
Therefore, the stability assumption does not hold, and this is another reason why it is inappropriate
to apply the tabular DID method.
55. The second implication of stability in this case requires China to design its comparison group
such that the effects of U.S. antidumping duties on China's exports do not have spillover effects on
comparison group exports. Figure 1 below illustrates the likely spillover effects that can be seen in
the CSPV case. In contrast to China 's "treated" exports, exports from countries other than China
increased in 2010 after U.S. antidumping duties were applied. Since it is likely that this is, at least
partially, a result of the antidumping duties applied to Chinese exports, it is a spillover effect that
invalidates DID analysis of this case.
Figure 1 – U.S. Imports of CSPV Cells

56. The uniformity assumption requires that the WTO-inconsistent U.S. antidumping duties be the
same for all "treated" groups. This assumption is violated both in the design and in the
implementation of China's tabular DID methodology. The uniformity assumption does not hold under
China's incorrect counterfactual. Moreover, the uniformity assumption also requires that exports in
the comparison group be equally "untreated." Erroneously, three of the four comparison groups
that China considers are composed of total U.S. imports, including the "treated" imports from China
and other countries subject to antidumping duties.
57. In short, a fundamental flaw in China 's approach is China 's failure to demonstrate that its
comparison groups can reasonably be expected to satisfy the key assumptions of tabular DID
methodology.
China's Final Estimates of Nullification or Impairment Are
Fundamentally Biased and Mutually Exclusive
58. The final estimates of nullification or impairment presented by China for each antidumping
duty order are averages of estimates obtained from tabular DID analysis showing the differences in
the level of import values and estimates obtained from tabular DID analysis showing the differences
in the natural logarithm ("log") of import values.

59. As noted in China's Exhibit CHN-18, a DID model may be applied to a variable in levels or in
logs, but the parallel trends assumption can only be met in either levels or logs. Put another way,
the parallel trends assumption cannot be met in both levels and logs. China's estimates from these
metrics are therefore biased. Contrary to China's assertions, the distortions attributable to China's
incorrect application of tabular DID analysis do not average out. Rather, they accumulate.
China's Methodology is Based on Incorrect Data Inputs
60. China's approach to data – capturing total trade flows occurring under basket HTS categories
– is unreasonable because it grossly over-estimates the value of trade of products subject to WTO-
inconsistent aspects of U.S. antidumping measures. Many of the reference HTS codes are broad
categories, of which the product subject to an antidumping duty order is just a subset.
61. China's data does not provide the Arbitrator a reliable basis to estimate nullification or
impairment in this proceeding. If the Arbitrator were to use China's incorrect data, it would lead to
a level of suspension that would be well in excess of the actual level of nullification or impairment.
IV. CONCLUSION
62. For the reasons set forth above, the United States respectfully requests that the Arbitrator
find that the level of suspension of concessions or other obligations requested by China is not
"equivalent" to the level of nullification or impairment. The United States requests that the Arbitrator
find that the level of nullification or impairment is no more than $200.790 million annually.

ANNEX B-2
EXECUTIVE SUMMARY OF THE ARGUMENTS OF CHINA
1. The United States has kept more than 100 WTO -inconsistent AD measures in place after the
expiration of the reasonable period of time in the present dispute DS471. These measures continue
to be in force today, causing significant monetary losses to multiple industries in China from reduced
export revenues. Because the United States has refused to bring its unlawful measures in compliance
with its WTO-obligations, China is seeking authorization to suspend concessions in the amount of $7
billion. China's written submissions show that this is a conservative estimate of the N/I China is
suffering.
I. CHINA'S PROPOSED METHODOLOGY IS A REASONABLE AND APPROPRIATE WAY TO
MEASURE THE N/I.
2. The mandate of the Arbitrator under Article 22.6 is to determine whether the level of
suspension requested by a complaining party is equivalent to its level of N/I. Based on past Article
22.6 decisions, the methodology proposed by the complaining party need only be reasonable and
equivalent. Rather, the non -complaining party bears the burden of proving that an alternative
calculation is more credible, verifiable, reasonable and equivalent.
3. In this proceeding, China has proposed the Arbitrator to use an econometric approach known
as "difference-in-differences" (DID) to estimate the value of Chinese imports "but for" the WTO -
inconsistent measures. This methodology compares the actual value of imports from China during
year 2017 with a representative group using a counterfactual based on the elimination of the WTO-
inconsistent measures. In this case, China used multiple alternative representative groups to show
that its overall conclusion about the level of N/I was reasonable, equivalent and robust.
A. The Appropriateness Of China's Counterfactual
4. China's counterfactual consists of the complete elimination of the WTO-inconsistent measures.
This counterfactual is in line with the treaty text and previous Article 22.6 DSU practice.
5. Article 3.7 of the DSU explicitly contemplates t he withdra wal of the measure as the first
objective of the dispute settlement mechanism in the absence of a mutually agreed solution.
Furthermore, the predominant practice under Article 22.6 has been to adopt the elimination of the
measure as the most appropriate counterfactual. This has been the case in 9 of the 11 Article 22.6
proceedings. The only two disputes where the Arbitrator adopted the modification of the measure -
instead of its withdrawal- present significant differences with the dispute at hand. In US – Gambling
(Article 22.6 – US), the Arbitrator took into account public policy concerns when choosing its
counterfactual. Similar concerns are not present in this dispute. The underlying circumstances of
US-Washing Machines (Article 22.6-US) are also distant. Specifically, US-Washing Machines (Article
22.6-US) concerned only 1 AD order, a few producers and a single product (in contrast with the
current dispute involving more than 100 AD orders, a vast number of exporters and multiple
products). Also, in US-Washing Machines (Article 22.6-US) a WTO-consistent margin dumping was
calculated during the administrative proceedings and communicated to the exporters (no similar
calculation exists in the present dispute). Further still, while in US-Washing Machines (Article 22.6-
US) the parties agreed as to the use of key underlying data and its reliability, the use of data is a
matter of much controversy and debate in this case.
6. There are multiple considerations that make China's counterfactual the most "reasonable" and
"plausible" in accordance with the requirements expressed in US – Gambling (Article 22.6 – US).
7. First, the counterfactual suggested by China provides legal certainty as it eliminates the
measures from a moment forward. This is a stable sol ution compared to the counterfactual
suggested by the United States (separate rates) which rests on the weak assumption that a
particular level of AD rate will continue to be applied in the future. The United States' proposal

however ignores the nature of its own retrospective system allowing for the modification of AD
margins in yearly AD reviews.
8. Second, China's proposed counterfactual ensures WTO -consistency at all stages. Under the
U.S. counterfactual both the AD rates resulting from the Article 22. 6 proceeding and the rates
resulting from administrative reviews are affected by WTO -inconsistency risks. This is all the more
troubling considering that China has identified four likely WTO-inconsistencies that would affect the
AD rates being proposed by the United States as benchmark AD rate to be used in the N/I calculation.
China considers that the Arbitrator should take into account the WTO -consistency issue of a
counterfactual to determine the reasonableness of the N/I calculation. At the same time, it will never
be "reasonable" for the Arbitrator to adopt a counterfactual that is fraught with multiple WTO -
inconsistencies. Other arbitrators have taken possible WTO-consistency into account.
9. Third, China's counterfactual provides a uniform solution , as the withdrawal applies in the
same manner to every AD order. In contrast, the U.S. proposed counterfactual is highly speculative
and complex as it involves different actions that the United States may or not adopt for each single
AD order.
10. Moreover, the counterfactual consisting of the withdrawal of the measure creates the proper
incentive to induce compliance with the Panel and Appellate Body findings. Within the context of the
present dispute, the Arbitrator has to take into consideration all relevant factors (Canada – Aircraft
Credits and Guarantees (Article 22.6 – Canada), para. 3.28.), including the nature of the violations
(use of the WA-T methodology; single rate presumption for a large number of AD proceedings) and
the continuous passivity of the United States. The United States could have made use of the
instruments that are available under the U.S. regulatory framework to bring its WTO -inconsistent
orders under compliance. However, it has not taken a single step in the more than 24 months that
have passed since the DSB recommendations and now ten months since the expiration of the RPT.
11. While acknowledging that the withdrawal of the measure would be the most appropriate
counterfactual, China believes that the only real alternatives for the Arbitrator are either (1) set the
dumping margins at 0.00%, or (2) use the suggested AD benchmark rates that China has proposed
in Exhibit CHN-53. We note that for 11 of the AD cases, the AD rates proposed by China in Exhibit
CHN-53 are the same as proposed by the United States. And for all other cases, China has proposed
a benchmark AD rate that the United States itself calculated in a previous phase of the AD case.
B. Appropriateness Of The DID Economic Model
12. China's DID methodology offers an accurate, reasonable, and conservative approach for
determining the level of trade that would have occurred in the absence of WTO -inconsistent
measures.
13. As a first step, China's DID methodology compares China's trade before WTO-inconsistent
duties were imposed with China's 2017 level of trade. Later, the methodology compares the change
in trade over the same period of time for a reasonable benchmark, which address the question of
how would trade have evolved "but for" the WTO-inconsistent AD orders. Finally, the methodology
compares the performance of China vis-à-vis the performance of the benchmark, which serves as a
basis for the N/I calculation.
14. In applying the DID methodology, China uses as a baseline a multi-year average of trade for
the period immediately preceding the imposition of AD duties. This multi -year average draws a
conservative estimation compared to the adoption of the "year prior" when imports can be at their
peak. The use of the period prior to th e imposition of the AD orders is essential for obtaining trade
volumes that are "untainted" by WTO -inconsistent measures. These levels are more accurate
compared to actual volumes in 2017, showing depressed levels at a height of 70% (or 99% in the
case of entities subject to the PRC-wide entity rate) because of the impact of the WTO-inconsistent
measures.
15. As to the remedy date, both parties agreed to use 2017 for which a full year data are available,
instead of 2018 which would have required annualization of partial year data. China used 2017 data
despite 2018 and 2019 data showing higher volumes and reflecting the growth in trade over time.

16. In order to determine its N/I calculation, China considered several alternative approaches in
construing the comparison group. Specifically, China considered (1) non-subject import suppliers for
the HS10 digit level products subject to the WTO-inconsistent AD duties and (2) all-import suppliers
(HS10) (including China for the purposes of completeness); (3) HS6 a ll suppliers; (4) HS4 all
suppliers (5) HS2 all suppliers. The last three benchmarks permitted the elimination of collateral
distortions caused by AD measures on specific products. The marginal variations between the
different approaches strongly support the verifiability, robustness and reliability of China's estimates.
17. In addition to this, China conducted alternative N/I estimates taking into account the impact
of CVD measures. To this end, China divided the cases assessed into three groups: (1) cases without
companion CVD measures; (2) cases with companion CVD measures where the CVD margin is
relatively large but the N/I is relatively small and (3) cases with companion CVD measures where
the margin is relatively large and the N/I estimate is relatively large. These separate scenarios avoid
the "double-counting" problem affecting the United States methodology and are in line with China's
conservative approach.
18. China applied its different perspectives (HS10, HS6, HS4, HS2 or with and without CVD) both
to the "as applied" and "as such" violations. For "as applied" violations China picked 13
representative cases out of the more than 100 AD WTO-inconsistent orders covering half of the trade
to the United States. Calculations at HS10 digit level (both at trade level and growth level) showed
averages between $10 billion and $7 billion. The estimations were confirmed at a more aggregated
level of trade (HS6, HS4 and HS2 ) with an average across all "as applied" estimates of $7,323
million.
19. China also calculated a N/I associated to the "as such" violation given that the United States
continues maintaining a "single rate presumption" contrary to the DSB recommendations . China
determined the N/I of "as such" violations based on 12 cases using the same methodology as the
"as applied" cases. The different approaches (HS 10, HS6, HS4, and HS2 with and without CVD)
showed averages ranging between $7,577 million to $4,571 million. Thus, summing the "as applied"
and "as such" estimations, the resulting N/I will always be over $10 billion even where the lowest
ranges of the two groups are considered.
20. Besides being conservative, China's methodology presents numerous advantag es. As an
illustration, the DID methodology is robust as to the duration of the duties, changes in the
competitive landscape (such as mergers and industry changes as well as other related follow -on
remedy actions) and common systematic shocks (e.g. exchang e rate shocks, a financial crisis, or
broad changes in U.S. protectionism).
21. Another advantage is that the different estimates and benchmarks offer the Arbitrator the
possibility to select the value it consider more reasonable. It is China's view that the most reasonable
option would be adopting the "average -of-averages" scenario. However, even if the Arbitrator
selected the lowest possible bound, the N/I will still be in excess of the $7 billion requested by China.
In any case, China's range of alternatives contrasts with the United States proposal which is based
in a single estimate for each precise case.
22. Moreover, China's approach is based on publicly available data easily verifiable and replicable.
China's approach utilizes official U.S. import st atistics published by the United States providing
import data for the very 10 -digit HS tariff codes. Both the USDOC itself and the USITC have used
these import statistics to present total values of the merchandise subject to the AD case. This can
be seen for instance in the USDOC "Fact Sheets" presenting the total import value affected by the
AD case. By contrast, the U.S. data are based on a mix of private (confidential) data (i.e. Census)
and public data. This is particularly reprehensible, considering th at the United States has specific
information and data for the quantity of imports by each and every single exporter under each of
the AD cases (and reviews).
23. In addition to this, China's proposed methodology anticipated and addressed all the concerns
raised by the United States about the methodology.
24. First, the United States insisted the Arbitrator impose some type of statistical significance test.
However, there are no previous Article 22.6 proceedings where the N/I calculations were subject to
such a significance test. Most recently, in US—Washing Machines (Article 22.6 – US) proceeding

neither party proposed a methodology that included tests of statistical significance. Likewise, in that
dispute the Arbitrator proposed a N/I method that did no t include any formal metrics of statistical
significance. Importantly, the United States has not provided evidence in the present dispute of
statistical significance in applying its own approach.
25. Second, the United States argued that China's results w ere not robust. Nevertheless, China
has presented ample proof of the robustness of its N/I approach through seven sets of benchmarks
(four estimates based on HS10 data, "with or without CVD"; and three estimates based on more
aggregated HS data). From the upper and lower bounds, each single scenario shows that the
requested $7 billion in countermeasures is a conservative request. In contrast, even if the U.S.
scenario is conceptually similar to China's methodology, its implementation presents important flaws
and mathematical mistakes. Also, the fact that the U.S. methodology is not subject to any robustness
checks exposes it to possible bias.
26. Third, the United States has criticised China for not using a regression approach in its N/I
methodology. Howeve r, China is not aware of any previous Article 22.6 proceeding where the
Arbitrator insisted on regression techniques as a basis for N/I estimates. Furthermore, China has
shown that its methodology produces exactly the same results as what would be produced under a
basic regression model. However, the fact that the tabular approach is easily implementable makes
it particularly attractive for this complex dispute. The dispute involves 100 AD orders, which is what
prompted China to focus on two dozen AD orders. Moreover, there are not HS10 digit level detailed
variables that can be used to predict trade patterns at product level for each country. Under these
circumstances, there is no sufficient data for a detailed analysis of specific products using a
regression technique as suggested by the United States. The fact that the United States itself does
not adopt such a detailed a regression approach in its own N/I evidences the complexities involved.
Indeed, the US' elasticity model is based on a handful (assumed) parameters and pieces of market
information producing predictions. The United States assumes perfect competition and ignores
market competitive conditions when running the model. Similarly, the formula approach adopted by
the United States is based on very little data.
27. Fourth, the United States condemns the lack of parallel trends, uniformity and stability of
China's model. These quibbles intend to obfuscate China's methodology but are not based on any
supporting facts or in any more verifiable, credible or equivalent alternative methodology. The United
States critiques ignore that China is not proposing any time series analyses in the methodology and
that parallel trends are more discussed in regression techniques. In addition, China's meta-analysis
of different scenarios washes out minor differences across multiple specifications. Also, the critiques
as to changes of the product scope of HS codes are innocuous in China's methodology, but to the
contrary, the variable HS codes would sustain the robustness of China's methodology.
28. Besides, much of the United States criticism confirms that China's estimation of N/I is
conservative. An example of this can be found in the United States insistence that China's trade was
growing faster than other countries. However, China's N/I approach understates China's 2017 trade
as it considers China's trade flows to follow the overall market average.
C. The Ability Of China's DID Methodology To Reflect PRC-Wide Entity Volume
Only And Changing AD Rates
29. China fully believes that its initially proposed methodology is reasonable for calculating N-I for
the AD cases at issue. However, should the Arbitrator desire to adopt the U.S. prosed limitations,
China's proposed DID methodology can easily be adapted to do so. Spe cifically, China's proposed
DID methodology can easily be adapted (a) to limit the N/I calculation only to PRC-wide entity import
volume and (b) to reflect changes in AD rates, rather than complete withdrawal of the measure.
China has presented the Arbitra tor an analytical framework that allows one to adjust the DID N/I
estimates to incorporate (a) and (b).
30. China has provided the Arbitrator with a revised N/I calculation that adopts both of these
adjustments. Concerning limiting the N -I calculation only to PRC-wide entity imports, China note
that it has adopted the very PRC -wide entity share of total China imports set forth by the United
States (in Exhibit USA -54), even though China believes that the PRC -wide entity shares proposed
by the United States are understated. Using the US's proposed PRC-wide entity shares China revised

N/I estimate is $5.6 billion (a figure which China believes understates the actual N/I due to the flaws
in the US's submission).
31. And concerning the changing AD rates, China no tes that it agrees with the United States on
many of the benchmark AD rates that should be used and for many others the China benchmark AD
rate that China proposes reflects a past AD margin calculated by the USDOC itself. (See Exhibit
CHN-53 and Exhibit CHN-57 (as corrected by China's 13 June 2019 letter). Adjusting its estimates
for changing AD rates, rather than removal, China's revised N/I estimate is $12 billion, well above
the $7 billion requested.
32. In short, China's proposed DID methodology can easily be adapted to reflect the two primary
concerns of the United States; namely, limiting the N/I calculation to PRC -wide entity volume only
and utilizing changing AD rates rather than complete withdrawal.
II. THE U.S. METHODOLOGY SUFFERS FROM SERIOUS FLAWS, AND MUST BE REJECTED
A. U.S. Proposed N/I Calculation Approaches Are Premised On Using USDOC
AD Determinations That Are WTO-Inconsistent.
33. The United States' assumption is that it could remedy the use of the WTO -inconsistent PRC-
wide rate simply by switching the PRC-wide entity AD rate to the "all others rates". This approach,
however, ignores that the "all others" AD rates for 2017 being used are, in fact, infected by multiple
WTO-inconsistencies.

34. First, the United States is aggressively appl ying "facts available" to many of the AD cases
involving China. China has shown that at least eight of the AD orders under dispute involved an
analysis inconsistent with Article 6.8 and Annex II of the Anti -Dumping Agreement for determining
the underlying individual-company AD rates used by the USDOC to calculate the "all others" AD rate
for 2017 imports.
35. Second, the Unites States has incurred improper double counting of AD and CVD duties in at
least 15 of the AD cases under dispute, thus infringing Article 19.3 of the SCM Agreement.
36. Third, the United States has engaged in differential pricing practices in more than 13 AD cases
under dispute in violation of the second sentence of Article 2.4.2 of the Anti-Dumping Agreement.
37. Fourth, the United S tates has improperly applied "zeroing" in at least five of the cases in
contravention of Article 9.3 of the Anti -Dumping Agreement. This practice has been found by the
DSB to be WTO-inconsistent (US – Zeroing (Japan), US – Stainless Steel (Mexico).)
38. Collectively these four legal theories alone apply to 22 of the 24 cases at issue, representing
virtually all of the N/I calculated by either China or the United States. These are the most obvious
WTO-inconsistencies. However China does not dismiss the possibility that a closer scrutiny on what
the U.S. would actually do in the future could reveal further WTO violations.
B. U.S. Proposed N/I Calculation Approaches Have Serious Methodological
Flaws
39. Unlike China's use of a single, consistently applie d methodology, the United States has
presented a mixture of different approaches. Both the "elasticities approach" and the "formula -
based" methodologies used for the single rate presumption have serious flaws. And the United
States then compounds these flaws when it turns to yet another approach to address zeroing.
40. The "elasticity" approach used for 17 cases is deeply flawed. The United States starts with a
tiny trade value for 2017 reflecting a severely trade -distorting effect of the WTO -inconsistent AD
duties. Indeed, in US-Washing Machines (Article 22.6 -US), the Arbitrator rejected the approach
proposed by the United States of adopting the actual and depressed level of trade. In these 17 AD
cases the Chinese imports have been driven out of the mark et because of the effects of the WTO -
inconsistent measures. However, the elasticity model does not predict the reinstatement of the
imports to previous levels, but produces a very small change in the trade estimates as a result from
the suppliers starting again from near zero levels.

41. Moreover, the United States does not establish a set of elasticities. For about half of the
required elasticities the United States just asserts a value with no documentation or backup (with
no distinction between import supply elasticity from subject China, non-subject China and all foreign
sources). This contrasts with the practice of the USITC which runs its models on a range of elasticities
in its injury investigations and never reports a single estimate. It is important to note that outcomes
can vary drastically with relatively small changes in specific elasticities. In fact, elasticity models are
not appropriate in cases with large AD duties and an estimated large reduction (in some cases of up
to 100% and on an average of 72.9% for all cases assessed). The greater the reduction is, the less
likely that the model will predict realistic trends in trade.
42. The United States further does not explain how it reaches these values for elasticities and
neither does it provid e sufficient data to replicate the results. Even worse, these older elasticities
are inappropriately applied to heavily distorted 2017 market conditions. Other flaws on the elasticity
model include reliance on inconsistent key data inputs, (including sales data), arbitrary adjustments
and uncertainty of certain data (e.g. domestic shipments).
43. As to the "formula-based" approach applied to 5 of the cases, the United States asserts that
the "elasticity" approach is not reliable when PRC-wide entity market shares are below 1%. However,
the United States does not support this cutoff with any factual or scientific background.
44. The U.S. formula is premised on the wrong factual assumption: the application of the historic
share of total imports for the PRC -wide entity is calculated by using import data from the original
investigation. This approach does not take account of the fact that the USDOC revoked the original
separate rate status of many Chinese exporters included under the PRC -wide rate in subsequent
reviews. As a result, the calculation of the N/I is underestimated.
45. Also, the "formula based" methodology incorrectly determines the total volume of 2017
imports from China absent the WTO -inconsistent measures. According to the U.S. formula,
compliance would not change the total value of imports from China. Under the United States' view,
compliance would simply mean reallocating trade from one set of Chinese firms to others with no
net increase in trade from China. This formula brings a biased downward result that omits any harm
China has suffered from the United States' WTO-inconsistent policy in certain cases for more than a
decade.
46. The U.S. approach for addressing zeroing in Coated Paper is also mistaken. At the outset, the
United States recognizes that without zeroing the AD rate would have been negligible [[***]] and
that an AD order would not have been imposed. Nevertheless, the United State ignores its own
assertion when calculating the level of N/I by adopting an approach that examines the difference in
trade volume during 2017 between the imposition of 7.62% and an AD rate of zero. The United
States adopts an untenable assumption that APP's 2017 import level would not have changed had
the United States correctly not imposed any AD duty order o n APP China's U.S. exports from the
start. Additionally, the United States ignores that a reduction in AD duty rate is simply not the same
as termination of the AD order. Under the U.S. system, the uncertainty of any AD order and the
need to go through annual administrative reviews each year imposed a burden on the exporter and
creates uncertainty about future trade flows.
47. Finally, the U.S. claim that it may calculate N/I that is zero for two AD orders ( Corrosion-
Resistant Steel and Diamond Sawblades) must be rejected because (i) the mere maintenance of a
AD order would cause an "as such" violation which is presumed to carry certain level of N/I in
accordance with WTO jurisprudence (US— 1916 Act (Article 22.6 (EC)) and (ii) even where the N/I
could be zero and was not - the United States has not met its burden of proof demonstrating that
the N/I was actually zero.
C. U.S. Failed To Provide Sufficient Data And Explanations To Allow Proper
Assessment And Replication
48. The U.S. methodology is based on the use of non-public data, which makes its replicability
impossible. Among the most troubling examples of this is the use of confidential import values of
"subject merchandise for 2017", since these values constitute the core for quantification under the
U.S. approach.

49. Another piece of relevant information that can neither be verified by China or the Arbitrator is
the amount of trade by the PRC -wide entity, and its entire underlying classification system (i.e., is
a particular firm a PRC -wide entity or not?). This data was provided only at the very end of the
proceeding, far too late for China to have any reasonable chance to verify the data.
50. What is perplexing is that the United States possesses this information and routinely provides
such information in every AD review for the purpose of mandatory respondent selection. Thus the
United States could have provided verifiable back-up data allowing China and the Arbitrator to check
any possible mistakes in the compilation exercise. Instead, the United States has chosen to provide
information that is not available from any public source.

51. The above contrasts with Article 22.6 practice (e.g. EC – Bananas III (Article 22.6 – EC) and
USDOC preference (e.g. Warmwater Shrimp from China) to use publicly available information as it
is more credible, factual and verifiable.
D. The United States Has Not Met Its Burden Of Proof
52. In an Article 22.6 proceeding, the non -complying party has the burden of proving that the
requested countermeasures are not equivalent to the level of N/I. In doing so, the non -complying
party should present a more reasonable methodology. Where both N/I calculation approaches are
equally reasonable, the Arbitrator must rule in favor of the requesting party ( EC – Hormones (US)
(Article 22.6 – EC).
53. The United States has not shown that the level of countermeasures proposed by China is not
equivalent to the level of N/I. In addition, the United States has not presented reasoned estimates
that rely on credible, verifiable and fact-specific information. As a result, the United States has not
met its burden of proof for an alternative calculation of N/I.
III. THE TWO-STEP METHODOLOGY FROM US—WASHING MACHINES (ARTICLE 22.6-US)
ALSO HAS FLAWS, BUT MAKES MORE SENSE THAN THE U.S. METHODOLOGY
54. In addition to all the adjustments proposed, China has cooperated with the Arbitrator in
exploring the option of adapting the two -step methodology used in US-Washing Machines (Article
22.6 -US) to the present dispute.
55. China continues to believe that its proposed DID methodology is more appropriate because it
can easily cover all cases, and can be adapted to address concerns about focusing on only the PRC-
wide entity trade and focusing on the change in the AD margins. But unlike the United States, China
has provided the Arbitrator with sufficient data to apply the alternative two-step approach for 19 of
24 cases (18 of which from public sources and other available information on the case Large
Residential Washers.).
A. Reasons Why The Two-Step Methodology Is Less Appropriate For This
Specific Dispute.
56. There are many reasons why the US-Washing Machines (Article 22.6-US) two-step approach
cannot be appropriately applied to the present proceeding.
57. In the first place, the N/I metho d used in US-Washing Machines requires the Arbitrator to
have specific credible data about total market size both for the year prior to the order (which varies)
and the remedy period (2017). In the U.S.'s methodology, such data do not even exist for some o f
the WTO-inconsistent measures. Moreover, the data provided by the United States are in many
cases overly broad or even confidential. This is in contrast with US-Washing Machines where both
Korea and United States agreed on some of the data inputs for the model (e.g., AHAM data used to
estimate the total market size). China's DID methodology is more appropriate because it is less
data intensive.
58. Further, the US-Washing Machines (Article 22.6 -US) model requires specific data on the
market share of those Chinese exporters who exported to the United States in the year prior to the
AD case, but were part of the PRC-wide entity in 2017. The United States has only provided part of
the required data following its oral statement and in many cases are subject to confidentiality. This

was not the situation in US-Washing Machines (Article 22.6 -US) where both parties had access to
the same information.
59. Additionally, elasticity models unreliably capture the impact of duties and duty rate changes
of the magnitudes observed in the dispute. In US-Washing Machines (Article 22.6 -US), the WTO-
inconsistent duty was approximately 11% and the remedy involved partial removal by percentage
points. The present dispute involves hundreds of AD rates ranging from modest levels to over 200
percentage points with possible adjustments of similar magnitude. Accordingly, the accuracy of
elasticity measures is paramount. China's DID methodology does not depend on accurate estimates
of elasticities.
60. Also, it is particularly diffi cult to incorporate the maintenance of the WTO -inconsistent
measures over time in the two-step methodology. More than a dozen of the 24 cases assessed had
WTO-inconsistent duties in place for more than a decade and Armington -style elasticity models
capture only the short -term impact of duties. As noted aove, China's DID methodology does not
depend on accurate estimates of elasticities.
61. On the top of that, there are multiple uncertainties that would affect the implementation of
the two-step approach, namely (i) at which level will the AD be adjusted; (ii) the potential WTO -
inconsistency of the AD rate; and (iii) the change in the exporter's status and its integration under
the PRC-wide entity. Due to these uncertainties the two -step approach is inadequat e under the
circumstances
B. If The Two-Step Approach Is Applied
62. However, notwithstanding these uncertainties if the Arbitrator decides to use the two -step
approach of US-Washing Machines (Article 22.6 -US), China would note the following. First, it is
important to be very clear about what that methodology actually involved. To clarify, China has
reviewed the computer programming code and would summarize those steps as follows:
63. Step 1: Identify the composition of the PRC-wide entity in 2017. Identification is determined by
the producers' or exporters' status, not by whether or not the producer or exporter shipped any
subject product in 2017.
64. Step 2: Identify, for the year preceding the imposition of the relevant AD duties, the value of
imports from the producers or exporters that were included in the entity in 2017, i.e. the PRC -
wide entity as composed in 2017. This should not be based on 2017 trade values.
65. Step 3: On that basis, find the market share of the PRC -wide entity (as defined by PRC -wide
status in 2017) in the year preceding the imposition of the relevant AD duties. In the same way,
calculate the market shares for the year preceding the imposition of the relevant AD duties for
all other market participates, namely: domestic shipments, imports from the rest of China, and
imports from the rest of the world.
66. Step 4: Using the market shares as calculated in step (3) apply the Armington -based model to
calculate the market shares of the PRC-wide entity (as defined by PRC-wide status in 2017) as
well as the other three sources, following the imposition of the WTO inconsistent AD duties
This step will produce the Armington model's short -run impact of the WTO inconsistent AD
duties.
67. Step 5: Using the market share data as calculated in step (4), re-run the Armington-based model
to calculate the market shares of the PRC -wide entity (as defined by PRC-wide status in 2017)
as well as the other three sources, assuming the WTO inconsistent AD duties (as applied to the
PRC-wide entity) are replace by WTO consistent AD duties.
68. Step 6: Calculate the difference in market share for the PRC-wide as calculated in step (5) with
the market share for the PRC-wide entity as calculated in step (4).
69. Step 7: Using a measure of the total market size for 2017, apply the difference in market shares
calculated in step (6) to calculate the short-run loss in trade to China due to the US application

of WTO inconsistent AD measures. This final step requires multiplying the difference in market
shares (step 6) by the size of total market. The most logical basis for the market size is the
remedy year, which in this dispute is 2017. If accurate data for overall market size is not
available for the remedy year, the Arbitrator could use market size in a prior year (adjusted for,
say, GDP growth).
This step will produce the N/I for the case.
70. China has provided the necessary information to the Arbitrator from public sources for
implementing the two -step approach in the case at hand. In this regard, China has been more
forthcoming with the Arbitrator and more willing to provide the necessary data than the United
States.
71. In addition, China has a number of observations in relation to the implementation of its
proposed methodology.
72. Particularly, China considers that the Arbitrator must reject distorted trade values of 2017 for
both the total volume of China trade and trade held by the PRC-wide entity. The 2017 trade volume
figures are significantly depressed because of the maintenance of WTO -inconsistent measures
spanning over more than a decade. In previous Article 22.6 disputes, Arbitrators have refused to
use parameters distorted by WTO -inconsistent measures (US-Washing Machines (Article 22.6 -US)
73. In the light of this, it is preferable for the Arbitrator to use a reasonable estimate based on
the data for "year prior", which is not affected by WTO-inconsistencies. China provided public "year
prior" data (total market size, US domestic shipments and all other imports) included in USITC injury
reports for 18 cases. In addition, China submitted other available information on the case Large
Residential Washers.
74. As to the market share held by the PRC -wide entity, the Arbitrator could use the percentage
for the year prior to the AD measures. This percentage is conservative as it understates the true
share of Chinese exporters that are part of the PRC -wide entity rate in 2017. The Arbitrator can
determine the PRC-wide entity share in the year prior through (a) total imports from China of subject
merchandise (as presented by China both in the HS code data for "year prior" in every single case
or in the USITC injury reports) and (b) through the best estimate of the PRC -wide entity share of
imports (as presented by United States in Exhibit USA -54). As to the information provided by the
United States, China disagrees with distinguishing between Group 3 and Group 4 exporters as no
evidentiary justification supports this contrived separation within the PRC-wide entity import volume.
75. For the total size of the U.S. market, the Arbitrator could use the data on the size of the
market for the year prior to the AD measures adjusted using U.S. GDP growth. China has strongly
recommended rejecting the problematic U.S. data which resorts in a variety of ad hoc unverifiable
sources and extrapolations (including the combination of private data and aggregated SEC financial
reports).
76. As to the elasticities, China suggested using the mi dpoint of N/I estimates included in the
USITC reports instead of a midpoint elasticities as proposed by the United States. The Armington
model is highly sensitive to elasticities, which makes it necessary to include the high and low end of
elasticity estimates in order to avoid distorting the N/I.
77. Finally, as regards the N/I calculation, China provided the Arbitrator specific rates that could
be used, and agreeing with the rates suggested by the United States for 11 out of 24 cases.
IV. DESPITE THE REMOVAL OF THE AD ORDER ON OTR TIRES, THE ARBITRATOR SHOULD
CALCULATE A N/I FOR THE PERIOD IT WAS IN PLACE FOLLOWING THE EXPIRY OF THE
IMPLEMENTATION PERIOD.
78. In the case at hand, the United States had not withdrawn the inconsistent measures contained
in OTR Tires by August 2018 – the end of reasonable period of time established by the Article 21.3(c)
Arbitration. On the contrary, the measures remained effective for six additional months – until
February 2019, covering most of the duration of the Article 22.6 of DSU proceeding.

79. China's considers that imposing a level of N/I on OTR Tires for the period it was in place after
the expiry of the implementation period is particularly important for inducing compliance in this case.
Conclusion
80. China has presented a methodology which is sound, supported by academic and scientific
background and which is based on a counterfactual that is in line with prior Article 2 2.6 practice.
The most conservative minimum estimate for each benchmark and alternative adjustments totals
$8 billion.
81. The United States has not met its burden of proving that China's requested countermeasures
do not equal the level of N/I by presenting a more reasonable and verifiable alternative. Further, in
the view of the lack of any action shown by the United States in the 24 months that passed since
the adoption of the DSB recommendations, the Arbitrator should approach the United States'
methodology sceptically; bearing in mind that it is based on mere hypotheticals and speculations
about what might be done and that remain fraught with WTO-inconsistencies.
82. In conclusion, China notes that its requested N/I of $7 billion is conservative and reasonable.

ANNEX C
PROCEDURAL RULING OF THE ARBITRATOR
Contents Page
Annex C-1 Procedural Ruling on the United States' Request to Partially Open the
Arbitrator's Meeting to Public Observation
34

ANNEX C-1
PROCEDURAL RULING ON THE UNITED STATES' REQUEST TO PARTIALLY OPEN THE
ARBITRATOR'S MEETING TO PUBLIC OBSERVATION
1 INTRODUCTION
1.1. The United States requests the Arbitrator to partially open the meeting with the parties in this
proceeding, by adopting "procedures that allow WTO Members and the public to observe U.S.
statements during the arbitration meeting ."1 The United States makes this request after China
opposed the United States' request to fully open the meeting in this proceeding. China also disagrees
with the United States' request to partially open the meeting.2 Below, we set out the main arguments
of the parties, followed by our analysis and ruling on the United States' request.
2 MAIN ARGUMENTS OF THE PARTIES
2.1. The United States contends that opening the Arbitrator's meeting with the parties would
enhance transparency of WTO dispute settlement proceedings and heighten confidence in the WTO.3
The United States substantiates its request by relying on the second sentence of Article 18.2 of the
DSU, which allows parties to a dispute to disclose "statements of its own positions to the public". 4
In addition, the United States contends that the DSU does not require an Arbitrator to close its
meeting in proce edings under Article 22.6 of the DSU. 5 Further, the United States relies on the
Arbitrator's statement in US – Tuna II (Mexico) (Article 22.6 – US) that "due process requires that
'all parties must be given the opportunity to lift the confidentiality of st atements of their own
positions at partially open meetings.'"6
2.2. China, for its part, relies on the language of the first sentence of Article 18.2 of the DSU, which
states that submissions shall remain confidential.7 In China's view, this obligation concerns not only
written submissions, but also extends to "proceedings to discuss those submissions". 8 China also
points to the panel working procedures contained in Appendix 3 to the DSU, which in paragraph 3
refer to the confidentiality of the deliberatio ns and submitted documents, and in paragraph 2 refer
to the panel meeting in closed session. 9 Seen in that context, Article 18.2 of the DSU cannot,
according to China, provide a basis to force a partially open meeting over China's objection.10
2.3. China submits that confidentiality of statements is particularly appropriate in Article 22.6
proceedings, which involve very technical economic and legal issues. 11 In China's view, having a
closed meeting would not prevent the United States from making public st atements of its own
positions in line with the second sentence of Article 18.2 of the DSU. 12 To that end, China argues
that the transparency objective invoked by the United States could be achieved through publication
of the Arbitrator's decision together with the executive summaries of the parties' arguments.13

1 United States' comments on the Arbitrator's draft timetable and Working Procedures, p. 4; and
comments on China's comments on the Arbitrator's draft timetable and Working Procedures, pp. 3-4.
2 China's comments on the Arbitrator's draft timetable and Working Procedures, pp. 4-5; and comments
on the United States' comments on the Arbitrator's draft timetable and Working Procedures, pp. 1-3.
3 United States' comments on the Arbitrator's draft timetable and Working Procedures, pp. 3-4.
4 United States' comments on the Arbitrator's draft timetable and Working Procedures, p. 4.
5 United States' comments on China's comments on the Arbitrator's draft timetable and Working
Procedures, p. 3.
6 United States' comments on the Arbitrator's draft timetable and Working Procedures, p. 4 (quoting
Decision by the Arbitrator, US – Tuna II (Mexico) (Article 22.6 – US), para. 2.26).
7 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.
8 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.
9 China's comments on the United States' comments on the Arbitrator's draft timetable and Working
Procedures, p. 2.
10 China's comments on the United States' comments on the Arbitrator's draft timetable and Working
Procedures, p. 3.
11 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.
12 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.
13 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.

3 ANALYSIS BY THE ARBITRATOR
3.1. Pursuant to paragraph 2 of the working procedures contained in Appendix 3 to the DSU, panels
by default meet in "closed session". However, Article 12.1 of the DSU provides that "[p]anels shall
follow the Working Procedures in Appendix 3 unless the panel decides otherwise after consulting the
parties to the dispute." WTO adjudicators, therefore, enjoy some discretion in establishing their own
working procedures. How ever, this discretion "does not extend to modifying the substantive
provisions of the DSU" 14, and therefore cannot be exercised in a manner that is inconsistent with
those provisions.
3.2. In this case, the United States argues that providing for a partia lly open meeting would serve
to facilitate the United States' right under Article 18.2 of the DSU to disclose statements of its own
positions to the public.15 China disagrees, and invokes its right to confidentiality under Article 18.2.
The parties thus have differing views on the scope of the obligation to protect confidential information
under Article 18.2.16
3.3. We observe that although Article 18.2 of the DSU authorizes a party to a dispute to disclose
statements of its own positions to the public, n othing in the DSU provides that this right must be
exercised through the holding of fully or partially open meetings, especially when the parties
disagree on the matter.17 We do not consider that a WTO adjudicator that declined a party's request
to hold partially open meetings would be depriving that party of its rights under Article 18.2 or under
any other provisions of the DSU. There are other ways in which parties can make statements of their
positions public: for example, some WTO Members post their sub missions and the written versions
of their statements at WTO dispute settlement meetings on the internet.18 Therefore, it is within our
discretion to grant or deny the United States' request.
3.4. When faced with requests to exercise their discretion to partially open their meetings to public
observation, WTO adjudicators have taken into account a number of considerations in determining
whether partially open meetings would be appropriate in the specific circumstances.19 In exercising
our discretion, we ha ve carefully considered the competing interests of the parties as well as the
need for prompt settlement of this dispute. In this context, we take into account that, to safeguard
China's right to maintain the confidentiality of its statements and the busin ess confidential
information submitted in this proceeding, the partial opening of our meeting would call for the
adoption and implementation of complex working procedures, which would require the participation
of both parties and may affect our ability to issue a timely decision. We have also taken into account
that with the exception of three proceedings, all in the same dispute 20, WTO adjudicators have
declined to fully or partially open substantive meetings for public viewing where one party was not
in agreement.21 In the current proceeding, we consider that the disagreement between the parties
on the proposal to partially open the meeting, as well as the parties' conflicting views on the scope
of the obligation to protect confidential information in the context of a partially open meeting, give
rise to concerns that counsel against holding a partially open meeting.

14 Appellate Body Report, India – Patents (US), para. 92.
15 See above para. 2.1.
16 See above paras. 2.2-2.3.
17 This view has been consistently affirmed in prior WTO dispute settlement proceedings. (See, e.g.
Decision by the Arbitrator, US – Gambling (Article 22.6 – US), para 2.29; and Appellate Body Report, EU –
Biodiesel (Argentina), Annex D-2, paras. 6-7.
18 See, e.g. Panel Reports, US – OCTG (Korea), Annex E-1, para. 3.4; and US – Upland Cotton (Article
21.5 – Brazil), para. 8.20.
19 For example, the arbitrator in US – Tuna II (Mexico) (Article 22.6 – US) identified four factors that
guide the evaluation of whether to grant a request to partially open a meeting: "(a) a non-disclosing party's
right to confidentiality protection of statements of its own position, (b) due process, (c) the prompt settlement
of disputes, or (d) the careful and efficient discharge, or the integrity, of the adjudicative function." (Decision
by the Arbitrator, US – Tuna II (Mexico) (Article 22.6 – US), para. 2.31).
20 Panel Reports, US – Tuna II (Mexico) (Article 21.5 – US) / US – Tuna II (Mexico) (Article 21.5 –
Mexico II), paras. 7.16-7.34; and Decision by the Arbitrator, US – Tuna II (Mexico) (Article 22.6 – US),
paras. 2.17-2.34.
21 See, e.g. Appellate Body Report, EU – Biodiesel (Argentina), Annex D-2, paras. 6-7; Panel Reports,
US – Upland Cotton (Article 21.5 – Brazil), para. 8.20, and US – OCTG (Korea), Annex E-1, paras. 3.1-3.4 and
fn 1; and Decision by the Arbitrator, US – Gambling (Article 22.6 – US), para. 2.29.

4 CONCLUSION
4.1. Based on the reasons set out above, we deny the United States' request to partially open our
meeting with the parties to public observation.

ANNEX D
GRAPHICAL ILLUSTRATIONS AND FIGURES CONCERNING THE PARTIES' PROPOSED CALCULATION
METHODOLOGIES
Contents Page
Annex D-1 China's proposed DID tabular approach: Graphical illustrations of the failure
to meet the parallel trends assumption provided by the United States
38
Annex D-2 United States' proposed Armington model: Relationship between the change
in the market share of Chinese exporters within the PRC -wide entity and the
duration of the anti-dumping orders
39
Annex D-3 United States' proposed Armington model: Relationship be tween the change
in the market share of Chinese exporters within the PRC -wide entity and the
level of the WTO-inconsistent PRC-wide duty rates
40

ANNEX D-1
CHINA'S PROPOSED DID TABULAR APPROACH: GRAPHICAL ILLUSTRATIONS OF THE FAILURE
TO MEET THE PARALLEL TRENDS ASSUMPTION PROVIDED BY THE UNITED STATES

ANNEX D-2
UNITED STATES' PROPOSED ARMINGTON MODEL: RELATIONSHIP BETWEEN THE CHANGE IN THE
MARKET SHARE OF CHINESE EXPORTERS WITHIN THE PRC-WIDE ENTITY AND THE DURATION OF
THE ANTI-DUMPING ORDERS

-100.000%
-99.000%
-98.000%
-97.000%
-96.000%
-95.000%
-94.000%
-93.000%
0 2 4 6 8 10 12 14 16
Percentage change of the market share of
Chinese exporters within the PRC-wide entity
Number of years between the year prior to the imposition of the anti-dumping order and 2017

ANNEX D-3
UNITED STATES' PROPOSED ARMINGTON MODEL: RELATIONSHIP BETWEEN THE CHANGE IN THE
MARKET SHARE OF CHINESE EXPORTERS WITHIN THE PRC-WIDE ENTITY AND THE LEVEL OF THE
WTO-INCONSISTENT PRC-WIDE DUTY RATES

ANNEX E
DATA INPUTS AND CALCULATIONS OF THE ARBITRATOR
Contents Page
Annex E-1 Data inputs for US market values in the year prior to the imposition of the
anti-dumping orders 42
Annex E-2 Data inputs for the share of US imports from China covered by different
Chinese exporters in the year prior to the imposition of the anti -dumping
orders
49
Annex E-3 List of Chinese exporters outside the PRC -wide entity used to estimate the
share of different Chinese exporters for six anti-dumping orders 57
Annex E-4 List of Chinese exporters subject to the WA-T duty rates and other Chinese
exporters outside the PRC-wide entity used to estimate the share of different
Chinese exporters for three anti-dumping orders
70
Annex E-5 Data inputs for elasticities 74
Annex E-6 Data inputs for the actual anti-dumping duty rates 76
Annex E-7 List of anti-dumping duty rates used for two anti-dumping orders 81
Annex E-8 Data inputs for US market values in 2017 85
Annex E-9 Code and text version of the Armington model 91
Annex E-10 Data inputs used to implement the Armington model under the two steps 96
Annex E-11 Results of implementing the Armington model under the first step 99

ANNEX E-1
DATA INPUTS FOR US MARKET VALUES IN THE YEAR PRIOR TO THE IMPOSITION OF THE ANTI-DUMPING ORDERS
Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Aluminum Extrusions 2010 4,606,386 3,557,906 537,498 510,982 All data from USITC publication 4677.
Bags 2003 995,491 772,295 [[***]] [[***]] Data on the value of US shipments from
USITC publication 3710. Aggregated value of
US imports from China based on company-
specific data from US Customs (Exhibit
USA-94 (BCI)). Value of US imports from the
rest of the world estimated by subtracting
the value of US imports from China, based on
data from US Customs (Exhibit USA-94
(BCI)), from the total value of US imports
reported in USITC publication 3710.
Coated Paper 2009 1,742,204 1,023,688 297,527 420,989 All data from USITC publication 4192.
Diamond Sawblades 2009 [[***]] 73,000 [[***]] 63,300 Value of US shipments provided by the
United States based on adjusted data from
USITC publication 4559 (Exhibit USA-58).
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).

1 The value of the total US market is obtained by adding the value of US shipments, the value of US imports from China, and the value of US imports from the
rest of the world.

Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Furniture 2003 4,666,667 1,878,740 [[***]] [[***]] Data on the value of US shipments from
USITC publication 3743. Aggregated value of
US imports from China based on company-
specific data from US Customs (Exhibit USA-
94 (BCI)). Value of US imports from the rest
of the world estimated by subtracting the
value of US imports from China, based on
data from US Customs (Exhibit USA-94
(BCI)), from the total value of US imports
reported in USITC publication 3743.
OCTG 2009 [[***]] 1,844,564 [[***]] 1,338,100 Annualized value of US shipments based on
data from USITC publication 4124.
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).
OTR Tires 2007 1,794,409 1,006,044 282,390 505,975 All data from USITC publication 4031.
PET Film 2007 [[***]] 1,157,356 [[***]] 259,200 Annualized value of US shipments based on
data from USITC publication 3962.
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).

Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Ribbons 2009 650,438 580,172 [[***]] [[***]] Value of US shipments provided by the
United States based on adjusted data from
the US Census Bureau's Annual Survey of
Manufactures and USITC DataWeb (Exhibit
USA-58). Aggregated value of US imports
from China based on company-specific data
from US Customs (Exhibit USA-94 (BCI)).
Value of US imports from the rest of the
world estimated by subtracting the value of
US imports from China, based on data from
US Customs (Exhibit-94 (BCI)), from the
total value of US imports reported in USITC
publication 4634.
Shrimp 2004 [[***]] 407,484 [[***]] 3,249,100 Annualized value of US shipments based on
data from USITC publication 3748.2
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).
Solar Panels 2011 [[***]] 804,853 [[***]] 2,748,200 Data on the value of US shipments from
USITC publication 4360. Aggregated value of
US imports from China based on company-
specific data from US Customs (Exhibit
USA-94 (BCI)). Value of US imports from the
rest of the world based on HTS aggregated
data from the US Census Bureau (Exhibit
USA-57).

2 China proposes to annualize the value of USD 12,434,000 of US shipments of selected US processors from USITC publication 3748 for January to June 2004
(USITC publication 3748, Table C-3). However, we note that according to the USITC report, this value excludes data for previously excluded, targeted related parties.
For consistency, we use the annualized value of USD 407,484,000 of US shipments from USITC publication 3748 (USITC publication 3748, Table C-1).

Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Steel Cylinders 2011 [[***]] 87,675 [[***]] 3,800 Value of US shipments provided by the
United States based on data from the annual
report by the only US producer, TriMas
Corporation (Exhibit USA-58). Aggregated
value of US imports from China based on
company-specific data from US Customs
(Exhibit USA-94 (BCI)). Value of US imports
from the rest of the world based on HTS
aggregated data from the US Census Bureau
(Exhibit USA-57).
Wood Flooring 2010 783,896 341,130 326,981 115,785 All data from USITC publication 4970.
Copper Pipe and Tube 2009 2,110,170 1,602,849 244,101 263,220 All data from USITC publication 4193.
Iron Pipe Fittings 2002 [[***]] 276,200 [[***]] 43,900 Value of US shipments based on data from
the US Census Bureau's Annual Survey of
Manufactures and USITC DataWeb adjusted
by the United States (Exhibit USA-58).
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).
Passenger Vehicle and
Light Truck Tires
2014 22,154,265 11,740,621 2,561,898 7,851,746 All data from USITC publication 4545.

Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Residential Washers 2016 [[***]] [[***]] [[***]] 639,000 Value of US shipments estimated by
subtracting the value of US imports, based
on data from US Customs (Exhibit USA-94
(BCI)) and data from the US Census Bureau
(Exhibit USA-57), from the total value of the
US market, based on data from the
Association of Home Appliance Manufacturers
(Exhibit CHN-56 (BCI)). Aggregated value of
US imports from China based on data from
US Customs (Exhibit USA-94(BCI)). Value of
US imports from the rest of the world based
on HTS aggregated data from the US Census
Bureau (Exhibit USA-57).
Sheet and Strip 2016 [[***]] 2,998,837 [[***]] 757,300 Annualized value of US shipments based on
data from USITC publication 4676.
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94(BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).
Steel Flat Products 2015 8,405,722 6,794,385 295,705 1,315,632 All data from USITC publication 4619.
Steel Line Pipe 2008 [[***]] 1,065,369 [[***]] 582,400 Annualized value of US shipments based on
data from USITC publication 4055.3
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Value of US
imports from the rest of the world based on
HTS aggregated data from the US Census
Bureau (Exhibit USA-57).

3 We note that, although 2008 is the year prior to the imposition of the anti-dumping order, China proposes to use data on the value of US shipments in 2007
reported in USITC publication 4055 (Exhibit CHN-55 (BCI)). We consider this an inadvertent error and instead annualize the value of US shipments for January to
September 2008 reported in USITC publication 4055.

Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Steel Nails 2007 984,270 220,411 [[***]] [[***]] Data on the value of US shipments from
USITC publication 4022. Aggregated value of
US imports from China based on company-
specific data from US Customs (Exhibit USA-
94 (BCI)). Value of US imports from the rest
of the world estimated by subtracting the
value of US imports from China, based on
data from US Customs (Exhibit USA-94
(BCI)), from the total value of US imports
reported in USITC publication 4022.
Steel Pipe 2007 2,185,379 1,350,791 470,787 363,801 All data from USITC publication 4435.
Steel Products 2015 17,055,633 13,451,548 [[***]] [[***]] Data on the value of US shipments from
USITC publication 4620.4 Aggregated value
of US imports from China based on company-
specific data from US Customs (Exhibit USA-
94 (BCI)). Value of US imports from the rest
of the world estimated by subtracting the
value of US imports from China, based on
data from US Customs (Exhibit USA-94
(BCI)), from the total value of US imports
reported in USITC publication 4620.
Steel Standard, Line, and
Pressure Pipe
2009 683,206 199,357 135,240 348,609 All data from USITC publication 4595.

4 We note that China proposes to use a value of USD 13,451,548 as the value of 2015 US shipments reported by the USITC (Exhibit CHN-55 (BCI)). However,
USITC publication 4620 reports the value of 2015 US domestic shipments as USD 13,451,548,000. We consider China's proposed value to be an inadvertent error and
use the value reported in USITC publication.

Anti-dumping order
Year prior to
the imposition
of the anti-
dumping order
Total US
market1
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)
Data sources
Steel Wire Rod 2014 [[***]] 2,682,510 [[***]] 970,200 Annualized value of US shipments based on
data from USITC publication 4509.
Aggregated value of US imports from China
based on company-specific data from US
Customs (Exhibit USA-94 (BCI)). Data on the
value of US imports from the rest of the
world based on HTS aggregated data from
the US Census Bureau (Exhibit USA-57).
Note: The values in this table have been rounded for display purposes only. The actual values were used when implementing the Armington model under the two
steps to estimate the level of nullification or impairment.

ANNEX E-2
DATA INPUTS FOR THE SHARE OF US IMPORTS FROM CHINA COVERED BY DIFFERENT CHINESE EXPORTERS IN THE YEAR PRIOR TO THE
IMPOSITION OF THE ANTI-DUMPING ORDERS
Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Aluminum Extrusions n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (United States' response to
Arbitrator question No. 62, paras. 70-72).
Bags n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Coated Paper [[***]]% [[***]]% [[***]]% Share of Chinese exporters subject to the PRC-wide duty rate
estimated by the United States by subtracting the value of US
imports from Chinese exporters outside the PRC-wide entity,
based on company-specific trade data reported by the
exporters, from the total value of US imports from China,
based on HTS aggregated monthly trade data from USITC
Dataweb (Exhibit USA-54 (BCI)). Share of Chinese exporters
subject to WA-T duty rate estimated by identifying their
names based on USDOC records for investigation A-570-958
(Annex E-4), and their corresponding shipments values based
on confidential company-specific trade data compiled by US
Customs (Exhibit USA-94 (BCI)). Share of remaining Chinese
exporters estimated by identifying their names based on
USDOC records for investigation A-570-958 (Annex E-4), and
their corresponding shipments values based on confidential
company-specific trade data compiled by US Customs (Exhibit
USA-94 (BCI)).
Diamond Sawblades n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC-wide duty rate
estimated by subtracting the aggregated value of shipments
by Chinese exporters outside the PRC-wide entity from the
total value of US imports from China. The aggregated value of
shipments by Chinese exporters outside the PRC-wide entity
estimated by identifying the names of all Chinese exporters
outside the PRC-wide entity, based on USDOC records for
investigation A-570-900 (Annex E-3), and their corresponding
shipments values, based on confidential company-specific
trade data compiled by US Customs (Exhibit USA-94 (BCI)).
Share of remaining Chinese exporters estimated as the
residual share.

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Furniture n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC-wide duty rate
estimated by subtracting the aggregated value of shipments
by Chinese exporters outside the PRC-wide entity from the
total value of US imports from China. The aggregated value of
shipments by Chinese exporters outside the PRC-wide entity
estimated by identifying the names of all Chinese exporters
outside the PRC-wide entity, based on USDOC records for
investigation A-570-890 (Annex E-3), and their corresponding
shipments values, based on confidential company-specific
trade data compiled by US Customs (Exhibit USA-94 (BCI)).
Share of remaining Chinese exporters estimated as the
residual share.
OCTG [[***]]% [[***]]% [[***]]% Share of Chinese exporters subject to the PRC-wide duty rate
estimated by the United States by subtracting the value of US
imports from Chinese exporters outside the PRC-wide entity,
based on company-specific trade data reported by the
exporters, from the total value of US imports from China,
based on HTS aggregated monthly trade data from USITC
Dataweb (Exhibit USA-54 (BCI)). Share of Chinese exporters
subject to WA-T duty rate estimated by identifying their
names based on USDOC records for investigation A-570-943
(Annex E-4), and their corresponding shipments values based
on confidential company-specific trade data compiled by US
Customs (Exhibit USA-94 (BCI)). Share of remaining Chinese
exporters estimated by identifying their names based on
USDOC records for investigation A-570-943 (Annex E-4), and
their corresponding shipments values based on confidential
company-specific trade data compiled by US Customs (Exhibit
USA-94 (BCI)).
OTR Tires n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
PET Film n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Ribbons n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC-wide duty rate
estimated by subtracting the aggregated value of shipments
by Chinese exporters outside the PRC-wide entity from the
total value of US imports from China. The aggregated value of
shipments by Chinese exporters outside the PRC-wide entity
estimated by identifying the names of all Chinese exporters
outside the PRC-wide entity, based on USDOC records for
investigation A-570-952 (Annex E-3), and their corresponding
shipments values, based on confidential company-specific
trade data compiled by US Customs (Exhibit USA-94 (BCI)).
Share of remaining Chinese exporters estimated as the
residual share.
Shrimp n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC-wide duty rate
estimated by subtracting the aggregated value of shipments
by Chinese exporters outside the PRC-wide entity from the
total value of US imports from China. The aggregated value of
shipments by Chinese exporters outside the PRC-wide entity
estimated by identifying the names of all Chinese exporters
outside the PRC-wide entity, based on USDOC records for
investigation A-570-893 (Annex E-3), and their corresponding
shipments values, based on confidential company-specific
trade data compiled by US Customs (Exhibit USA-94 (BCI)).
Share of remaining Chinese exporters estimated as the
residual share.

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Solar Panels n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Cylinders [[***]]% [[***]]% [[***]]% Share of Chinese exporters subject to PRC-wide duty rate
estimated by subtracting the aggregated value of shipments
by Chinese exporters outside the PRC-wide entity from the
total value of US imports from China. The aggregated value of
shipments by Chinese exporters outside the PRC-wide entity
estimated by identifying the names of all Chinese exporters
outside the PRC-wide entity, based on USDOC records for
investigation A-570-977 (Annex E-3), and their corresponding
shipments values, based on confidential company-specific
trade data compiled by US Customs (Exhibit USA-94 (BCI)).
Share of Chinese exporters subject to WA-T duty rate
estimated by identifying their names based on USDOC records
for investigation A-570-977 (Annex E-4), and their
corresponding shipments values based on confidential
company-specific trade data compiled by US Customs (Exhibit
USA-94 (BCI)). Share of remaining Chinese exporters
estimated by identifying their names based on USDOC records
for investigation A-570-977 (Annex E-4), and their
corresponding shipments values based on confidential
company-specific trade data compiled by US Customs (Exhibit
USA-94 (BCI)).
Wood Flooring n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Copper Pipe and Tube n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Iron Pipe Fittings n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Passenger Vehicle and Light Truck Tires n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Residential Washers n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC-wide duty rate
estimated by subtracting the aggregated value of shipments
by Chinese exporters outside the PRC-wide entity from the
total value of US imports from China. The aggregated value of
shipments by Chinese exporters outside the PRC-wide entity
estimated by identifying the names of all Chinese exporters
outside the PRC-wide entity, based on USDOC records for
investigation A-570-033 (Annex E-3), and their corresponding
shipments values, based on confidential company-specific
trade data compiled by US Customs (Exhibit USA-94 (BCI)).
Share of remaining Chinese exporters estimated as the
residual share.

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Sheet and Strip n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Flat Products n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Line Pipe n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Nails n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).

Anti-dumping order
Share of
Chinese
exporters
subject to
WA-T duty
rate
Share of
Chinese
exporters
subject to
PRC-wide duty
rate
Share of
remaining
Chinese
exporters
Data sources
Steel Pipe n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Products n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Standard, Line, and Pressure Pipe n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).
Steel Wire Rod n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide
entity estimated by the United States based on company-
specific trade data reported by the exporters. Share of
Chinese exporters subject to the PRC-wide duty rate estimated
by the United States by subtracting the share of Chinese
exporters outside the PRC-wide entity from the total value of
US imports from China, based on HTS aggregated monthly
trade data from USITC Dataweb (Exhibit USA-54 (BCI)).

ANNEX E-3
LIST OF CHINESE EXPORTERS OUTSIDE THE PRC-WIDE ENTITY USED TO ESTIMATE THE SHARE
OF DIFFERENT CHINESE EXPORTERS FOR SIX ANTI-DUMPING ORDERS
Anti-dumping order Exporter Producer Data source
Diamond Sawblades Advanced Technology &
Materials Co., Ltd.

Bosun Tools Group Co.,
Ltd.

Danyang Huachang
Diamond Tools
Manufacturing Co., Ltd.

Danyang NYCL Tools
Manufacturing Co., Ltd.

Danyang Youhe Tool
Manufacturer Co., Ltd

Fujian Quanzhou
Wanlong Stone Co., Ltd.

Guilin Tebon Superhard
Material Co., Ltd.

Hebei Jikai Industrial
Group Co., Ltd.

Huzhou Gu's Import &
Export Co., Ltd.

Huzhou Gu's Import &
Export Co., Ltd.

Jiangsu Fengtai Diamond
Tool Manufacture Co.,
Ltd.

Jiangyin Likn Industry
Co., Ltd.

Jiangyin Likn Industry
Co., Ltd.

Qingdao Shinhan
Diamond Industrial Co.,
Ltd.

Quanzhou Zhongzhi
Diamond Tool Co., Ltd.

Rizhao Hein Saw Co.,
Ltd.

Shanghai Deda Industry
& Trading Co., Ltd.

Advanced Technology &
Materials Co., Ltd.

Bosun Tools Group Co. ,
Ltd

Danyang Huachang
Diamond Tools
Manufacturing Co., Ltd.

Danyang NYCL Tools
Manufacturing Co., Ltd.

Danyang Youhe Tool
Manufacturer Co., Ltd.

Fujian Quanzhou
Wanlong Stone Co., Ltd.

Guilin Tebon Superhard
Material Co., Ltd.

Hebei Jikai Industrial
Group Co., Ltd.

Danyang Aurui Hardware
Products Co., Ltd.

Danyang Huachang
Diamond Tools
Manufacturing Co., Ltd.

Jiangsu Fengtai Diamond
Tool Manufacture Co.,
Ltd.

Jiangsu Fengtai Diamond
Tool Manufacture Co.,
Ltd.

Wuhan Wanbang Laser
Diamond Tools Co.

Qingdao Shinhan
Diamond Industrial Co.,
Ltd.

Quanzhou Zhongzhi
Diamond Tool Co., Ltd.

Rizhao Hein Saw Co.,
Ltd.

Hua Da Superabrasive
Tools Technology Co.,
Ltd.

USDOC records for
investigation A-570-900
(Exhibit USA-50)

Anti-dumping order Exporter Producer Data source
Shanghai Robtol Tool
Manufacturing Co., Ltd.

Shijiazhuang Global New
Century Tools Co., Ltd.

Sichuan Huili Tools Co.

Sichuan Huili Tools Co.

Weihai Xiangguang
Mechanical Industrial
Co., Ltd.

Wuhan Wanbang Laser
Diamond Tools Co.

Xiamen ZL Diamond
Tools Co., Ltd.

Zhejiang Tea Import &
Export Co., Ltd.

Zhejiang Tea Import &
Export Co., Ltd.

Zhejiang Tea Import &
Export Co., Ltd.

Zhejiang Wanli Tools
Group Co., Ltd.

Zhenjiang Inter–China
Import & Export Co.,
Ltd.
Shanghai Robtol Tool
Manufacturing Co., Ltd.

Shijiazhuang Global New
Century Tools Co., Ltd.

Chengdu Huifeng
Diamond Tools Co., Ltd.

Sichuan Huili Tools Co.

Weihai Xiangguang
Mechanical Industrial
Co., Ltd.

Wuhan Wanbang Laser
Diamond Tools Co.

Xiamen ZL Diamond
Tools Co., Ltd.

Danyang Dida Diamond
Tools Manufacturing Co.,
Ltd.

Danyang Tsunda
Diamond Tools Co., Ltd.

Wuxi Lianhua Superhard
Material Tools Co., Ltd.

Zhejiang Wanli Super–
hard Materials Co., Ltd.

Danyang Weiwang Tools
Manufacturing Co., Ltd.

Furniture Dongguan Lung Dong
Furniture Co., Ltd., or
Dongguan Dong He
Furniture Co., Ltd (Lung
Dong)

Rui Feng Woodwork Co.,
Ltd., or Rui Feng Lumber
Development Co., Ltd. or
Dorbest Limited
(Dorbest)

Lacquer Craft Mfg. Co.,
Ltd

Markor International
Furniture (Tianjin)
Manufacturing Company,
Ltd

Shing Mark Enterprise
Co., Ltd., or Carven
Industries Limited (BVI),
or Carven I Industries
Limited (HK), or
Dongguan Zhenxin
Furniture Co., Ltd., or
Dongguan Yongpeng
Furniture Co., Ltd (Shing
Mark)
n/a

n/a

n/a

n/a

n/a

USDOC records for
investigation A-570-890
(Exhibit USA-50)

Anti-dumping order Exporter Producer Data source

Starcorp Furniture
(Shanghai) Co., Ltd., or
Orin Furniture
(Shanghai) Co., Ltd., or
Shanghai Starcorp
Furniture Co., Ltd.

Alexandre International
Corp., or Southern Art
Development Ltd., or
Alexandre Furniture
(Shenzhen) Co., Ltd., or
Southern Art Furniture
Factory

Art Heritage
International, Ltd., or
Super Art Furniture Co.,
Ltd., or Artwork Metal &
Plastic Co., Ltd., or
Jibson Industries Ltd., or
Always Loyal
International

Billy Wood Industrial
(Dong Guan) Co., Ltd.,
or Great Union Industrial
(Dongguan) Co., Ltd., or
Time Faith Ltd

Changshu HTC Import &
Export Co., Ltd

Cheng Meng Furniture
(PTE) Ltd., or China
Cheng Meng Decoration
& Furniture Co., Ltd

Chuan Fa Furniture
Factory

Classic Furniture Global
Co., Ltd

Clearwise Co., Ltd

COE Ltd

Dalian Guangming
Furniture Co., Ltd

Dalian Huafeng Furniture
Co., Ltd

Dongguan Cambridge
Furniture Co., or Glory
Oceanic Co., Ltd

Dongguan Chunsan
Wood Products Co., Ltd

Dongguan Creation
Furniture Co., Ltd., or
Creation Industries Co.,
Ltd

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
Dongguan Grand Style
Furniture, or Hong Kong
Da Zhi Furniture Co., Ltd

Dongguan Great
Reputation Furniture
Co., Ltd

Dongguan Hero Way
Woodwork Co., Ltd., or
Dongguan Da Zhong
Woodwork Co., Ltd., or
Hero Way Enterprises
Ltd., or Well Earth
International Ltd

Dongguan Hung Sheng
Artware Products Co.,
Ltd., or Coronal
Enterprise Co., Ltd

Dongguan Kin Feng
Furniture Co., Ltd

Dongguan Kingstone
Furniture Co., Ltd., or
Kingstone Furniture Co.,
Ltd

Dongguan
Liaobushangdun Huada
Furniture Factory, or
Great Rich (HK)
Enterprise Co. Ltd

Dongguan Qingxi Xinyi
Craft Furniture Factory
(Joyce Art Factory)

Dongguan Singways
Furniture Co., Ltd

Dongguan Sunrise
Furniture Co., or Taicang
Sunrise Wood Industry
Co., Ltd., or Shanghai
Sunrise Furniture Co.,
Ltd., or Fairmont
Designs

Dongying Huanghekou
Furniture Industry Co.,
Ltd

Dream Rooms Furniture
(Shanghai) Co., Ltd

Eurosa (Kunshan) Co.,
Ltd., or Eurosa Furniture
Co., (PTE) Ltd

Ever Spring Furniture
Co. Ltd., or S.Y.C.
Family Enterprise Co.,
Ltd

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
Fine Furniture
(Shanghai) Ltd

Foshan Guanqiu
Furniture Co., Ltd

Fujian Lianfu Forestry
Co., Ltd., or Fujian
Wonder Pacific Inc

Gaomi Yatai Wooden
Ware Co., Ltd., or Team
Prospect International
Ltd., or Money Gain
International Co

Garri Furniture (Dong
Guan) Co., Ltd., or
Molabile International,
Inc., or Weei Geo
Enterprise Co., Ltd

Green River Wood
(Dongguan) Ltd

Guangming Group
Wumahe Furniture Co.,
Ltd

Hainan Jong Bao Lumber
Co., Ltd., or Jibbon
Enterprise Co., Ltd

Hamilton & Spill Ltd

Hang Hai Woodcraft’s Art
Factory

Hualing Furniture
(China) Co., Ltd., or
Tony House Manufacture
(China) Co., Ltd., or
Buysell Investments
Ltd., or Tony House
Industries Co., Ltd

Jardine Enterprise, Ltd

Jiangmen Kinwai
Furniture Decoration
Co., Ltd

Jiangmen Kinwai
International Furniture
Co., Ltd

Jiangsu Weifu Group
Fullhouse Furniture
Manufacturing Corp

Jiangsu Yuexing
Furniture Group Co., Ltd

Jiedong Lehouse
Furniture Co., Ltd

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
King's Way Furniture
Industries Co., Ltd., or
Kingsyear Ltd

Kuan Lin Furniture
(Dong Guan) Co., Ltd.,
or Kuan Lin Furniture
Factory, or Kuan Lin
Furniture Co., Ltd

Kunshan Lee Wood
Product Co., Ltd

Kunshan Summit
Furniture Co., Ltd

Langfang Tiancheng
Furniture Co., Ltd
Leefu Wood (Dongguan)
Co., Ltd., or King Rich
International, Ltd

Link Silver Ltd. (V.I.B.),
or Forward Win
Enterprises Co. Ltd., or
Dongguan Haoshun
Furniture Ltd

Locke Furniture Factory,
or Kai Chan Furniture
Co., Ltd., or Kai Chan
(Hong Kong) Enterprise
Ltd., or Taiwan Kai Chan
Co., Ltd

Longrange Furniture Co.,
Ltd

Nanhai Baiyi Woodwork
Co., Ltd

Nanhai Jiantai Woodwork
Co., Ltd

Nantong Dongfang
Orient Furniture Co., Ltd

Nantong Yushi Furniture
Co., Ltd

Nathan International
Ltd., or Nathan Rattan
Factory

Orient International
Holding Shanghai
Foreign Trade Co., Ltd

Passwell Corporation, or
Pleasant Wave Ltd

Perfect Line Furniture
Co., Ltd

Prime Wood
International Co., Ltd.,
or Prime Best
n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
International Co., Ltd.,
or Prime Best Factory, or
Liang Huang (Jiaxing)
Enterprise Co., Ltd

PuTian JingGong
Furniture Co., Ltd

Qingdao Liangmu Co.,
Ltd

Restonic (Dongguan)
Furniture Ltd., or
Restonic Far East
(Samoa) Ltd

RiZhao SanMu
Woodworking Co., Ltd

Season Furniture
Manufacturing Co., or
Season Industrial
Development Co

Sen Yeong International
Co., Ltd., or Sheh Hau
International Trading Ltd

Shanghai Jian Pu Export
& Import Co., Ltd

Shanghai Maoji Imp and
Exp Co., Ltd

Sheng Jing Wood
Products (Beijing) Co.,
Ltd., or Telstar
Enterprises Ltd

Shenyang Shining
Dongxing Furniture Co.,
Ltd

Shenzhen Forest
Furniture Co., Ltd

Shenzhen Jiafa High
Grade Furniture Co.,
Ltd., or Golden Lion
International Trading Ltd

Shenzhen New Fudu
Furniture Co., Ltd

Shenzhen Wonderful
Furniture Co., Ltd

Shenzhen Xiande
Furniture Factory

Shenzhen Xingli
Furniture Co., Ltd

Shun Feng Furniture Co.,
Ltd

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
Songgang Jasonwood
Furniture Factory, or
Jasonwood Industrial
Co., Ltd. S.A

Starwood Furniture
Manufacturing Co. Ltd

Starwood Industries Ltd

Strongson Furniture
(Shenzhen) Co., Ltd., or
Strongson Furniture Co.,
Ltd., or Strongson (HK)
Co

Sunforce Furniture (Hui-
Yang) Co., Ltd., or Sun
Fung Wooden Factory, or
Sun Fung Co., or Shin
Feng Furniture Co., Ltd.,
or Stupendous
International Co., Ltd

Superwood Co., Ltd., or
Lianjin Zongyu Art
Products Co., Ltd
Tarzan Furniture
Industries Ltd., or
Samso Industries Ltd

Teamway Furniture
(Dong Guan) Ltd., or
Brittomart Inc

Techniwood Industries
Ltd., or Ningbo Furniture
Industries Limited, or
Ningbo Hengrun
Furniture Co., Ltd

Tianjin Fortune Furniture
Co., Ltd

Tianjin Master Home
Furniture

Tianjin Phu Shing
Woodwork Enterprise
Co., Ltd

Tianjin Sande Fairwood
Furniture Co., Ltd

Tube-Smith Enterprise
(ZhangZhou) Co., Ltd.,
or Tube-Smith
Enterprise (Haimen) Co.,
Ltd., or Billonworth
Enterprises Ltd

Union Friend
International Trade Co.,
Ltd

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
U-Rich Furniture
(Zhangzhou) Co., Ltd.,
or U-Rich Furniture Ltd

Wanhengtong Nueevder
(Furniture) Manufacture
Co., Ltd., or Dongguan
Wanengtong Industry
Co., Ltd

Woodworth Wooden
Industries (Dong Guan)
Co., Ltd

Xiamen Yongquan Sci-
Tech Development Co.,
Ltd

Jiangsu XiangSheng
Bedtime Furniture Co.,
Ltd

Xingli Arts & Crafts
Factory of Yangchun

Yangchun Hengli Co. Ltd

Yeh Brothers World
Trade, Inc

Yichun Guangming
Furniture Co., Ltd

Yida Co., Ltd., or Yitai
Worldwide, Ltd., or Yili
Co., Ltd., or Yetbuild
Co., Ltd

Yihua Timber Industry
Co., Ltd

Zhang Zhou Sanlong
Wood Product Co., Ltd

Zhangjiagang Zheng Yan
Decoration Co., Ltd

Zhangjiagang Daye
Hotel Furniture Co., Ltd

Zhangzhou Guohui
Industrial & Trade Co.
Ltd

Zhanjiang Sunwin Arts &
Crafts Co., Ltd

Zhong Shan Fullwin
Furniture Co., Ltd

Zhongshan Fookyik
Furniture Co., Ltd

Zhongshan Golden King
Furniture Industrial Co.,
Ltd

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
Zhoushan For-Strong
Wood Co., Ltd

n/a

Residential Washers Nanjing LG-Panda
Appliances Co., Ltd

Suzhou Samsung
Electronics Co.,
Ltd./Suzhou Samsung
Electronics Co. Ltd-
Export

Nanjing LG-Panda
Appliances Co., Ltd

Suzhou Samsung
Electronics Co.,
Ltd./Suzhou Samsung
Electronics Co. Ltd-
Export
USDOC records for
investigation A-570-033
(Exhibit USA-50)
Ribbons Yama Ribbons and Bows
Co., Ltd (Yama)

Beauty Horn Investment
Limited

Fujian Rongshu Industry
Co., Ltd

Guangzhou Complacent
Weaving Co., Ltd

Ningbo MH Industry Co.,
Ltd

Ningbo V.K. Industry &
Trading Co., Ltd

Stribbons (Guangzhou)
Ltd

Stribbons (Guangzhou)
Ltd

Sun Rich (Asia) Limited

Tianjin Sun Ribbon Co.,
Ltd

Weifang Dongfang
Ribbon Weaving Co.,
Ltd.

Weifang Yu Yuan Textile
Co., Ltd.

Xiamen Yi He Textile
Co., Ltd

Yangzhou Bestpak Gifts &
Crafts Co., Ltd (Bestpak)

Yama Ribbons and Bows
Co., Ltd. (Yama)

Tianjin Sun Ribbon Co.,
Ltd

Fujian Rongshu Industry
Co., Ltd.

Guangzhou Complacent
Weaving Co., Ltd.

Hangzhou City Linghu
Jiacheng Silk Ribbon Co.,
Ltd

Ningbo Yinzhou Jinfeng
Knitting Factory

Stribbons (Guangzhou)
Ltd

Stribbons (Nanyang)
MNC Ltd

Dongguan Yi Sheng
Decoration Co., Ltd

Tianjin Sun Ribbon Co.,
Ltd

Weifang Dongfang
Ribbon Weaving Co., Ltd

Weifang Yu Yuan Textile
Co., Ltd

Xiamen Yi He Textile
Co., Ltd

Yangzhou Bestpak Gifts
& Crafts Co., Ltd
USDOC records for
investigation A-570-952
(Exhibit USA-50)
Shrimp Allied Pacific Group
(Allied)

Yelin Entprise Co Hong
Kong (Yelin)

Shantou Red Garden
Foodstuff Co., Ltd. (Red
Garden)

n/a

n/a

n/a

USDOC records for
investigation A-570-893
(Exhibit USA-50)

Anti-dumping order Exporter Producer Data source
Zhanjiang Guolian
Aquatic Products Co.,
Ltd. (Zhanjiang Guolian)

Asian Seafoods
(Zhanjiang) Co., Ltd.

Beihai Zhengwu Industry
Co., Ltd.

Chaoyang Qiaofeng
Group Co., Ltd.
(Shantou Qiaofeng
(Group) Co., Ltd.)
(Shantou/Chaoyang
Qiaofeng)

Chenghai Nichi Lan Food
Co., Ltd.

Dalian Ftz Sea-Rich
International Trading
Co., Ltd.

Dongri Aquatic Products
Freezing Plants

Fuqing Dongwei Aquatic
Products Industry Co.,
Ltd.

Gallant Ocean
(Liangjiang) Co., Ltd.

Hainan Fruit Vegetable
Food Allocation Co., Ltd.

Hainan Golden Spring
Foods Co., Ltd./Hainan
Brich Aquatic Products
Co., Ltd.

Kaifeng Ocean Sky
Industry Co., Ltd.

Leizhou Zhulian Frozen
Food Co., Ltd.

Pingyang Xinye Aquatic
Products Co., Ltd.

Savvy Seafood Inc.

Shanghai Taoen
International Trading
Co., Ltd

Shantou Long Feng
Foodstuffs Co., Ltd.
(Shantou Longfeng
Foodstuffs Co., Ltd.)

Shantou Wanya Food
Factory Co., Ltd.

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Anti-dumping order Exporter Producer Data source
Shantou Jinyuan District
Mingfeng Quick-Frozen
Factory

Shantou Ocean Freezing
Industry and Trade
General Corporation

Shantou Shengping
Oceanstar Business Co.,
Ltd.

Shantou Yuexing
Enterprise Company

Shantou Ruiyuan
Industry Co., Ltd.

Shantou Freezing
Aquatic Product Food
Stuffs Co.

Shantou Jinhang Aquatic
Industry Co., Ltd.

Xuwen Hailang Breeding
Co., Ltd.

Yantai Wei-Cheng Food
Co., Ltd.

Zhangjiang Newpro Food
Co., Ltd.

Zhangjiang Bobogo
Ocean Co., Ltd.

Zhanjiang Runhai Foods
Co., Ltd.

Zhanjiang Go-Harvest
Aquatic Products Co.,
Ltd.

Zhanjiang Universal
Seafood Corp.

Zhanjiang Evergreen
Aquatic Product Science
and Technology Co., Ltd.

Zhoushan Huading
Seafood Co., Ltd.

Zhoushan Cereals Oils
and Foodstuffs Import
and Export Co., Ltd.

Zhoushan Lizhou Fishery
Co., Ltd.
n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

n/a

Steel Cylinders Beijing Tianhai Industry
Co., Ltd. (BTIC)

Beijing Tianhai Industry
Co., Ltd. (BTIC)

Beijing Tianhai Industry
Co., Ltd.

Tianjin Tianhai High
Pressure Container Co.,
Ltd.

USDOC records for
investigation A-570-977
(Exhibit USA-50)

Anti-dumping order Exporter Producer Data source
Beijing Tianhai Industry
Co., Ltd. (BTIC)

Shanghai J.S.X.
International Trading
Corporation (J.S.X)

Zhejiang Jindun Pressure
Vessel Co., Ltd. (Jindun)

Shijiazhuang Enric Gas
Equipment Co., Ltd.
(Enric)

Langfang Tianhai High
Pressure Container Co.,
Ltd.

Shanghai High Pressure
Special Gas Cylinder Co.,
Ltd.

Zhejiang Jindun Pressure
Vessel Co., Ltd.

Shijiazhuang Enric Gas
Equipment Co., Ltd.

ANNEX E-4
LIST OF CHINESE EXPORTERS SUBJECT TO THE WA-T DUTY RATES AND OTHER CHINESE
EXPORTERS OUTSIDE THE PRC-WIDE ENTITY USED TO ESTIMATE THE SHARE OF DIFFERENT
CHINESE EXPORTERS FOR THREE ANTI-DUMPING ORDERS
Anti-
Dumping
order
Exporter Producer Data source

Coated Paper Exporters subject the WA-T duty rate USDOC
records for
investigation
A-570-958
 APP-China covering:
 Gold East Paper (Jiangsu) Co., Ltd. Gold East Paper (Jiangsu) Co., Ltd.
 Gold Huasheng Paper Co., Ltd. Gold Huasheng Paper Co., Ltd.
 Ningbo Zhonghua Paper Co., Ltd. Ningbo Asia Pulp and Paper Co., Ltd.
 Gold East (Hong Kong) Trading Co.,
Ltd.
n/a
 Shandong Chenming Paper
Holdings Ltd.
Shandong Chenming Paper
Holdings Ltd.

Remaining exporters outside the PRC-wide entity

 n/a n/a
OCTG Exporters subject the WA-T duty rate USDOC
records for
investigation
A-570-943
 Tianjin Pipe International Economic
and Trading Corp. (TPCO)
Tianjin Pipe (Group) Corporation
(TPCO)
 Angang Group Hong Kong Co., Ltd. Angang Steel Co. Ltd.
 Angang Steel Co., Ltd., and
Angang Group International Trade
Corporation
Angang Steel Co. Ltd.
 Anhui Tianda Oil Pipe Co., Ltd. Anhui Tianda Oil Pipe Co., Ltd.
 Anshan Zhongyou Tipo Pipe &
Tubing Co., Ltd.
Anshan Zhongyou Tipo Pipe &
Tubing Co., Ltd.

 Baotou Steel International
Economic and Trading Co., Ltd.
Seamless Tube Mill of Inner
Mongolia Baotou Steel Union Co.,
Ltd.

 Benxi Northern Steel Pipes Co.,
Ltd.
Benxi Northern Steel Pipes Co., Ltd.
 Chengdu Wanghui Petroleum Pipe
Co. Ltd.
Chengdu Wanghui Petroleum Pipe
Co. Ltd.

 Dalipal Pipe Company Dalipal Pipe Company

Anti-
Dumping
order
Exporter Producer Data source

 Faray Petroleum Steel Pipe Co. Ltd. Faray Petroleum Steel Pipe Co. Ltd.
 Freet Petroleum Equipment Co.,
Ltd. of Shengli Oil Field, The
Thermal Recovery Equipment, Zibo
Branch
Freet Petroleum Equipment Co.,
Ltd. of Shengli Oil Field, The
Thermal Recovery Equipment, Zibo
Branch

 Hengyang Steel Tube Group
International Trading, Inc.
Hengyang Valin MPM Tube Co.,
Ltd.; Hengyang Valin Steel Tube
Co., Ltd.

 Huludao Steel Pipe Industrial Co.,
Ltd./Huludao City Steel Pipe
Industrial Co., Ltd.
Huludao Steel Pipe Industrial Co.,
Ltd./Huludao City Steel Pipe
Industrial Co., Ltd.

 Jiangyin City Changjiang Steel Pipe
Co., Ltd.
Jiangyin City Changjiang Steel Pipe
Co., Ltd.

 Pangang Group Beihai Steel Pipe
Corporation
Pangang Group Beihai Steel Pipe
Corporation

 Pangang Group Chengdu Iron &
Steel
Pangang Group Chengdu Iron &
Steel

 Qingdao Bonded Logistics Park
Products International Trading Co.,
Ltd.
Shengli Oilfield Highland Petroleum
Equipment Co., Ltd.; Shandong
Continental Petroleum Equipment
Co., Ltd.; Aofei Tele Dongying
Import & Export Co., Ltd.;
Highgrade Tubular Manufacturing
(Tianjin) Co., Ltd.; Cangzhou City
Baohai Petroleum Material Co., Ltd.

 Qiqihaer Haoying Iron and Steel
Co., Ltd. of Northeast Special Steel
Group
Qiqihaer Haoying Iron and Steel
Co., Ltd. of Northeast Special Steel
Group

 Shandong Dongbao Steel Pipe Co.,
Ltd.
ShanDong HuaBao Steel Pipe Co.,
Ltd.

 ShanDong HuaBao Steel Pipe Co.,
Ltd.
ShanDong HuaBao Steel Pipe Co.,
Ltd.

 Shandong Molong Petroleum
Machinery Co., Ltd.
Shandong Molong Petroleum
Machinery Co., Ltd.

 Shanghai Metals & Minerals Import
& Export Corp. / Shanghai
Minmetals Materials & Products
Corp.
Jiangsu Changbao Steel Pipe Co.,
Ltd.; Huludao Steel Pipe Industrial
Co., Ltd.; Northeast Special Steel
Group Qiqihaer Haoying Steel and
Iron Co., Ltd.; Beijing Youlu Co.,
Ltd.

 Shanghai Zhongyou Tipo Steel Pipe
Co., Ltd.
Freet Petroleum Equipment Co.,
Ltd. of Shengli Oil Field, The
Thermal Recovery Equipment, Zibo
Branch; Faray Petroleum Steel Pipe
Co., Ltd.; Shengli Oil Field Freet
Petroleum Steel Pipe Co., Ltd.

Anti-
Dumping
order
Exporter Producer Data source

 Shengli Oil Field Freet Petroleum
Steel Pipe Co., Ltd.
Freet Petroleum Equipment Co.,
Ltd. of Shengli Oil Field, The
Thermal Recovery Equipment, Zibo
Branch; Anhui Tianda Oil Pipe Co.,
Ltd; Wuxi Fastube Dingyuan
Precision Steel Pipe Co., Ltd.

 Shengli Oilfield Highland Petroleum
Equipment Co., Ltd.
Tianjin Pipe Group Corp.; Goods &
Materials Supply Dept. of Shengli
Oilfield SinoPEC; Dagang Oilfield
Group New Century Machinery Co.
Ltd.;Tianjin Seamless Steel Pipe
Plant; Baoshan Iron & Steel Co.
Ltd.

 Shengli Oilfield Shengji Petroleum
Equipment Co., Ltd.
Shengli Oilfield Shengji Petroleum
Equipment Co., Ltd.

 Tianjin Xingyuda Import and
Export Co., Ltd. & Hong Kong
Gallant Group Limited
Tianjin Lifengyuanda Steel Group
Co., Ltd.

 Tianjin Seamless Steel Pipe Plant Tianjin Seamless Steel Pipe Plant
 Tianjin Tiangang Special Petroleum
Pipe Manufacturer Co., Ltd.
Tianjin Tiangang Special Petroleum
Pipe Manufacturer Co., Ltd.

 Wuxi Baoda Petroleum Special Pipe
Manufacturing Co., Ltd.
Wuxi Baoda Petroleum Special Pipe
Manufacturing Co., Ltd.

 Wuxi Seamless Oil Pipe Co., Ltd. Wuxi Seamless Oil Pipe Co., Ltd.
 Wuxi Sp. Steel Tube Manufacturing
Co., Ltd.
Wuxi Precese Special Steel Co., Ltd.
 Wuxi Zhenda Special Steel Tube
Manufacturing Co., Ltd.
Huai'an Zhenda Steel Tube
Manufacturing Co., Ltd.

 Xigang Seamless Steel Tube Co.,
Ltd.
Xigang Seamless Steel Tube Co.,
Ltd.; Wuxi Seamless Special Pipe
Co., Ltd.

 Yangzhou Lontrin Steel Tube Co.,
Ltd.
Yangzhou Lontrin Steel Tube Co.,
Ltd.

 Zhejiang Jianli Co., Ltd. & Zhejiang
Jianli Steel Tube Co., Ltd.
Zhejiang Jianli Co., Ltd.; Zhejiang
Jianli Steel Tube Co., Ltd.

Remaining exporters outside the PRC-wide entity

 Chengde Group covering:
 (i) Jiangsu Chengde Steel Tube
Share Co., Ltd.;
n/a
 (ii) Taizhou Chengde Steel Tube
Co., Ltd.; and
n/a
 (iii) Yangzhou Chengde Steel Tube
Co., Ltd.
n/a

Anti-
Dumping
order
Exporter Producer Data source

Steel
Cylinders
Exporters subject the WA-T duty rate USDOC
records for
investigation
A-570-977
 Shanghai J.S.X. International
Trading Corporation
Shanghai High Pressure Special Gas
Cylinder Co., Ltd.
 Zhejiang Jindun Pressure Vessel
Co., Ltd.
Zhejiang Jindun Pressure Vessel
Co., Ltd.
 Shijiazhuang Enric Gas Equipment
Co., Ltd. (Enric)
Shijiazhuang Enric Gas Equipment
Co., Ltd.

Remaining exporters outside the PRC-wide entity

 Beijing Tianhai Industry Co., Ltd.
(BTIC)
Beijing Tianhai Industry Co., Ltd.
(BTIC)

 Beijing Tianhai Industry Co., Ltd.
(BTIC)
Tianjin Tianhai High Pressure
Container Co., Ltd.

 Beijing Tianhai Industry Co., Ltd.
(BTIC)
Langfang Tianhai High Pressure
Container Co., Ltd.

ANNEX E-5
DATA INPUTS FOR ELASTICITIES1
Anti-dumping order
Total
demand
elasticity
Domestic
supply
elasticity
Elasticity of
substitution Data sources
Aluminum Extrusions -0.375 4.000 5.000 Midpoint values from USITC publication 4677 (Exhibit
USA-16).
Bags -0.450 3.000 5.000 Midpoint values from USITC publication 4605 (Exhibit
USA-16).
Coated Paper -1.000 4.000 3.000 Midpoint values from USITC publication 4656 (Exhibit
USA-16).
Diamond Sawblades -0.750 5.000 3.000 Midpoint values from USITC publication 4559 (Exhibit
USA-16).
Furniture -0.750 4.500 4.500 Midpoint values from USITC publication 4665 (Exhibit
USA-16).
OCTG -0.875 3.000 4.000 Midpoint values from USITC publication 4124 (Exhibit
USA-16).
OTR Tires -0.250 7.500 4.000 Midpoint values from USITC publication 4031 (Exhibit
USA-16).
PET Film -0.750 3.500 4.500 Midpoint values from USITC publication 4512 (Exhibit
USA-16).
Ribbons -1.250 5.000 4.000 Midpoint values from USITC publication 4634 (Exhibit
USA-16).
Shrimp -2.000 3.500 4.000 Midpoint values from USITC publication 4688 (Exhibit
USA-16).
Solar Panels -0.875 6.000 4.000 Midpoint values from USITC publication 4360 (Exhibit
USA-16).
Steel Cylinders -0.500 7.500 4.000 Midpoint values from USITC publication 4328 (Exhibit
USA-16).

1 As discussed in paragraph 7.37 of the Decision, the supply elasticity for (i) US imports from the Chinese exporters subject to the WTO-inconsistent PRC-wide
duty rates, (ii) US imports from the remaining Chinese exporters, and (iii) US imports from the rest of the world are all set to 10 for all of the anti-dumping orders at
issue.

Anti-dumping order
Total
demand
elasticity
Domestic
supply
elasticity
Elasticity of
substitution Data sources
Wood Flooring -1.000 5.500 4.000 Midpoint values from USITC publication 4746 (Exhibit
USA-16).
Copper Pipe and Tube -0.875 2.000 4.000 Midpoint values from USITC publication 4650 (Exhibit
USA-16).
Iron Pipe Fittings -1.250 4.500 4.500 Midpoint values from USITC publication 3586 (Exhibit
USA-16).
Passenger Vehicle and Light Truck
Tires
-0.375 3.000 4.000 Midpoint values from USITC publication 4545 (Exhibit
USA-16).
Residential Washers -0.550 7.000 4.000 Midpoint values from USITC publication 4666 (Exhibit
USA-16).
Sheet and Strip -0.750 5.000 4.000 Midpoint values from USITC publication 4676 (Exhibit
USA-16).
Steel Flat Products -0.500 6.000 4.000 Midpoint values from USITC publication 4619 (Exhibit
USA-16).
Steel Line Pipe -0.375 4.000 3.000 Midpoint values from USITC publication 4055 (Exhibit
USA-16).
Steel Nails -0.375 4.000 4.000 Midpoint values from USITC publication 4022 (Exhibit
USA-16).
Steel Pipe -0.625 4.000 5.000 Midpoint values from USITC publication 4019 (Exhibit
USA-16).
Steel Products -0.750 6.000 4.000 Midpoint values from USITC publication 4620 (Exhibit
USA-16).
Steel Standard, Line, and Pressure
Pipe
-0.750 7.500 3.000 Midpoint values from USITC publication 4190 (Exhibit
USA-16).
Steel Wire Rod -0.625 2.000 4.000 Midpoint values from USITC publication 4509 (Exhibit
USA-16).

ANNEX E-6
DATA INPUTS FOR THE ACTUAL ANTI-DUMPING DUTY RATES
Product WA-T duty
rate
PRC-wide
duty rate
Duty rate
for
remaining
exporters
Data sources
Aluminum Extrusions n/a 85.96% [[***]]% PRC-wide duty rate obtained from USDOC records for
investigation A-570-967 (Annex E-7). Duty rate for
remaining exporters outside the PRC-wide entity estimated
as a simple average based on USDOC records for
investigation A-570-967 (Annex E-7).
Bags n/a 77.57% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-886 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-886 (Exhibit USA-92 (BCI)).
Coated Paper 7.62% 135.8% [[***]]% WA-T duty rate provided by the United States based on
USDOC records for investigation A-570-958 (United States'
written submission, para. 104). PRC-wide duty rate provided
by the United States based on USDOC records for
investigation A-570-958 (Exhibits USA-77 (BCI) and USA-92
(BCI)). Duty rate for remaining exporters outside the PRC-
wide entity estimated as a simple average based on USDOC
records for investigation A-570-958 (Exhibit USA-92 (BCI)).
Diamond Sawblades n/a 82.05% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-900 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-900 (Exhibit USA-92 (BCI)).

Product WA-T duty
rate
PRC-wide
duty rate
Duty rate
for
remaining
exporters
Data sources
Furniture n/a 216% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-890 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-890 (Exhibit USA-92 (BCI)).
OCTG 32.07% 99.14% [[***]]% WA-T duty rate provided by the United States based on
USDOC records for investigation A-570-943 (United States'
written submission, para. 108; and Exhibit USA-14). PRC-
wide duty rate provided by the United States based on
USDOC records for investigation A-570-943 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated as a simple
average based on USDOC records for investigation A-570-
943 (Exhibit USA-92 (BCI)).
OTR Tires n/a 105.3% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-912 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-912 (Exhibit USA-92 (BCI)).
PET Film n/a 76.72% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-924 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-924 (Exhibit USA-92 (BCI)).
Ribbons n/a 247.3% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-952 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-952 (Exhibit USA-92 (BCI)).

Product WA-T duty
rate
PRC-wide
duty rate
Duty rate
for
remaining
exporters
Data sources
Shrimp n/a 112.8% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-893 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-893 (Exhibit USA-92 (BCI)).
Solar Panels n/a 239% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-979 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-979 (Exhibit USA-92 (BCI)).
Steel Cylinders 6.62% 31.21% [[***]]% WA-T duty rate provided by the United States based on
USDOC records for investigation A-570-977 (United States'
response to Arbitrator question No. 7, para. 33; and Exhibit
USA-50). PRC-wide duty rate provided by the United States
based on USDOC records for investigation A-570-977
(Exhibits USA-77 (BCI) and USA-92 (BCI)). Duty rate for
remaining exporters outside the PRC-wide entity estimated
as a simple average based on USDOC records for
investigation A-570-977 (Exhibit USA-92 (BCI)).
Wood Flooring n/a 25.62% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-970 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-970 (Exhibit USA-92 (BCI)).
Copper Pipe and Tube n/a 60.85% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-964 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-964 (Exhibit USA-92 (BCI)).

Product WA-T duty
rate
PRC-wide
duty rate
Duty rate
for
remaining
exporters
Data sources
Iron Pipe Fittings n/a 75.5% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-875 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-875 (Exhibit USA-92 (BCI)).
Passenger Vehicle and Light Truck Tires n/a 76.46% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-016 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-016 (Exhibit USA-92 (BCI)).
Residential Washers n/a 49.72% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-033 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-033 (Exhibit USA-92 (BCI)).
Sheet and Strip n/a 76.64% [[***]]% PRC-wide duty rate obtained from USDOC records for
investigation A-570-042 (Annex E-7). Duty rate for
remaining exporters outside the PRC-wide entity estimated
as a simple average based on USDOC records for
investigation A-570-042 (Annex E-7).
Steel Flat Products n/a 199.8% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-029 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-029 (Exhibit USA-92 (BCI)).
Steel Line Pipe n/a 101.1% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-935 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-935 (Exhibit USA-92 (BCI)).

Product WA-T duty
rate
PRC-wide
duty rate
Duty rate
for
remaining
exporters
Data sources
Steel Nails n/a 118% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-909 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-909 (Exhibit USA-92 (BCI)).
Steel Pipe n/a 85.55% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-910 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-910 (Exhibit USA-92 (BCI)).
Steel Products n/a 199.4% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-026 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-026 (Exhibit USA-92 (BCI)).
Steel Standard, Line, and Pressure Pipe n/a 98.74% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-956 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-956 (Exhibit USA-92 (BCI)).
Steel Wire Rod n/a 97.24% [[***]]% PRC-wide duty rate provided by the United States based on
USDOC records for investigation A-570-012 (Exhibits USA-
77 (BCI) and USA-92 (BCI)). Duty rate for remaining
exporters outside the PRC-wide entity estimated by the
United States as a simple average based on USDOC records
for investigation A-570-012 (Exhibit USA-92 (BCI)).

ANNEX E-7
LIST OF ANTI-DUMPING DUTY RATES USED FOR TWO ANTI-DUMPING ORDERS
Anti-dumping order Exporter  Producer Duty rate Data source
Aluminium Extrusions United States Square Industrial Limited Zhaoqing United States Square Industry Limited 32.79% USDOC records for
investigation A-570-
967 North United States Aluminum Co., Ltd North United States Aluminum Co., Ltd 32.79%
PanAsia Aluminium (United States) Limited PanAsia Aluminium (United States) Limited 32.79%
Pingguo United States Aluminum Co., Ltd Pingguo United States Aluminum Co., Ltd 32.79%
Skyline Exhibit Systems (Shanghai) Co.,
Ltd
n/a 32.79%
Gold Mountain International Development
Limited
n/a 32.79%
Shenzhen Jiuyuan Co., Ltd n/a 32.79%
Dynamic Technologies China Ltd n/a 32.79%
Zhejiang Xinlong Industry Co., Ltd n/a 32.79%
Changzhou Tenglong Auto Parts Co., Ltd n/a 32.79%
Xin Wei Aluminum Company Limited n/a 32.79%
Classic & Contemporary Inc n/a 22.28%
Dynabright Int'l Group (HK) Limited n/a 22.28%
Hanyung Metal (Suzhou) Co., Ltd n/a 22.28%
Global Point Technology (Far East) Limited n/a 22.28%
Jiangsu Changfa Refrigeration Co., Ltd n/a 27.22%
Jiaxing Jackson Travel Products Co., Ltd n/a 27.22%

Anti-dumping order Exporter  Producer Duty rate Data source
Midea International Trading Co., Ltd n/a 27.22%
Shanghai Tongtai Precise Aluminum Alloy n/a 27.22%
Sincere Profit Limited n/a 27.22%
Guang Ya Aluminium Industries Co., Ltd.;
Foshan Guangcheng Aluminium Co., Ltd.;
Kong Ah International Company Limited;
Guang Ya Aluminium Industries (Hong
Kong) Limited; Zhaoqing New Zhongya
Aluminum Co., Ltd.; Zhongya Shaped
Aluminium (HK) Holding Limited; Karlton
Aluminum Company Ltd
Guang Ya Aluminium Industries Co., Ltd.; Foshan
Guangcheng Aluminium Co., Ltd.; Kong Ah
International Company Limited; Guang Ya
Aluminium Industries (Hong Kong) Limited;
Zhaoqing New Zhongya Aluminum Co., Ltd.;
Zhongya Shaped Aluminium (HK) Holding
Limited; Karlton Aluminum Company Ltd.; Xinya
Aluminum & Stainless Steel Product Co., Ltd.
(A.K.A. New Asia Aluminum & Stainless Steel
Product Co., Ltd.)
33.02%
Alnan Aluminium Co., Ltd Alnan Aluminium Co., Ltd 0.00%
Changshu Changsheng Aluminium Products
Co., Ltd
Changshu Changsheng Aluminium Products Co.,
Ltd
0.00%
China Square Industrial Limited China Square Industrial Limited 0.00%
Cosco (J.M.) Aluminium Co., Ltd Cosco (J.M.) Aluminium Co., Ltd 0.00%
First Union Property Limited First Union Property Limited 0.00%
Foshan Jinlan Non-ferrous Metal Product
Co. Ltd
Foshan Jinlan Non-ferrous Metal Product Co. Ltd 0.00%
Foshan Sanshui Fenglu Aluminium Co., Ltd Foshan Sanshui Fenglu Aluminium Co., Ltd 0.00%
Guangdong Hao Mei Aluminium Co., Ltd Guangdong Hao Mei Aluminium Co., Ltd 0.00%
Guangdong Weiye Aluminium Factory Co.,
Ltd
Guangdong Weiye Aluminium Factory Co., Ltd 0.00%
Guangdong Xingfa Aluminium Co., Ltd Guangdong Xingfa Aluminium Co., Ltd 0.00%
Hanwood Enterprises Limited Hanwood Enterprises Limited 0.00%
Honsense Development Company Honsense Development Company 0.00%

Anti-dumping order Exporter  Producer Duty rate Data source
Innovative Aluminium (Hong Kong) Limited Innovative Aluminium (Hong Kong) Limited 0.00%
Jiangyin Trust International Inc Jiangyin Trust International Inc 0.00%
Longkou Donghai Trade Co., Ltd Longkou Donghai Trade Co., Ltd 0.00%
Ningbo Yili Import and Export Co., Ltd Ningbo Yili Import and Export Co., Ltd 0.00%
North China Aluminum Co., Ltd North China Aluminum Co., Ltd 0.00%
PanAsia Aluminium (China) Limited PanAsia Aluminium (China) Limited 0.00%
Pingguo Asia Aluminum Co., Ltd Pingguo Asia Aluminum Co., Ltd 0.00%
Popular Plastics Co., Ltd Popular Plastics Co., Ltd 0.00%
Press Metal International Ltd Press Metal International Ltd 0.00%
Shenyang Yuanda Aluminium Industry
Engineering Co. Ltd
Shenyang Yuanda Aluminium Industry
Engineering Co. Ltd
0.00%
Tai-Ao Aluminium (Taishan) Co., Ltd Tai-Ao Aluminium (Taishan) Co., Ltd 0.00%
Tianjin Ruixin Electric Heat Transmission
Technology Co., Ltd
Tianjin Ruixin Electric Heat Transmission
Technology Co., Ltd
0.00%
USA Worldwide Door Components (Pinghu)
Co., Ltd.; Worldwide Door Components
(Pinghu) Co
USA Worldwide Door Components (Pinghu) Co.,
Ltd.; Worldwide Door Components (Pinghu) Co
0.00%
Zhejiang Yongkang Listar Aluminium
Industry Co., Ltd
Zhejiang Yongkang Listar Aluminium Industry
Co., Ltd
0.00%
Zhongshan Gold Mountain Aluminium
Factory Ltd
Zhongshan Gold Mountain Aluminium Factory Ltd 0.00%
Justhere Co., Ltd n/a 85.73%
Kromet International Inc n/a 85.66%
Permasteelisa Hong Kong Ltd 30 n/a 85.73%
Union Industry (Asia) Co., Ltd n/a 85.73%

Anti-dumping order Exporter  Producer Duty rate Data source
Allied Maker Limited n/a 85.94%
Birchwoods (Lin'an) Leisure Products Co.,
Ltd
n/a 85.94%
Changzhou Changzheng Evaporator Co.,
Ltd
n/a 85.94%
Dongguan Aoda Aluminum Co., Ltd n/a 85.94%
JMA (HK) Company Limited n/a 85.94%
Kam Kiu Aluminium Products Sdn Bhd n/a 85.94%
Metaltek Group Co., Ltd n/a 85.94%
Tianjin Jinmao Import & Export Corp., Ltd n/a 85.94%
tenKsolar (Shanghai) Co., Ltd n/a 85.96%
PRC-wide entity n/a 85.96%
Sheet and Strip Taiyuan Ridetaixing Precision Stainless
Steel Incorporated Co., Ltd
Taiyuan Ridetaixing Precision Stainless Steel
Incorporated Co., Ltd
45.26%
Zhangjiagang Pohang Stainless Steel Co.,
Ltd
Zhangjiagang Pohang Stainless Steel Co., Ltd 45.26%
PRC-Wide Entity PRC-Wide Entity 58.04%

ANNEX E-8
DATA INPUTS FOR US MARKET VALUES IN 2017
Anti-dumping order
Total US
market
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)1
Data sources
Aluminum Extrusions [[***]] 5,537,962 [[***]] 1,077,900 Value of US shipments estimated by applying annual growth
rates to the 2015 value of US shipments reported in USITC
publication 4677.2 Data on the value of US imports from China
from US Customs (Exhibit USA-21 (BCI)). Data on the value of
US imports from the rest of the world based on HTS aggregated
data from the US Census Bureau (United States' response to
Arbitrator question No. 62, para. 73).
Bags [[***]] 1,120,838 [[***]] 280,300 Value of US shipments provided by the United States based on
data from USITC publication 4605 (Exhibit USA-58). Data on the
value of US imports from China from US Customs (Exhibit USA-
30 (BCI)). Value of US imports from the rest of the world based
on HTS aggregated data from the US Census Bureau (Exhibit
USA-57).
Coated Paper [[***]] 1,125,000 [[***]] 1,554,800 Value of US shipments provided by the United States based on
data from USITC publication 4656 (Exhibit USA-58). Data on the
value of US imports from China from US Customs (Exhibit USA-
30 (BCI)). Value of US imports from the rest of the world based
on HTS aggregated data from the US Census Bureau (Exhibit
USA-57).

1 The value of 2017 US imports from the rest of the world is derived by subtracting the value of US imports from China from the total value of US imports from
the world, both reported in Exhibit USA-57.
2 For Aluminum Extrusions, the United States contends that the 2017 value of US shipments is USD 5.8 billion. (United States' response to Arbitrator question
No. 62, para. 65). However, we note that the USITC reports the 2015 value of US shipments to be USD 5.28 billion and that the United States proposes to use a
2015-2016 growth rate of 1.8% and a 2016-2017 growth rate of 3.1%. Using these figures, we estimate the 2017 value of US shipments to be USD 5,537,962,000.

Anti-dumping order
Total US
market
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)1
Data sources
Diamond Sawblades [[***]] 79,745 [[***]] 213,500 Value of US shipments estimated by the United States by
applying a growth rate to the 2014 value of US shipments
reported in USITC publication 4559 (Exhibit USA-58). Data on
the value of US imports from China from US Customs (Exhibit
USA-30 (BCI)). Value of US imports from the rest of the world
based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
Furniture [[***]] 700,000 [[***]] 1,991,300 Value of US shipments estimated by the United States by
applying estimated growth rates to the 2015 value of US
shipments reported in USITC publication 4665 (Exhibit USA-58).
Data on the value of US imports from China from US Customs
(Exhibit USA-30 (BCI)). Value of US imports from the rest of the
world based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
OCTG [[***]] 4,000,000 [[***]] 2,913,200 Value of US shipments estimated by the United States by
multiplying the average US price by the corresponding estimated
US production quantity based on data from Preston Pipe and
Tube (Exhibit USA-58). Data on the value of US imports from
China from US Customs (Exhibit USA-30 (BCI)). Value of US
imports from the rest of the world based on HTS aggregated
data from the US Census Bureau (Exhibit USA-57).
OTR Tires [[***]] 915,650 [[***]] 9,100 Value of US shipments provided by the United States based on
data from USITC publication 4448 (Exhibit USA-58). Data on the
value of US imports from China from US Customs (Exhibit USA-
30 (BCI)). Value of US imports from the rest of the world based
on HTS aggregated data from the US Census Bureau (Exhibit
USA-57).
PET Film [[***]] 766,472 [[***]] 588,200 Value of US shipments provided by the United States based on
data from USITC publication 4605 (Exhibit USA-58). Data on the
value of US imports from China from US Customs (Exhibit USA-
30 (BCI)). Value of US imports from the rest of the world based
on HTS aggregated data from the US Census Bureau (Exhibit
USA-57).

Anti-dumping order
Total US
market
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)1
Data sources
Ribbons [[***]] 510,208 [[***]] 31,500 Value of US shipments estimated by the United States by
applying a growth rate to the data published in the US Census
Bureau's 2016 Annual Survey of Manufactures (Exhibit USA-58).
Data on the value of US imports from China from US Customs
(Exhibit USA-30 (BCI)). Value of US imports from the rest of the
world based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
Shrimp [[***]] 494,000 [[***]] 5,959,500 Value of US shipments provided by the United States based on
data from the 2016 Fisheries of the United States Report of the
National Oceanic and Atmospheric Administration (Exhibit USA-
58). Data on the value of US imports from China from US
Customs (Exhibit USA-30 (BCI)). Value of US imports from the
rest of the world based on HTS aggregated data from the US
Census Bureau (Exhibit USA-57).
Solar Panels [[***]] 325,920 [[***]] 5,652,300 Value of US shipments estimated by the United States by
multiplying the average price reported by the US Department of
Energy by the production quantity reported by the International
Energy Agency (Exhibit USA-58). Data on the value of US
imports from China from US Customs (Exhibit USA-30 (BCI)).
Value of US imports from the rest of the world based on HTS
aggregated data from the US Census Bureau (Exhibit USA-57).
Steel Cylinders [[***]] 64,000 [[***]] 5,200 Value of US shipments estimated by the United States based on
TriMas Corporation's 2017 annual report (Exhibit USA-58). Data
on the value of US imports from China from US Customs (Exhibit
USA-30 (BCI)). Value of US imports from the rest of the world
based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
Wood Flooring [[***]] 490,000 [[***]] 614,600 Value of US shipments estimated by the United States by
applying a growth rate to the 2016 value of US shipments
reported in USITC publication 4665 (Exhibit USA-58). Data on
the value of US imports from China from US Customs (Exhibit
USA-30 (BCI)). Value of US imports from the rest of the world
based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).

Anti-dumping order
Total US
market
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)1
Data sources
Copper Pipe and Tube [[***]] 1,940,000 [[***]] 448,400 Value of US shipments estimated by the United States by
applying a growth rate to the 2015 US shipment value reported
in USITC Publication 4650 (Exhibit USA-58). Data on the value of
US imports from China from US Customs (Exhibit USA-30 (BCI)).
Value of US imports from the rest of the world based on HTS
aggregated data from the US Census Bureau (Exhibit USA-57).
Iron Pipe Fittings [[***]] 481,967 [[***]] 31,800 Value of US shipments estimated by the United States by
applying a growth rate to the estimated 2016 value of US
shipments of all fabricated pipe and pipe fittings based on the US
Census Bureau's 2016 Annual Survey of Manufacturers (Exhibit
USA-58). Data on the value of US imports from China from US
Customs (Exhibit USA-30 (BCI)). Value of US imports from the
rest of the world based on HTS aggregated data from the US
Census Bureau (Exhibit USA-57).
Passenger Vehicle and
Light Truck Tires
[[***]] 11,740,449 [[***]] 8,616,200 Value of US shipments provided by the United States based on
data reported in USITC publication 4545 (Exhibit USA-58). Data
on the value of US imports from China from US Customs (Exhibit
USA-30 (BCI)). Value of US imports from the rest of the world
based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
Residential Washers [[***]] 3,121,197 [[***]] 1,552,500 Value of US shipments estimated by subtracting the total value
of US imports from total value of the US market based on AHAM
data (Exhibit CHN-56 (BCI)). Data on the value of US imports
from China from US Customs (Exhibit USA-30 (BCI)). Value of
US imports from the rest of the world based on HTS aggregated
data from the US Census Bureau (Exhibit USA-57).
Sheet and Strip [[***]] 3,623,089 [[***]] 892,800 Value of US shipments estimated by the United States by
multiplying the average US price of subject imports, based on
data from USITC DataWeb, by the subject HTS8's share of the
broader HTS categories related to flat steel products, based on
data from USITC DataWeb, and by the American Iron and Steel
Institute's production estimate for stainless steel sheet and strip
(Exhibit USA-58). Data on the value of US imports from China
from US Customs (Exhibit USA-30 (BCI)). Value of US imports
from the rest of the world based on HTS aggregated data from
the US Census Bureau (Exhibit USA-57).

Anti-dumping order
Total US
market
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)1
Data sources
Steel Flat Products [[***]] 8,216,479 [[***]] 2,002,700 Value of US shipments provided by the United States based on
data reported in USITC Publication 4619 (Exhibit USA-58). Data
on the value of US imports from China from US Customs (Exhibit
USA-30 (BCI)). Value of US imports from the rest of the world
based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
Steel Line Pipe [[***]] 542,483 [[***]] 605,600 Value of US shipments estimated by the United States by
multiplying the average US price by the 2017 total production
quantity of welded line pipe multiplied by the share of all line
pipe less than 16 inches, based on data from Preston Pipe and
Tube (Exhibit USA-58). Data on the value of US imports from
China from US Customs (Exhibit USA-30 (BCI)). Value of US
imports from the rest of the world based on HTS aggregated
data from the US Census Bureau (Exhibit USA-57).
Steel Nails [[***]] 139,285 [[***]] 477,600 Value of US shipments estimated by the United States by
applying a growth rate and a share reflecting the correct product
scope to the 2016 value of US shipments based on the US
Census Bureau's 2016 Annual Survey of Manufacturers (Exhibit
USA-58). Data on the value of US imports from China from US
Customs (Exhibit USA-30 (BCI)). Value of US imports from the
rest of the world based on HTS aggregated data from the US
Census Bureau (Exhibit USA-57).
Steel Pipe [[***]] 923,716 [[***]] 1,461,600 Value of US shipments estimated by the United States by
adjusting the data in 2016 reported in USITC publication 4651
(Exhibit USA-58). Data on the value of US imports from China
from US Customs (Exhibit USA-30 (BCI)). Value of US imports
from the rest of the world based on HTS aggregated data from
the US Census Bureau (Exhibit USA-57).
Steel Products [[***]] 12,364,944 [[***]] 3,403,900 Value of US shipments estimated by the United States by
multiplying the average price of subject imports, based on data
from USITC DataWeb, by the subject HTS8's share of the
broader HTS categories related to flat steel products, based on
data from USITC DataWeb, and by the American Iron and Steel
Institute's production estimate for flat steel products (Exhibit
USA-58). Data on the value of US imports from China from US
Customs (Exhibit USA-30 (BCI)). Value of US imports from the

Anti-dumping order
Total US
market
(1,000 USD)
US
shipments
(1,000 USD)
US imports
from China
(1,000 USD)
US imports
from the rest
of the world
(1,000 USD)1
Data sources
rest of the world based on HTS aggregated data from the US
Census Bureau (Exhibit USA-57).
Steel Standard, Line, and
Pressure Pipe
[[***]] 137,584 [[***]] 680,300 Annualized value of US shipments provided by the United States
based on data from USITC publication 4656 (Exhibit USA-58).
Data on the value of US imports from China from US Customs
(Exhibit USA-30 (BCI)). Value of US imports from the rest of the
world based on HTS aggregated data from the US Census Bureau
(Exhibit USA-57).
Steel Wire Rod [[***]] 427,645 [[***]] 1,024,280 Value of US shipments estimated by the United States by
multiplying the average price of subject imports, based on data
from USITC DataWeb, by the subject HTS8's share of the
broader HTS categories related to wire rod, based on data from
USITC DataWeb, and by the American Iron and Steel Institute's
production estimate for wire rod (Exhibit USA-58). Data on the
value of US imports from China from US Customs (Exhibit USA-
30 (BCI)). Value of US imports from the rest of the world based
on HTS aggregated data from the US Census Bureau (Exhibit
USA-57)
Note: The values in this table have been rounded for display purposes only. The actual values were used when implementing the Armington model under the two
steps to estimate the level of nullification or impairment.

ANNEX E-9
CODE AND TEXT VERSION OF THE ARMINGTON MODEL1

clear all
capture program drop all

************************* SOLUTION OF THE ARMINGTON MODEL *************************

program nlArmington
 syntax varlist(min=2 max=2) [if], at(name)
 // Specify name
 local RHS: word 1 of `varlist'
 local exogenous: word 2 of `varlist'

 // Specify the temporary variable names
 tempname p_us p_wat p_prc p_roc p_row epsilon_us epsilon_wat epsilon_prc ///
 epsilon_roc epsilon_row m_us m_wat m_prc m_roc m_row Y theta ///
 sigma t0_wat t_wat t0_prc t_prc t0_roc t_roc LHS P Q a_us a_wat ///
 a_prc a_roc a_row b_us b_wat b_prc b_roc b_row QS_us QS_wat ///
 QS_prc QS_roc QS_row QD_us QD_wat QD_prc QD_roc QD_row

 // Specify the endogenous parameters
 scalar `p_us' = `at'[1, 1] // US shipments
 scalar `p_wat' = `at'[1, 2] // US imports from China subject to WA-T rate
 scalar `p_prc' = `at'[1, 3] // US imports from China subject to PRC-wide rate
 scalar `p_roc' = `at'[1, 4] // US imports from the rest of China
 scalar `p_row' = `at'[1, 5] // US imports from the rest of the world

 // Specify the exogenous parameters (i.e. elasticities, initial market
 // shares, initial total expenditure and initial anti-dumping duties)
 local i = 1
 foreach param in epsilon_us epsilon_wat epsilon_prc epsilon_roc ///
 epsilon_row m_us m_wat m_prc m_roc m_row Y theta sigma ///
 t0_wat t_wat t0_prc t_prc t0_roc t_roc {
 levelsof `exogenous' in `i'
 generate double ``param'' = `r(levels)'
 local i = `i' + 1

 replace `t0_wat' = 0 if `t0_wat' == .

 // Specify the initial market clearance conditions
 generate double `LHS' = 0

 // Compute the index price
 generate double `P' = (`m_us'/100 * `p_us' ^(1 - `sigma') + ///
 `m_wat'/100 * `p_wat' ^(1 - `sigma') + ///
 `m_prc'/100 * `p_prc' ^(1 - `sigma') + ///
 `m_roc'/100 * `p_roc' ^(1 - `sigma') + ///
 `m_row'/100 * `p_row' ^(1 - `sigma')) ///
 ^(1/(1 - `sigma'))

 // Compute the aggregate demand
 generate double `Q' = `Y' * `P' ^`theta'

 local i = 1
 foreach x in us wat prc roc row {
 // Compute the shifting factors
 if "`x'" == "us" | "`x'" == "row" generate double ///
 `a_`x'' = `Y' * `m_`x''/100

1 This Stata code (do-file) has been reviewed using STATA 13 (and above).

 if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double ///
 `a_`x'' = `Y' * `m_`x''/100 * (1 + `t0_`x''/100) ^(`epsilon_`x'')
 generate double `b_`x'' = exp(ln(`m_`x''/100) / `sigma')
 replace `b_`x'' = 0 if `m_`x'' == 0 | `m_`x'' == .

 // Compute the supply functions
 if "`x'" == "us" | "`x'" == "row" generate double ///
 `QS_`x'' = `a_`x'' * (`p_`x'') ^`epsilon_`x''
 if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double ///
 `QS_`x'' = `a_`x'' * ((`p_`x'')/(1 + `t_`x''/100)) ^`epsilon_`x''

 // Compute the demand functions
 generate double `QD_`x'' = `Q' * (`b_`x''^`sigma') * ///
 (`p_`x''/`P')^(-`sigma')

 // Compute the market clearance conditions
 replace `LHS' = `QD_`x'' - `QS_`x'' in `i'
 if `i' == 5 replace `LHS' = `QD_`x'' - `QS_`x'' + 1 in `i'

 local i = `i' + 1

 // Ensure the market clearance conditions are met
 replace `RHS' = `LHS'
end

********************* CORRESPONDING PRICES AND QUANTITIES **********************

program define dPQ
 // Specify the input variables:
 * `1': variable with prices
 * `2': variable with exogenous parameters

 // Specify the temporary variable names
 tempname p_us p_wat p_prc p_roc p_row epsilon_us epsilon_wat epsilon_prc ///
 epsilon_roc epsilon_row m_us m_wat m_prc m_roc m_row Y theta ///
 sigma t0_wat t_wat t0_prc t_prc t0_roc t_roc LHS P Q a_us a_wat ///
 a_prc a_roc a_row

 // Specify the parameters
 local i = 1
 foreach param in p_us p_wat p_prc p_roc p_row epsilon_us epsilon_wat ///
 epsilon_prc epsilon_roc epsilon_row m_us m_wat m_prc ///
 m_roc m_row Y theta sigma t0_wat t_wat t0_prc t_prc ///
 t0_roc t_roc {
 if `i' <= 5 scalar ``param'' = `1' in `i'
 if `i' > 5 local j = `i' - 5
 if `i' > 5 scalar ``param'' = `2' in `j'
 local i = `i' + 1

 // Compute the index price
 generate double `P' = (`m_us'/100 * `p_us' ^(1 - `sigma') + ///
 `m_wat'/100 * `p_wat' ^(1 - `sigma') + ///
 `m_prc'/100 * `p_prc' ^(1 - `sigma') + ///
 `m_roc'/100 * `p_roc' ^(1 - `sigma') + ///
 `m_row'/100 * `p_row' ^(1 - `sigma')) ///
 ^(1/(1 - `sigma'))

 // Compute the aggregate demand
 generate double `Q' = `Y' * `P' ^`theta'

 local i = 1
 foreach x in us wat prc roc row {
 // Compute the shifting factors
 if "`x'" == "us" | "`x'" == "row" generate double ///
 `a_`x'' = `Y' * `m_`x''/100
 if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double ///

 `a_`x'' = `Y' * `m_`x''/100 * (1 + `t0_`x''/100) ^(`epsilon_`x'')

 // Compute the percent changes in prices
 generate double dp_`x' = (p_`x' - 1) * 100 in 1

 // Compute the initial equilibrium quantities
 if "`x'" == "us" | "`x'" == "row" generate double ///
 iniq_`x' = `a_`x'' * 1 ^`epsilon_`x'' in 1
 if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double ///
 iniq_`x' = `a_`x'' * (1 / (1 + `t0_`x''/100)) ^`epsilon_`x'' in 1

 // Compute the new equilibrium quantities
 if "`x'" == "us" | "`x'" == "row" generate double ///
 newq_`x' = `a_`x'' * (p_`x') ^`epsilon_`x'' in 1
 if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double ///
 newq_`x' = `a_`x'' * ( p_`x' / (1 + `t_`x''/100)) ^`epsilon_`x'' in 1

 // Compute the percent changes in quantities
 generate double dq_`x' = (newq_`x' - iniq_`x')/iniq_`x' * 100 in 1
 if dq_`x' == . replace dq_`x' = 0 in 1

 // Compute the new expenditures
 generate double newX_`x' = p_`x' * newq_`x' in 1

 // Compute the change in expenditures
 generate double dX_`x' = (newX_`x' - iniq_`x') in 1

end

*************************** IMPLEMENTATION OF STEP 1 ***************************

* Import data inputs for each anti-dumping order reported in Appendix Table [XX]
* Appendix Table [XX] saved in an Excel file named "Data.xlsx"

 import excel "Data.xlsx", firstrow clear
 rename Antidumpingorder Product
 drop if Product == ""

* Remove the double brackets for BCI inputs
 foreach var in m_us m_wat m_prc m_roc m_row Y Y2017 t_wat t_roc {
 replace `var' = subinstr(`var',"[[","",1)
 replace `var' = subinstr(`var',"]]","",1)
 destring `var', replace force

* Create additional inputs
 foreach var in wat prc roc {
 generate double epsilon_`var' = epsilon_import
 generate double t0_`var' = 0
 rename t_`var' t1_`var'

 rename epsilon_import epsilon_row
 save "Inputs.dta", replace

* Solve the Armington model for each anti-dumping order at issue in the year
* prior to the imposition of the anti-dumping duty rates
 use "Inputs.dta", clear
 levelsof Product, local(Product)
 foreach product of local Product {
 use "Inputs.dta", clear
 keep if Product == "`product'"
 display " "
 display "********************* `product' *********************"
 quietly {
 * Create constraints and exogenous variables structure
 set obs 19
 generate double MrktEq = 0

 replace MrktEq = 1 in 5
 local i = 1
 generate paramname = ""
 generate double param = .
 foreach param in epsilon_us epsilon_wat epsilon_prc ///
 epsilon_roc epsilon_row m_us m_wat m_prc ///
 m_roc m_row Y theta sigma t0_wat t1_wat ///
 t0_prc t1_prc t0_roc t1_roc {
 levelsof `param' in 1, local(temp)
 replace paramname = "`param'" in `i'
 capture replace param = `temp' in `i'
 replace param = 0 if param == . in `i'
 local i = `i' + 1

 * Solve the Armington model with imposition of anti-dumping duties
 nl Armington @ MrktEq param, param(p_us p_wat p_prc p_roc p_row) ///
 initial(p_us 1 p_wat 1 p_prc 1 p_roc 1 p_row 1) eps(1e-12)
 quietly {
 matrix B = e(b)
 svmat double B
 local i = 1
 foreach x in us wat prc roc row {
 rename B`i' p_`x' // New price
 local i = `i' + 1

 * Compute new market shares
 matrix B = B'
 svmat double B
 dPQ B param
 egen double Y1 = rowtotal(newX_*)
 foreach x in us wat prc roc row {
 generate double m1_`x' = newX_`x' / Y1 * 100

 drop p_* dp_* iniq_* newq_* dq_* newX_* dX_* MrktEq param* B1
 keep in 1

 quietly save "`product'.dta", replace

 quietly keep if Product == "?"
 foreach product of local Product {
 append using "`product'.dta"
 erase "`product'.dta"

*************************** IMPLEMENTATION OF STEP 2 ***************************

* Create additional inputs
 generate double t2_wat = 0
 * Brackets should be removed before running the code
 replace t2_wat = [[***]] if Product == "OCTG" // This is BCI
 generate double t2_prc = 0
 generate double t2_roc = t1_roc
 save "Inputs.dta", replace

* Solve the Armington model ifor each anti-dumping order at issue in 2017 by using
* the simulated market shares associated with the imposition of the anti-dumping
* duty rates and calculated in step 1
 use "Inputs.dta", clear
 levelsof Product, local(Product)
 foreach product of local Product {
 use "Inputs.dta", clear
 keep if Product == "`product'"
 display " "
 display "********************* `product' *********************"
 quietly {
 * Create constraints and exogenous variables structure

 set obs 19
 generate double MrktEq = 0
 replace MrktEq = 1 in 5
 local i = 1
 generate paramname = ""
 generate double param = .
 foreach param in epsilon_us epsilon_wat epsilon_prc ///
 epsilon_roc epsilon_row m1_us m1_wat m1_prc ///
 m1_roc m1_row Y2017 theta sigma t1_wat t2_wat ///
 t1_prc t2_prc t1_roc t2_roc {
 levelsof `param' in 1, local(temp)
 replace paramname = "`param'" in `i'
 capture replace param = `temp' in `i'
 replace param = 0 if param == . in `i'
 local i = `i' + 1

 * Solve the Armington model for counterfactual anti-dumping duty rates
 nl Armington @ MrktEq param, param(p_us p_wat p_prc p_roc p_row) ///
 initial(p_us 1 p_wat 1 p_prc 1 p_roc 1 p_row 1) eps(1e-12)
 quietly {
 matrix B = e(b)
 svmat double B
 local i = 1
 foreach x in us wat prc roc row {
 rename B`i' p_`x' // New price
 local i = `i' + 1

 * Compute the level nullification or impairment
 matrix B = B'
 svmat double B
 dPQ B param
 generate double NI = dX_wat + dX_prc + dX_roc
 keep Product NI
 keep in 1

 quietly save "`product'.dta", replace

 quietly keep if Product == "?"
 foreach product of local Product {
 append using "`product'.dta"
 erase "`product'.dta"

ANNEX E-10
DATA INPUTS USED TO IMPLEMENT THE ARMINGTON MODEL UNDER THE TWO STEPS1
Anti-
dumping
order
theta epsilon
_us
epsilon
_import sigma m_us m_wat m_prc m_roc m_row Y Y 2017 t_wat t_prc t_roc
Aluminum
Extrusions -0.375 4.00 10.00 5.00 77.239 n/a [[***]] [[***]] 11.093 4606386.000 [[***]] n/a 85.96 [[***]]
Bags -0.450 3.00 10.00 5.00 77.579 n/a [[***]] [[***]] [[***]] 995491.000 [[***]] n/a 77.57 [[***]]
Coated
Paper -1.000 4.00 10.00 3.00 58.758 [[***]] [[***]] [[***]] 24.165 1742204.000 [[***]] [[***]] 135.84 [[***]]
Diamond
Sawblades -0.750 5.00 10.00 3.00 [[***]] n/a [[***]] [[***]] 36.115 [[***]] [[***]] n/a 82.05 [[***]]
Furniture -0.750 4.50 10.00 4.50 40.259 n/a [[***]] [[***]] [[***]] 4666667.000 [[***]] n/a 216.01 [[***]]
OCTG -0.875 3.00 10.00 4.00 [[***]] [[***]] [[***]] [[***]] 31.560 [[***]] [[***]] [[***]] 99.14 [[***]]
OTR Tires -0.250 7.50 10.00 4.00 56.066 n/a [[***]] [[***]] 28.197 1794409.000 [[***]] n/a 105.31 [[***]]
PET Film -0.750 3.50 10.00 4.50 [[***]] n/a [[***]] [[***]] 17.791 [[***]] [[***]] n/a 76.72 [[***]]
Ribbons -1.250 5.00 10.00 4.00 89.197 n/a [[***]] [[***]] [[***]] 650438.000 [[***]] n/a 247.26 [[***]]
Shrimp -2.000 3.50 10.00 4.00 [[***]] n/a [[***]] [[***]] 82.273 [[***]] [[***]] n/a 112.81 [[***]]

1 The code (do-file) of the software STATA in Annex E-9 refers to this input table.

Anti-
dumping
order
theta epsilon
_us
epsilon
_import sigma m_us m_wat m_prc m_roc m_row Y Y 2017 t_wat t_prc t_roc
Solar Panels -0.875 6.00 10.00 4.00 [[***]] n/a [[***]] [[***]] 41.144 [[***]] [[***]] n/a 238.95 [[***]]
Steel
Cylinders -0.500 7.50 10.00 4.00 [[***]] [[***]] [[***]] [[***]] 2.705 [[***]] [[***]] [[***]] 31.21 [[***]]
Wood
Flooring -1.000 5.50 10.00 4.00 43.517 n/a [[***]] [[***]] 14.770 783896.000 [[***]] n/a 25.62 [[***]]
Copper Pipe
and Tube -0.875 2.00 10.00 4.00 75.958 n/a [[***]] [[***]] 12.474 2110170.000 [[***]] n/a 60.85 [[***]]
Iron Pipe
Fittings -1.250 4.50 10.00 4.50 [[***]] n/a [[***]] [[***]] 12.310 [[***]] [[***]] n/a 75.5 [[***]]
Passenger
Vehicle and
Light Truck
Tires
-0.375 3.00 10.00 4.00 52.995 n/a [[***]] [[***]] 35.442 22154265.000 [[***]] n/a 76.46 [[***]]
Residential
Washers -0.550 7.00 10.00 4.00 [[***]] n/a [[***]] [[***]] [[***]] [[***]] [[***]] n/a 49.72 [[***]]
Sheet and
Strip -0.750 5.00 10.00 4.00 [[***]] n/a [[***]] [[***]] 19.791 [[***]] [[***]] n/a 76.64 [[***]]
Steel Flat
Products -0.500 6.00 10.00 4.00 80.830 n/a [[***]] [[***]] 15.652 8405722.000 [[***]] n/a 199.76 [[***]]
Steel Line
Pipe -0.375 4.00 10.00 3.00 [[***]] n/a [[***]] [[***]] 33.561 [[***]] [[***]] n/a 101.1 [[***]]
Steel Nails -0.375 4.00 10.00 4.00 22.393 n/a [[***]] [[***]] [[***]] 984270.000 [[***]] n/a 118.04 [[***]]
Steel Pipe -0.625 4.00 10.00 5.00 61.810 n/a [[***]] [[***]] 16.647 2185379.000 [[***]] n/a 85.55 [[***]]

Anti-
dumping
order
theta epsilon
_us
epsilon
_import sigma m_us m_wat m_prc m_roc m_row Y Y 2017 t_wat t_prc t_roc
Steel
Products -0.750 6.00 10.00 4.00 78.869 n/a [[***]] [[***]] [[***]] 17055633.000 [[***]] n/a 199.43 [[***]]
Steel
Standard,
Line, and
Pressure
Pipe
-0.750 7.50 10.00 3.00 29.180 n/a [[***]] [[***]] 51.025 683206.000 [[***]] n/a 98.74 [[***]]
Steel Wire
Rod -0.625 2.00 10.00 4.00 [[***]] n/a [[***]] [[***]] 25.287 [[***]] [[***]] n/a 97.24 [[***]]
Note: The names used in the table refer to the following: theta: total demand elasticity; epsilon_us: domestic supply elasticity; epsilon_import: import supply
elasticity; sigma: elasticity of substitution; m_us: market share of US domestic producers in year prior; m_wat: market share of Chinese exporters subject to
WTO-inconsistent WA-T duty rate in year prior; m_prc: market share of Chinese exporters subject to WTO-inconsistent PRC-wide duty rate in year prior; m_roc:
market share of remaining Chinese exporters in year prior; m_row: market share of exporters from rest of the world in year prior; Y: total US market value in
1,000 USD in year prior; Y 2017: total US market value in 1,000 USD in 2017; t_wat: WA-T duty rate; t_prc: PRC-wide duty rate; and t_roc: duty rate for
remaining Chinese exporters in 2017.

ANNEX E-11
RESULTS OF IMPLEMENTING THE ARMINGTON MODEL UNDER THE FIRST STEP
Anti-dumping order
Simulated market
share of US
domestic
producers
Simulated market
share of Chinese
exporters subject
to the WA-T duty
rate
Simulated market
share of Chinese
exporters subject
to the PRC-wide
duty rate
Simulated market
share of remaining
Chinese exporters
Simulated market
share of exporters
from the rest of the
world
Aluminum Extrusions 84.3% n/a [[***]]% [[***]]% 12.6%
Bags [[***]]% n/a [[***]]% [[***]]% [[***]]%
Coated Paper 60.0% [[***]]% [[***]]% n/a 24.8%
Diamond Sawblades [[***]]% n/a [[***]]% [[***]]% 40.0%
Furniture [[***]]% n/a [[***]]% [[***]]% [[***]]%
OCTG [[***]]% [[***]]% [[***]]% [[***]]% 37.9%
OTR Tires 61.3% n/a [[***]]% [[***]]% 31.1%
PET Film [[***]]% n/a [[***]]% [[***]]% 18.2%
Ribbons [[***]]% n/a [[***]]% [[***]]% [[***]]%
Shrimp [[***]]% n/a [[***]]% [[***]]% 84.9%
Solar Panels [[***]]% n/a [[***]]% [[***]]% 53.0%
Steel Cylinders [[***]]% [[***]]% [[***]]% [[***]]% 3.1%
Wood Flooring 48.9% n/a [[***]]% [[***]]% 16.9%
Copper Pipe and Tube 78.7% n/a [[***]]% [[***]]% 13.2%
Iron Pipe Fittings [[***]]% n/a [[***]]% [[***]]% 13.2%

Anti-dumping order
Simulated market
share of US
domestic
producers
Simulated market
share of Chinese
exporters subject
to the WA-T duty
rate
Simulated market
share of Chinese
exporters subject
to the PRC-wide
duty rate
Simulated market
share of remaining
Chinese exporters
Simulated market
share of exporters
from the rest of the
world
Passenger Vehicle and Light Truck Tires 53.9% n/a [[***]]% [[***]]% 36.4%
Residential Washers [[***]]% n/a [[***]]% [[***]]% 15.9%
Sheet and Strip [[***]]% n/a [[***]]% [[***]]% 20.1%
Steel Flat Products 83.4% n/a [[***]]% n/a 16.2%
Steel Line Pipe [[***]]% n/a [[***]]% [[***]]% 34.8%
Steel Nails [[***]]% n/a [[***]]% [[***]]% 36.4%
Steel Pipe 72.8% n/a [[***]]% [[***]]% 20.9%
Steel Products [[***]]% n/a [[***]]% [[***]]% 18.7%
Steel Standard, Line, and Pressure Pipe 33.2% n/a [[***]]% [[***]]% 58.4%
Steel Wire Rod [[***]]% n/a [[***]]% [[***]]% 26.7%
Note: The percentage values in this table have been rounded for display purposes only. The actual percentage values were used when implementing the Armington
model under the second step to estimate the level of nullification or impairment.