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Saccharin from China - USITC

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significant volumes of saccharin to the United States if the order were revoked. For all of the foregoingreasons, we find that the volume of subject imports is likely to be significant if the order were revoked.2. Likely Price Effects of Subject ImportsIn evaluating the likely price effects of subject imports if the order under review were revoked,the Commission is directed to consider whether there is likely to be significant underselling by thesubject imports as compared to the domestic like product and whether the subject imports are likely toenter the United States at prices that otherwise would have a significant depressing or suppressing effecton the price of the domestic like product. 142In the original determination, the Commission found that the domestic like product and subjectmerchandise were interchangeable and that price was an important factor in purchasing decisions. 143The Commission found that subject imports undersold the domestic product in all quarters and for allfive product categories for which price comparisons were available; the margins of underselling ranged<strong>from</strong> 6.1 percent to 59.6 percent. 144 The Commission found this underselling to be significant. 145In the original determination, the Commission also found that there was significant pricesuppression by reason of subject imports. 146 PMC’s cost of goods sold relative to net sales increasedsteadily over the period examined. 147 The Commission found that PMC’s inability to increase prices tomeet rising costs was due to a significant degree to the increased volume of low-priced subjectimports. 148 The Commission also found some evidence of price depression on the record, as domesticprices for products 4 and 5 fell during the period of investigation, while the quantity of subject importsrose. 149 The Commission also noted that lost sales allegations totaling approximately $*** wereconfirmed. 150 In light of the large and increasing volumes of subject imports over the period, persistentunderselling, significant margins of underselling, evidence of price suppression and depression, andconfirmed lost sales allegations, the Commission found that subject imports had significant adverseprice effects. 151The record evidence in this review indicates that price continues to be an important factor inpurchasing decisions, 152 and that the domestic like product and subject imports continue to beinterchangeable. 153 The overwhelming majority of purchasers reported that the domestic like product142See 19 U.S.C. § 1675a(a)(3). The SAA states that “{c}onsistent with its practice in investigations, inconsidering the likely price effects of imports in the event of revocation and termination, the Commission may relyon circumstantial, as well as direct, evidence of the adverse effects of unfairly traded imports on domestic prices.”SAA at 886.143Original Determination at 12.144Id.145Id.146Id.147Id.148Id.149Id.150Id.151Id.152CR/PR at Tables II-3 & II-4.153See, e.g., CR at II-8 to II-9; PR at II-5 to II-6; CR/PR at Table II-5.19

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