OTTAWA, December 5, 2003
4249-33
AD 1306
STATEMENT OF REASONS
concerning the initiation of an investigation into the dumping of
WOOD VENETIAN BLINDS AND SLATS ORIGINATING IN OR EXPORTED FROM MEXICO AND THE PEOPLE'S REPUBLIC OF CHINA
DECISION
Pursuant to subsection 31(1) of the Special Import Measures Act, the Commissioner of Customs and Revenue initiated an investigation on November 21, 2003, into the alleged injurious dumping of wood venetian blinds and slats originating in or exported from Mexico and the People's Republic of China.
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TABLE OF CONTENTS
SUMMARY
INTERESTED PARTIES
PRODUCT INFORMATION
CANADIAN INDUSTRY
STANDING
THE CANADIAN MARKET
EVIDENCE OF DUMPING
VOLUME OF DUMPED GOODS
EVIDENCE OF INJURY
CONCLUSION
SCOPE OF THE INVESTIGATION
FUTURE ACTION
RETROACTIVE DUTY ON MASSIVE IMPORTATIONS
UNDERTAKINGS
PUBLICATION
INFORMATION
APPENDIX 1
APPENDIX 2
APPENDIX 3
[1] On October 8, 2003, the Canada Customs and Revenue Agency (CCRA) received a written complaint from Stores de bois de Montréal Inc. (SBM) concerning the alleged injurious dumping of wood venetian blinds and slats originating in or exported from Mexico and the People's Republic of China. On October 22, 2003, pursuant to subsection 32(1) of the Special Import Measures Act (SIMA), the CCRA informed the complainant in writing that its complaint was properly documented. The CCRA also notified the governments of Mexico and the People's Republic of China (China).
[2] The complainant provided evidence that these products have been dumped. Further, 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.
[3] As a result, on November 21, 2003, the Commissioner of Customs and Revenue initiated an investigation pursuant to subsection 31(1) of SIMA.
[4] Stores de bois de Montréal Inc.
8320 Place Lorraine
Montréal (Anjou district), Quebec H1J 1E6
[5] From Customs import documentation; the CCRA has identified 51 possible exporters of the subject goods.
[6] From Customs import documentation; the CCRA has identified 47 possible importers of the subject goods.
[7] For the purpose of this investigation, the subject goods are defined as:
Wood venetian blinds and slats originating in or exported from Mexico and the People's Republic of China.
[8] Wood venetian blinds1 (blinds) are composed of stained, varnished and/or film-coated slats.2 Most often, the slats are one inch (25 mm) or two inches (50 mm) wide and an eighth of an inch (3 mm) thick. The blinds are used to cover windows of varied dimensions.
[9] Imported blinds come in standard sizes. The most-often used standard dimensions are 48 inches and 72 inches high by 23, 30, 37, 44, 51, 58, 65, and 72 inches wide. Before delivery, the blinds are adjusted to fit the dimensions required by the consumer. As needed, slats are removed to shorten the blind and can be cut by up to 3.5 inches on each side. Hence, a standard blind measuring 23 inches wide can be used to cover a window measuring anywhere from 16 to 23 inches wide.
[10] The slats are connected by strings used to tilt, raise, and lower the slats. There is also a locking mechanism. The slats can be enhanced using decorative cords instead of strings. The blind is equipped with either a tilt cord or wand mechanism for opening and closing. The various mechanisms are housed in a headrail made of metal, PVC, or other material. The slats rest on a bottom rail, usually made of wood, when the blinds are raised.
[11] The slats are also imported separately and are the main component of the blinds. These slats have no other purpose or commercial use. They may be stained, painted, film-coated, or bare. The types of wood most commonly used to manufacture slats are basswood, cherry, white ash, beech, poplar, ramin, samba, red oak, and red cedar.
[12] Note that ramin products imported into Canada must be accompanied by a CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora) export permit issued by the exporting country if the wood is from a nation that has included ramin on the list of protected species; or a CITES export permit, a CITES certificate of origin, or a CITES re-export certificate if the specimen is from another nation.
[13] Wood venetian blinds are properly classified under the following Harmonized System classification numbers:
4421.90.30.00 4421.90.40.40
[14] Wood slats are properly classified under the following Harmonized System classification numbers:
4421.90.40.40 4421.90.90.50 4421.90.90.99
[15] Because there is no specific tariff classification for slats, it is difficult to determine slat imports accurately. Also, it is impossible for Statistics Canada to produce electronic data on imports of this product. There is therefore no public information available for slat imports.
[16] There are very few integrated producers in Canada, i.e., producers that produce slats and assemble them into blinds. In its documented complaint, the complainant identified three other Canadian producers of wood venetian blinds that produce their own slats-Industries La Belle in Blainville, Quebec, Tapis Saucier in Trois-Pistoles, Quebec, and Trans UV in Ville Saint-Laurent, Quebec.
[17] However, there are a number of Canadian companies that assemble blinds using imported wood slats. Many of these producers are major companies, such as the Hunter Douglas Group, which includes Shade-O-Matic, Blinds To Go, and Levolor.
[18] The CCRA also identified two producers that assemble blinds using wood slats imported by a national distributor. These two producers are therefore part of the Canadian industry.
[19] SIMA requires that the following conditions be met in order to initiate an investigation:
[20] For the application of standing under SIMA, domestic industry means the domestic producers as a whole of the like goods except that, if a domestic producer is related to an exporter or importer of allegedly dumped goods, or is an importer of such goods, "domestic industry" may be interpreted as meaning the rest of those domestic producers.
[21] The number of domestic producers considered producers as a whole of like goods in this case is six. Refer to the list in Appendix 1.
[22] Of these six domestic producers, the two companies with the highest production support the complaint and no producer opposes it. The complainant represents more than 25% of domestic production on its own and with the support of Trans UV, their collective production represents more than 50% of domestic production.
[23] The Canadian market can be divided into two: the made-to-measure blind market and the standard blind market. Both products are essentially the same since in both cases, the consumer orders blinds by specifying the dimensions of the window to be covered. The order can be placed at a superstore, in small boutiques, or directly with the manufacturer.
[24] Standard blinds, also called "Ready-Made" blinds, are mass-produced blinds that come in the same dimensions and colour that producers or retailers keep in stock and adjust to suit the needs of consumers. These blinds are sold particularly in superstores and specialized boutiques. The big names include Sears, Rona, Ikea, Canadian Tire, Blinds To Go, and Bouclair.
[25] Made-to-measure blinds are manufactured after the consumer has placed an order and are generally more expensive than standard blinds. Made-to-measure blinds have advantages over standard blinds. These advantages are: a size guarantee, a better degree and quality of finishing, and a wider selection of colours. Currently, because of the alleged dumping, the advantages of made-to-measure blinds are not enough to offset the price difference with the standard blinds.
[26] The window covering market is subject to the whims of fashion. For several years, the wood venetian blind has been in increasing demand. However, there is no consolidated data for the market as a whole. Statistics Canada publishes data on the value of assembled wood blind imports but none on the value of wood slat imports. Further, there is no data on the overall volume of wood blinds and slats imported because existing data is not compatible; the volume of blinds may be measured as units, in square feet, or in linear feet for slats.
[27] The CCRA believes that the Canadian market is growing because the volume of blind imports, according to Statistics Canada, is on the rise and because of the emergence, over the past three years, of new producers in Canada, including Trans UV in 2002, Les Industries l'Avant-Garde in 2001, and V.P. Fabricants de Stores, which opened its doors in 2003.
[28] Appendix 2 shows that the value of blind imports is increasing. The data indicates an increase of at least 14% in 2001 and 17% in 2002. As for 2003, data is available for the first seven months only. According to Statistics Canada, there appears to have been a decrease in the value of imports-the first seven months in 2003 reported $8,896,500 as compared to $9,670,566 for the same period in 2002, a decrease of approximately 8%. This drop may be circumstantial when the appreciation of the Canadian dollar in 2003 relative to the American dollar is taken into consideration.
[29] In view of the incomplete data, the CCRA believes it reasonable to estimate the Canadian market at around $30 million. If need be, at the time of the preliminary determination, the CCRA will be able to more accurately assess the Canadian market.
[30] The complainant alleges that wood venetian blinds and slats from Mexico and China 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. The complainant's allegations of dumping are based on a comparison of estimated normal values of the subject goods and the estimated export prices to Canada.
[31] Estimates of normal values, export prices, and margins of dumping are discussed below.
[32] Normal values are generally based on the domestic selling price of the goods in the country of export or on the full cost of the goods plus a reasonable amount for profits.
[33] The complainant is not aware of the domestic prices in Mexico or China. Consequently, the complainant estimated the normal values by adding its production costs, selling and administrative expenses, and an amount for profits. The costs were adjusted to reflect labour costs and selling and administrative expenses, which are less in Mexico and China. All of the amounts are in Canadian dollars and are calculated per square foot.
[34] SBM chose to construct the normal values using its production costs for the standard height models in highest demand in the Canadian market, 48 inches and 72 inches. The material cost was considered universal. The labour costs were calculated as a percentage of SBM salaries. These percentages were obtained from the US Import Administration's Web site.3 The same Web site was used to calculate the factory overhead and selling and administrative expenses.4 A generally accepted rate of 8% was used for profits. The same reasoning was used to construct the normal values of slats.
[35] The CCRA verified the cost estimates provided by the complainant. The complainant's estimates are conservative since they include very significant adjustments. The CCRA accepted the complainant's estimated normal values.
[36] The CCRA also considered whether, in the case of China, there were grounds to apply section 20 of SIMA. At this time, there is nothing to suggest that domestic prices of wood blinds and slats are substantially determined by the government of China and that there is sufficient reason to believe that they are not substantially the same as they would be if they were determined in a competitive market. The CCRA therefore does not expect to use section 20.
[37] The export price is generally the lesser of the importer's purchase price or the exporter's selling price to Canada less all charges and expenses resulting from the exportation of the goods.
[38] To estimate the export prices of blinds, SBM used the retail price from Sears. Sears' prices were used because they are neither the most expensive nor the least and, according to SBM, best represent the blind market in Canada.
[39] To estimate the export price, SBM reduced the retail price by two margins: 30% for the retailer and 30% for the importer. Freight, handling, and insurance charges totalling 7% and a 10% commission were then deducted. In the case of blinds from China, customs duties of 3% were also deducted.
[40] SBM based the export price of stained slats on the average selling price of Chinese suppliers to Canadian manufacturers. To calculate the export price of bare slats, a quotation that SBM received in September 2003 from a Chinese producer was used. As with blinds, freight, handling, and insurance charges totalling 7% and a 10% commission were deducted. In the case of slats from China, customs duties of 3% were also deducted.
[41] The CCRA reviewed this method and considers it to be sufficient and realistic. The CCRA also compared these estimated export prices with its own internal import statistics. In almost every case, the export prices reported by importers are less than SBM's estimates. As a result, given the conservative nature of the assessments, the CCRA considered the complainant's estimated export prices to be reasonable.
[42] Using the above normal values and export prices, the estimated margins of dumping range from 77% to 119% when expressed as a percentage of the export price. These margins are significant and clearly indicate that wood blinds and slats are being dumped.
[43] Based on the complainant's information, information publicly available and the CCRA's own data on imports, there is reasonable evidence that the imported goods are being dumped.
[44] Taking into consideration the estimated margins of dumping, all of the subject goods imported during the 12-month period from October 1, 2002, to September 30, 2003 (investigation period), were dumped.
[45] Under section 35 of SIMA, if, before the Commissioner makes a preliminary determination, the actual and potential volume of dumped goods from a designated country is considered to be negligible, i.e., less than 3% of total imports of like goods, the Commissioner must terminate the investigation with respect to that country. The estimated volume of dumped goods expressed as a percentage of total imports for the period is 3.2% for Mexico and 59.5% for China. The CCRA will continue to examine the question of the dumped volumes during the preliminary stage of its investigation.
[46] The complainant has alleged that the subject goods from Mexico and China have been dumped into Canada and that the dumping has caused or is threatening to cause material injury to the Canadian industry. In support of its allegations, the complainant provided evidence of an increase in the volume of imports of the dumped goods, price erosion, lost sales, and lost investment.
[47] The complainant used Statistics Canada data (see Appendix 2) to show that there has been an increase in imports of the subject goods. The CCRA prepared a table (see Appendix 3) based on information taken from its internal information system. The tables confirm that the volume of imports from China has significantly increased. The complainant believes that in a growing market, it should have had a share of the growth and that if China was able to significantly increase its market share, it is because of dumping. Further, if Mexico was able to maintain its relative market share, it is because goods from that country were also dumped.
[48] The complainant stated that the prices for imported wood blinds are steadily decreasing. According to the complainant, dumping by Chinese exporters is increasing, and Mexican exporters are following suit. The import prices of goods from China dropped by more than 20% between February 2002 and June 2003, as seen on customs invoices.
[49] SBM also lowered its selling prices by adding an additional 20% discount since last summer. Despite the fact that SBM's suggested selling prices have increased this year, this additional discount represents a reduction that is greater than the increase in price. The complainant attached invoices to its complaint showing that net prices dropped by 12% in one year.
[50] The selling prices of dumped blinds are not only dropping, they have also reached a level where the complainant feels it can no longer compete without financially endangering the company.
[51] SBM could stop producing slats and import them instead. However, even if the import price of these slats were half of SBM's cost prices, SBM's selling prices would still not be competitive.
[52] SBM experienced continuous growth up to February 2003 but has since lost sales almost every month. As stated above, since 2002, import prices for blinds from China have dropped by approximately 20%. SBM also had to offer greater discounts and review its price structure. Further, SBM developed new markets in Canada by engaging three other distributors in Ontario. In spite of this, these efforts have not borne fruit because SBM is continuing to experience lost sales. The losses would probably be even greater were SBM not looking to increase sales across Canada. According to the complainant, import prices for blinds from Mexico are also dropping in order to remain competitive with prices from China.
[53] One aggravating factor of losing sales because of dumping is the lack of interest of Canadian retailers in continuing to offer Canadian wood blinds because of their lack of competitive pricing relative to the prices of imported blinds.
[54] SBM would also like access to the standard blind market, which it believes is impossible because of the dumping of the subject goods. Producing standard blinds would allow SBM to sell to major distributors such as Rona and Sears at economic prices. However, SBM cannot penetrate that sector because of the presence of the subject goods. The other integrated Canadian producers are in the same situation.
[55] SBM is also able to produce slats in sufficient quantity to satisfy the blind assembly market in Canada. However, for the same reasons as those for standard blinds, SBM and the other Canadian slat producers have no chance of penetrating the blind assembly market in Canada.
[56] The production of blinds and slats is a major investment for SBM. Over the years, it has invested in research and development to ensure that it is on the cutting edge. However, because of this year's difficulties and lost sales, SBM had to invest in diversification to ensure its survival. This caused a significant decrease in the company's working capital, which caused SBM to lose its competitive edge. Also, SBM is unable to improve its production facilities in a growing market.
[57] Another aspect of lost investment for the owners of SBM is the lost possibility of reselling the company. The owners of SBM have, in the past, received a few offers to buy the business. Since SBM started losing sales due to dumped imports, it has become impossible for shareholders to receive a sufficient return on their investment.
[58] SBM's machinery is a major investment. It allows SBM to be able to produce on a large scale, but given the current situation, SBM is using only a small proportion of its capacity. This underutilization means a loss on SBM's return on investment and affects the number of jobs at SBM.
[59] Based on the complainant's information, other available information, and the CCRA's data on imports, there is evidence that the goods have been dumped and there is a reasonable indication that such dumping has caused or is threatening to cause injury to the Canadian industry.
[60] The CCRA will conduct an investigation to determine whether the subject goods have been dumped.
[61] The period of investigation is the time frame selected, during which imports into Canada from Mexico and China will be reviewed to determine whether the subject goods have been dumped. The period of investigation is October 1, 2002, to September 30, 2003, and includes all subject goods shipped to Canada during this period. Information, including sales and costs, will be requested from exporters to estimate the margins of dumping.
[62] In view of the large number of exporters, the CCRA is limiting its examination of dumping to six exporters from China and three exporters from Mexico, pursuant to subsection 30.3(1) of SIMA. The combined declared value for duty of these six exporters from China and three exporters from Mexico represents more than 75% and 95%, respectively, of the total value of the subject goods imported into Canada in the 12-month period from October 1, 2002, to September 30, 2003, from these two countries.
[63] Exporters not required to provide information necessary to determine the individual margin of dumping were informed of the initiation of the investigation and the future action and may voluntarily submit that information if they so wish. The CCRA will consider voluntary submissions for the purpose of the preliminary determination only if time permits.
[64] The Canadian International Trade Tribunal (Tribunal) will conduct a preliminary inquiry into whether the evidence discloses a reasonable indication that the dumping of the goods 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.
[65] If the CCRA's investigation reveals that imports of the subject goods have not been dumped, that the margin of dumping is insignificant, or that the actual and potential volume of dumped goods is negligible, the investigation will be terminated.
[66] If the evidence reveals that the goods have been dumped and the Tribunal finds that there is a reasonable indication that the dumping of the goods 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.
[67] 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.
[68] If provisional duty becomes applicable, it will be imposed in the following manner:
[69] 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.
[70] 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. The Tribunal is required to make a finding, with respect to the goods to which the final determination of dumping applies, not later than 120 days after the CCRA notice of a preliminary determination.
[71] In the event of an injury finding by the Tribunal, subject goods would be subject to an anti-dumping duty equal to the margin of dumping.
[72] 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 of the preliminary determination of dumping.
[73] When the Tribunal conducts an inquiry on material injury to the Canadian industry, it may consider if dumped goods that were imported close to or after the initiation of the investigation constitute massive importations over a relatively short period of time and have caused injury to the Canadian industry.
[74] 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.
[75] After a preliminary determination of dumping, the exporter may submit a written undertaking to revise its selling prices to Canada so that the margin of dumping or the injury caused by the dumping is eliminated. An acceptable undertaking must account for all or substantially all of the exports to Canada of the dumped goods.
[76] Interested parties may provide comments regarding the acceptability of undertakings within nine days of the receipt of an undertaking by the CCRA. The CCRA will maintain a list of parties who wish to be notified should an undertaking proposal be received. Those who are interested in being notified should provide their name, telephone and fax numbers, mailing address and email address, if available, to one of the officers identified in the "Information" section.
[77] If an undertaking were to be accepted, the required payment of provisional duty on the goods would be suspended. However, notwithstanding the acceptance of an undertaking, an exporter may request that the investigation be completed and that the Tribunal completes its injury inquiry.
[78] Notice of the initiation of this investigation is being published in the Canada Gazette pursuant to subparagraph 34(1)(a)(ii) of SIMA.
[79] Interested parties 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 attention of one of the officers identified below.
[80] To be given consideration in this phase of the investigation, all information should be received by the CCRA by January 5, 2004.
[81] Any information submitted to the CCRA by interested parties concerning this investigation is deemed to be public information unless clearly marked "confidential." Where the submission by an interested party is confidential, a non-confidential version of the submission must also be provided at the same time. This non-confidential version will be made available to other interested parties upon request.
[82] Confidential information submitted to the Commissioner of Customs and Revenue 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) panel. If you require additional information respecting the Directorate's policy on the disclosure of information under SIMA, please contact one of the officers identified below or visit the Directorate's Web site.
[83] This Statement of Reasons has been provided to persons directly interested in these proceedings. It is also posted on the Directorate's Web site at the address below. For further information, please contact Michel Desmarais or Hugh Marcil as follows:
Mail
Canada Customs and Revenue Agency
Anti-Dumping and Countervailing Directorate
191 Laurier Avenue West, 10th Floor
Ottawa, Ontario K1A 0L5
Canada
Telephone
Michel Desmarais (613) 954-7188
Hugh Marcil (613) 941-6340
Fax
(613) 948-4844
Email
Michel.Desmarais@ccra@adrc.gc.ca
Hugues.Marcil@ccra@adrc.gc.ca
Web site
http://www.cbsa-asfc.gc.ca/sima-lmsi/menu-eng.html
Suzanne Parent
Director General
Anti-Dumping and Countervailing Directorate
Domestic producers who make up the Canadian industry of like goods:
Les Industries La Belle
Division de la Belle Vénitienne Inc.
46 Blvd. de la Seigneurie
Blainville, QC J7C 3V5
Les Industries l'Avant-Garde
318B Saint-Paul Street
Le Gardeur, QC J5Z 3T3
Stores de bois de Montréal
8320 Place Lorraine
Montréal (Anjou district), QC H1J 1E6
Tapis Saucier
98 Route 132 West
Trois-Pistoles, QC G0L 4K0
Trans UV
5235 Henri-Bourassa West
Saint-Laurent, QC H4R 1B8
V.P. Fabricants de Stores
2315 des Entreprises, Suite 102
Terrebonne, QC J6X 4J9
Value of Imports of Wood Blinds
|
7 months |
||||||||||
|
2000 |
2001 |
2002 |
2002 |
2003 |
||||||
|
Value |
% |
Value |
% |
Value |
% |
Value |
% |
Value |
% |
|
|
China |
1,657,326 |
13% |
4,484,777 |
33% |
7,344,900 |
48% |
4,145,422 |
43% |
5,415,389 |
61% |
|
United States |
8,900,297 |
72% |
7,759,119 |
56% |
6,975,300 |
45% |
4,895,037 |
51% |
2,957,275 |
33% |
|
Hong Kong |
421,698 |
3% |
336,155 |
2% |
- |
0% |
- |
0% |
665 |
0% |
|
Mexico |
607,468 |
5% |
573,341 |
4% |
523,845 |
3% |
327,222 |
3% |
248,510 |
3% |
|
Taiwan |
314,420 |
3% |
398,115 |
3% |
343,358 |
2% |
208,684 |
2% |
193,129 |
2% |
|
Other countries |
378,920 |
3% |
239,686 |
2% |
261,238 |
2% |
94,201 |
1% |
81,532 |
1% |
|
Total |
12,280,129 |
13,791,193 |
15,448,641 |
9,670,566 |
8,896,500 |
|||||
Source:
Statistics Canada
Value of Imports from Main Countries
Country |
October 1999 to September 2000 |
October 2000 to September 2001 |
October 2001 to September 2002 |
October 2002 to September 2003 |
|
China |
$ 1,161,219 |
$ 3,882,718 |
$ 7,228,611 |
$ 8,348,804 |
|
United States |
$ 8,172,243 |
$ 7,907,626 |
$ 8,116,114 |
$ 4,808,169 |
|
Mexico |
$ 594,579 |
$ 584,255 |
$ 549,629 |
$ 442,953 |
|
Taiwan |
$ 292,081 |
$ 459,997 |
$ 344,402 |
$ 279,330 |
|
Other countries |
$ 776,785 |
$ 573,147 |
$ 281,782 |
$ 156,595 |
|
Total |
$ 10,996,907 |
$ 13,407,742 |
$ 16,520,537 |
$ 14,035,852 |
Source:
Import data is based on information taken from the CCRA's internal information system.
1 This product is known by several names: wood venetian blinds, wood blinds, basswood or other wood blinds, or simply blinds.
2 Both "strips" and "laths" are synonymous with slats.
3 US Import Administration: Safeguarding American Industries and Jobs against Unfair Trade, Expected Wages of Selected Non-Market Economy Countries Corrected 2000 Income Data, Revised September 2002 http://ia.ita.doc.gov/wages/
4 US Import Administration: April 1997, Memorandum to: all reviewers, From: Richard W. Moreland, Acting Deputy Assistant Secretary. Subject: Index of Factor Values for Use in Antidumping Duty Investigations Involving Product