[Federal Register Volume 59, Number 71 (Wednesday, April 13, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-8909]
[[Page Unknown]]
[Federal Register: April 13, 1994]
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DEPARTMENT OF COMMERCE
[A-580-806]
Sweaters Wholly or in Chief Weight of Man-Made Fiber From Korea;
Final Results of Antidumping Duty Administrative Review
AGENCY: International Trade Administration/Import Administration,
Department of Commerce.
ACTION: Notice of final results of antidumping duty administrative
review.
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SUMMARY: On December 3, 1993, the Department of Commerce published the
preliminary results of its administrative review of the antidumping
duty order on sweaters wholly or in chief weight of man-made fiber from
Korea. The review covers 69 manufacturers/exporters and the period
April 27, 1990 through August 31, 1991.
We gave interested parties an opportunity to comment on our
preliminary results. Based on our analysis of the comments received we
have changed the results from those presented in the preliminary
results of review.
EFFECTIVE DATE: April 13, 1994.
FOR FURTHER INFORMATION CONTACT: Elisabeth Urfer, G. Leon McNeill, or
Maureen Flannery, Office of Antidumping Compliance, International Trade
Administration, U.S. Department of Commerce, 14th Street and
Constitution Avenue NW., Washington, DC 20230; telephone: (202) 482-
4733.
SUPPLEMENTARY INFORMATION:
Background
On September 24, 1990, the Department of Commerce (the Department)
published in the Federal Register (55 FR 39036) the antidumping duty
order on sweaters wholly or in chief weight of man-made fiber (MMF
sweaters) from Korea. On September 30, 1991, the petitioner, the
National Knitwear & Sportswear Association (NKSA), requested that we
conduct an administrative review, in accordance with section 353.22(a)
of the Department's regulations (19 CFR 353.22(a)). We published the
notice of initiation of the antidumping duty administrative review on
October 18, 1991 (56 FR 52254), covering the period April 27, 1990
through August 31, 1991. On December 3, 1993 the Department published
the preliminary results in the Federal Register (58 FR 63920). The
initiation notice named 69 companies. Of these 69 companies, the
following six companies were selected to be analyzed, using sampling
techniques: Chunji Industrial Company, Ltd. (Chunji), Kee Ryung
Industrial Company, Ltd. (Kee Ryung), Suhcheon Company, Ltd.
(Suhcheon), Tae Kwang Industrial Company, Ltd. (Tae Kwang), Young Woo &
Company, Ltd. (Young Woo), and Yurim Company, Ltd. (Yurim). The other
companies included in the sample pool have received a rate which is the
simple average of the margins of these six companies. The Department
has now conducted the review in accordance with section 751 of the
Tariff Act of 1930, as amended (the Tariff Act).
Scope of the Review
Imports covered by this review are shipments of MMF sweaters from
Korea. MMF sweaters are defined as garments for outerwear that are
knitted or crocheted, in a variety of forms including jacket, vest,
cardigan with button or zipper front, or pullover, usually having
ribbing around the neck, bottom, and cuffs on the sleeves (if any),
encompassing garments of various lengths, wholly or in chief weight of
man-made fiber. The term ``in chief weight of man-made fiber'' includes
sweaters where the man-made fiber material predominates by weight over
each other single textile material. This excludes sweaters 23 percent
or more by weight of wool. It includes men's, women's, boys', or girls'
sweaters, as defined above, but does not include sweaters for infants
24 months of age or younger. It includes all sweaters as defined above,
regardless of the number of stitches per centimeter, provided that,
with regard to sweaters having more than nine stitches per two linear
centimeters horizontally, it includes only those with a knit-on rib at
the bottom.
Garments which extend below mid-thigh or cardigans that contain a
sherpa lining or heavy-weight fiberfill lining, including quilted
linings, used to provide extra warmth to the wearer, are not considered
sweaters and are excluded from the scope of the review. Also
specifically excluded from the scope are sweaters assembled in Guam
that are produced from knit-to-shape component parts knit in and
imported from Korea and entering under Harmonized Tariff Schedule (HTS)
item number 9902.61.
The subject merchandise is currently classifiable under HTS item
numbers 6110.30.30.10, 6110.30.30.15, 6110.30.30.20, 6110.30.30.25,
6103.23.00.70, 6103.29.10.40, 6103.29.20.62, 6104.23.00.40,
6104.29.10.60, 6104.29.20.60, 6110.30.10.10, 6110.30.10.20,
6110.30.20.10, and 6110.30.20.20. This merchandise may also enter under
HTS item numbers 6110.30.30.50 and 6110.30.30.55. The HTS item numbers
are provided for convenience and Customs purposes only. The written
description remains dispositive.
Analysis of the Comments Received
We gave interested parties an opportunity to comment on the
preliminary results of review. We received collective comments from
Chunji, Kee Ryung, Suhcheon, Tae Kwang, Young Woo, and Yurim. No
interested party submitted a rebuttal.
Comment 1: Respondents argue that the Department's excessive
reliance on constructed value (CV) distorted the calculation of the
dumping margins. They contend that the Department should rely on CV as
the basis for foreign market value (FMV) only with respect to U.S.
sales for which there are no similar, above-cost, contemporaneous
models sold in the third-country market. They note that 19 U.S.C.
1677b(a)(1) directs the Department to base FMV on home market prices
or, if home market sales are inadequate, third-country prices, unless
there are insufficient sales above cost in the appropriate market.
Respondents claim that the Department's use of the ``10/90/10''
test on a product-specific basis is inappropriate and contrary to the
mandate of the antidumping statute because it leads the Department to
disregard infrequent below-cost sales. As respondents explain the test,
if between 10 and 90 percent of third-country sales are below cost, the
Department excludes below-cost sales, basing FMV on the remaining
above-cost sales. If over 90 percent of third-country sales are below
cost, the Department excludes all third-country sales and bases FMV
entirely on CV. Below-cost sales are included in the calculation of CV
if the volume of such sales is less than ten percent. Respondents claim
that in past cases, including the original investigation, the
Department has applied the 10/90/10 test on total sales of such or
similar merchandise, and argue that this approach contemplates that,
under some circumstances, all sales of certain models may be below cost
because the sales may be of obsolete or end-of-the-year models. They
argue that when the test is applied on a product-specific basis, the
sales of such models will almost always be disregarded in calculating
the FMV even though, viewed in the aggregate, they are infrequent in
number.
Respondents state that the Department has recently begun applying a
two-tiered 10/90/10 system in which first the Department applies the
test, called the ``macro test,'' to total third-country sales; if the
macro test indicates that between 10 and 90 percent of total sales are
below cost, the Department then applies a second 10/90/10 test, called
the ``micro test,'' to each individual model sold in the third country.
Respondents go on to say that, more recently, the Department has in
several cases applied only the micro test.
Respondents contend that the Department's reliance solely on the
micro test is particularly distortive in this proceeding, because there
is frequently only one sale for each individual product. In many
instances, therefore, the third-country product will be either totally
above or totally below cost, even though only an insignificant fraction
of total third-country sales may be below cost. They argue that the
Department should have used the alternate third-country price data for
the next most similar model in calculating the FMV since they have
provided ample third-country price data for the top three most similar
models.
Respondents also contend that the Department, in considering only
one particular third-country model as ``such or similar merchandise,''
compounds its bias for CV. Respondents claim that a large number of
physical differences in sweaters make precise systemization and
quantification of such differences for model matching purposes
impossible. Identification of a single best match is, therefore, highly
arbitrary. They argue that, by contrast, pricing and cost are not
arbitrary because exporters face the same cost curve and compete based
on relative mark-up. They contend that for their six firms there are,
on average, 50 third-country models within a 20 percent cost range for
each U.S. model. Respondents also claim that the Department's refusal
to use prices for alternative third-country merchandise is tantamount
to finding that there is only one ``such or similar'' third-country
match for each U.S. model.
Respondents ask that for the final results the Department use CV
only if there are insufficient above-cost sales of similar products in
the third country. They suggest that the Department implement this
method by dropping all below-cost third-country sales before creating
its product concordance, thereby matching U.S. sales only to above-cost
third-country sales.
Department's Position: We disagree with respondents that we relied
excessively on CV. Specifically, we disagree with their claim that a
``macro'' test, rather than a model-specific, or ``micro,'' test, is
the appropriate method of determining what below-cost sales should be
disregarded. Section 773(b) of the Tariff Act directs us to disregard
below-cost sales in calculating FMV. As FMV is based on a model-
specific comparison and focuses on the prices actually used for FMV,
employing a model-specific methodology is the most appropriate approach
to the 10/90/10 test. For this reason, we have rejected using the
``macro'' test and have only tested individual models for sales below-
cost.
We also disagree with respondents' argument that we should drop all
below-cost third-country sales before creating our product concordance,
or model-match groupings. Section 771(16) of the Tariff Act defines
such or similar merchandise and provides a hierarchy of preferences for
determining which merchandise sold in the foreign market is most
similar to the merchandise sold in the United States. Whether a model
is sold in the home market or third countries at prices below cost is
not a criterion for determining what is most similar merchandise under
the statute. Therefore, we rejected the product concordances proposed
by respondents, which eliminated most similar models when those models
were sold at prices below cost.
In determining whether third-country sales were made at prices
below the cost of production (COP), we compared the sales prices of
each model to its COP. Below-cost sales were disregarded on a model-
specific basis in accordance with the 10/90/10 rule. If we found that
less than 10 percent of the sales of a model were made at less than
cost, we included all third-country sales of that model in the
calculation of FMV. If between 10 and 90 percent of third-country sales
of a specific model were made at less than cost, we disregarded those
sales made at less than cost and used the above-cost sales in the price
comparisons. If more than 90 percent of third-country sales of a model
were made at less than cost we disregarded all sales of that model.
For the preliminary results, where there were more than one equally
similar model, in accordance with our model match criteria as set out
in Appendix V of our questionnaire, we selected a single most similar
model, based on the cost differences between the third-country and U.S.
models. That is, we selected the one with the lowest cost difference.
If more than 90 percent of the sales of a model chosen as the most
similar third-country model were below cost, we used CV as the basis of
FMV. For these final results, rather than choose the single most
similar model based on cost differences, we used the pool of equally
similar models as long as those models were within the 20 percent cost
differential. When there was more than one equally similar above-cost
model, we adjusted the FMV of each model for differences in
merchandise, and then weight averaged the results. If any of these
models were found to be below cost, we excluded them from our analysis
and used only the above-cost models.
Comment 2: Respondents argue that in calculating COP for the final
results, the Department should use the respondents' 1990 selling,
general and administrative expenses (SG&A) rather than the 1990-91
average SG&A. They contend that most sales in this review were produced
in 1990, and because MMF sweater production and shipments vary from
season to season, SG&A for a full fiscal year should be used.
Department's Position: We agree with the respondents that we should
use SG&A expense data from full fiscal years to account for
seasonality. All the data which were averaged for the preliminary
review results were, in fact, full fiscal year data, derived from the
companies' annual financial statements. We disagree, however, with
respondents' argument that we should rely exclusively on 1990 SG&A. For
the final results for Kee Ryung, Suhcheon, Young Woo, and Yurim, whose
fiscal years are also the calendar year, the period of review includes
an equal number of months from each of the fiscal years and, therefore,
we have continued to use a simple average of 1990 and 1991 SG&A. For
Chunji, we have continued to add Chunji's SG&A for the fiscal year July
1, 1990 through June 30, 1991, to the average of its related company's
SG&A for the fiscal/calendar years 1990 and 1991. Twelve of the 16
review months occurred during the July 1, 1990 through June 30, 1991
period; of the remaining four months, we have data only for the two
months in the prior fiscal year, but not for the two months in the
subsequent fiscal year. Thus, it is appropriate to only use SG&A
expenses from the one fiscal year for Chunji. For Tae Kwang, we used a
weighted average SG&A, weighted three-fourths for the fiscal year
covering the period September 1, 1990 through August 31, 1991, and one-
fourth for the fiscal year covering the period September 1, 1989
through August 31, 1990, since twelve months of the review period
occurred in the first fiscal year, and four months occurred in the
second.
Comment 3: Respondents state that the Department incorrectly
adjusted for the value added tax (VAT), by increasing reported costs
such as foreign inland freight, foreign brokerage, containerization,
commissions and packing, by 10 percent for both the U.S. and third-
country sales. Respondents contend that VATs ``paid'' on purchases of
goods and services are not costs because they are rebated upon payment
and thus do not constitute an expense to the company.
They state that the VAT adjustment probably did not affect dumping
margins where net U.S. prices were compared to net third-country
prices, but it likely resulted in more below-cost sales which, in turn,
increased the dumping margin. They state that the Department should
recalculate costs and exclude the relevant VATs.
Department's Position: We agree with respondents and have changed
our calculations accordingly.
Comment 4: Respondents contend that the Department should not
include U.S. and third-country sample sales and resales in its dumping
calculations. Resales occurred when a customer cancelled an order, and
the manufacturer found another buyer for the merchandise. They argue
that these sales did not occur in the ordinary course of trade and that
their inclusion affected the dumping margins. They claim that sample
sales and resales are unrepresentative of sales routinely undertaken by
Korean companies, and that the inclusion of such sales is patently
unfair, as they are not a means of price discrimination, but of
promoting sweater sales and disposing of small volumes of cancelled
orders.
Respondents argue that the Department has in the past excluded
small quantity/high price sales when the transactions in question are
``trial sales for evaluation'' or ``sales of sample merchandise'' and
are ``not for consumption but rather for evaluation purposes.'' To
support this argument they cite Tapered Roller Bearings; Finished and
Unfinished, and Parts Thereof, From Japan; Final Results of Antidumping
Administrative Review, 57 FR 4951, 4959 (February 11, 1992) (TRBs from
Japan), and Granular Polytetrafluoroethylene Resin from Japan; Final
Results of Antidumping Duty Administrative Review, 58 FR 50343, 50345
(September 27, 1993) (PTFE from Japan).
Department's Position: It is our established practice not to
exclude sample sales or resales in the U.S. market in administrative
reviews, and respondents provide no justification for doing so in this
case. There is no statutory or regulatory authority for excluding U.S.
sales from review. Section 353.46(a) provides for the exclusion of
sales made outside the ordinary course of trade from the calculation of
FMV; however, no such provision is made for disregarding sales made
outside the ordinary course of trade from the calculation of U.S.
price. In a less-than-fair-value (LTFV) investigation we have the
discretion to eliminate unusual sales from our analysis; in an
administrative review, however, the statute and the regulations require
that we analyze all U.S. sales, except when sampling techniques are
used. (See 19 U.S.C. 1677f-1; 19 C.F.R. 353.59 (1994). See, also, Final
Results of Antidumping Duty Administrative Reviews and Revocation in
Part of an Antidumping Duty Order; Antifriction Bearings (Other Than
Tapered Roller Bearings) and Parts Thereof From France, Germany, Italy,
Japan, Romania, Singapore, Sweden, Thailand, and the United Kingdom, 58
FR 39729, 39776 (July 26, 1993) and Final Results of Antidumping Duty
Administrative Review; Portable Electric Typewriters from Japan, 56 FR
14072, 14079 (April 5, 1991).) In PTFE from Japan we noted that,
historically, the Department has considered all transactions to be
sales whenever ownership transfers to an unrelated party. Due to the
peculiar nature of PTFE resin, the consideration of transfer of
ownership was inapplicable, because samples of resin, once used in
testing, could not be returned in the original form to the seller. In
the present case, sample sales made in the United States involved a
transfer of ownership between parties, and respondents have not shown
the existence of any special circumstances, such as obtained in PTFE
from Japan, that would cause us to deviate from our practice. TRBs from
Japan, which respondents cite, does not address sample sales and
resales in the United States.
We have in the past excluded sales outside the ordinary course of
trade only in the home and third-country markets for administrative
reviews. In order for us to exclude sales, a firm must provide
substantial evidence that such sales are outside the ordinary course of
trade. (See Final Results of Antidumping Duty Administrative Review;
Antifriction Bearings (Other Than Tapered Roller Bearings) and Parts
From France, et al. 57 FR 28360, 28395 (June 24, 1992).) Respondents in
this case have not provided convincing evidence that third-country
sample sales and resales were outside the ordinary course of trade.
For the final results, we attempted, when possible, to match sample
sales in the United States to sample sales in the third country, and
resales in the United States to resales in the third country, within
the constraints of our model-matching criteria.
Final Results of Review
As a result of our review, we determine that the following margins
exist:
------------------------------------------------------------------------
Margin
Manufacturer/exporter Period of review (percent)
------------------------------------------------------------------------
Chunji Industrial Company, Ltd. and
Sungwha Garment Company, Ltd........... 04/27/90-08/31/91 2.55
Kee Ryung Industrial Company, Ltd....... 04/27/90-08/31/91 2.17
Suhcheon Company, Ltd................... 04/27/90-08/31/91 2.19
Tae Kwang Industrial Company, Ltd....... 04/27/90-08/31/91 0.30
Young Woo Industrial Company, Ltd....... 04/27/90-08/31/91 4.75
Yurim Industrial Company, Ltd........... 04/27/90-08/31/91 2.16
Bangil Industrial, Ltd.................. 04/27/90-08/31/91 \1\2.35
Boun Kyung Corporation.................. 04/27/90-08/31/91 \1\2.35
Bum-Yang Apparel Company, Ltd........... 04/27/90-08/31/91 \1\2.35
Chai-Knit Trading Company, Ltd.......... 04/27/90-08/31/91 \1\2.35
Chang Jae Corporation................... 04/27/90-08/31/91 \1\2.35
Chongju Textiles Company, Ltd........... 04/27/90-08/31/91 \1\2.35
Dae Kyung Company, Ltd.................. 04/27/90-08/31/91 \1\2.35
Daewoo Corporation...................... 04/27/90-08/31/91 \1\2.35
Dae Yu Company, Ltd..................... 04/27/90-08/31/91 \1\2.35
Do Sung Textile Company, Ltd............ 04/27/90-08/31/91 \1\2.35
Dong Kwang Corporation.................. 04/27/90-08/31/91 \1\2.35
Dong Woo Company, Ltd................... 04/27/90-08/31/91 \1\2.35
Doosung Textile Company, Ltd............ 04/27/90-08/31/91 \1\2.35
Full Bright Industrial Co., Ltd......... 04/27/90-08/31/91 \1\2.35
Hae Yang Knitting Factory, Ltd.......... 04/27/90-08/31/91 \1\2.35
Hanil Synthetic Fiber Ind. Co., Ltd..... 04/27/90-08/31/91 \1\2.35
Hwa Man Industrial Company, Ltd......... 04/27/90-08/31/91 \1\2.35
Jo Woo Company, Ltd..................... 04/27/90-08/31/91 \1\2.35
Kolon International Corporation......... 04/27/90-08/31/91 \1\2.35
Kuk Rim Ltd............................. 04/27/90-08/31/91 \1\2.35
Kun Ja Industrial Company, Ltd.......... 04/27/90-08/31/91 \1\2.35
Ryu Kyung Industrial Company, Ltd....... 04/27/90-08/31/91 \1\2.35
Samdo Trading Company and Daishin
Trading Company, Ltd................... 04/27/90-08/31/91 \1\2.35
Samjin Moolsan Ltd...................... 04/27/90-08/31/91 \1\2.35
Samsung Company, Ltd.................... 04/27/90-08/31/91 \1\2.35
Se Dong Company, Ltd.................... 04/27/90-08/31/91 \1\2.35
Shin Chang Knitting Company, Ltd........ 04/27/90-08/31/91 \1\2.35
Shinwon Corporation..................... 04/27/90-08/31/91 \1\2.35
Sunny Apparel, Inc...................... 04/27/90-08/31/91 \1\2.35
Uksung Company, Ltd..................... 04/27/90-08/31/91 \1\2.35
Wha Jin Apparel Company, Ltd............ 04/27/90-08/31/91 \1\2.35
Yakjin Trading Corporation.............. 04/27/90-08/31/91 \1\2.35
Baik Yang Company, Ltd.................. 04/27/90-08/31/91 \2\1.30
Choongbang Company, Ltd................. 04/27/90-08/31/91 \2\1.30
Dongwoo Silk Company, Ltd............... 04/27/90-08/31/91 \2\1.30
Doosan Industrial Company, Ltd.......... 04/27/90-08/31/91 \2\1.30
Hanjoo Corporation...................... 04/27/90-08/31/91 \2\1.30
Hoejun Knit Goods Company, Ltd.......... 04/27/90-08/31/91 \2\1.30
Jung Woo Textile Company, Ltd........... 04/27/90-08/31/91 \2\1.30
San Han Synthetic Fiber Co., Ltd........ 04/27/90-08/31/91 \2\1.30
Cheon Woo Express....................... 04/27/90-08/31/91 \3\1.30
Chin Ji Industrial...................... 04/27/90-08/31/91 \3\1.30
Daelim.................................. 04/27/90-08/31/91 \3\1.30
Goo San Trading......................... 04/27/90-08/31/91 \3\1.30
Hanjoo Shipping International........... 04/27/90-08/31/91 \3\1.30
Hanlim.................................. 04/27/90-08/31/91 \3\1.30
Hyop Sung............................... 04/27/90-08/31/91 \3\1.30
Hyop Woon Enterprises................... 04/27/90-08/31/91 \3\1.30
Jung Wong............................... 04/27/90-08/31/91 \3\1.30
Kook Industries......................... 04/27/90-08/31/91 \3\1.30
Ryu Kyung............................... 04/27/90-08/31/91 \3\1.30
Sam Jin Industries...................... 04/27/90-08/31/91 \3\1.30
Sam Jing Industries..................... 04/27/90-08/31/91 \3\1.30
Shen Heung Textile...................... 04/27/90-08/31/91 \3\1.30
Wahjin.................................. 04/27/90-08/31/91 \3\1.30
Woorin Trading.......................... 04/27/90-08/31/91 \3\1.30
Ye In................................... 04/27/90-08/31/91 \3\1.30
Yoo Chang Enterprise.................... 04/27/90-08/31/91 \3\1.30
Yuwon Trading........................... 04/27/90-08/31/91 \3\1.30
All Others.............................. 04/27/90-08/31/91 1.30
------------------------------------------------------------------------
\1\Not selected from the sample pool; rate is the simple average of the
margins for the six selected companies.
\2\No shipments during the period; rate is the weighted-average margin
for each company from the less-than-fair-value investigation, or, if a
company was not involved in the investigation, the ``All Others''
rate.
\3\Not known to Korean Garment and Knitwear Export Association as a
shipper; rate is the weighted-average margin for each company from the
less-than-fair-value investigation, or, if the company was not
involved in the investigation, the ``All Others'' rate.
The Department shall determine, and the Customs Service shall
assess, antidumping duties on all appropriate entries. Individual
differences between U.S. price and FMV may vary from the percentages
stated above. The Department will issue appraisement instructions on
each exporter directly to the Customs Service.
Furthermore, the following deposit requirements will be effective
upon publication of this notice of final results of review for all
shipments of MMF sweaters from Korea entered, or withdrawn from
warehouse, for consumption on or after the publication date, as
provided by section 751(a)(1) of the Tariff Act: (1) The cash deposit
rates for the reviewed companies will be those established in the final
results of this administrative review; (2) for previously investigated
companies not listed above, the cash deposit rate will continue to be
the company-specific rate published for the LTFV investigation; (3) if
the exporter is not a firm covered in this review or the LTFV
investigation, but the manufacturer is, the cash deposit rate will be
the rate established in the LTFV investigation for the manufacturer of
the merchandise; and (4) the cash deposit rate for all other
manufacturers or exporters will be the ``all others'' rate of 1.30
percent established in the final notice of LTFV investigation of this
case, in accordance with the Court of International Trade's decisions
in Floral Trade Council v. United States, 822 F.Supp 766 (1993), and
Federal-Mogul Corporation and the Torrington Company v. United States,
839 F.Supp 864 (1993). Since the margin for Tae Kwang is less than 0.50
percent and, therefore, de minimis for cash deposit purposes, the
Department will instruct customs to collect a cash deposit of zero
antidumping duties on entries from Tae Kwang. These deposit
requirements, when imposed, shall remain in effect until publication of
the final results of the next administrative review.
This notice serves as a final reminder to importers of their
responsibility under 19 CFR 353.26 to file a certificate regarding the
reimbursement of antidumping duties prior to liquidation of the
relevant entries during this review period. Failure to comply with this
requirement could result in the Secretary's presumption that
reimbursement of antidumping duties occurred and subsequent assessment
of double antidumping duties.
Notification to Interested Parties
This notice also serves as a reminder to parties subject to
administrative protective order (APO) of their responsibility
concerning the disposition of proprietary information disclosed under
APO in accordance with 19 CFR 353.34(d). Timely written notification of
return/destruction of APO materials or conversion to judicial
protective order is hereby requested. Failure to comply with the
regulations and the terms of an APO is a sanctionable violation.
This administrative review and notice are in accordance with
section 751(a)(1) of the Tariff Act (19 U.S.C. 1675(a)(1)) and 19 CFR
353.22.
Dated: April 6, 1994.
Paul L. Joffe,
Deputy Assistant Secretary for Import Administration.
[FR Doc. 94-8909 Filed 04-12-94; 8:45 am]
BILLING CODE 3510-DS-P