Calculation of average margins
08/12/2022 07:16
Companies should note a number of important points about the Commerce Department's method of calculating dumping margins. First, as discussed earlier, transactions with negative dumping margins (where the United States price is higher than the foreign market price) do not offset the transactions with positive dumping margins.
Second, large volume transactions disproportionately affect the final margin. When a company discovers such a transaction, it should carefully review the facts about the transaction. Perhaps it is possible to exclude the transaction from the investigation (for example, if it is arguably outside the period of investigation). Alternatively, perhaps there is some basis for raising the United States price (by disallowing an adjustment that would lower the United States price).
Third, the Commerce Department calculates a single margin for all models under investigation, not model-by-model margins. Dumping margins on a few models can therefore result in dumping margins for all models that the foreign company exports to the United States. In general, margins on high-value products tend to weigh more heavily than the margins on low-value products.
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