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CIT Upholds Commerce's Remand Results in Oil Country Tubular Goods AD Review

The Court of International Trade in an Aug. 26 opinion upheld the Commerce Department's remand results in the 2016-17 administrative review of the antidumping duty order on oil country tubular goods from South Korea. Previously, Judge Jennifer Choe-Groves remanded Commerce's particular market situation finding, reallocation of respondent NEXTEEL's reported costs for non-prime products for an allocation based on actual costs, adjustment to NEXTEEL' production line suspension costs, calculation of respondent SeAH Steel Co.'s affiliated seller's further manufacturing cost and inclusion of SeAH's inventory valuation losses in its general and administrative expense ratio.

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On remand, Commerce dropped the PMS finding, the adjustment from SeAH's and NEXTEEL's margin calculation and the reallocation of NEXTEEL's non-prime products -- instead relying on the actual costs of prime and non-prime goods reported by NEXTEEL. The agency did, though, stick by its positions on the remaining issues, providing further explanation. Choe-Groves upheld Commerce's new or further-explained positions, which dropped the dumping rates for SeAH, NEXTEEL and the non-examined companies from 16.73% to 5.28%, 32.24% to 9.77% and 24.49% to 7.53%, respectively.