Zhejiang Dunan Hetian Metal Co., Ltd. v. United States

An anti-dumping petition claimed that Chinese firms were exporting frontseating service valves at less than fair value. The Department of Commerce calculated normal value of the valves by using India as a surrogate market economy and identifying brass bars as a primary raw material; it valued the labor factor of production using regression analysis that included wage rates and gross national income data from sixty-one market economy countries. Commerce issued a final determination that calculated the surrogate value for brass bar without excluding the imports from Japan, France, and the UAE. The Court of International Trade upheld the determination. The Federal Circuit vacated and remanded for revaluation of labor, not using the regression approach, and reconsideration of sales at issue for calculating the relevant total dumping margin. Commerceâs reading of the evidence was reasonable in including data on imports from Japan, France, and the UAE, to calculate the surrogate value of brass bar.