[Federal Register Volume 63, Number 132 (Friday, July 10, 1998)]
[Notices]
[Pages 37334-37338]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 98-18446]
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DEPARTMENT OF COMMERCE
[A-580-807]
Polyethylene Terephthalate Film, Sheet, and Strip From the
Republic of Korea; Final Results of Antidumping Duty Administrative
Review
AGENCY: Import Administration, International Trade Administration,
Department of Commerce.
ACTION: Notice of Final Results of Antidumping Duty Administrative
Review.
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SUMMARY: On March 6, 1998, the Department of Commerce (the Department)
published the preliminary results of administrative review of the
antidumping duty order on polyethylene terephthalate film sheet, and
strip (PET film) from the Republic of Korea. The review covers one
manufacturer/exporter of the subject merchandise to the United States
and the period June 1, 1996 through May 31, 1997.
As a result of comments we received, the dumping margin has changed
from that presented in our preliminary results.
EFFECTIVE DATE: July 10, 1998.
FOR FURTHER INFORMATION CONTACT:
Michael J. Heaney, or Linda Ludwig, AD/CVD Enforcement Group III,
Import Administration, International Trade Administration, U.S.
Department of Commerce, 14th Street and Constitution Avenue, NW,
Washington, DC 20230, telephone: (202) 482-4475, or 3833, respectively.
SUPPLEMENTAL INFORMATION:
Background
On March 6, 1998, (63 FR 11214), the Department published the
preliminary results of administrative review and recission in part of
the antidumping duty order on PET film from the Republic of Korea, 56
FR 25669, (June 5, 1991).
This review covers one manufacturers/exporter of the subject
merchandise to the United States: SKC Co., Ltd, (SKC), and the period
June 1, 1996 through May 31, 1997.
The Department has concluded this 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 all gauges of raw,
pretreated, or primed polyethylene terephthalate film, sheet, and
strip, whether extruded or coextruded. The films excluded from this
review are metallized films and other finished films that have had at
least one of their surfaces modified by the application of a
performance-enhancing resinous or inorganic layer of more than 0.00001
inches (0.254 micrometers) thick. Roller transport cleaning film which
has at least one of its surfaces modified by the application of 0.5
micrometers of SBR latex has also been ruled as not within the scope of
the order.
PET film is currently classifiable under Harmonized Tariff Schedule
(HTS) subheading 3920.62.00.00. The HTS subheading is provided for
convenience and for U.S. Customs purposes. The written description
remains dispositive as to the scope of the product coverage.
The review covers the period June 1, 1996 through May 31, 1997.
Applicable Statute and Regulations
Unless otherwise indicated, all citations to the Tariff Act of
1930, as amended (the Tariff Act), are references to the provisions
effective January 1, 1995, the effective date of the amendments made to
the Tariff Act by the Uruguay Round Agreements Act. In addition, unless
otherwise indicated, all references to the Department's regulations are
to 19 CFR part 353 (1997).
Analysis of Comments Received
We invited interested parties to comment on the preliminary results
of this administrative review. On April 6, 1998, we received timely
comments from the respondent, SKC and the petitioners (E.I. DuPont de
Nemours & Company, Hoechst Celanese Corporation, and ICI America's
Inc.) (Petitioners). SKC and the Petitioners submitted their reply
briefs on April 13, 1998 and April 14, 1998 respectively.
Comment 1: SKC contends that the payment dates for some of the U.S.
sales reported in its December 8, 1997 letter were incorrectly
transcribed, thereby overstating its U.S. credit expense. SKC contends
that the Department should accept the corrected payment dates set forth
in its March 16, 1998 letter. SKC further contends that the correct
payment dates are discernible from the record, and that the error in
question is clearly clerical in nature.
SKC argues that the Department's established practice is to accept
corrections following the preliminary results when (1) the error in
question is demonstrated to be a clerical error; (2) the corrective
documentation provided in support of the clerical error allegation is
reliable; (3) the respondent availed itself of the earliest reasonable
opportunity to correct the error; (4) the clerical error allegation,
and any corrective documention, is submitted to the Department no later
than the due date for the respondent's administrative case brief; (5)
the clerical error does not entail a substantial revision of the
response; and (6) the respondent's corrective documentation does not
contradict information previously determined to be accurate at
verification. (See e.g., Certain Fresh Cut Flowers from Colombia, Final
Results of Antidumping Duty Administrative Reviews, (Colombian Flowers)
61 FR 42833, 42834 (August 19, 1996).)
SKC asserts that the corrected information meets the criteria
outlined in Colombian Flowers because the error contained in its
December 8, 1997 response is demonstrably clerical, can reliably be
discerned from the data on
[[Page 37335]]
record, and was brought immediately to the Department's attention upon
receipt by SKC of its disclosure materials. Moreover, SKC argues that
correction of this error would not entail a substantial revision of its
response. Finally, SKC notes that the data provided in its March 16,
1998 submission does not contradict any previously verified
information.
Department's Position: We agree with SKC. The Department will
accept a respondent's clerical corrections so long as it fulfills the
criteria first articulated in Colombian Flowers. (See Tapered Roller
Bearings and Parts Thereof, Finished and Unfinished, From Japan, and
Tapered Roller Outside Diameter, and Components Thereof, From Japan,
Final Results of Antidumping Duty Administrative Reviews and
Termination in Part, 20585, 20610 (April 27, 1998) (citing NTN Bearing
Corp. v. United States, 74 F.3d 1204 (Fed. Cir. 1995) and Colombian
Flowers).) The formatting error resulted in the uniform transcription
of ``9'' as ``0'' for certain U.S. sales. For example, payments made on
March 5, 1997 were incorrectly read as ``070305'' rather than
``970305''. This error is clearly clerical in nature. Further, SKC
provided reliable documentation supporting its correction of that
clerical error. SKC corrected the clerical error five days after
receipt of its disclosure materials, and provided the corrective
documentation prior to submission of its case brief. Finally,
correction of this clerical error does not constitute a substantial
revision of SKC's response, and does not contradict previously verified
information. Thus, consistent with the position established in
Colombian Flowers, we have used SKC's corrected payment dates in these
final results.
Comment 2: Consistent with previous administrative reviews of this
case, SKC objects to the Department's equal allocation of scrap costs
to A-grade and B-grade film. SKC contends that its allocation
methodology is reasonable and consistent with widely accepted
accounting concepts. In support of its argument, SKC cites to the March
5, 1996 case brief filed in the second and third administrative reviews
of this case. (See Attachment 1 of SKC's April 6, 1998 case brief.)
SKC states that allocating the cost of scrap film equally to A-
grade and B-grade films improperly overstates the cost of B-grade films
while understating the cost of A-grade films. SKC contends that its
methodology of initially allocating costs equally among A-grade film,
B-grade film, and scrap, and then reallocating the cost of scrap to the
cost of A-grade film is consistent with accepted cost accounting
methodologies.
SKC also asserts that its methodology is consistent with the
Department's treatment of jointly produced products in numerous other
antidumping proceedings, wherein the Department recognized that a pure
quantitative, or physical measures approach to cost allocation is
unreasonable where there is a significant difference in the value of
the jointly produced products.
SKC cites Elemental Sulphur from Canada, 61 FR 8239, 8241-8243
(March 4, 1996) (Sulphur from Canada); Oil Country Tubular Goods from
Argentina, 60 FR 33539, 33547 (June 28, 1995) (OCTG from Argentina);
Canned Pineapple Fruit from Thailand, 60 FR 29553, 29560 (June 5, 1995)
(Pineapple from Thailand) in support of its position.
SKC maintains that it is the Department's well-established practice
to calculate costs in accordance with a respondent's normal cost
accounting system unless the system results in an unreasonable
allocation of costs, and cites Pineapple from Thailand as support for
this assertion. SKC states that its reported cost of manufacturing
(COM) data were calculated in accordance with its normal and long-
established management cost accounting system. SKC notes that in the
first review of this case (covering the period November 30, 1990
through May 31, 1992), the Department allocated all of the costs
associated with the production of scrap film to A-grade film. SKC
contends that this methodology was recently upheld by the Court of
International Trade (CIT). (See E.I. Dupont de Nemours & Co., et al. v.
United States, No. 98-35, Slip. Op. at 12-14 (CIT March 26, 1998
(DuPont).) Based upon the foregoing, SKC concludes that the Department
should allocate all scrap costs to A-grade film.
Petitioners argue that SKC has not provided justification for the
Department deviating from its current practice which is to allocate
costs equally between prime- and off-grade merchandise. Petitioners
note that the allocation of scrap film has been a contentious issue
from the LTFV investation of this case. Petitioners further note that
the Department's method of allocating yield losses equally between A-
grade and B-grade film is consistent with the ruling of the U.S. Court
of Appeal for the Federal Circuit in IPSCO v. United States, 965 2d.
1056 (Fed Cir., 1992) (IPSCO). Petitioners contend that the methodology
employed by the Department in this review is consistent with that
employed in the second (June 1, 1992 through May 31, 1993) and third
(June 1, 1993 through May 31, 1994) reviews of this case. Additionally,
Petitioners assert that the decision by the CIT in DuPont does not
require the Department to employ the allocation methodology used in the
first review of this case. Petitioners contend that in accepting SKC's
reported costs for the first review, the Department predicated its
acceptance of SKC's allocation methodology on the understanding that
SKC had applied ``a cost methodology that assigns equal costs to the
prime and off-grade PET film in accordance with the Ipsco Appeal.''
(original emphasis). (See Polyethylene Terephthalate Film, Sheet and
Strip From the Republic of Korea; Final Results of Antidumping Duty
Administrative Review, 60 FR 42835, 42839 (August 17, 1995).)
Petitioners assert that this indicates that the Department believed
that ``SKC's reported cost allocation system was based on allocating
equal costs'' to A-grade and B-grade film. Petitioners contend that the
allocation methodology set forth by SKC does not allocate scrap costs
equally to A-grade and B-grade film, and thus should be rejected by the
Department.
Additionally, Petitioners challenge SKC's characterization of its
proposed allocation methodology as ``normal and long-established.''
Petitioners cite to their April 14, 1997 reply brief filed in the fifth
administrative review (June 1, 1995 through May 31, 1996) of this case
in which Petitioners contend that SKC had historically assigned equal
costs to all PET film and devised its current cost system only after
the initiation of this dumping case.
Department's Position: We agree with Petitioners and disagree with
SKC. As we explained in the final results of previous reviews of this
order, we have determined that A-grade and B-grade PET film have
identical production costs. Accordingly, we continue to rely on an
equal cost methodology for both grades of PET film in these final
results (See Polyethylene Terephthalate Film, Sheet, and Strip from the
Republic of Korea: Final Results of Review and Notice of Revocation in
Part 61 FR 35177, 33182-83 (July 5, 1996) (Second and Third Reviews);
Polyethylene Terephthalate Film, Sheet, and Strip from the Republic of
Korea; Final results of Review and Notice of Revocation in Part 61 FR
58374, 58375-76, (November 14, 1996) (Fourth Review); and Polyethylene
Terephthalate Film, Sheet, and Strip from the Republic of Korea; Final
Results of Review, 62 FR 38064, 38065-66, (July 16, 1997) (Fifth
Review).)
[[Page 37336]]
Moreover, as noted in the final results of the second through the
fifth reviews, the CIT has also ruled that our allocation of SKC's
production costs between A-grade and B-grade film is reasonable (see
E.I. DuPont de Nemours & Co., Inc. et al. v. United States, 932 F.
Supp. 296 (CIT 1996)).
As Petitioners have indicated, our acceptance of SKC's allocation
of scrap costs in the first review of this case was based upon our
understanding that SKC had properly allocated the costs of A-grade and
B-grade film. In that review, we did not verify SKC's costs data. We
determined that no verification of SKC was necessary because SKC was
verified in the original investigation. Second and Third Reviews, 60 FR
at 42839. Based upon the evidence existing in the record during that
proceeding, we accepted SKC's computations because we were satisfied
that it had calculated actual costs consistent with the IPSCO decision.
During the second and third administrative reviews, however, we
carefully examined SKC's allocation methodology and conducted a
thorough verification of SKC's accounting records. We determined that
the allocation methodology employed by SKC fails to capture the actual
production costs of A-grade and B-grade film. Based upon this
determination, we have consistently required SKC to allocate yield
losses equally between A-grade and B-grade film since the second review
of this case. Further, we have determined that A-grade and B-grade film
undergo an identical production process that involves an equal amount
of material and fabrication expenses. The only difference in the
resulting A- and B-grade film is that at the end of the manufacturing
process a quality inspection is performed during which some of the film
is classified as high quality A-grade product while other film is
classified as lower quality B-grade film (see Fourth Review (covering
the period June 1, 1994 through May 31, 1995), 61 FR at 58375).
Finally, SKC's argument that DuPont affirmed SKC's allocation
methodology is without merit. DuPont does not require the Department to
accept an allocation methodology that does not accurately capture the
actual cost of A-grad and B-grade film. In DuPont, the CIT concluded
that the Department's acceptance of SKC's calculations was supported by
substantial evidence. The Court further concluded that the calculations
properly reflected SKC's actual costs of production. The CIT, however,
did not affirm SKC's allocation methodology. It merely accepted the
allocations resulting from the methodology because those allocations
(based upon record evidence) reflected actual production costs as
required by IPSCO.
In the four previous reviews of this case, the Department has
determined that SKC's allocation methodology fails to capture the
actual cost of A-grade and B-grade film. We continue to maintain that
SKC's reliance on Sulphur from Canada. Pineapple from Thailand, and
OCTG from Argentina is misplaced. Those cases concerned the appropriate
cost methodology for products manufactured from a joint production
process. SKC has mischaracterized the continuous production process of
PET film as a joint production process. A joint production process
occurs when ``two or more products result simultaneously from the use
of one raw material as production takes place.'' (See, Management
Accountants Handbook, Keeler, et al., Fourth Edition at 11:1.) A joint
production process produces two distinct products and the essential
point of a joint production process is that ``the raw material, labor,
and overhead costs prior to the initial split-off can be allocated to
the final product only in some arbitrary, although necessary, manner.''
Id. The identification of different grades of merchandise does not
transform the manufacturing process into a joint production process
which would require the allocation of costs. In this case, since
production records clearly identify the amount of yield losses for each
specific type of PET film, our allocation of yield losses to the films
bearing those losses is reasonable, not arbitrary (Fourth Review, 61 FR
at 58575-76).
It is the Department's practice to calculate costs in accordance
with a respondent's management accounting system. Where that system
reconciles to the respondent's normal financial and cost accounting
records and results in a reasonable allocation of costs. Management
accounting deals with providing information that managers inside an
organization will use. Managerial accounting reports typically provide
more detailed information about product costs, revenue and profits.
They are used to identify problems, objectives or goals, and possible
alternatives. In order to respond to the Department's questionnaires,
SKC officials devised a management accounting methodology for
allocating costs incurred in the film and chip production cost centers
to individual products produced during the period of investigation. SKC
adopted this cost accounting system to reflect a management goal (i.e.,
to respond to the Department). Under this system, SKC assigns the yield
loss from the production of A- and B-grade films exclusively to the A-
grade films. This methodology helps management to focus on the film
types with low yields. However, notwithstanding SKC management's
concern that it accurately portray the cost of their A-grade products,
this managerial accounting methodology is not appropriate for reporting
the actual costs of A- and B-grade products. As previously noted, A-
grade and B-grade films undergo an identical production process. B-
grade film is made using the same materials, on the same equipment, at
the same time as the A-grade film. As such, scrap costs must be
allocated equally to A- and B-grade films. It is within the
Department's mandate to accept or reject the allocation methodologies
devised by respondents. In this instance, we have continued to rely on
an equal cost allocation methodology which reflects the actual costs
incurred for both A-grade and B-grade film.
Comment 3: SKC asserts that the Department double counted inventory
carrying costs in its calculation of COP and CV. SKC contends that all
COP interest expenses were included in the variable RCOP, and that all
CV interest expenses were included in the variable INTEXCV.
Department's Position: We agree with SKC. In these final results,
we have revised the computer program to eliminate the double-counting
of inventory carrying costs in our calculation of COP and CV.
Comment 4: SKC asserts that the Department failed to include U.S.
indirect selling expenses incurred in the home market for purposes of
calculating CEP profit. SKC contends that the Department should adjust
its calculation of CEP profit to account for all U.S. selling expenses.
regardless of where they were incurred.
Department's Position: We agree with SKC. Consistent with our
established practice, we have not distinguished ``activities in the
United States from other selling expenses'' in our calculation of CEP
profit. (See Import Administration Policy Bulletin No. 97/1.
Calculation of Profit for Constructed Export Price Transactions
(September 4, 1997).)
Comment 5: SKC contends that the Department should offset interest
revenue against imputed credit in building up the pool of U.S. selling
expenses used to allocate profit to CEP sales. SKC notes that the
Department made this offset in the final results of the fifth review.
(See Final Analysis
[[Page 37337]]
Memorandum for SKC from Analyst to the file, June 30, 1997.)
Department's Position: We agree with SKC. In these final results,
we have offset SKC's interest expense with the interest revenue
realized by SKC.
Comment 6: Petitioners contend that the Department should revise
SKC's imputed credit expenses on sales to Anacomp. Petitioners assert
that SKC's calculation of credit expense is inconsistent with the
ruling of the Federal Circuit in LMI-LaMetalli Industriale, S.p.A. v.
United States. (LMI) 912 F.2d 455 (Fed. Cir. 1990) because SKC has not
based its calculation of U.S. credit expense upon ``usual and
reasonable commercial behavior.'' (LMI at 461.)
Petitioners contend that the Department's calculation of SKC's U.S.
imputed credit expense should consider Anacomp's ``poor financial
condition and the unusual trade credit term that SKC provided to
Anacomp.'' Petitioners note that Anacomp declared bankruptcy just prior
to the period of review, and emerged from bankruptcy in June 1996.
Petitioners point to Anacomp's debt-to-equity ratio as another
indication of the company's poor financial condition. Petitioners also
note that the interest rate incurred by SKC on borrowings in the U.S.
is below the U.S. prime rate. Petitioners assert that Anacomp's
financial condition ``is shaky at best,'' and that credit expenses on
sales to Anacomp should reflect Anacomp's poor financial condition.
Petitioners further contend that the Department should use a rate
higher than the rate used to calculate SKC's interest revenue on sales
to Anacomp. Petitioners note that in DuPont, the CIT granted the
Department's request for a remand to consider Anacomp's financial
condition in determining the short-term interest rate to be utilized on
SKC's U.S. sales. DuPont at 24.
SKC contends that the purpose of making an adjustment for U.S.
credit expenses is to account for the opportunity cost that the seller
incurs in waiting for payment from the buyer. SKC argues that the
Department requested a remand in DuPont only because the issue had not
been addressed on the record of that review. SKC further contends that
the cost of extending credit can only be measured by the cost that the
seller incurs in borrowing funds. SKC argues that bad debt expense (and
not credit) represents the costs associated with not receiving payment.
SKC further argues that Departmental practice is to base bad debt
expense upon the actual expenses realized by the company. SKC notes
that is has included its actual U.S. bad debt expenses in its
calculation of U.S. indirect selling expenses. Finally, SKC contends
that Petitioners' reliance on LMI is misplaced. SKC notes that in LMI,
the Court instructed the Department to base U.S. interest expense upon
the costs associated with borrowing funds in the United States. SKC
notes that is based its calculation of U.S. credit expense upon the
costs that it incurred in borrowing funds in the United States.
Department's Position: We agree with SKC and disagree with
Petitioners. The Department has adopted a policy of using a short-term
interest rate tied to the currency in which the sales are denominated.
(See Import Administration Policy Bulletin No. 98.2, Imputed Credit
Expenses and Interest Rates (February 23, 1998).) Subsequent to the LMI
decision we established a practice of matching the short-term interest
rate to the currency because we view this measure as accurately
reflecting the cost of providing credit to the customer. (See, e.g.;
AIMCOR v. United States, Nos. 96-1502, 97-1009, 1998 U.S. App. Lexis
7077, at * 40 (Fed. Cir. April 9, 1998) (AIMCOR); Final Determination
of Sales at Less Than Fair Value: Oil Country Tubular Goods From
Austria, 60 FR 33551, 33555 (June 28, 1995); Certain Cut-to-Length
Carbon Steel Plate From Sweden; Final Results of Antidumping
Administrative Review, 61 FR 15772, 15780 (April 9, 1996).) Moreover,
in the second and third administrative reviews where the respondent had
borrowings in the same currency as the transaction we used the
weighted-average borrowing rates realized in that particular currency.
(See Second and Third Reviews at 35184.) In these final results we have
continued to base our calculations of SKC's credit expense upon the
interest rate incurred on SKC's borrowings in the United States. This
approach is consistent with the Court of Appeals' decision in LMI. In
that case the Federal Circuit reversed the Department's calculation of
U.S. imputed credit expenses which used home market borrowing rates
because the respondent had actual U.S. loans at a much lower rate. (LMI
at 460-61.) Inasmuch as the respondent's actual borrowing experience
demonstrated its ability to secure financing in the United States at a
lower rate, the Federal Circuit reasoned that use of the higher
interest rates did not reflect the commercial reality of the
respondent's borrowing experience in the United States.
Petitioner' arguments make clear that they have confused credit and
bad-debt expenses. Bad debt represents the risk that the seller incurs
of not receiving payment, and was separately reported by SKC in its
calculation of indirect selling expenses. In contrast, credit expenses
represents the opportunity cost incurred by the seller in awaiting
payment. The extension of credit constitutes an expense to the firm,
because it obligates funds which would otherwise be available for other
business activities. Anacomp's financial status and condition has no
bearing on SKC's imputed credit expenses computations because imputed
credit expense reflects the opportunity cost experienced by the seller
(See AIMCOR, at *7-8). Anacomp's poor financial condition is irrelevant
in this instance because it has no bearing upon the opportunity costs
incurred by SKC due to delayed payment. Similarly, neither Anacomp's
declared bankruptcy nor it's interest rate in the commercial market
place are reflective of the opportunity costs incurred by SKC in
extending credit. Finally, we note that if we were to adopt the
approach advanced by Petitioners, the distinction between credit
expenses and bad debt would cease to exist.
SKC misapprehends the LMI decision. In LMI, the Federal Circuit
reversed the Department for basing U.S. imputed credit costs upon the
cost of borrowing funds in the home market, as opposed to the market in
which the sales where made. SKC's calculation of U.S. credit, however,
is based upon borrowings undertaken by SKC in the United States. SKC's
calculation is therefore consistent with LMI and the Department's
established practice.
Final Results of Review
As a result of our review, we determine that a weighted-average
margin of 0.36 percent exists for SKC.
The Department shall determine, and the Customs Service shall
assess, antidumpting duties on all appropriate entries. Individual
differences between export price and normal value may vary from the
percentage stated above. The Department will issue appraisement
instructions directly to the Customs Service.
Furthermore, the following deposit requirements will be effective
upon publication of this notice of final results for all shipments of
PET film from the Republic of Korea within the scope of the order
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) no cash deposit shall be required for SKC because the weighted
average margin is less than 0.5 percent and therefore de minimis; (2)
for previously reviewed or investigated companies not listed above, the
rate will continue to be the company-specific rate published for the
[[Page 37338]]
most recent period; (3) if the exporter is not a firm covered in this
review, a prior review, or the original less-than-fair value (LTFV)
investigation, but the manufacturer is, the cash deposit rate will be
the rate established for the most recent period for the manufacturer of
the merchandise; and (4) for all other producers and/or exporters of
this merchandise, the cash deposit rate will be 21.50 percent, the
``all others'' rate established in the remand redetermination of the
LTFV investigation, as explained below. These deposit requirements
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 of 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. Timely
written notification of the return/destruction of APO materials or
conversion to judicial protective order is hereby requested.
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: July 2, 1998.
Joseph A. Spetrini,
Acting Assistant Secretary for Import Administration.
[FR Doc. 98-18446 Filed 7-9-98; 8:45 am]
BILLING CODE 3510-DS-M
