./.RESTRICTEDWORLD TRADE
ORGANIZATIONG/ADP/AHG/W/89
19 April 2000
(00-1610)
Committee on Anti-Dumping Practices
Ad Hoc Group on ImplementationOriginal:  English
PRACTICAL ISSUES AND EXPERIENCE
IN APPLYING ARTICLE 2.4.2
Paper by the United States
In prior communications, the United States explained that it is authorized under its
antidumping law to use in investigations either an average-to-average comparison methodology or a
transaction-to-transaction comparison methodology, in accordance with Article 2.4.2.  However, the
United States also explained that its strong preference, as reflected in US regulations, is to use theaverage-to-average comparison methodology in investigations.  This preference was adopted to avoid
extreme difficulty in selecting the appropriate normal value transaction to compare to any given
export transaction.  It is the view of the United States that, in many cases, the
transaction-to-transaction methodology, with which US authorities has little experience, could present
a heavy administrative burden with no guarantee of any increase in the accuracy of the resultingdumping margin calculations.
In light of these concerns, the United States would like to present for discussion the following
questions in order to gain a better understanding application of the transaction-to-transaction
methodology:
1. What criteria should be used in selecting the appropriate normal value transaction for
comparison to a given export transaction?
2. Should similarity of the merchandise being compared or contemporaneousness of the sales be
a more important criterion?  If a sale of similar, although not identical, merchandise is made in the
home market on the same day as the export sale under consideration, but a sale of identicalmerchandise is made in the home market one month later, which home market transaction should be
used for the comparison?  What considerations go into making this selection?
3. If several sales of identical merchandise are made in the home market on the same day as the
export sale, what factors should be used in selecting a home market sale for comparison?
4. How long a time may transpire before a particular home market sale is no longer eligible for
comparison under the transaction-to-transaction methodology?  Would this determination vary from
case to case?  If so, what considerations should go into making this determination?
5. To what extent, if at all, is a similarity in the levels of trade of the home market and export
customer relevant to selecting a home market transaction for purpose of a transaction-to-transaction
comparison?  If it is a relevant consideration, how should it be weighed against other criteria, such as
similarity of the merchandise being compared or contemporaneousness of the sales?G/ADP/AHG/W/89
Page 2
6. Certain Members have indicated that their authorities normally apply a
transaction-to-transaction methodology.  Under wh at circumstances would such Members apply an
average-to-average comparison methodology?
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