Anti-dumping and Countervailing Program

Hot-rolled carbon steel plate and high-strength low-alloy steel plate

4258-121
AD/1304

STATEMENT OF REASONS

Concerning the initiation on June 13, 2003, of a dumping investigation pursuant to subsection 31(1) of the Special Import Measures Act regarding

CERTAIN HOT-ROLLED CARBON STEEL PLATE AND HIGH-STRENGTH LOW-ALLOY STEEL PLATE ORIGINATING IN OR EXPORTED FROM BULGARIA, THE CZECH REPUBLIC AND ROMANIA.

Pursuant to subsection 31(1) of the Special Import Measures Act, the Commissioner of Customs and Revenue initiated an investigation on June 13, 2003, with respect to the alleged dumping of certain hot-rolled carbon steel plate and high-strength low-alloy steel plate originating in or exported from Bulgaria, the Czech Republic and Romania.

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TABLE OF CONTENTS

• SUMMARY
• INTERESTED PARTIES
• BACKGROUND
• PRODUCT INFORMATION

• Definition
• Technical information
• Production Process
• Product Application

• CLASSIFICATION OF IMPORTS
• LIKE GOODS
• THE CANADIAN INDUSTRY
• STANDING
• THE CANADIAN MARKET
• EVIDENCE OF DUMPING

• Normal Value
• Export Price
• Estimated Margins of Dumping
• Volume of Dumped Goods

• EVIDENCE OF INJURY

• Reduced Market Share
• Lost Sales
• Price Erosion
• Price Suppression
• Underutilization of Plate Production Capacity
• Previous Injury Findings

• CONCLUSION
• SCOPE OF THE INVESTIGATION

• Period of Investigation

• FUTURE ACTION
• RETROACTIVE DUTY ON MASSIVE IMPORTATIONS
• UNDERTAKINGS
• PUBLICATION
• INFORMATION
• APPENDIX 1
• APPENDIX 2

STATEMENT OF REASONS

SUMMARY

A complaint was filed by Algoma Steel Inc. (Algoma) of Sault Ste. Marie, Ontario, supported by IPSCO Inc. (IPSCO) of Regina, Saskatchewan and Stelco Inc. (Stelco) of Hamilton, Ontario, alleging the injurious dumping into Canada of certain hot-rolled carbon steel plate and high-strength low-alloy steel plate originating in or exported from Bulgaria, the Czech Republic and Romania.

The complainant supplied evidence that these products have been dumped. Furthermore, the evidence discloses a reasonable indication that the dumping has caused injury or is threatening to cause injury to the Canadian industry producing these goods.

As a result, the Commissioner of Customs and Revenue (Commissioner) on June 13, 2003, initiated an investigation pursuant to subsection 31(1) of the Special Import Measures Act (SIMA).

INTERESTED PARTIES

Complainant

The complainant, Algoma, is a major producer of hot-rolled carbon steel plate and high-strength low-alloy steel plate in Canada. The only other producers of like products in Canada, IPSCO and Stelco, have expressed their support for the complaint.

Exporters

Importers

The CCRA has identified 20 possible importers of the subject goods.

BACKGROUND

PRODUCT INFORMATION

Definition

For the purpose of this investigation, the subject goods are defined as:

It should be noted that the metric equivalent dimensions in the definition of the subject goods are rounded numbers as indicated by the "+/-" symbols.

Technical information

Steel is considered to be carbon steel when the manganese content does not exceed 1.65% by weight, the silicon and copper contents do not exceed 0.60%, and no minimum content is specified for alloying elements such as aluminium, chromium, columbium, molybdenum, nickel and vanadium. If a minimum is specified for copper content, it must be less than 0.40%.

Steel plate is categorized by different "qualities" which refer to the suitability and integrity of the steel for its intended purpose. In the case of the subject goods, the two most common qualities are structural quality and pressure vessel quality (PVQ). Structural quality plate is intended for general applications such as bridges, buildings, transportation equipment and machined parts. It is usually produced to meet specific composition limits and certain mechanical properties. PVQ plate on the other hand is intended for use in pressure vessels required to hold their contents under pressure and is of higher quality than structural plate.

Heat-treated or normalized plate is heated in a furnace to homogenize and refine the grain structure in order to improve the steel's ability to resist fracture at low service temperatures. PVQ plate, particularly that which is thicker than 1.5 inches, is usually heat-treated, while structural quality plate tends not to be heat-treated.

The CSA specifications covered by the product definition represent different grades within the broad specification G40.21 that covers steel for general construction purposes.

In the ASTM, specifications A283M/A283 and A36M/A36 include structural plate, specifications A572M/A572, A588M/A588 and A242M/A242 include HSLA steel plate and specifications A515M/A515 and A516M/A516 include PVQ plate.

The ASTM specification A36M/A36 is considered to be equivalent to the CSA specification G40.21, Grade 300W/44W and together these are the most common specifications of structural quality plate sold in Canada. The most common specification of PVQ plate sold in Canada is the ASTM specification A516M/A516, Grade 70.

Production Process

Carbon steel is, in effect, refined pig iron. Integrated producers make pig iron by combining iron ore, coke, limestone and oxygen and superheating the mixture in a blast furnace. The ensuing hot liquefied pig iron is combined with scrap metal and additional oxygen in a basic oxygen furnace. Mini-mills, on the other hand, produce molten carbon steel in electric arc furnaces. The basic raw material used by mini-mills is scrap metal rather than virgin iron ore.

At this point, in both integrated and mini-mill production, the molten carbon steel is poured from a ladle into the tundish of a continuous strand caster. From the tundish, it flows into the caster's moulds to cool and to form a slab. The slab continues to move through the caster, cooling as it progresses, until it exits the caster, where it is cut to length with a torch. The slab is then either placed in inventory or immediately transferred to a reheat furnace where it is heated to a uniform rolling temperature. The plate is rolled to its final gauge in a series of rolling mills, levelled, identified and inspected for conformance to thickness tolerances and surface requirements.

Heat-treated plate is manufactured in the manner described above. However, after rolling, it is placed in a heat furnace (charged), reheated to a uniform temperature, removed from the furnace and allowed to cool.

Product Application

CLASSIFICATION OF IMPORTS

The subject hot-rolled carbon steel plate and HSLA steel plate are generally properly classified under the following Harmonized System classification numbers:

7208.51.91.10   7208.51.99.10   7208.52.90.10

7208.51.91.91   7208.51.99.91   7208.52.90.91

7208.51.91.92   7208.51.99.92   7208.52.90.92

7208.51.91.93   7208.51.99.93   7208.52.90.93

7208.51.91.94   7208.51.99.94   7208.52.90.94

7208.51.91.95   7208.51.99.95   7208.52.90.95

LIKE GOODS

Like goods, in relation to any other goods, are goods that are identical in all respects to the other goods, or in the absence of identical goods, goods for which the uses and other characteristics closely resemble those of the other goods.

Hot-rolled carbon steel plate and HSLA steel plate made by the Canadian manufacturers are in direct competition with, have the same use as, and may be used as substitute products for hot-rolled carbon steel plate and HSLA steel plate made in the named countries. For the like goods and for the allegedly dumped goods, the CCRA is of the opinion that there are no separate classes of goods based on variances in their ultimate use, their material characteristics, or other factors.

The CCRA has concluded that hot-rolled carbon steel plate and HSLA steel plate produced by the Canadian industry are like goods to the subject goods.

THE CANADIAN INDUSTRY

There are three major Canadian producers of hot-rolled carbon steel plate and HSLA steel plate in cut-lengths.

Algoma produces plate up to 152" wide and 2 3/4" thick on its 166" Plate Mill and 106" Hot Strip Mill in Sault Ste. Marie, Ontario. IPSCO produces plate up to 72" wide and 3" thick on a reversing roughing mill and a reversing Steckel mill at its steelworks in Regina, Saskatchewan. Plate cut from coil can be produced at IPSCO's facilities in Regina, Saskatchewan, Vancouver, British Columbia and Toronto, Ontario. Stelco produces plate up to 140" wide and up to 5.25" in thickness on the plate mill at its Hilton Works in Hamilton, Ontario, and can also provide plate cut from coils produced on hot strip mills at Hilton Works and its Lake Erie Works at Nanticoke, Ontario.

Gerdau MRM Steel Inc., of Sherkirk, Manitoba, had been identified as a small Canadian manufacturer of plate. However, this company does not manufacture goods that meet the product definition for this investigation.

STANDING

Algoma is the sole complainant. IPSCO and Stelco have both provided letters declaring support for the complaint. Stelco has also provided injury evidence. The three Canadian producers provided the CCRA with the volume and value of their domestic shipments of like goods for the year 2002 and the first quarter of 2003. In order for Canadian producers to have "standing" under SIMA, the domestic producers of the subject goods who support the complaint must represent 25 per cent or more of the total domestic production of like goods, and the complaint must be supported by those domestic producers whose collective production constitutes more than 50 per cent of the total production of like goods by those producers who express either support for, or opposition to, the complaint.

THE CANADIAN MARKET

Appendix 1 shows the apparent Canadian market for hot-rolled carbon steel plate and HSLA steel plate of the same description as the subject goods including imports of hot-rolled carbon steel plate and HSLA steel plate from all sources.

Hot-rolled carbon steel plate and HSLA steel plate are either sold directly to end-users or to service centres, which may re-sell standard cut-to-length sizes and grades or offer custom cutting services. Canadian mill shipments are roughly equally divided between the two types of purchasers. Algoma and Stelco market their plate to customers across Canada. IPSCO markets its plate predominantly in Western Canada and Ontario.

The complainant provided an estimate of the size of the Canadian hot-rolled carbon steel plate and HSLA steel plate market for the years 1999 to 2002. Production and sales data for the first quarter of 2003 were also provided. This estimate of the apparent Canadian market was based on information from Statistics Canada reports on imports and on actual domestic production.

The CCRA adjusted this market estimate to reflect actual import data for these periods obtained from its internal information system. The CCRA also examined customs entry documentation for imports from the named countries as well as other countries.

EVIDENCE OF DUMPING

The complainant alleges that certain hot-rolled carbon steel plate and HSLA steel plate from Bulgaria, the Czech Republic and Romania are being injuriously dumped into Canada. Dumping occurs when the normal value of the goods exceeds the export price of the goods sold to importers in Canada. Normal values are generally based on the selling price of the goods in the country of export, where competitive market conditions exist, or on the full cost of the goods plus a reasonable amount for profits. The export price of goods sold to importers in Canada is generally the exporter's ex-factory selling price to the importer in Canada.

Estimates of normal value and export price are discussed below.

Normal Value

Complainant's Estimated Normal Value:

For the purpose of estimating the margins of dumping, the complainant estimated normal values using two methods.

The first method was based on the estimated domestic selling price of plate in the Czech Republic. The complainant was unable to obtain domestic price information for sales of like goods in Bulgaria and Romania.

As a second method of estimating normal values, the complainant used the estimated full costs of producing plate in the named countries, a methodology similar to section 19 of the SIMA.

To estimate the costs of producing steel plate, the complainant started with the costs of various steelmakers for producing slab (including overhead and financial expenses), as published in Paine-Webber's April 2002 issue of World Steel Dynamics. The April 2002 issue was the most recent available to the complainant and was considered reasonable for purposes of estimating normal value. No specific costs were listed in the Paine-Webber report for the named countries. Therefore, the complainant used the average cost for the Commonwealth of Independent

States (C.I.S.), Germany, U.K. and France in order to calculate a European average. To this estimated slab cost of production, the complainant added its own costs to produce subject plate from slab.

Domestic market price information for the named countries provided by the complainant was limited and appeared to indicate that domestic selling prices of like goods in the Czech Republic may not have covered all costs, a situation that would not allow for the determination of normal values under section 15 of the SIMA. Therefore, the CCRA did not rely on this information to estimate normal values.

Export Price

Complainant's Estimated Export Price:

The complainant estimated export price using two methods. In its first estimate, the complainant estimated export prices on the basis of an average import price per country determined from Statistics Canada information for 2002. As its second methodology, the complainant used as a starting point actual offer pricing in Canada of subject goods from each of the named countries, from which deductions were made for distributor profit and expenses, ocean freight and stevedoring as well as inland freight in the originating country. The resulting amount is an estimated ex-factory price.

Estimated Margins of Dumping

The margins of dumping were estimated by comparing the estimated normal values to corresponding export prices as estimated by the CCRA. All entries of the subject goods during the period of April 1, 2002, to March 31, 2003, were reviewed.

Volume of Dumped Goods

Before making a preliminary determination of dumping, the CCRA must be satisfied that the actual and potential volumes of dumped goods from each country are not negligible. Pursuant to section 2 of the SIMA, the volume of dumped goods from each of the named countries must account for at least 3% of total imports of goods of the same description as the subject goods.

On the basis of the estimated margins of dumping and the actual import data for all countries for the 12-month period of April 1, 2002 to March 31, 2003, as compiled by the CCRA, the estimated volume of dumped goods from each of the named countries is greater than the negligibility threshold of 3% established in section 2 of the SIMA. The estimated volume of dumped goods as a percentage of total imports is equal to 3.3% for Bulgaria, 3.6% for the Czech Republic and 13.1% for Romania during that period.

The CCRA will continue to examine the question of negligibility during the preliminary portion of its investigation.

EVIDENCE OF INJURY

The complainant has alleged that subject goods from Bulgaria, the Czech Republic and Romania have been dumped into Canada and that the dumping has caused or is threatening to cause material injury to the industry in Canada. In support of its allegations, the complainant provided evidence of reduced market share, lost sales, price erosion, price suppression and underutilization of production capacity.

Reduced Market Share

The complainant alleged that it suffered injury in the form of reduced market share due to imports from the named countries. The complainant alleged that the share of the market served by domestic mill shipments declined significantly in 2002 compared to the three previous years while the share from the named countries was increasing.

As shown in Appendix 1, domestic shipments have declined from 70.7% of the market in 2001 to 59.4% during the period of April 1, 2002, to March 31, 2003. At the same time, imports of the subject plate from the named countries have risen from 2.0% in 2001 to 8.1% during that period. Appendix 1 demonstrates that while the Canadian market for these goods has been in decline since 2000, the market share of imports from the named countries continued to grow.

Of the 11.3% of market share lost to imports by the Canadian industry between 2001 and the 12-month period ending March 31, 2003, 6.1% of market share loss was captured by imports from the named countries. By comparison, imports from all other countries during the same time frame increased by 5.1% of market share. In this regard, the three named countries have gained more than half of the market share lost by the Canadian industry.

Lost Sales

The complainant also alleges that the dumped imports from the named countries resulted in various lost sales. The complainant provided evidence of lost orders and lost sales to specific accounts in 2002 and the first quarter of 2003. The evidence indicates that the sales were lost to imports from the named countries. The complainant documented numerous instances where their potential customers placed orders for increasing quantities of subject goods from the named countries based on price. Algoma also provided evidence suggesting that some of its larger customers were purchasing steel plate originating in the named countries based strictly on price. The complaint contained various import activity reports, relating to the named countries, detailing import price offerings, landed shipments and lost orders.

Stelco also provided evidence of various sales lost to imports from the named countries. Stelco publicly announced that it was forced to temporarily idle its plate mill as a result of low-priced plate imports.

Price Erosion

The complainant also alleges that imports from the named countries resulted in injury to the Canadian industry in the form of price erosion.

The complainant claims that prices are still below the 1998 levels when there had been dumping from several other countries, which eventually led to an injury finding by the Tribunal on imports from Brazil, Finland, India, Indonesia, Thailand and Ukraine, which is still in effect to this date. Algoma claims that it was only able to realize part of the price increases that it announced in 2002. It also notes that the 2001 prices were also eroded because of earlier imports from Romania.

Most importantly, Algoma claims that prices in the first quarter of 2003 declined from pricing in the last quarter of 2002. Among the reports on the activities of import competition provided by Algoma and Stelco, evidence was presented indicating that customers were seeking lower pricing as a direct result of imports from the named countries.

The evidence provided by Algoma and Stelco indicates a strong downward pressure on the pricing of steel plate in the Canadian industry due to the availability of low-priced imports from the named countries. Some of the evidence relates to specific instances of price erosion that had occurred while in other cases, the evidence indicates that sales were lost due to eroding asking prices. In both cases, the evidence indicates that the price erosion was caused by low-priced steel plate from the named countries.

Price Suppression

Algoma claims that the increasing presence of allegedly dumped imports in the Canadian market has resulted in an inability on the part of the domestic mills to raise prices to match increases in their costs. According to the complainant, sales at such prices have cost them significant revenues.

According to the complainant, due to the decrease in shipment volumes, the high fixed costs associated with the operation of an integrated steel mill had to be absorbed over fewer tons, causing a significant increase in the costs per ton shipped.

Underutilization of Plate Production Capacity

According to the complainant, the domestic industry has continued to make capital investments in their production facilities to reduce costs and improve international competitiveness. Algoma claims that based on its available production capacity, it could have produced more steel plate than what was shipped, even though export sales by the Canadian industry increased over the past two years.

Stelco also claimed injury in the form of underutilized production capacity. Stelco claims that allegedly dumped imports had caused it to cut back its plate mill operation to only 25% of its capacity. Given the high fixed costs of the plate business, the company alleges that it could not sustain such a low level of operation without suffering significant losses. Stelco provided evidence of sales that could have helped bring its production level to a viable level that were lost to low-priced imports from the named countries.

As a result, Stelco claimed that it was forced to idle its mill until higher prices could be obtained rather than to continue to sustain significant losses while operating at only 25% of capacity. If proper pricing can be restored and sufficient volume obtained, Stelco said it would restart the mill.

The evidence provided by Algoma and Stelco indicates that the Canadian mills' inability to obtain sufficient volume at a proper price level was significantly affected by the low-priced imports from the named countries. The CCRA noted that the United States is by far the largest exporter of steel plate to Canada. However, the price of steel plate from the United States is considerably higher than the price from the named countries. It is therefore believed that it is the low price and the increasing volume of steel plate imports from the named countries that are influencing the pricing level in the Canadian industry and resulting in lost sales and unused production capacity. The idling of Stelco's plate mill is, by itself, a strong indicator that a high proportion of the Canadian industry's capacity to produce steel plate is not utilized.

Previous Injury Findings

This complaint is the fifth in a series of complaints that have been filed by the industry on steel plate in the past 11 years. Imports of this product appear to be importer-driven, rather than foreign exporters offering their products on the world markets at dumped prices. On each occasion following the imposition of anti-dumping measures against a given group of countries, importers have located, as a result of their international connections or affiliations, other sources of dumped steel plate.

As part of the expiry review process, on June 11, 2002, the Commissioner determined that the expiry of the 1997 injury finding would likely result in the continuation or resumption of dumping of the goods from the four subject countries. On January 10, 2003, the Tribunal continued the finding on goods from China, South Africa and Russia but rescinded its finding on goods from Mexico. In its Statement of Reasons, the Tribunal stated that the domestic industry was vulnerable to injury from resumed dumping and from competition from imports from offshore, non-subject countries.

The various findings in place appear to demonstrate that, given the very nature of the product, the Canadian steel plate industry is highly vulnerable to low priced imports. It has been recognized in past cases that price is the overriding factor in this market and that prices from all suppliers in the market will tend to converge over time on the lowest-priced offerings.

It is the complainant's contention that unless countered by anti-dumping duty, allegedly dumped imports of subject goods from the named countries will continue to enter Canada in increasing volumes.

The complainant contends that there is a threat of future injury which will be exacerbated by the increased number of anti-dumping actions recently concluded or being undertaken by Canada and by other countries, including the United States, the European Communities and Mexico against steel products originating in or exported from the named countries. In its submission, the complainant provided evidence that the named countries have had an increasing number of cases initiated against them and have been found to have exported dumped steel plate and other steel products into other jurisdictions.

CONCLUSION

SCOPE OF THE INVESTIGATION

The CCRA will conduct an investigation to determine whether the subject goods have been dumped.

Period of Investigation

Information relating to the subject goods sold to or imported into Canada during the period of April 1, 2002, to March 31, 2003, the selected period of investigation, will be requested from exporters-manufacturers, exporters-vendors and importers. Sales and costing information will also be requested from exporters-producers to determine margins of dumping.

FUTURE ACTION

The Tribunal will conduct a preliminary inquiry to determine if there is evidence that discloses a reasonable indication that the dumping has caused or is threatening to cause injury to the Canadian industry. The Tribunal must make its decision within 60 days after the date of initiation of the investigation. If the Tribunal concludes that the evidence does not disclose a reasonable indication of injury to the Canadian industry, the investigation will be terminated.

If the CCRA's investigation reveals that imports of the subject goods have not been dumped, that the amount of dumping is insignificant, or that the actual or potential volume of the dumped goods is negligible, the investigation will be terminated.

If the CCRA's investigation reveals that the goods have been dumped and the Tribunal finds that there is a reasonable indication that the dumping has caused injury or is threatening to cause injury, the Commissioner will make a preliminary determination of dumping within 90 days from the date of the initiation of the investigation. Where circumstances warrant, this period may be extended to 135 days.

Should the Commissioner make a preliminary determination of dumping, imports of subject goods released from Customs' possession on and after the date of a preliminary determination of dumping may be subject to provisional duty equal to the estimated margin of dumping.

Should the CCRA make a preliminary determination of dumping, the investigation will be continued for the purpose of making a final determination or terminating the investigation within 90 days of the date of the preliminary determination. If a final determination of dumping is made, the Tribunal will continue its inquiry and hold public hearings into the question of material injury to the Canadian industry resulting from the dumped imports.

Subsequent to the CCRA making a final determination of dumping, but no later than 120 days after the notice of a preliminary determination, the Tribunal is required to make a finding with respect to the goods to which the final determination of dumping applies.

In the event of an injury finding by the Tribunal, subject goods would be subject to anti-dumping duty equal to the margin of dumping.

RETROACTIVE DUTY ON MASSIVE IMPORTATIONS

Under certain circumstances, anti-dumping duty can be imposed retroactively on subject goods imported into Canada in the period starting on the day the investigation was initiated and ending on the day prior to the preliminary determination of dumping.

Should the Tribunal issue a finding that there were recent massive importations of dumped goods that caused injury, importations of subject goods released by the CCRA on or after the initiation of this investigation could be subject to an anti-dumping duty.

UNDERTAKINGS

Interested parties may provide comments regarding the acceptability of undertakings within nine days of the receipt of undertakings by the CCRA. The CCRA will maintain a list of parties who wish to be notified should undertaking proposals be received. Those who are interested in being notified should provide their name, telephone and fax numbers, mailing address and e-mail address, if available, to one of the officers identified in the "Information" section.

If undertakings were accepted, the required payment of provisional duty on the goods would be suspended. However, notwithstanding the acceptance of undertakings, exporters may request that the investigation be completed and that the Tribunal complete its injury inquiry.

PUBLICATION

INFORMATION

Interested persons are invited to file written submissions presenting facts, arguments and evidence that they feel are relevant to the alleged dumping. Written submissions should be forwarded to the Central Registry, 10^th Floor, Sir Richard Scott Building, to the attention of one of the officers identified below. To be given consideration in this phase of the investigation, the written submissions should be received by the CCRA by August 5, 2003.

Any information submitted to the CCRA concerning this investigation is deemed to be public information unless clearly marked confidential. Written submissions marked confidential must be accompanied by a non-confidential version. This non-confidential version will be made available to other parties upon request.

Confidential information submitted to the CCRA will be disclosed on written request to independent counsel for parties to these proceedings, subject to conditions to protect the confidentiality of the information. Confidential information may also be released to the Tribunal, any court in Canada or a World Trade Organization (WTO) Dispute Settlement Panel. If you require additional information respecting the Directorate's policy on the disclosure of information under the SIMA, please contact one of the officers identified below or visit the Directorate's Web site.

This Statement of Reasons has been provided to persons directly interested in these proceedings. It is also posted at the Directorate's Internet Web site at the address below. For further information, please contact Denis Chénier or Michel Leclair as follows:

Mail

Canada Customs and Revenue Agency
Anti-dumping and Countervailing Directorate
10th Floor, Sir Richard Scott Building
191 Laurier Avenue West
Ottawa, Ontario
Canada  K1A 0L5

Telephone

Denis Chénier : (613) 954-7394
Michel Leclair: (613) 954-7232

Denis.Chenier@ccra-adrc.gc.ca
Michel.Leclair@ccra-adrc.gc.ca

Fax
(613) 941-2612

www.ccra-adrc.gc.ca/sima

Suzanne Parent

Director General
Anti-dumping and Countervailing Directorate

APPENDIX 1

APPARENT CANADIAN MARKET

CERTAIN HOT-ROLLED CARBON STEEL PLATE

AND HSLA STEEL PLATE

2000 TO MARCH 31, 2003 (Q1)

	2000	2001	2002	2003 (Q1)	Q2 2002 to Q1 2003 (incl.)
Domestic Shipments	609,079	584,358	447,614	106,363	442,074
IMPORTS: Bulgaria Czech Republic Romania All Named Imports Other Imports Total Imports	0 11,928 17,835 29,763 229,969 259,732	0 22 16,231 16,253 226,363 242,616	9,562 11,132 32,521 53,215 227,435 280,650	360 119 13,087 13,566 56,286 69,852	9,922 10,897 39,543 60,363 242,167 302,530
TOTAL MARKET	868,811	826,974	728,264	176,215	744,604
MARKET SHARES: Domestic Named Countries Other Imports Total Imports	70.1% 3.4% 26.5% 29.9%	70.7% 2.0% 27.4% 29.4%	61.5% 7.3% 31.2% 38.5%	60.4% 7.7% 32.0% 39.6%	59.4% 8.1% 32.5% 40.6%

SOURCES:

Import data based on information from the CCRA's internal information system.

Domestic data based on information from Canadian producers.

* For purposes of estimating the Apparent Canadian Market for the period of April 1, 2002 to

March 31, 2003, the actual domestic shipments for the first quarter of 2003 were added to 75% of the total domestic shipments for 2002.

APPENDIX 2

ESTIMATED MARGINS OF DUMPING

CERTAIN HOT-ROLLED CARBON STEEL PLATE

AND HSLA STEEL PLATE

(April 1, 2002 to March 31, 2003)

Country	Estimated% of Goods Dumped (in Terms of Volume of Total Subject Goods)	Estimated Margin of Dumping Range (% of Export Price)	Estimated Weighted Average Margins of Dumping (% of Export Price)
Bulgaria Czech Republic Romania	100.0% 99.8% 100.0%	14.1% to 35.3% 3.5% to 39.0% 5.7% to 93.6%	20.6% 19.9% 63.8%
All Named Countries	99.9%		48.8%