   
  
WT/DS471/ARB/Add.1  
 
1 November 2019  
(19-7341) Page: 1/100 
  Original: English  
 
  
UNITED STATES – CERTAIN METHODOLOGIE S AND THEIR APPLICATION 
TO ANTI -DUMPING PROCEEDINGS  INVOLVING CHINA  
RECOURSE TO ARTICLE 22.6 OF THE DSU BY T HE UNITED  STATES  
DECISION BY THE ARBITRATOR  
Addendum  
BCI redacted, as indicated [[***]]  
This addendum  contains Annexes A to E to the Decision of the Arbitrator  to be found in document  
WT/DS471/ ARB. 
 
 
_______________  
 
 WT/DS471/ARB/Add.1  
 
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LIST OF ANNEXES  
ANNEX  A 
WORKING PROCEDURES O F THE ARBITRATOR  
Contents  Page  
Annex  A-1 Working Procedures of the Arbitrator  5 
Annex  A-2 Additional Working Procedures of the Arbitrator concerning Business 
Confidential Information  10 
ANNEX B  
ARGUMENTS OF THE PAR TIES 
Contents  Page  
Annex  B-1 Executive summary of the arguments of the United States  12 
Annex  B-2 Executive summary of the arguments of China  23 
ANNEX  C 
PROCEDURAL RULING  OF THE ARBITRATOR  
Contents  Page  
Annex  C-1 Procedural Ruling on the United States' Request to Partially Open the 
Arbitrator's Meeting to Public Observation  34 
ANNEX  D 
GRAPHICAL ILLUSTRATI ONS AND FIGURES CONC ERNING THE PARTIES' PROPOSED CALCULATION  
METHODOLOGIES  
Contents  Page  
Annex  D-1 China's proposed DID tabular approach: Graphical illustrations of the failure 
to meet the parallel trends assumption provided by the United States  38 
Annex D -2 United States' proposed Armington model: Relationship between the change 
in the market share of Chinese exporters within the PRC -wide entity and the 
duration of the anti -dumping orders  39 
Annex D -3 United States' proposed Armington model: Relationship between the change 
in the market share of Chinese exporters within the PRC -wide entity and the 
level of the WTO -inconsistent PRC-wide duty rates  40 
ANNEX  E 
DATA INPUTS AND CALC ULATIONS OF THE ARBI TRATO R 
Contents  Page  
Annex E -1 Data inputs for US market values in the year prior to the imposition of the 
anti-dumping orders  42 
Annex E -2 Data inputs for the share of US imports from China covered by different 
Chinese exporters in the year prior to the imposition of the anti -dumping 
orders  49 
Annex E -3 List of Chinese exporters outside the PRC -wide entity used to estimate the 
share of different Chinese exporters for six anti -dumping orders  57 WT/DS471/ARB/Add.1  
 
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  Contents  Page  
Annex E -4 List of Chinese exporters subject to the WA -T duty rates and other Chinese 
exporters outside the PRC -wide entity used to estimate the share of different 
Chinese exporters for three anti -dumping orders  70 
Annex E -5 Data inputs for elasticities  74 
Annex E -6 Data inputs for the actual anti -dumping duty  rates 76 
Annex E -7 List of anti -dumping duty rates used for two anti -dumping orders  81 
Annex E -8 Data inputs for US market values in 2017  85 
Annex E -9 Code and text version of the Armington model  91 
Annex E -10 Data inputs used to implement the Armington model under the two steps  96 
Annex E -11 Results of implementing the Armington model under the first step  99 
 
 
 
 
 WT/DS471/ ARB/Add.1  
 
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  ANNEX  A 
WORKING PROCEDURES O F THE ARBITRATOR  
Contents  Page  
Annex  A-1 Working Procedures of the Arbitrator  5 
Annex  A-2 Additional Working Procedures of the Arbitrator concerning Business 
Confidential Information  10 
 
 WT/DS471/ARB/Add.1  
 
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  ANNEX A -1 
WORKING PROCEDURES O F THE ARBITRATOR  
 
Adopted on 15 November 2018  
 
Amended on 13 February 2019  
 
General  
 
1. (1) In this proceeding, the Arbitrator shall follow the relevant provisions of the 
Understanding on Rules and Procedures Governing the Settlement of Disputes ("DSU").  In 
addition, the following Working Procedures apply.   
(2) The Arbitrator reserves the right to modify these procedures as necessary, after 
consultation with the parties.  
Confidentiality  
2. (1) The deliberations of the Arbitrator  and the documents submitted to it  shall be kept 
confidential. Members shall treat as confidential information that is submitted to the Arbitrator 
by another Member which the submitting Member has designated as confidential.  
(2) Nothing in the DSU or in these Working Procedures shall preclude a party from disclosing 
statements of its own positions to the public.   
(3) If a party submits a confidential version of its written submissions to the Arbitrator , it 
shall also, upon request of a Member , provide a non -confidential summary of the information 
contained in its submissions that could be disclosed to the public. Non-confidential summaries 
shall be submitted no later than ten days after the written submission in question is presented 
to the Arbitrator, unless a different deadline is est ablished by the Arbitrator upon written 
request of a party showing good cause.   
(4) Upon request, the Arbitrator may adopt appropriate additional procedures for the 
treatment and handling of confidential information after consultation with the parties.  
Submissions  
3. (1) Before the substantive meeting of the Arbitrator with the parties, China shall transmit 
to the Arbitrator and to the United States a communication explaining the basis for its request, 
including the methodology and data supporting it, in a ccordance with the timetable adopted 
by the Arbitrator.   
(2) Each party to the dispute shall also transmit to the Arbitrator a written submission in 
which it presents the facts of the case and its arguments as well as the economic and legal 
basis supporti ng them, if any, in accordance with the timetable adopted by the Arbitrator.  
(3) The Arbitrator  may invite the parties to make  additional submissions during  the 
proceeding, including with respect to requests for preliminary rulings in accordance with 
paragraph 4 below.   
Preliminary rulings  
4. (1) If the United States considers that the Arbitrator  should make a ruling before the 
issuance of the Decision  that c ertain measures, claims or issues are not properly before the 
Arbitrator , the following procedure applies . Exceptions to this procedure shall be granted upon 
a showing of good cause.     WT/DS471/ ARB/Add.1  
 
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  a. The United States shall submit any such request for a preliminary ruling at the earliest 
possible opportunity. China shall submit its response to the request at a time to be 
determined by the Arbitrator in light of the request.  
b. The Arbitrator  may issue a preliminary ruling on the issues raised in such a preliminary 
ruling request before, during or after the substantive meeting , or the Arbitrator  may defer 
a ruling on the issues raised by a preliminary ruling until it issues its Decision  to the parties.  
c. If the Arbitrator  finds it appropriate to issue a preliminary ruling before  the issuance of its 
Decision , the Arbitrator  may provide  reasons for the ruling at the time that the ruling is 
made, or subsequently in its Decision .   
(2) This procedure is without prejudice to the pa rties' right to request other types of 
preliminary or procedural rulings during  the proceeding, and to the procedures that the 
Arbitrator  may follow with respect to such requests.  
Evidence  
5. (1) Each party shall submit all evidence to the Arbitrator  no later than the substantive 
meeting , except evidence necessary for purposes of rebuttal, or evidence necessary for 
answers to questions or comments on answers provided by the other party. Additional 
exceptions may be granted upon a showing of good cause.  
(2) If any new evidence has been admitted upon a showing of good cause, the Arbitrator  
shall accord the other party an appropriate period of time to comment on the new evidence 
submitted.  
6. (1) If the original language of an exhibit  or portion thereof is not  a WTO working language, 
the submitting party shall simultaneously submit a translation of the exhibit or relevant portion 
into the WTO working language of the submission . The Arbitrator may grant reasonable 
extensions of time for the translation of exhibits upon a showing of good cause.  
(2) Any objection as to the accuracy of a translation should be raised promptly  in writing, 
preferably no later than the next filing or the meeting (whichever occurs earlier) following the 
submission which contains the translation in question. Any objection shall be accompanied by 
a detailed explanation of the grounds for the  objection and an alternative translation.  
7. (1) To facilitate the maintenance of the record of the dispute and maximize the clarity of 
submissions, each party shall sequentially number its exhibits throughout the course of the 
dispute, indicating the submitting Member and the number of each exhibit on its cover page.  
Exhibits submitted by China should be numbered CHN -1, CHN -2, etc. Exhibits submitted by 
the United States should be numbered USA -1, USA -2, etc. If the last exhibit in  connection 
with a submission was numbered CHN-5, the first exhibit in connection with the next 
submission thus would be numbered CHN-6.  
 
(2) Each party shall provide a n updated  list of exhibits  (in Word or Excel format) together 
with each of its submissions, oral statements, and responses to questions.  
(3) If a party submits a document that has already been submitted as an exhibit by the 
other party, it should explain why it is submitting that d ocument again.  
(4) Insofar as a party cons iders that the Arbitrator should take into account a document 
already submitte d as an exhibit in the prior panel proceeding s, it should resubmit that 
document as an exhibit for the purpose of this proceeding. In its list of exhibits, it should refer 
to the number of the original exhibit in the original panel proceeding (OP) , if applicable  
(example: USA-1 (USA-21-OP)).  
(5) If a party includes a hyperlink to the content of a website in a submission, and intends 
that the cited content form part of the official record, the cited content of the website shall be 
provided in the form of an exhibit.  WT/DS471/ARB/Add.1  
 
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  Editorial Guide  
8. In order to facilitate the work of the Arbitrator , each party is invited  on a voluntary basis  to 
make its s ubmissions in accordance with the WTO Editorial Guide for Submissio ns (electronic copy 
provided).  
Questions  
 
9. The Arbitrator may pose questions to the parties at any time, including:  
a. Before the meeting, the Arbitrator  may send written  questions , in ad dition to written 
questions already specified in the timetable,  or a list of topics it intends to pursue in 
questioning orally or in writing during the meeting. The Arbitrator may ask different or 
additional questions at the meeting.   
b. The Arbitrator  may put questions to the parties orally  or in writing  during  the meeting, 
and in writing following the meeting, as provided for in paragraph 16 below.   
Substantive meeting  
 
10. The Arbitrator shall meet in clos ed session.   
11. The parties shall  be present at the meetings only when invited by the Arbitrator  to appear 
before it.  
12. (1) Each party has the right to determine the composition of its own delegation when 
meeting with the Arbitrator .  
(2) Each party shall  have the responsibility for al l members of its delegation and shall 
ensure that each member of its delegation acts in accordance with the DSU and these Working 
Procedures, particularly with regard to the confidentiality of the proceeding and the 
submissions of the parties.  
13. Each pa rty shall provide to the Arbitrator the list of members of its delegation no later than 
5.00 p.m. (Geneva time ) three working days before  the first day of each meeting with the Arbitrator .  
14. A request for interpretation by any party should be made to th e Arbitrator as early as possible, 
preferably at the organizational stage, to allow sufficient time to ensure availability of interpreters.  
15. There shall be one substantive meeting with the parties.  
16. The substantive meeting of the Arbitrator with the parties shall be conducted as follows:  
a. The Arbitrator shall invite the United States to make an opening statement to present 
its case first.  Subsequently, the Arbitrator shall invite China to present its point of view. Before 
each party takes the floor, it shall provide the Arbitrator with a provisional written version of 
its statement, including any visual presentations. If interpretation is needed, each party shall 
provide additional copies for the interpreters.  
b. Each party should avoid lengthy repetition of the arguments in its submissions. Each 
party is invited to limit the duration  of its opening statement to not more than 60  minutes. I f 
either party considers that it requires more time for its opening statement, it should inform 
the Arbitrator  and the other party at least 10 days prior to the meeting, together with  an 
estimate of the expected duration  of its statement. The  Arbitrator  will accord equal time to 
the other party.   
c. After the conclusion of the opening statements, the Arbitrator shall give each party the 
opportunity to make comments or ask the other party questions.  
d. The Arbitrator may subsequently pose questions to the p arties.  WT/DS471/ ARB/Add.1  
 
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  e. Once the questioning has concluded, the Arbitrator shall afford each party an 
opportunity to present a brief closing statement, with the United States presenting its 
statement first. Before each party takes the floor, it shall provide the Arbitrator and other 
participants at the meeting with a provisional written version of its closing statement , if 
available . 
f. Following the meeting:  
i. Each party shall submit a final written version of its opening statement no later than 
5.00 p.m. (Geneva time) on the first working day following the meeting.  At the same 
time, each party should also submit a final written version of any prepared closing  
statement that it delivered at the meeting.   
ii. Each party shall send in writing, within the timeframe establ ished by the Arbitrator 
before the end of the meeting, any questions to the other party to which it wishes to 
receive a response in writing.  
iii. The Arbitrator shall send in writing, within the timeframe established by the Arbitrator  
before  the end of the mee ting, any questions to the parties to which it wishes to receive 
a response in writing.  
iv. Each party shall respond in writing to the questions from the Arbitrator, and to any 
questions posed by the other party, within the time -frame established by the Arbitrator 
before  the end of the meeting . The parties may be given time to comment on the other 
party's responses.  
Descriptive part and executive summaries  
 
17. The description of the arguments of the parties in the Decision  of the Arbitrator shall consist  
of executive summaries provided by the parties, which shall be annexed  as addenda to the Decision. 
These executive summaries shall not in any way serve as a substitute for the submissions of the 
parties in the Arbitrator's examination of the case.  
18. Each pa rty shall submit one integrated executive summary , which shall summarize the facts 
and arguments as presented to the Arbitrator  in the party's  submissions and statements , and if 
possible, its responses to questions and comments thereon  following the substa ntive meeting.  
19. Each integrated executive summary shall be limited to no more than 15 pages.   
20. The Arbitrator  may request the partie s to provide executive summaries of facts and arguments 
presented in any other submissions to the Arbitrator  for which a deadline may not be specified in 
the timetable.  
Service of documents  
 
21. The following procedures regarding service of documents apply to all documents submitted by 
parties during the proceeding:  
a. Each party shall submit all documents to the Arbitrator by submitting them with the 
DS Registry (office No. 2047).  
b. Each party shall submit 2 paper copies of all documents it submits to the  Arbitrator by 
5.00 p.m. (Geneva time) on the due dates established by the Arbitrator. The DS  Registrar 
shall stamp the documents with the date and time of submission. The paper version 
submitted to the DS Registry shall constitute the official version for  the purposes of 
submission deadlines and the record of the dispute. If any documents are in a format that 
is impractical to submit as a paper copy, then the party may submit such documents to 
the DS Registrar by email or on a CD -ROM, DVD or USB key only.  
c. Each party shall also send an email to the DS Registry, at the same time that it submits 
the paper versions, attaching an electronic copy of all documents that it submits to the WT/DS471/ARB/Add.1  
 
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  Arbitrator, preferably in both Microsoft Word and PDF format. All such emai ls to the 
Arbitrator shall be addressed to DSRegistry@wto.org, and copied to other WTO Secretariat 
staff whose email addresses have been provided to the parties during the proceeding. If 
it is not possible to attach all the Exhibits to one email, the submi tting party shall provide 
the DS Registry with four copies of the Exhibits in electronic form on USB keys, CD -ROMs 
or DVDs.  
d. In addition, each party is invited to submit all documents through the Digital Dispute 
Settlement Registry (DDSR) within 24 hours  following the deadline for the submission of 
the paper versions. If the parties have any questions or technical difficulties relating to 
the DDSR, they are invited to consult the DDSR User Guide (electronic copy provided) or 
contact the DS Registry at DSR egistry@wto.org.  
e. Each party shall serve any document submitted to the Arbitrator directly on the other 
party. A party may submit its documents to another party by email or on a CD -ROM or a 
DVD, unless the recipient party has previously requested a paper  copy. Each party shall 
confirm, in writing, that copies have been served on the parties, as appropriate, at the 
time it provides each document to the Arbitrator.  
f. Each party shall submit its documents with the DS Registry and serve copies on the other 
party by 5.00  p.m. (Geneva time) on the due dates established by the Arbitrator.  
g.  All communications from the Arbitrator to the parties will be via email.  
Correction of clerical errors in submissions  
22. The Arbitrator  may grant leave to a party to cor rect clerical errors in any of its submissions 
(including paragraph numbering and typographical mistakes). Any such request should identify the 
nature of the errors to be corrected, and should be made promptly following the filing of the 
submission in ques tion.  WT/DS471/ ARB/Add.1  
 
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  ANNEX A -2 
ADDITIONAL WORKING P ROCEDURES OF THE ARB ITRATOR CONCERNING  
BUSINESS CONFIDENTIA L INFORMATION  
 
Adopted on 15 November 2018 
 
1. These procedures apply to any business confidential information (BCI) that a party wishes to 
submit to the Arbitrator, including BCI  that was previously treated by  the U.S. Department of 
Commerce  as confidential or proprietary information protected by Admi nistrative Protective Order  in 
the course of the anti-dumping  duty proceedings relevant to  this dispute . However, these procedures 
do not apply to information that is available in the public domain.  In addition, these procedures do 
not apply to any BCI if  the person who provided the information in the course of the relevant  
proceedings agrees in writing to make the information p ublicly available.  
2. The first time that a party submits to the Arbitrator  BCI, as defined above , from an entity that 
submitted that  information in one of the  relevant proceedings , the party shall also provide, with a 
copy to the other party, an authorizing letter from the entity.  That letter shall authorize both China  
and the United States  to submit in this dispute, in accordance wit h these procedures, any confidential 
information submitted by that entity in the course of those proceedings.  
3. If an entity refuses to grant the authorization letter, a party may bring the situation to the 
attention of the Arbitrator . The Arbitrator  shall c onsider what steps to take, which may include 
requesting information pursuant to Article 13 of the DSU.  
4. No person may have access to BCI except a member of the Secretariat or the Arbitrator , an 
employee of a party, and an outside advisor for the purposes of this dispute to a party.  An outside 
advisor may include a person providing to a party advice on any matter related to the dispute.  
However, an outside advisor is not permitted access to BCI if that advisor is an officer or employee 
of an enterprise en gaged in the production, export, or import of the product s that were the subject 
of the proceedings  relevant to  this dispute.  
5. A party having access to BCI shall treat it as confidential, i.e., shall not disclose that 
information other than to those persons authorized to receive it pursuant to these procedures.  Each 
party shall have responsibility in this regard for its employees  as well as any outside advisors used 
for the purposes of this dispute.  BCI obtained under these procedures may be used only for the 
purpose of providing information and argumentation in this arbitration and for no other purpose.  
6. The party submitting BCI shall mark the cover and/or first page of the document containing 
BCI, and each page of the document, to indicate the presence of such information. The specific 
information in question shall be placed between double brackets, as follows: [[xx,xxx.xx]].  Th e first 
page or cover of the document shall state “Contains business confidential information on pages 
xxxxxx”, and each page of the document shall contain the notice “Contains Business Confidential 
Information” at the top of the page.  
7. Where a party submit s a document containing BCI to the Arbitrator , the other party referring 
to that BCI in its documents, including written submissions and oral statements, shall clearly identify 
all such information in those documents.  All such documents shall be marked as  described in 
paragraph 6.  In the case of an oral statement containing BCI, the party making such a statement 
shall inform the Arbitrator  before making it that the statement will contain BCI, and the Arbitrator  
will ensure that only persons authorized to have access to BCI pursuant to these procedures are in 
the room to hear that statement.  
8. The Arbitrator  will not disclose BCI, in its decision  or in any other way, to persons not 
authorized under these procedures to have access to BCI.  The Arbitrator  may, however, make 
statements of conclusion drawn from such information.  Before the Arbitrator  circulates its final 
decision  to the Members, the Arbitrator  will give each party an opportunity to review the  decision  
to ensure that it does not contain any information that the party has designated as BCI.  
_______________  WT/DS471/ ARB/Add.1  
 
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  ANNEX  B 
ARGUMENTS OF THE PAR TIES 
Contents  Page  
Annex  B-1 Executive summary of the arguments of the United States  12 
Annex  B-2 Executive summary of the arguments of China  23 
 
 WT/DS471/ ARB/Add.1  
 
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  ANNEX  B-1 
EXECUTIVE SUMMARY OF THE ARGUMENTS OF THE UNITED STATES  
I. INTRODUCTION  
1. Contrary to the requirements of the Understanding on Rules and Procedures Governing the 
Settlement of Disputes  ("DSU"), the level of suspension of concessions that China has requeste d is 
not equivalent to the level of nullification or impairment.    
2. Pursuant to Article 22.7 of the DSU, the task of an arbitrator is to determine whether the 
requested level of suspension of concessions or other obligations is equivalent to the level o f 
nullification or impairment of benefits accruing to the complaining party under the relevant covered 
agreement(s).  The starting point in any analysis of a request for authorization to suspend 
concessions is to determine the extent to which the Member 's WTO-inconsistent measure that is the 
subject of the Dispute Settlement Body 's ("DSB") recommendations nullifies or impairs benefits 
accruing to the complaining party.  Thus, an analysis of the level of nullification or impairment must 
focus on the benefit allegedly nullified or impaired as a result of the breach found by the DSB.  Due 
to conceptual flaws and methodological errors, however, China has not provided a calculation that 
is equivalent to the level of nullification or impairment.  
3. This proceeding  requires that each of the 25 antidumping duty determinations specifically 
identified in China 's methodology paper be separately analyzed to determine the most appropriate 
methodology to calculate the level of nullification or impairment.  China appears to  agree.  Yet, China 
proposes a one -size-fits-all approach to estimating its requested level of suspension of concessions.  
China 's proposed methodology is of no use to the Arbitrator for it cannot capture the impact of 
antidumping duty margins on trade flo ws, which is the key issue in this proceeding.  China 
compounds its methodological error by relying on false assumptions and incorrect data to implement 
its approach.  
4. Furthermore, China 's methodology paper contains errors sufficient by themselves to est ablish 
that China 's proposal is fundamentally flawed.  For instance, China proposes an incorrect 
counterfactual, applies an economic method that is completely inappropriate, and makes numerous 
errors when compiling the data inputs it uses to estimate the l evel of nullification or impairment.  As 
a result, China overestimates the level of nullification or impairment attributable to the maintenance 
following  the expiration of the reasonable period of time ("RPT") of the U.S. antidumping measures 
about which the DSB adopted recommendations.  
5. China bases its request on the assertion that the Arbitrator must use a counterfactual that 
assumes the complete remov al of the U.S. antidumping duty measures following the expiration of 
the RPT, even U.S. antidumping duty measures that have not been found to be WTO -inconsistent.  
China 's proposal is contrary to the DSU and results in a gross overestimation of the level o f 
nullification or impairment.  The proper counterfactual to be applied for the purpose of this 
proceeding is the elimination of the WTO -inconsistent aspects of the U.S. antidumping duty 
measures, not the revocation or complete removal of the antidumping d uty orders themselves.  
6. In response to the flawed one -size-fits-all methodology proposed by China, the United States 
proposes three approaches that accurately estimate the trade effects of the WTO -inconsistent U.S. 
antidumping duty measures following  the expiration of the RPT.   
II. APPROPRIATE CALCULATION OF THE LEVEL OF NULLIFICATION OR 
 IMPAIRMENT  
A. Article 22 of the DSU Requires that the Proposed Level of Suspension Be 
 Equivalent to the Level of Nullification or Impairment  
7. Pursuant to Article 22.4 of the DSU, the DSB is not to authorize the suspension of concessions 
or other obligations unless "the level" of suspension is "equivalent" to the level of nullification or WT/DS471/ ARB/Add.1  
 
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  impairment.  Article 22.7 of the DSU further provides that where a matter is referred to arbitration, 
the arbitrator "shall determine whether the level of . . . suspension is equivalent to the level of 
nullification or impairment."  The starting point in the analysis of  a suspension request is to 
determine the extent to which any WTO -inconsistent measure maintained following  the expiration 
of the RPT nullifies or impairs benefits accruing to the complaining Member under the relevant 
covered agreement(s).  
8. Thus, an ana lysis of the level of nullification or impairment must focus on the "benefit" 
accruing to the complaining Member under a covered agreement that is allegedly nullified or 
impaired as a result of the breach found by the DSB.  Arbitrators in past proceedings have uniformly 
based their determinations on hard evidence and have refused to "accept claims that are 'too 
remote ', 'too speculative ', or 'not meaningfully quantified. '"  As the arbitrators in EC – Hormones 
(US) (Article 22.6 – EC) and EC – Hormones (Cana da) (Article 22.6 – EC) found , "we need to guard 
against claims of lost opportunities where the causal link with the inconsistent [measure] is less than 
apparent, i.e., where exports are allegedly foregone not because of the [inconsistent measure] but 
due to other circumstances."  
9. In previous Article 22.6 proceedings, the arbitrator has compared the level of trade for the 
complaining party under the WTO -inconsistent measure to what the complaining party 's level of 
trade would be expected to be where the Member concerned has brought the WTO -inconsistent 
measure into conformity following the expiration of the RPT.  The situation in which the Member 
concerned has removed the WTO inconsistency is referred to as the "counterfactual."  The difference 
in the lev el of trade under these two situations typically represents the level of nullification or 
impairment.  Other Article 22.6 arbitrators have recognized that a counterfactual was an appropriate 
method in those proceedings to calculate a level of nullification  or impairment, and China itself 
proposes the use of a counterfactual in this proceeding.  China, however, has proposed an incorrect 
counterfactual.   
10. The appropriate analysis requires consideration of the present trading relationship between 
China and  the United States (as represented by the 2017 baseline), as well as what that relationship 
would be if the U.S. measures had been brought into compliance with the DSB recommendations 
following the expiration of the RPT (the counterfactual).  As described below, the trade differential 
will be the level of nullification or impairment attributable to the maintenance of the U.S. measures.  
B. The Appropriate Counterfactual Eliminates the WTO -Inconsistent Aspects 
 of the U.S. Antidumping Duty Measures  
China 's Counterfactual Has No Support in the DSU  
11. China proposes to estimate the level of nullification or impairment based on assuming the 
withdrawal of all of the U.S. antidumping duty orders, even parts of the U.S. antidumping duty 
measures that are not subject to the DSB 's recommendations.   
12. Article 22.1 of the DSU provides that compensation and the suspension of concessions is 
available in the "event that the recommendations" of the DSB "are not implemented within a 
reasonable period of time."  Thus, Article 22.1 of the DSU directs an arbitrator to base an Article 
22.6 decision on the "recommendations" of the DSB.  Similarly, Article 22.2 of the DSU, which is 
explicitly referenced in the first sentence of Article 22.6, limits the role of an arbit rator to assessing 
the effects of the WTO -inconsistent U.S. antidumping duty measures in accordance with the DSB 's 
recommendations.  To go beyond the DSB recommendations, as China proposes, would be contrary 
to the DSU.  
13. The DSB recommendations at issu e in this proceeding relate to the use by the U.S. Department 
of Commerce ("USDOC") of the Single Rate Presumption ("SRP"), as well as the use in certain 
proceedings of an alternative, average -to-transaction comparison methodology and "zeroing" in 
conjunct ion with that alternative comparison methodology.   To determine the equivalent level of 
nullification or impairment in this proceeding, it is necessary to correctly understand the findings 
adopted by the DSB.  The DSB findings of WTO inconsistency relate t o certain aspects of the U.S. 
antidumping measures, but other aspects of the U.S. antidumping measures have not been found 
to be WTO -inconsistent.  As the United States will discuss in the following section, the antidumping WT/DS471/ ARB/Add.1  
 
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  duty rates that apply to Chinese  imports at issue in this proceeding can be broken down into four 
categories.   
14. Similarly, for the three investigations and one administrative review for which the panel made 
findings concerning the USDOC 's use of the alternative, average -to-transactio n comparison 
methodology and "zeroing," only certain companies were assigned antidumping duty rates found to 
be WTO -inconsistent.  Those rates can be isolated and the level of nullification or impairment 
resulting from their maintenance following the expir ation of the RPT can be estimated accurately 
without incorrectly assuming, as China does, the total withdrawal of the U.S. antidumping duty 
measures.  
The Correct Counterfactual is Modification of the WTO -Inconsistent 
U.S. Antidumping Duty Measures To El iminate the WTO -
Inconsistencies Found by the DSB , Not the Total Withdrawal of the 
Antidumping Duty Measures  
15. In this proceeding, the correct counterfactual is the estimated value of exports of relevant 
products from China to the United States if the WTO -inconsistent U.S. antidumping duty measures 
were brought into compliance with U.S. WTO obligations, holding all other factors constant.  The 
level of "nullification or impairment" to China is the difference between the value of China 's exports 
to the Unit ed States as reflected in the 2017 trade data, and the estimated export value under the 
counterfactual scenario.  
16. In other words, the question is:  for each of the 13 products subject to "as applied" findings 
and for each of the 12 products China has i dentified in connection with the "as such" findings, how 
many additional exports from China would enter the United States under the separate duty rate (the 
rate that applies to what the United States calls Group 2) if the presumption of a China -government 
entity were eliminated.  As discussed above, China 's methodology paper applies an incorrect 
counterfactual.  The key assumption in China 's counterfactual is the removal of all antidumping 
duties, even the U.S. antidumping duties that were not found to be W TO-inconsistent.  Under the 
correct counterfactual, however, those firms that are subject to the China -government entity rate 
and did not fail to cooperate would, instead, be assigned the separate duty rate.  The correct 
estimate of the level of nullificat ion or impairment is the difference in the value of trade that would 
be induced by changing —if, in fact, there were a difference between the rate assigned the China 
government entity and separate -rate respondents —the rate for these firms only.  For most ca ses, 
this represents a small share of imports from China at any given period.  To illustrate, Chinese 
imports are divided into four groups:  
Group 1 :  Chinese imports from firms to which individual duty rates 
apply;  
Group 2 :  Chinese imports from firms that  were not individually 
examined yet received what is labeled as a "separate duty rate" 
(that is, a rate separate from the rate assigned to the China -
government entity);  
Group 3 :  Chinese imports from firms that are subject to the China -
government entity a ntidumping duty rate for which there is evidence 
that they failed to cooperate with the USDOC 's investigation, such 
that a rate based on facts available could have applied even if they 
were not part of the China -government entity; and  
Group 4:   Chinese imports from firms that are subject to the China -
government entity antidumping duty rate for whi ch there is no 
evidence that they failed to cooperate with the USDOC 's 
investigation.  
17. Under the correct counterfactual,  the only modification is that duties on Group 4 imports are 
changed from the rate assigned to the China -government entity to a sepa rate duty rate.  With the 
exception of certain antidumping duty rates determined using the alternative, average -to-WT/DS471/ ARB/Add.1  
 
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  transaction comparison methodology with "zeroing," all other antidumping duties would remain 
unchanged.  
C. The Correct Methodology for Deter mining the Level of Nullification or 
 Impairment Must Be Determined Case by Case  
Complying with the DSB Recommendations Concerning U.S. 
Antidumping Duty Measures on Corrosion -Resistant Steel and 
Diamond Sawblades Would Not Result in Any Increase in the Value 
of Exports of Those Products from China to the United States; the 
Level of Nullification or Impairment is Zero  
a. The DSU Permits the Arbitrator to Find that a Measure Causes 
No Nullification or Impairment  
18. Article 3.8 of the DSU plainly provides for the possibility that the Member concerned may 
rebut the presumption of the existence of nullification or impairment by putting forth evidence that 
a breach of WTO obligations does not have an adverse impact on th e complaining party.  Additionally, 
nothing in Article 3.8 of the DSU, which is one of the "General Provisions" of the DSU, limits the 
opportunity of the Member concerned to make such a rebuttal only during the original panel phase 
of a dispute settlement proceeding.  The more logical time for a Member concerned to make such a 
rebuttal would be in the context of an arbitration under Article 22.6 of the DSU, wherein the question 
of the level of nullification or impairment – and indeed, the question of the ex istence of any level of 
nullification or impairment at all following the expiration of the RPT – is placed squarely before the 
decision maker that is tasked by the DSU with evaluating that question and the question of the level 
of suspension – i.e., the DS U Article 22.6 arbitrator.  If no trade is foregone due to a WTO -
inconsistent measure 's continuing existence beyond the expiration of the RPT, i.e., if the estimate 
of the trade foregone is zero, then the correct conclusion is that the level of nullificati on or 
impairment is zero.  
19. Furthermore, the factual circumstances related to a WTO -inconsistent measure 's impact on 
the complaining party might change over time, including after a panel report is circulated and before 
a suspension request is made under Article 22.2 of the DSU.  In an arbitration under Article 22.6 of 
the DSU, it is incumbent upon the arbitrator to establish the level of nullification or impairment 
following the end of the RPT, so as to ensure that the level of suspension authorized by th e DSB 
does not exceed the level of nullification or impairment.   
20. Accordingly, it is necessary for the Arbitrator to determine in this proceeding the ongoing trade 
effects of the U.S. antidumping duty measures on corrosion -resistant steel and diamond s awblades 
from China (using 2017 as the baseline for the counterfactual).  China suggests in its methodology 
paper that the "question that must be answered [in this proceeding] is what would have been the 
value of imports from China in 2017 'but for ' the United States continued imposition of the WTO 
inconsistent measures."  By this, China uses 2017 as a proxy (presumably for reasons of data 
availability) for the ongoing trade effects caused by the maintenance of WTO -inconsistent measures 
beyond the ex piry of the RPT in August 2018.  For purposes of the counterfactual, the United States 
has also used 2017 data.   
b. The Evidence Demonstrates that the Level of Nullification or 
Impairment from the Antidumping Duty Measures on 
Corrosion -Resistant Steel and  Diamond Sawblades is Zero  
21. The evidence demonstrates that bringing the U.S. antidumping duty measures on corrosion -
resistant steel and diamond sawblades from China into compliance would result in no increase at all 
in the value of corrosion -resistant s teel or diamond sawblades exported from China to the United 
States.  
22. In cases where the China -entity rate and a separate duty rate are the same, the level of 
nullification or impairment is zero because the counterfactual scenario in which the USDOC 
undertook a redetermination and changed the WTO -inconsistent rate for companies that form part 
of the China -government entity —an entity based on a presumption found to be WTO -inconsistent —
from the China -government entity rate to the separate duty rate determi ned for those separate -rate WT/DS471/ ARB/Add.1  
 
- 16 - 
 
  respondents subject to the relevant proceeding, would, in these cases, not result in any reduction 
of the antidumping duty rate.  In Corrosion -Resistant Steel , the China -government entity rate is 
199.43 percent and the separate rate is also 199.43 percent.  In Diamond Sawblades , in 2017, the 
China -government entity rate was 82.03 percent and the separate rate also was 82.03 percent.  
Accordingly, the level of nullification or impairment is zero.  
An Armington -Based Imperfect S ubstitutes Partial Equilibrium 
Model is the Appropriate Method for Estimating the Level of 
Nullification or Impairment Resulting from the Maintenance 
Following the Expiration of the RPT of the WTO -Inconsistent U.S. 
Antidumping Duty Measures on Aluminum Ext rusions, Shrimp, Steel 
Cylinders, Woven Ribbons, PET Film, Carrier Bags, Coated Paper, 
Steel Line and Pressure Pipe, Welded Carbon Steel Pipe, Welded 
Carbon Steel Line Pipe, Steel Nails, Stainless Steel Sheet and Strip, 
Cast Iron Pipe Fittings, Copper Pipe  and Tube, Cold Rolled Steel Flat 
Products, Truck Tires, and Washers  
23. China recognizes that an "elasticities style trade model" or "a partial equilibrium model" "could 
be used for calculating" the level of nullification or impairment.  Indeed, China ch aracterizes such 
an approach as "an excellent short -run quantitative model."   
24. Despite China 's suggestion that "many policies have been found to be inconsistent with WTO 
rules" and "various and complicating issues" support the use of China 's flawed app roach – discussed 
further below – the analysis required in this proceeding actually is quite simple.  Antidumping duty 
measures are tariffs.  The simplest description of the correct counterfactual scenario here is that the 
tariffs imposed by the United Sta tes are assumed to be reduced.  Partial equilibrium analysis is, to 
use China 's term, an "excellent" tool for modeling the trade effects of a tariff reduction.   
25. Under correct economic theory, the effect of the reduction or removal of the WTO -inconsistent 
U.S. antidumping duties applied to aluminum extrusions, shrimp, steel cylinders, woven ribbons, 
PET film, carrier bags, coated paper, steel line and pressure pipe , welded carbon steel, welded carbon 
steel line pipe, steel nails, stainless steel sheet and strip, cast iron pipe fittings, copper pipe and 
tube, cold rolled steel flat products, truck tires, and washers  from China depends on the 
substitutability between (1) the domestic like product (the product made in the United States), (2) 
subject imports (the product imported from China that is subject to the WTO -inconsistent 
antidumping duty), (3) non -subject imports from China (the product imported from China that is 
not subject to the WTO -inconsistent antidumping duty), and (4) non -subject imports from the rest 
of the world (the product imported from countries other than China).  To properly measure the effect 
of the reduction of the antidumping duties on aluminum extrusions, shrimp, steel cylinders, woven 
ribbons, PET film, carrier bags, coated paper, steel line and pressure pipe, welded carbon steel, 
welded carbon steel line pipe, steel nails, stainless steel sheet and strip, cast iron pipe fittings, 
copper pipe a nd tube, cold rolled steel flat products, truck tires, and washers  from China, one would 
need to use for each product an economic model that accounts for the substitution effects on all four 
of these varieties.  
26. An example of such a model – an Armington -based imperfect substitutes partial equilibrium 
model – that would be appropriate to use can be found in a 2017 paper by Ross Hallren and David 
Riker.  The Hallren and Riker paper provides a convenient framework to undertake a partial 
equilibrium analysis  of the trade effects of modifying import tariffs where the imported and domestic 
goods are imperfect substitutes.  Indeed, the Hallren and Riker paper provides as an "illustrative 
application" an example of modeling the effects of "a reduction in the impo rt ad-valorem tariff 
applied to subject imports from 5 to 0 percent," which corresponds to the modification of duties for 
purposes of this discussion.  The partial equilibrium model in the Hallren and Riker paper is based 
on the Armington approach to trade , where products are differentiated by source countries and 
consumers view products from different countries as imperfect substitutes.   As explained in A 
Practical Guide to Trade Policy Analysis , "most simulation models use the 'Armington assumption ' 
where by varieties of goods are differentiated by country of origin (Armington, 1969)."  
27. The U.S. version of the model assumes that there are four varieties of products in the industry 
that are imperfect substitutes in demand.  The four varieties are the dom estic product, non -subject 
imports from rest of world, non -subject imports from China, and subject imports from China.  As 
the Hallren and Riker paper explains, all source varieties are imperfect substitutes and consumers WT/DS471/ ARB/Add.1  
 
- 17 - 
 
  substitute between each variety at  a constant rate, which is the Armington elasticity.  The Hallren 
and Riker paper points out that the Armington elasticity "is a key element in the model" because it 
tells how sensitive consumers are to changes in the relative prices of each of the source varieties.  
28. The model detailed in the Hallren and Riker paper permits the estimation of the magnitudes 
of the changes in the prices of the four varieties of products, the industry 's overall price index, and 
the quantities of the products as a result of a reduction in the ad valorem  tariff on subject imports.  
The goal of the analysis is to quantify these changes given information on the duties and the initial 
values of trade and market shares in the respective industries in this proceeding.  
a. Reduction of Tariff Rates on Subject Imports from the China -
Entity Rate to the Separate Duty Rate  
29. To use the four -country model, one first needs to define 2017 imports from subject imports 
versus non -subject imports from China.  U.S. Customs and Border  Protection ("CBP") is able to 
compile U.S. import data for all products subject to an antidumping order.  The United States has 
provided a table with CBP -sourced data for each of the 13 products subject to "as applied" findings 
and for each of the 12 prod ucts subject to "as such" findings that are discussed in China 's 
methodology paper.  This CBP data is separated into total imports subject to an antidumping duty 
order as well as total imports subject to the China -government entity rate.   
30. Finally, we note that the Armington model, like all other standard trade models, relies on the 
observed value of imports as a share of the market to characterize an entity 's relative competiveness 
given the conditions in the market, including the imposition of duties.   In this context, an appropriate 
minimal trade share for subject China imports is at least one percent of total U.S. imports from 
China.  If the share is lower than one percent, the United States uses a formula -based approach to 
calculate the level of nul lification or impairment.  
b. Correct Data Inputs that Would Be Used in Applying an 
Armington -Based Imperfect Substitutes Partial Equilibrium 
Model  
31. The Hallren and Riker paper explains that the following data inputs would be used in applying 
the Armin gton-based imperfect substitutes partial equilibrium model that the paper describes: 
domestic shipments of domestic producers; trade value of subject imports from China; trade value 
of non -subject imports from China; trade value of non -subject imports from  rest of world ("ROW"); 
supply elasticity for domestic producers; supply elasticity for subject imports from China; supply 
elasticity for non -subject imports from China; supply elasticity for non -subject imports from ROW; 
elasticity of substitution within the industry; price elasticity of total demand; change in tariff rates 
on subject imports.  
c. Results of Armington -Based Model  
32. As a result of applying the Armington -based model, the level of nullification or impairment 
from the maintenance following th e expiration of the RPT of the U.S. antidumping duty measures on 
aluminum extrusions, shrimp, steel cylinders, woven ribbons , PET film, carrier bags, coated paper, 
steel line and pressure pipe, welded carbon steel, welded carbon steel line pipe, steel nail s, stainless 
steel sheet and strip, cast iron pipe fittings, copper pipe and tube, cold rolled steel flat products, 
truck tires, and washers from China is no more than $ 24.03  million  per year.  For these same 
products, China 's one -size-fits-all approach es timated the level of nullification or impairment to be 
$8,638 billion  annually.   
A Formula -Based Approach is the Appropriate Method for Estimating 
the Level of Nullification or Impairment from the U.S. Antidumping 
Duty Measures on Wood Flooring, OCTG, CSPV Cells, and Off -the-
Road Tires  
33. Total U.S. imports under the China -government entity rate as a share of total U.S. imports 
from China under the order for wood flooring, OCTG, CSPV cells, off -the-road tires, and bedroom 
furniture  was less than one percent in 2017.  That being the case, an Armington -based imperfect WT/DS471/ ARB/Add.1  
 
- 18 - 
 
  substitutes partial equilibrium model cannot reliably be used to estimate the level of nullification or 
impairment for these products.   
34. In light of the facts of these ca ses and the evidence available, the most appropriate 
methodology to estimate the level of nullification or impairment for wood flooring, OCTG, CSPV cells, 
off-the-road tires, and bedroom furniture  is a formula -based approach.  A formula -based approach 
exam ines China 's historical import share of the U.S. market for Group 4 companies for the five 
products prior to the imposition of the WTO -inconsistent antidumping duty measure and applies that 
market share to the total value of imports of the goods from China  in 2017.  The United States 
observes that this approach reflects trade distorted by dumping and thus overestimates the level of 
nullification or impairment.  Nevertheless, this approach is consistent with the approach taken by 
arbitrators in past Article 22.6 proceedings and fits well with the evidence on record for these five 
products.   
35. Where the relevant data were available, previous Article 22.6 arbitrators have used historical 
export or import levels to determine the level of nullification or impairment caused by a measure.  
In EC – Hormones , for example, the arbitrator calculated the level of nullification or impairment in 
respect of edible beef offal by: (1) considering average U.S. exports of the covered product in the 
three years preceding the import ban at issue; (2) making a downward adjustment based on 
changing preferences; (3) m ultiplying the estimated figure by the estimated price of the products; 
and (4) deducting the value of current imports.  In EC – Bananas III , the arbitrator calculated the 
effect of the EU measure based on the level of Ecuador 's "best -ever exports," which occurred the 
year before the measure was enacted.  In US – Gambling , the arbitrator used the difference between 
the complaining Member 's revenues from supplying the services affected by the challenged measure 
the year before the measure came into effect an d the average actual annual revenue in the years 
following to calculate the level of nullification or impairment.  
36. A similar formula -based approach is appropriate in this proceeding because historical levels of 
U.S. imports of the five Chinese products are indicative of the level of nullification or impairment 
caused by the U.S. antidumping duty measures.   
37. The United States starts with the maximum share of imports that may have been assigned 
the China -government entity rate during the period of inve stigation.   
38. The United States calculated the level of trade during the period of investigation for the 
relevant U.S. Harmonized Tariff Schedule (HTS) codes.  It then calculated the share of trade covered 
by the mandatory respondents and the separate rate respondents.  The remainder would be the 
maximum share of imports covered by the China -government entity rate.  The maximum or 
estimated share is then applied to U.S. imports from China for the specified product in 2017 to 
determine the level  of nullification or impairment.  Next, the United States calculated the share of 
companies that did not respond to the USDOC quantity and value questionnaire and would have 
correctly been assigned a rate based on facts available, which was the basis on wh ich the China -
government entity rate was determined.  The maximum share was then reduced by this amount.  
39. The level of nullification or impairment resulting from the U.S. antidumping duty measures on 
wood flooring, OCTG, CSPV cells, and off -the-road tir es from China is no more than $176.733 
million .  This contrasts with China 's estimate of $6.036 billion  for these four products.  
Estimating the Level of Nullification or Impairment Related to 
Recommendations Adopted by the DSB Concerning the USDOC 's Use 
of the Alternative, Average -to-Transaction Comparison Methodology 
and "Zeroing" in Certain Proceedings  
40. In the original dispute, China challenged, and the DSB adopted "as applied" recommendations 
concerning, the use of the alternative, average -to-transaction comparison methodology and 
"zeroing" in only three original investigations ( OCTG , Steel Cylinders , and Coated Paper ) and one 
administrative review ( PET Film ).  The other antidumping proceedings at issue in this arbitration are 
not implicated by th e findings related to the use of the alternative, average -to-transaction 
comparison methodology and "zeroing," so there can be no nullification or impairment related to 
those other proceedings as a result of the findings on the average -to-transaction compa rison 
methodology and "zeroing."  WT/DS471/ ARB/Add.1  
 
- 19 - 
 
  a. Steel Cylinders  
41. The level of nullification or impairment related to the USDOC 's use of the alternative, average -
to-transaction comparison methodology and "zeroing" during the original antidumping investigation 
of steel cylinders from China is zero.  With respect to the Steel Cylinders antidumping investigation, 
China only challenged  the USDOC 's use of the alternative, average -to-transaction comparison 
methodology and "zeroing" with respect to the margin of dumping determined for BTIC, and BTIC is 
the only company for which there was an "as applied" finding concerning the use of the a lternative, 
average -to-transaction comparison methodology and "zeroing."  In response to a decision of the 
U.S. Court of International Trade, the USDOC revoked the antidumping duty measure with respect 
to BTIC effective August 27, 2017.  The USDOC took thi s action prior to the expiration of the RPT 
and there is nothing else for the United States to do to implement the DSB 's recommendations with 
respect to the findings related to the USDOC 's use of the alternative, average -to-transaction 
comparison methodolo gy and "zeroing" to determine the margin of dumping for BTIC in the Steel 
Cylinders antidumping investigation.  Therefore, there is no nullification or impairment to China 
related to this finding.  
b. PET Film Administrative Review  
42. The level of nullif ication or impairment related to the USDOC 's use of "zeroing" during the 
third administrative review of the antidumping order on PET film from China is zero.  With respect 
to the third administrative review of PET film, China only challenged the USDOC 's use of "zeroing" 
with respect to the margin of dumping determined for the DuPont Group, and the DuPont Group is 
the only entity for which there was an "as applied" finding concerning the use of "zeroing."  However, 
the results of the third administrative rev iew of PET film have been succeeded by the results of the 
fourth administrative review of PET film, which were published on July 2, 2014.  In the fourth 
administrative review, the USDOC assigned the DuPont Group a margin of dumping that was not 
determined using "zeroing."   The antidumping rate applicable to the DuPont Group at the end of 
the RPT (and during the baseline year 2017) would not be changed as a result of any redetermination 
of the results of the third administrative review that are the subject of findings adopted by the DSB.  
Therefore, there can be no nullification or impairment following the expiration of the RPT related to 
this finding.  
c. Coated Paper  
43. In the Coated Paper  antidumping duty investigation, the USDOC found that the average -to-
transaction rate in the investigation for APP China was 7.62 percent, and the average -to-average 
rate (without "zeroing") would have been de minimis  ([[***]] percent).  Thus, there would not have 
been an antidumping duty imposed for APP China.  The separ ate rate assigned by the USDOC was 
the APP China rate, which was determined using "zeroing."  That rate was applied as a separate rate 
in 2017.   
44. The level of nullification or impairment resulting from the maintenance of the antidumping 
duty rate deter mined using the average -to-transaction  comparison methodology and "zeroing" 
following the expiration of the RPT can be estimated using the Armington -based imperfect 
substitutes partial equilibrium model.  Specifically, the model can be used to estimate the  trade 
effect of a reduction from the WTO -inconsistent rate of 7.62 percent to zero percent for the non -
China -government entity imports in 2017, and to model a reduction of the China -government rate 
to zero for the China -government entity shipments.  The r esult provides the level of nullification or 
impairment related to this finding, which is no more than $0.19 million.  
45. If the USDOC assigned facts available to any Chinese firms due to non -cooperation, this 
approach may overstate the level of nullifica tion or impairment.  
d. OCTG  
46. In the OCTG  antidumping duty investigation, the USDOC found that, for Chinese respondent 
TPCO, the margin of dumping calculated using the average -to-average comparison methodology 
was [[ ***]] percent, while the margin of dum ping calculated using the average -to-transaction 
comparison methodology with "zeroing," which is the WTO -inconsistent aspect of the measure, was 
32.07 percent.  Thus, there still would have been an antidumping duty imposed for TPCO.  The WT/DS471/ ARB/Add.1  
 
- 20 - 
 
  separate rate assi gned by the USDOC was the TPCO rate, which was determined using "zeroing."  
That rate appears to have been applied as the separate rate in 2017.  
47. There is not a sufficient level of subject imports from China in 2017 for the United States to 
apply the Armington -based model for this product.  Nevertheless, given that the tariff modification 
that would apply in the counterfactual scenario is less than [[ ***]], the impact would be so small 
that it cannot be "meaningfully quantified."  An estimati on of zero as the level of nullification or 
impairment is thus reasonable and plausible in this situation.  
III. THE LEVEL OF SU SPENSION OF CONCESSI ONS OR OTHER OBLIGAT IONS 
 PROPOSED BY CHINA F AR EXCEEDS THE LEVEL  OF NULLIFICATION OR  
 IMPAIRMENT  
A. China Grossly Overstates the Level of Nullification or Impairment Because 
 China 's Proposed Approach Is Not Appropriate, It Is Premised on False 
 Assumptions, and It Is Based on Incorrect Data Inputs  
China 's DID Tabular Methodology is Not Appropriate  
48. China justifies using Differences -in-Differences (DID) tabular analysis by alluding to its 
"simplicity."  While simplicity can be a virtue, it does not justify using the tabular DID methodology 
in this proceeding.  The tabular DID methodology cannot cap ture the impact of different antidumping 
duty margins on trade flows, which is the key issue to estimate any nullification or impairment in 
this proceeding.  China 's tabular DID methodology is only able to estimate termination of all 
antidumping duties on China, including WTO -consistent duties on imports from China (Group 1, 
Group 2, and Group 3).  
49. Thus, it is not possible, as a legal matter, to use China 's tabular DID analysis, because it would 
necessarily overestimate the level of nullification or impa irment by including in the estimate the 
removal of WTO -consistent duties.  
50. The United States observes that there is no support in the economics literature for using DID 
tabular analysis to estimate the effects of antidumping duties on imports.  After a n extensive search 
of the economics literature, the United States did not find any academic studies using DID tabular 
analysis to estimate the effects of antidumping duties or tariffs on imports.  
China 's Methodology is Premised on False Assumptions and  Is 
Fundamentally Flawed as a Result   
51. China 's tabular DID methodology cannot provide accurate estimates of the level of nullification 
or impairment because it is premised on false assumptions.  According to economic literature, the 
following three key  assumptions must hold in a tabular DID analysis:  (1) parallel trends (the 
comparison group is composed of exports that would be expected to follow the same trends as 
China 's exports of the subject products in the absence of antidumping duties); (2) stabi lity (the 
treated and comparison exports must remain the same over time); and (3) uniformity (the treatment 
or lack thereof ( i.e., antidumping duties) must be the same for all exports that comprise the 
treatment and control groups, respectively).  
52. Together, the assumptions of parallel trends, stability, and uniformity mean that an 
appropriate comparison group must be comparable enough that its exports could reasonably be 
expected to follow the same trend as those from China without the "treatment" o f the WTO -
inconsistent U.S. antidumping duties, but distinct enough that the effects of imposing U.S. 
antidumping duties on China 's imports will not "spillover" on their exports.  If these three key 
assumptions do not hold, China 's tabular DID methodology will produce estimates that are 
inaccurate.  In this proceeding, all three assumptions do not hold in the comparison groups 
constructed by China.   
53. In its methodology paper, China acknowledges the importance of the parallel trends 
assumption, and asser ts that it made a "considerable effort" to demonstrate that the parallel trends 
assumption holds for its control groups.  While China 's methodology paper provides a considerable  WT/DS471/ ARB/Add.1  
 
- 21 - 
 
  amount of discussion on the parallel trends assumption, China fails to demonst rate that the parallel 
trends assumption, in fact, holds in its control groups.  
54. China entirely disregards the second (stability) and third (uniformity) assumptions.  The 
stability assumption has two implications in this context.  First, stability requ ires that the set of 
"treated" and "comparison" exports remains unchanged between the initial period and 2017.  
However, China 's analysis incorrectly relies on HTS codes to define imports subject to each 
antidumping duty order, and in some significant case s (for example, Aluminum Extrusions ), the set 
of HTS codes to which antidumping duties are applied in the initial period is not the same in 2017.   
Therefore, the stability assumption does not hold, and this is another reason why it is inappropriate 
to app ly the tabular DID method.  
55. The second implication of stability in this case requires China to design its comparison group 
such that the effects of U.S. antidumping duties on China 's exports do not have spillover effects on 
comparison group exports.  Figure 1  below illustrates the likely spillover effects that can be seen in 
the CSPV case.  In contrast to China 's "treated" exports, exports from countries other than China 
increased in 2010 after U.S. antidumping duties were applied.  Since it is likely th at this is, at least 
partially, a result of the antidumping duties applied to Chinese exports, it is a spillover effect that 
invalidates DID analysis of this case.  
Figure 1 – U.S. Imports of CSPV Cells  
 
56. The uniformity assumption requires that the WTO -inconsistent U.S. antidumping duties be the 
same for all "treated" groups.  This assumption is violated both in the design and in the 
implementation of China 's tabular DID methodology.  The uniformity assumption does not hold under 
China 's incorrect count erfactual.  Moreover, the uniformity assumption also requires that exports in 
the comparison group be equally "untreated."  Erroneously, three of the four comparison groups 
that China considers are composed of total U.S. imports, including the "treated" im ports from China 
and other countries subject to antidumping duties.  
57. In short, a fundamental flaw in China 's approach is China 's failure to demonstrate that its 
comparison groups can reasonably be expected to satisfy the key assumptions of tabular DID 
methodology.   
China 's Final Estimates of Nullification or Impairment Are 
Fundamentally Biased and Mutually Exclusive  
58. The final estimates of nullification or impairment presented by China for each antidumping 
duty order are averages of estimates obtained from tabular DID analysis showing the differences in 
the level of import values and estimates obtained from tabular DID  analysis showing the differences 
in the natural logarithm ("log") of import values.  
WT/DS471/ ARB/Add.1  
 
- 22 - 
 
  59. As noted in China 's Exhibit CHN -18, a DID model may be applied to a variable in levels or in 
logs, but the parallel trends assumption can only be met in either levels  or logs.  Put another way, 
the parallel trends assumption cannot be met in both levels and logs.  China 's estimates from these 
metrics are therefore biased.  Contrary to China 's assertions, the distortions attributable to China 's 
incorrect application of tabular DID analysis do not average out.  Rather, they accumulate.  
China 's Methodology is Based on Incorrect Data Inputs  
60. China 's approach to data – capturing total trade flows occurring under basket HTS categories 
– is unreasonable because it gross ly over -estimates the value of trade of products subject to WTO -
inconsistent aspects of U.S. antidumping measures.  Many of the reference HTS codes are broad 
categories, of which the product subject to an antidumping duty order is just a subset.  
61. China 's data does not provide the Arbitrator a reliable basis to estimate nullification or 
impairment in this proceeding.  If the Arbitrator were to use China 's incorrect data, it would lead to 
a level of suspension that would be well in excess of the actual le vel of nullification or impairment.  
IV. CONCLUSION  
62. For the reasons set forth above, the United States respectfully requests that the Arbitrator 
find that the level of suspension of concessions or other obligations requested by China is not 
"equivalent " to the level of nullification or impairment.  The United States requests that the Arbitrator 
find that the level of nullification or impairment is no more than $200.790 million  annually.  WT/DS471/ ARB/Add.1  
 
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  ANNEX  B-2 
EXECUTIVE SUMMARY OF THE ARGUMENTS OF CHINA  
1. The United States has kept more than 100 WTO -inconsistent AD measures in place after the 
expiration of the reasonable period of time in the present dispute DS471. These measures continue 
to be in force today, c ausing significant monetary losses to multiple industries in China from reduced 
export revenues. Because the United States has refused to bring its unlawful measures in compliance 
with its WTO -obligations, China is seeking authorization to suspend concessi ons in the amount of $7 
billion. China's written submissions show that this is a conservative estimate of the N/I China is 
suffering.  
I. CHINA'S PROPOSED METHODOLOGY IS A REASONABLE AND APPROPRIATE WAY TO 
MEASURE THE N/I.  
2. The mandate of the Arbitrator under Article 22.6 is to determine whether the level of 
suspension requested by a complaining party is equivalent to its level of N/I.   Based on past Article 
22.6 decisions, the methodology proposed by the complaining party need only be reasonable and 
equivalent.  Rather, the non -complaining party bears the burden of proving that an alternative 
calculation is more credible, verifiable, reasonable and equivalent.  
3. In this proceeding, China has proposed the Arbitrator to use an econometric approach known 
as "difference -in-differences" (DID) to estimate the value of Chinese imports "but for" the WTO -
inconsistent measures. This methodology compares the actual value of imports from China during 
year 2017 with a representative group using a counterfactual base d on the elimination of the WTO -
inconsistent measures.  In this case, China used multiple alternative representative groups to show 
that its overall conclusion about the level of N/I was reasonable, equivalent and robust.  
A. The Appropriateness Of China's Counterfactual  
4. China's counterfactual consists of the complete elimination of the WTO -inconsistent measures. 
This counterfactual is in line with the treaty text and previous Article 22.6 DSU practice.  
5. Article 3.7 of the DSU explicitly contemplates t he withdra wal of the measure as the first 
objective of the dispute settlement mechanism in the absence of a mutually agreed solution. 
Furthermore, the predominant practice under Article 22.6 has been to adopt the elimination of the 
measure as the most appr opriate counterfactual. This has been the case in 9 of the 11 Article 22.6 
proceedings. The only two disputes where the Arbitrator adopted the modification of the measure -
instead of its withdrawal - present significant differences with the dispute at hand.  In US – Gambling 
(Article 22.6 – US), the Arbitrator took into account public policy concerns when choosing its 
counterfactual. Similar concerns are not present in this dispute. The underlying circumstances of 
US-Washing Machines (Article 22.6 -US) are als o distant. Specifically, US-Washing Machines (Article 
22.6-US) concerned only 1 AD order, a few producers and a single product (in contrast with the 
current dispute involving more than 100 AD orders, a vast number of exporters and multiple 
products). Also,  in US-Washing Machines (Article 22.6 -US) a WTO -consistent margin dumping was 
calculated during the administrative proceedings and communicated to the exporters (no similar 
calculation exists in the present dispute). Further still, while in US-Washing Mach ines (Article 22.6 -
US) the parties agreed as to the use of key underlying data and its reliability, the use of data is a 
matter of much controversy and debate in this case.  
6. There are multiple considerations that make China's counterfactual the most "re asonable" and 
"plausible" in accordance with the requirements expressed in US – Gambling (Article 22.6 – US). 
7. First, the counterfactual suggested by China provides legal certainty as it eliminates the 
measures from a moment forward. This is a stable sol ution compared to the counterfactual 
suggested by the United States (separate rates) which rests on the weak assumption that a 
particular level of AD rate will continue to be applied in the future. The United States' proposal WT/DS471/ ARB/Add.1  
 
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  however ignores the nature of its own retrospective system allowing for the modification of AD 
margins in yearly AD reviews.  
8. Second, China's proposed counterfactual ensures WTO -consistency at all stages. Under the 
U.S. counterfactual both the AD rates resulting from the Article 22. 6 proceeding and the rates 
resulting from administrative reviews are affected by WTO -inconsistency risks. This is all the more 
troubling considering that China has identified four likely WTO -inconsistencies that would affect the 
AD rates being proposed by the United States as benchmark AD rate to be used in the N/I calculation.  
China considers that the Arbitrator should take into account the WTO -consistency issue of a 
counterfactual to determine the reasonableness of the N/I calculation. At the same time, it will never 
be "reasonable" for the Arbitrator to adopt a counterfactual that is fraught with multiple WTO -
inconsistencies.   Other arbitrators have taken possible WTO -consistency into account.  
9. Third, China's counterfactual provides a uniform solution , as the withdrawal applies in the 
same manner to every AD order. In contrast, the U.S. proposed counterfactual is highly speculative 
and complex as it involves different actions that the United States may or not adopt for each single 
AD order.  
10. Moreov er, the counterfactual consisting of the withdrawal of the measure creates the proper 
incentive to induce compliance with the Panel and Appellate Body findings. Within the context of the 
present dispute, the Arbitrator has to take into consideration all re levant factors  (Canada – Aircraft 
Credits and Guarantees (Article 22.6 – Canada),  para. 3.28. ), including the nature of the violations 
(use of the WA -T methodology ; single rate presumption for a large number of AD proceedings) and 
the continuous passivity of the United States. The United States could have made use of the 
instruments that are available under the U.S. regulatory framework to bring its WTO -inconsistent 
orders under compliance. However, it has not taken a single step in the more than 24 months that 
have passed since the DSB recommendations and now ten months since the expiration of the RPT.  
11. While acknowledging that the withdrawal of the measure would be the most appropriate 
counterfactual, China believes that the only real alternatives for the Arbitrator are either (1) set the 
dumping margins at 0.00%, or (2) use the suggested AD benchmark rates that China has proposed 
in Exhibit CHN -53.  We note that for 11 of the AD cases, the AD rates proposed by China in Exhibit 
CHN-53 are the same as pr oposed by the United States. And for all other cases, China has proposed 
a benchmark AD rate that the United States itself calculated in a previous phase of the AD case.  
B. Appropriateness Of The DID Economic Model  
12. China's DID methodology offers an accurate, reasonable, and conservative approach for 
determining the level of trade that would have occurred in the absence of WTO -inconsistent 
measures.  
13. As a first step, China's DID methodology compares China's trade before WTO -inconsistent 
duties were imposed with China's 2017 level of trade. Later, the methodology compares the change 
in trade over the same period of time for a reasonable benchmark, which address the question of 
how would trade have evolved "but for" the WTO -inconsistent AD orders. Finally, the methodology 
compares the performance of China vis-à-vis the performance of the benchmark, which serves as a 
basis for the N/I calculation.  
14. In applying the DID methodology, China uses as a baseline a multi -year average of trade for 
the period immediately preceding the imposition of AD duties. This multi -year average draws a 
conservative estimation compared to the adoption of the "year prior" when imports can be at their 
peak. The use of the period prior to th e imposition of the AD orders is essential for obtaining trade 
volumes that are "untainted" by WTO -inconsistent measures. These levels are more accurate 
compared to actual volumes in 2017, showing depressed levels at a height of 70% (or 99% in the 
case of entities subject to the PRC -wide entity rate) because of the impact of the WTO -inconsistent 
measures.  
15. As to the remedy date, both parties agreed to use 2017 for which a full year data are available, 
instead of 2018 which would have required annualizat ion of partial year data. China used 2017 data 
despite 2018 and 2019 data showing higher volumes and reflecting the growth in trade over time.  WT/DS471/ ARB/Add.1  
 
- 25 - 
 
  16. In order to determine its N/I calculation, China considered several alternative approaches in 
construing the  comparison group. Specifically, China considered (1) non -subject import suppliers for 
the HS10 digit level products subject to the WTO -inconsistent AD duties and (2) all -import suppliers 
(HS10) (including China for the purposes of completeness); (3) HS6 a ll suppliers; (4) HS4 all 
suppliers (5) HS2 all suppliers. The last three benchmarks permitted the elimination of collateral 
distortions caused by AD measures on specific products. The marginal variations between the 
different approaches strongly support t he verifiability, robustness and reliability of China's estimates.  
17. In addition to this, China conducted alternative N/I estimates taking into account the impact 
of CVD measures. To this end, China divided the cases assessed into three groups: (1) case s without 
companion CVD measures; (2) cases with companion CVD measures where the CVD margin is 
relatively large but the N/I is relatively small and (3) cases with companion CVD measures where 
the margin is relatively large and the N/I estimate is relative ly large. These separate scenarios avoid 
the "double -counting" problem affecting the United States methodology and are in line with China's 
conservative approach.  
18. China applied its different perspectives (HS10, HS6, HS4, HS2 or with and without CVD) both 
to the "as applied" and "as such" violations. For "as applied" violations China picked 13 
representative cases out of the more than 100 AD WTO -inconsistent orders c overing half of the trade 
to the United States. Calculations at HS10 digit level (both at trade level and growth level) showed 
averages between $10 billion and $7 billion. The estimations were confirmed at a more aggregated 
level of trade (HS6, HS4 and HS2 ) with an average across all "as applied" estimates of $7,323 
million.  
19. China also calculated a N/I associated to the "as such" violation given that the United States 
continues maintaining a "single rate presumption" contrary to the DSB recommendations . China 
determined the N/I of "as such" violations based on 12 cases using the same methodology as the 
"as applied" cases. The different approaches (HS 10, HS6, HS4, and HS2 with and without CVD) 
showed averages ranging between $7,577 million to $4,571 mil lion. Thus, summing the "as applied" 
and "as such" estimations, the resulting N/I will always be over $10 billion even where the lowest 
ranges of the two groups are considered.  
20. Besides being conservative, China's methodology presents numerous advantag es. As an 
illustration, the DID methodology is robust as to the duration of the duties, changes in the 
competitive landscape (such as mergers and industry changes as well as other related follow -on 
remedy actions) and common systematic shocks (e.g. exchang e rate shocks, a financial crisis, or 
broad changes in U.S. protectionism).  
21. Another advantage is that the different estimates and benchmarks offer the Arbitrator the 
possibility to select the value it consider more reasonable. It is China's view that t he most reasonable 
option would be adopting the "average -of-averages" scenario. However, even if the Arbitrator 
selected the lowest possible bound, the N/I will still be in excess of the $7 billion requested by China. 
In any case, China's range of alternat ives contrasts with the United States proposal which is based 
in a single estimate for each precise case.  
22. Moreover, China's approach is based on publicly available data easily verifiable and replicable. 
China's approach utilizes official U.S. import st atistics published by the United States providing 
import data for the very 10 -digit HS tariff codes. Both the USDOC itself and the USITC have used 
these import statistics to present total values of the merchandise subject to the AD case. This can 
be seen f or instance in the USDOC "Fact Sheets" presenting the total import value affected by the 
AD case. By contrast, the U.S. data are based on a mix of private (confidential) data (i.e. Census) 
and public data. This is particularly reprehensible, considering th at the United States has specific 
information and data for the quantity of imports by each and every single exporter under each of 
the AD cases (and reviews).  
23. In addition to this, China's proposed methodology anticipated and addressed all the concerns  
raised by the United States about the methodology.  
24. First, the United States insisted the Arbitrator impose some type of statistical significance test. 
However, there are no previous Article 22.6 proceedings where the N/I calculations were subject to 
such a significance test. Most recently, in US—Washing Machines (Article 22.6 – US) proceeding WT/DS471/ ARB/Add.1  
 
- 26 - 
 
  neither party proposed a methodology that included tests of statistical significance.  Likewise, in that 
dispute the Arbitrator proposed a N/I method that did no t include any formal metrics of statistical 
significance. Importantly, the United States has not provided evidence in the present dispute of 
statistical significance in applying its own approach.  
25. Second, the United States argued that China's results w ere not robust. Nevertheless, China 
has presented ample proof of the robustness of its N/I approach through seven sets of benchmarks 
(four estimates based on HS10 data, "with or without CVD"; and three estimates based on more 
aggregated HS data). From the upper and lower bounds, each single scenario shows that the 
requested $7 billion in countermeasures is a conservative request. In contrast, even if the U.S. 
scenario is conceptually similar to China's methodology, its implementation presents important flaw s 
and mathematical mistakes. Also, the fact that the U.S. methodology is not subject to any robustness 
checks exposes it to possible bias.  
26. Third, the United States has criticised China for not using a regression approach in its N/I 
methodology. Howeve r, China is not aware of any previous Article 22.6 proceeding where the 
Arbitrator insisted on regression techniques as a basis for N/I estimates. Furthermore, China has 
shown that its methodology produces exactly the same results as what would be produced  under a 
basic regression model. However, the fact that the tabular approach is easily implementable makes 
it particularly attractive for this complex dispute. The dispute involves 100 AD orders, which is what 
prompted China to focus on two dozen AD orders . Moreover, there are not HS10 digit level detailed 
variables that can be used to predict trade patterns at product level for each country. Under these 
circumstances, there is no sufficient data for a detailed analysis of specific products using a 
regressi on technique as suggested by the United States. The fact that the United States itself does 
not adopt such a detailed a regression approach in its own N/I evidences the complexities involved. 
Indeed, the US' elasticity model is based on a handful (assumed)  parameters and pieces of market 
information producing predictions. The United States assumes perfect competition and ignores 
market competitive conditions when running the model. Similarly, the formula approach adopted by 
the United States is based on ver y little data.  
27. Fourth, the United States condemns the lack of parallel trends, uniformity and stability of 
China's model. These quibbles intend to obfuscate China's methodology but are not based on any 
supporting facts or in any more verifiable, credi ble or equivalent alternative methodology. The United 
States critiques ignore that China is not proposing any time series analyses in the methodology and 
that parallel trends are more discussed in regression techniques. In addition, China's meta -analysis 
of different scenarios washes out minor differences across multiple specifications. Also, the critiques 
as to changes of the product scope of HS codes are innocuous in China's methodology, but to the 
contrary, the variable HS codes would sustain the robustn ess of China's methodology.  
28. Besides, much of the United States criticism confirms that China's estimation of N/I is 
conservative. An example of this can be found in the United States insistence that China's trade was 
growing faster than other countries . However, China's N/I approach understates China's 2017 trade 
as it considers China's trade flows to follow the overall market average.  
C. The Ability Of China's DID Methodology To Reflect PRC -Wide Entity Volume 
Only And Changing AD Rates  
29. China fully  believes that its initially proposed methodology is reasonable for calculating N -I for 
the AD cases at issue.  However, should the Arbitrator desire to adopt the U.S. prosed limitations, 
China's proposed DID methodology can easily be adapted to do so. Spe cifically, China's proposed 
DID methodology can easily be adapted (a) to limit the N/I calculation only to PRC -wide entity import 
volume and (b) to reflect changes in AD rates, rather than complete withdrawal of the measure. 
China has presented the Arbitra tor an analytical framework that allows one to adjust the DID N/I 
estimates to incorporate (a) and (b).  
30. China has provided the Arbitrator with a revised N/I calculation that adopts both of these 
adjustments. Co ncerning limiting the N -I calculation only  to PRC -wide entity imports, China note 
that it has adopted the very PRC -wide entity share of total China imports set forth by the United 
States (in Exhibit USA -54), even though China believes that the PRC -wide entity shares proposed 
by the United States a re understated. Using the US's proposed PRC -wide entity shares China revised WT/DS471/ ARB/Add.1  
 
- 27 - 
 
  N/I estimate is $5.6 billion (a figure which China believes understates the actual N/I due to the flaws 
in the US's submission).  
31. And concerning the changing AD rates, China no tes that it agrees with the United States on 
many of the benchmark AD rates that should be used and for many others the China benchmark AD 
rate that China proposes reflects a past AD margin calculated by the USDOC itself.  (See Exhibit 
CHN-53 and Exhibit C HN-57 (as corrected by China's 13 June 2019 letter). Adjusting its estimates 
for changing AD rates, rather than removal, China's revised N/I estimate is $12 billion, well above 
the $7 billion requested.  
32. In short, China's proposed DID methodology can ea sily be adapted to reflect the two primary 
concerns of the United States; namely, limiting the N/I calculation to PRC -wide entity volume only 
and utilizing changing AD rates rather than complete withdrawal.  
II. THE U.S. METHODOLOGY SUFFERS FROM SERIOUS FLA WS, AND MUST BE REJECTED  
A. U.S. Proposed N/I Calculation Approaches Are Premised On Using USDOC 
AD Determinations That Are WTO -Inconsistent.  
33. The United States' assumption is that it could remedy the use of the WTO -inconsistent PRC -
wide rate simply by  switching the PRC -wide entity AD rate to the "all others rates". This approach, 
however, ignores that the "all others" AD rates for 2017 being used are, in fact, infected by multiple 
WTO-inconsistencies.  
 
34. First, the United States is aggressively appl ying "facts available" to many of the AD cases 
involving China. China has shown that at least eight of the AD orders under dispute involved an 
analysis inconsistent with Article 6.8 and Annex II of the Anti -Dumping Agreement for determining 
the underlying individual -company AD rates used by the USDOC to calculate the "all others" AD rate 
for 2017 imports.  
35. Second, the Unites States has incurred improper double counting of AD and CVD duties in at 
least 15 of the AD cases under dispute, thus infringing Ar ticle 19.3 of the SCM Agreement.  
36. Third, the United States has engaged in differential pricing practices in more than 13 AD cases 
under dispute in violation of the second sentence of Article 2.4.2 of the Anti -Dumping Agreement.  
37. Fourth, the United S tates has improperly applied "zeroing" in at least five of the cases in 
contravention of Article 9.3 of the Anti -Dumping Agreement. This practice has been found by the 
DSB to be WTO -inconsistent ( US – Zeroing (Japan) , US – Stainless Steel (Mexico) .)  
38. Collectively these four legal theories alone apply to 22 of the 24 cases at issue, representing 
virtually all of the N/I calculated by either China or the United States. These are the most obvious 
WTO-inconsistencies. However China does not dismiss the  possibility that a closer scrutiny on what 
the U.S. would actually do in the future could reveal further WTO violations.  
B. U.S. Proposed N/I Calculation Approaches Have Serious Methodological 
Flaws  
39. Unlike China's use of a single, consistently applie d methodology, the United States has 
presented a mixture of different approaches.  Both the "elasticities approach" and the "formula -
based" methodologies used for the single rate presumption have serious flaws.  And the United 
States then compounds these f laws when it turns to yet another approach to address zeroing.  
40. The "elasticity" approach used for 17 cases is deeply flawed. The United States starts with a 
tiny trade value for 2017 reflecting a severely trade -distorting effect of the WTO -inconsisten t AD 
duties. Indeed, in US-Washing Machines (Article 22.6 -US), the Arbitrator rejected the approach 
proposed by the United States of adopting the actual and depressed level of trade. In these 17 AD 
cases the Chinese imports have been driven out of the mark et because of the effects of the WTO -
inconsistent measures. However, the elasticity model does not predict the reinstatement of the 
imports to previous levels, but produces a very small change in the trade estimates as a result from 
the suppliers starting again from near zero levels.  WT/DS471/ ARB/Add.1  
 
- 28 - 
 
   
41. Moreover, the United States does not establish a set of elasticities. For about half of the 
required elasticities the United States just asserts a value with no documentation or backup (with 
no distinction between import supply elasticity from subject China, non -subject China and all foreign 
sources). This contrasts with the practice of the USITC which runs its models on a range of elasticities 
in its injury investigations and never reports a single estimate. It is importa nt to note that outcomes 
can vary drastically with relatively small changes in specific elasticities. In fact, elasticity models are 
not appropriate in cases with large AD duties and an estimated large reduction (in some cases of up 
to 100% and on an avera ge of 72.9% for all cases assessed). The greater the reduction is, the less 
likely that the model will predict realistic trends in trade.  
42. The United States further does not explain how it reaches these values for elasticities and 
neither does it provid e sufficient data to replicate the results. Even worse, these older elasticities 
are inappropriately applied to heavily distorted 2017 market conditions. Other flaws on the elasticity 
model include reliance on inconsistent key data inputs, (including sales  data), arbitrary adjustments 
and uncertainty of certain data (e.g. domestic shipments).  
43. As to the "formula -based" approach applied to 5 of the cases, the United States asserts that 
the "elasticity" approach is not reliable when PRC -wide entity market  shares are below 1%. However, 
the United States does not support this cutoff with any factual or scientific background.  
44. The U.S. formula is premised on the wrong factual assumption: the application of the historic 
share of total imports for the PRC -wide entity is calculated by using import data from the original 
investigation. This approach does not take account of the fact that the USDOC revoked the original 
separate rate status of many Chinese exporters included under the PRC -wide rate in subsequent 
reviews. As a result, the calculation of the N/I is underestimated.  
45. Also, the "formula based" methodology incorrectly determines the total volume of 2017 
imports from China absent the WTO -inconsistent measures. According to the U.S. formula, 
compliance  would not change the total value of imports from China. Under the United States' view, 
compliance would simply mean reallocating trade from one set of Chinese firms to others with no 
net increase in trade from China. This formula brings a biased downward result that omits any harm 
China has suffered from the United States' WTO -inconsistent policy in certain cases for more than a 
decade.  
46. The U.S. approach for addressing zeroing  in Coated Paper is also mistaken. At the outset, the 
United States recognize s that without zeroing the AD rate would have been negligible [[***]] and 
that an AD order would not have been imposed. Nevertheless, the United State ignores its own 
assertion when calculating the level of N/I by adopting an approach that examines the dif ference in 
trade volume during 2017 between the imposition of 7.62% and an AD rate of zero. The United 
States adopts an untenable assumption that APP's 2017 import level would not have changed had 
the United States correctly not imposed any AD duty order o n APP China's U.S. exports from the 
start. Additionally, the United States ignores that a reduction in AD duty rate is simply not the same 
as termination of the AD order. Under the U.S. system, the uncertainty of any AD order and the 
need to go through ann ual administrative reviews each year imposed a burden on the exporter and 
creates uncertainty about future trade flows.  
47. Finally, the U.S. claim that it may calculate N/I that is zero for two AD orders  ( Corrosion -
Resistant Steel and Diamond Sawblades ) must be rejected because (i) the mere maintenance of a 
AD order would cause an "as such" violation which is presumed to carry certain level of N/I in 
accordance with WTO jurisprudence ( US— 1916 Act (Article 22.6 (EC)) and (ii) even where the N/I 
could be z ero and was not - the United States has not met its burden of proof demonstrating that 
the N/I was actually zero.  
C. U.S. Failed To Provide Sufficient Data And Explanations To Allow Proper 
Assessment And Replication  
48. The U.S. methodology is based on the  use of non -public data, which makes its replicability 
impossible. Among the most troubling examples of this is the use of confidential import values of 
"subject merchandise for 2017", since these values constitute the core for quantification under the 
U.S. approach.   WT/DS471/ ARB/Add.1  
 
- 29 - 
 
  49. Another piece of relevant information that can neither be verified by China or the Arbitrator is 
the amount of trade by the PRC -wide entity, and its entire underlying classification system (i.e., is 
a particular firm a PRC -wide entity or not?). This data was provided only at the very end of the 
proceeding, far too late for China to have any reasonable chance to verify the data.  
50. What is perplexing is that the United States possesses this information and routinely provides 
such informati on in every AD review for the purpose of mandatory respondent selection. Thus the 
United States could have provided verifiable back -up data allowing China and the Arbitrator to check 
any possible mistakes in the compilation exercise.  Instead, the United S tates has chosen to provide 
information that is not available from any public source.  
 
51. The above contrasts with Article 22.6 practice (e.g. EC – Bananas III (Article 22.6 – EC) and 
USDOC preference (e.g. Warmwater Shrimp from China ) to use publicly av ailable information as it 
is more credible, factual and verifiable.  
D. The United States Has Not Met Its Burden Of Proof  
52. In an Article 22.6 proceeding, the non -complying party has the burden of proving that the 
requested countermeasures are not equivalent to the level of N/I. In doing so, the non -complying 
party should present a more reasonable methodology. Where both N/I calculation approaches are 
equally reasonable, the Arbitrator must rule in favor of the requesting party ( EC – Hormones (US) 
(Article 22.6 – EC).  
53. The United States has not shown that the level of countermeasures proposed by China is not 
equivalent to the level of N/I. In addition, the United States has not presented reasoned estimates 
that rely on credible, verifiable and fa ct-specific information. As a result, the United States has not 
met its burden of proof for an alternative calculation of N/I.  
III. THE TWO -STEP METHODOLOGY FROM US—WASHING MACHINES (ARTICLE 22.6 -US) 
ALSO HAS FLAWS, BUT MAKES MORE SENSE THAN THE U.S. METHO DOLOGY  
54. In addition to all the adjustments proposed, China has cooperated with the Arbitrator in 
exploring the option of adapting the two -step methodology used in US-Washing Machines (Article 
22.6 -US) to the present dispute.  
55. China continues to bel ieve that its proposed DID methodology is more appropriate because it 
can easily cover all cases, and can be adapted to address concerns about focusing on only the PRC -
wide entity trade and focusing on the change in the AD margins.  But unlike the United S tates, China 
has provided the Arbitrator with sufficient data to apply the alternative two -step approach for 19 of 
24 cases (18 of which from public sources and other available information on the case Large 
Residential Washers. ).  
A. Reasons Why The Two-Step Methodology Is Less Appropriate For This 
Specific Dispute.  
56. There are many reasons why the US-Washing Machines (Article 22.6 -US) two-step approach 
cannot be appropriately applied to the present proceeding.  
57. In the first place, the N/I metho d used in US-Washing Machines  requires the Arbitrator to 
have specific credible data about total market size both for the year prior to the order (which varies) 
and the remedy period (2017). In the U.S.'s methodology, such data do not even exist for some o f 
the WTO -inconsistent measures. Moreover, the data provided by the United States are in many 
cases overly broad or even confidential. This is in contrast with US-Washing Machines  where both 
Korea and United States agreed on some of the data inputs for the  model (e.g., AHAM data used to 
estimate the total market size).  China's DID methodology is more appropriate because it is less 
data intensive.  
58. Further, the US-Washing Machines (Article 22.6 -US) model requires specific data on the 
market share of thos e Chinese exporters who exported to the United States in the year prior to the 
AD case, but were part of the PRC -wide entity in 2017. The United States has only provided part of 
the required data following its oral statement and in many cases are subject t o confidentiality. This WT/DS471/ ARB/Add.1  
 
- 30 - 
 
  was not the situation in US-Washing Machines (Article 22.6 -US) where both parties had access to 
the same information.  
59. Additionally, elasticity models unreliably capture the impact of duties and duty rate changes 
of the magnitud es observed in the dispute. In US-Washing Machines (Article 22.6 -US), the WTO -
inconsistent duty was approximately 11% and the remedy involved partial removal by percentage 
points. The present dispute involves hundreds of AD rates ranging from modest levels  to over 200 
percentage points with possible adjustments of similar magnitude. Accordingly, the accuracy of 
elasticity measures is paramount.  China's DID methodology does not depend on accurate estimates 
of elasticities.  
60. Also, it is particularly diffi cult to incorporate the maintenance of the WTO -inconsistent 
measures over time in the two -step methodology. More than a dozen of the 24 cases assessed had 
WTO-inconsistent duties in place for more than a decade and Armington -style elasticity models 
capture  only the short -term impact of duties. As noted aove, China's DID methodology does not 
depend on accurate estimates of elasticities.  
61.  On the top of that, there are multiple uncertainties that would affect the implementation of 
the two -step approach, na mely (i) at which level will the AD be adjusted; (ii) the potential WTO -
inconsistency of the AD rate; and (iii) the change in the exporter's status and its integration under 
the PRC -wide entity. Due to these uncertainties the two -step approach is inadequat e under the 
circumstances  
B. If The Two -Step Approach Is Applied  
62. However, notwithstanding these uncertainties if the Arbitrator decides to use the two -step 
approach of US-Washing Machines (Article 22.6 -US), China would note the following.  First, it is 
important to be very clear about what that methodology actually involved.  To clarify, China has 
reviewed the computer programming code and would summarize those steps as follows:  
63. Step 1 : Identify the composition of the PRC -wide entity in 2017. Identification is determined by 
the producers' or exporters' status, not by whether or not the producer or exporter shipped any 
subject product in 2017.  
64. Step 2:  Identify, for the year preceding the imposition of the relevant AD duties, the value  of 
imports from the producers or exporters that were included in the entity in 2017, i.e. the PRC -
wide entity as composed in 2017. This should not be based on 2017 trade values.  
65. Step 3:  On that basis, find the market share of the PRC -wide entity (as defined by PRC -wide 
status in 2017) in the year preceding the imposition of the relevant AD duties. In the same way, 
calculate the market shares for the year preceding the imposition of the relevant AD duties for 
all other market participates, namely: dome stic shipments, imports from the rest of China, and 
imports from the rest of the world.  
66. Step 4:  Using the market shares as calculated in step (3) apply the Armington -based model to 
calculate the market shares of the PRC -wide entity (as defined by PRC -wide status in 2017) as 
well as the other three sources, following the imposition of the WTO inconsistent AD duties  
This step will produce the Armington model's short -run impact of the WTO inconsistent AD 
duties.  
67. Step 5:  Using the market share data as calculated in step (4), re -run the Armington -based model 
to calculate the market shares of the PRC -wide entity (as defined by PRC -wide status in 2017) 
as well as the other three sources, assuming the WTO inconsistent AD duties (as applied to the 
PRC-wide e ntity) are replace by WTO consistent AD duties.  
68. Step 6:  Calculate the difference in market share for the PRC -wide as calculated in step (5) with 
the market share for the PRC -wide entity as calculated in step (4).  
69. Step 7: Using a measure of the tota l market size for 2017, apply the difference in market shares 
calculated in step (6) to calculate the short -run loss in trade to China due to the US application WT/DS471/ ARB/Add.1  
 
- 31 - 
 
  of WTO inconsistent AD measures. This final step requires multiplying the difference in market 
shares (step 6) by the size of total market. The most logical basis for the market size is the 
remedy year, which in this dispute is 2017. If accurate data for overall market size is not 
available for the remedy year, the Arbitrator could use market size i n a prior year (adjusted for, 
say, GDP growth).  
This step will produce the N/I for the case.  
70. China has provided the necessary information to the Arbitrator from public sources for 
implementing the two -step approach in the case at hand.  In this regard,  China has been more 
forthcoming with the Arbitrator and more willing to provide the necessary data than the United 
States.  
71. In addition, China has a number of observations in relation to the implementation of its 
proposed methodology.  
72. Particularly , China considers that the Arbitrator must reject distorted trade values of 2017 for 
both the total volume of China trade and trade held by the PRC -wide entity. The 2017 trade volume 
figures are significantly depressed because of the maintenance of WTO -inconsistent measures 
spanning over more than a decade. In previous Article 22.6 disputes, Arbitrators have refused to 
use parameters distorted by WTO -inconsistent measures ( US-Washing Machines (Article 22.6 -US) 
para. 3.115 ; US-Gambling (Article 22.6 -US) para. 3.134 ).  
73. In the light of this, it is preferable for the Arbitrator to use a reasonable estimate based on 
the data for "year prior", which is not affected by WTO -inconsistencies. China provided public "year 
prior" data (total market size, US domestic shipments and all other imports) included in USITC injury 
reports for 18 cases. In addition, China submitted other available information on the case Large 
Residential Washers .  
74. As to the market share held by the PRC -wide entity, the Arbitrator could use the percentage 
for the year prior to the AD measures. This percentage is conservative as it understates the true 
share of Chinese exporters that are part of the PRC -wide entity rate in 2017. The Arbitrator can 
determine the PRC -wide en tity share in the year prior through (a) total imports from China of subject 
merchandise (as presented by China both in the HS code data for "year prior" in every single case 
or in the USITC injury reports) and (b) through the best estimate of the PRC -wide entity share of 
imports (as presented by United States in Exhibit USA -54). As to the information provided by the 
United States, China disagrees with distinguishing between Group 3 and Group 4 exporters as no 
evidentiary justification supports this contriv ed separation within the PRC -wide entity import volume.  
75. For the total size of the U.S. market, the Arbitrator could use the data on the size of the 
market for the year prior to the AD measures adjusted using U.S. GDP growth. China has strongly 
recommen ded rejecting the problematic U.S. data which resorts in a variety of ad hoc  unverifiable 
sources and extrapolations (including the combination of private data and aggregated SEC financial 
reports).  
76. As to the elasticities, China suggested using the mi dpoint of N/I estimates included in the 
USITC reports instead of a midpoint elasticities as proposed by the United States. The Armington 
model is highly sensitive to elasticities, which makes it necessary to include the high and low end of 
elasticity estim ates in order to avoid distorting the N/I.  
77. Finally, as regards the N/I calculation, China provided the Arbitrator specific rates that could 
be used, and agreeing with the rates suggested by the United States for 11 out of 24 cases.  
IV. DESPITE THE RE MOVAL OF THE AD ORDER ON OTR TIRES, THE ARBITRATOR SHOULD 
CALCULATE A N/I FOR THE PERIOD IT WAS IN PLACE FOLLOWING THE EXPIRY OF THE 
IMPLEMENTATION PERIOD.   
78. In the case at hand, the United States had not withdrawn the inconsistent measures contained 
in OTR Tires  by August 2018 – the end of reasonable period of time established by the Article 21.3 (c) 
Arbitrat ion. On the contrary, the measures remained effective  for six additional months – until 
February 2019, covering most of the duration of the Article 22.6 of DSU proceeding.  WT/DS471/ ARB/Add.1  
 
- 32 - 
 
  79. China's considers that imposing a level of N/I on OTR Tires  for the period it was in place after 
the expiry of the implementation per iod is particularly important for inducing compliance in this case.  
Conclusion  
80. China has presented a methodology which is sound, supported by academic and scientific 
background and which is based on a counterfactual that is in line with prior Article 2 2.6 practice.  
The most conservative minimum estimate for each benchmark and alternative adjustments totals 
$8 billion.  
81. The United States has not met its burden of proving that China's requested countermeasures 
do not equal the level of N/I by presenti ng a more reasonable and verifiable alternative. Further, in 
the view of the lack of any action shown by the United States in the 24 months that passed since 
the adoption of the DSB recommendations, the Arbitrator should approach the United States' 
methodo logy sceptically; bearing in mind that it is based on mere hypotheticals and speculations 
about what might be done and that remain fraught with WTO -inconsistencies.  
82. In conclusion, China notes that its requested N/I of $7 billion is conservative and re asonable.  
 
 
_______________  
 
 
 
 WT/DS471/ ARB/Add.1  
 
- 33 - 
 
  ANNEX  C 
PROCEDURAL RULING OF  THE ARBITRATOR  
Contents  Page  
Annex  C-1 Procedural  Ruling on the United States' Request to Partially Open the 
Arbitrator's Meeting to Public Observation  34 
 
 
 WT/DS471/ ARB/Add.1  
 
- 34 - 
 
  ANNEX  C-1 
PROCEDURAL RULING ON  THE UNITED STATES' REQUEST TO PARTIALLY  OPEN THE 
ARBITRATOR'S MEETING  TO PUBLIC OBSERVATI ON 
1  INTRODUCTION  
1.1.  The United States requests the Arbitrator to partially open the meeting with the parties in this 
proceeding, by adopting "procedures that allow WTO Members and the public to observe U.S. 
statements during the arbitration meeting ."1 The United States makes this request after China 
opposed the United  States' request to fully open the mee ting in this proceeding. China also disagrees 
with the United States' request to partially open the meeting.2 Below, we set out the main arguments 
of the parties, followed by our analysis and ruling on the United States' request.  
2  MAIN ARGUMENTS OF  THE P ARTIES  
2.1.  The United States contends that opening the Arbitrator's meeting with the parties would 
enhance transparency of WTO dispute settlement proceedings and heighten confidence in the WTO.3 
The United States substantiates its request by relying on t he second sentence of Article 18.2 of the 
DSU, which allows parties to a dispute to disclose "statements of its own positions to the public".4 
In addition, the United States contends that the DSU does not require an Arbitrator to close its 
meeting in proce edings under Article 22.6 of the DSU.5 Further, the United States relies on the 
Arbitrator's statement in US – Tuna II (Mexico) (Article 22.6 – US) that "due process requires that 
'all parties must be given the opportunity to lift the confidentiality of st atements of their own 
positions at partially open meetings.'"6 
2.2.  China, for its part, relies on the language of the first sentence of Article 18.2 of the DSU, which 
states that submissions shall remain confidential.7 In China's view, this obligation co ncerns not only 
written submissions, but also extends to "proceedings to discuss those submissions".8 China also 
points to the panel working procedures contained in Appendix 3 to the DSU, which in paragraph 3 
refer to the confidentiality of the deliberatio ns and submitted documents, and in paragraph 2 refer 
to the panel meeting in closed session.9 Seen in that context, Article 18.2 of the DSU cannot, 
according to China, provide a basis to force a partially open meeting over China's objection.10 
2.3.  China submits that confidentiality of statements is particularly appropriate in Article 22.6 
proceedings, which involve very technical economic and legal issues.11 In China's view, having a 
closed meeting would not prevent the United States from making public st atements of its own 
positions in line with the second sentence of Article 18.2 of the DSU.12 To that end, China argues 
that the transparency objective invoked by the United States could be achieved through publication 
of the Arbitrator's decision together with the executive summaries of the parties' arguments.13 
                                                
1 United States' comments on the Arbitrator's draft timetable and Working Procedures, p. 4; and 
comments on China's comments on the Arbitrator's draft timetable and Working Procedures, pp. 3 -4. 
2 China's comments on the Arbitrator's draft timetable and Work ing Procedures, pp. 4 -5; and comments 
on the United States' comments on the Arbitrator's draft timetable and Working Procedures, pp. 1 -3. 
3 United States' comments on the Arbitrator's draft timetable and Working Procedures, pp. 3 -4. 
4 United States' commen ts on the Arbitrator's draft timetable and Working Procedures, p. 4.  
5 United States' comments on China's comments on the Arbitrator's draft timetable and Working 
Procedures, p. 3.  
6 United States' comments on the Arbitrator's draft timetable and Working P rocedures, p. 4 (quoting 
Decision by the Arbitrator, US – Tuna II (Mexico) (Article 22.6 – US), para. 2.26).  
7 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.  
8 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.  
9 China's comments on the United States' comments on the Arbitrator's draft timetable a nd Working 
Procedures, p. 2.  
10 China's comments on the United States' comments on the Arbitrator's draft timetable and Working 
Procedures, p. 3.  
11 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.  
12 China's comments on t he Arbitrator's draft timetable and Working Procedures, p. 4.  
13 China's comments on the Arbitrator's draft timetable and Working Procedures, p. 4.  WT/DS471/ ARB/Add.1  
 
- 35 - 
 
  3  ANALYSIS BY THE A RBITRATOR  
3.1.  Pursuant to paragraph 2 of the working procedures contained in Appendix 3 to the DSU, panels 
by default meet in "closed session". However, Article  12.1 of the DSU  provides that "[p]anels shall 
follow the Working Procedures in Appendix 3 unless the panel decides otherwise after consulting the 
parties to the dispute." WTO adjudicators, therefore, enjoy some discretion in establishing their own 
working procedures. How ever, this discretion "does not extend to modifying the substantive 
provisions of the DSU"14, and therefore cannot be exercised in a manner that is inconsistent with 
those provisions.  
3.2.  In this case, the United States argues that providing for a partia lly open meeting would serve 
to facilitate the United States' right under Article 18.2 of the DSU to disclose statements of its own 
positions to the public.15 China disagrees, and invokes its right to confidentiality under Article 18.2. 
The parties thus ha ve differing views on the scope of the obligation to protect confidential information 
under Article  18.2.16  
3.3.  We observe that although Article 18.2 of the DSU authorizes a party to a dispute to disclose 
statements of its own positions to the public, n othing in the DSU provides that this right must be 
exercised through the holding of fully or partially open meetings, especially when the parties 
disagree on the matter.17 We do not consider that a WTO adjudicator that declined a party's request 
to hold pa rtially open meetings would be depriving that party of its rights under Article  18.2 or under 
any other provisions of the DSU. There are other ways in which parties can make statements of their 
positions public: for example, some WTO Members post their sub missions and the written versions 
of their statements at WTO dispute settlement meetings on the internet.18 Therefore, it is within our 
discretion to grant or deny the United States' request.  
3.4.  When faced with requests to exercise their discretion to p artially open their meetings to public 
observation, WTO adjudicators have taken into account a number of considerations in determining 
whether partially open meetings would be appropriate in the specific circumstances.19 In exercising 
our discretion, we ha ve carefully considered the competing interests of the parties as well as the 
need for prompt settlement of this dispute. In this context, we take into account that, to safeguard 
China's right to maintain the confidentiality of its statements and the busin ess confidential 
information submitted in this proceeding, the partial opening of our meeting would call for the 
adoption and implementation of complex working procedures, which would require the participation 
of both parties and may affect our ability to issue a timely decision. We have also taken into account 
that with the exception of three proceedings, all in the same dispute20, WTO adjudicators have 
declined to fully or partially open substantive meetings for public viewing where one party was not 
in agreement.21 In the current proceeding, we consider that the disagreement between the parties 
on the proposal to partially open the meeting, as well as the parties' conflicting views on the scope 
of the obligation to protect confidential information in the context of a partially open meeting, give 
rise to concerns that counsel against holding a partially open meeting.  
                                                
14 Appellate Body Report, India – Patents (US) , para. 92.  
15 See above para. 2.1.  
16 See above paras. 2.2-2.3. 
17 This view has been consistently affirmed in prior WTO dispute settlement proceedings. (See, e.g. 
Decision by the Arbitrator, US – Gambling (Article 22.6 – US), para 2.29; and Appellate Body Report, EU –
Biodiesel (Argentina) , Annex D -2, paras. 6 -7. 
18 See, e.g. Panel Reports, US – OCTG (Korea) , Annex E -1, para. 3.4; and US – Upland Cotton (Article 
21.5 – Brazil) , para. 8.20.  
19 For example, the arbitrator in US – Tuna II (Mexico) (Article 22.6 – US) identified four factors that 
guide the evaluati on of whether to grant a request to partially open a meeting: "(a) a non -disclosing party's 
right to confidentiality protection of statements of its own position, (b) due process, (c) the prompt settlement 
of disputes, or (d) the careful and efficient disc harge, or the integrity, of the adjudicative function." (Decision 
by the Arbitrator, US – Tuna II ( Mexico ) (Article 22.6 – US), para. 2.31).  
20 Panel Reports, US – Tuna II (Mexico) (Article 21.5 – US) / US – Tuna II (Mexico) (Article 21.5 – 
Mexico II) , paras. 7.16-7.34; and Decision by the Arbitrator, US – Tuna II (Mexico) (Article 22.6 – US), 
paras.  2.17-2.34. 
21 See, e.g. Appellate Body Report, EU – Biodiesel (Argentina) , Annex D -2, paras. 6 -7; Panel Reports, 
US – Upland Cotton (Article 21.5 – Brazil), para. 8.20, and US – OCTG (Korea) , Annex E -1, paras.  3.1-3.4 and 
fn 1; and Decision by the Arbitrator, US – Gambling (Article 22.6 – US), para. 2.29.  WT/DS471/ ARB/Add.1  
 
- 36 - 
 
  4  CONCLUSION  
4.1.  Based on the reasons set out above, we deny the United States' request to partially open our 
meeting with the parties to public observation.  
 
_______________  
 
 
 
 WT/DS471/ ARB/Add.1  
 
- 37 - 
 
  ANNEX D  
GRAPHICAL ILLUSTRATI ONS AND FIGURES CONC ERNING THE PARTIES' PROPOSED CALCULATION  
METHODOLOGIES  
Contents  Page  
Annex  D-1 China's proposed DID tabular approach: Graphical illustrations of the failure 
to meet the parallel trends assumption provided by the United States  38 
Annex D -2 United States' proposed Armington model: Relationship between the change 
in the market share of Chinese exporters within the PRC -wide entity and the 
duration of the anti -dumping orders  39 
Annex D-3 United States' proposed Armington model: Relationship be tween the change 
in the market share of Chinese exporters within the PRC -wide entity and the 
level of the WTO -inconsistent PRC-wide duty rates  40 
 
 
 WT/DS471/ ARB/Add.1  
 
- 38 - 
 
  ANNEX  D-1 
CHINA'S PROPOSED DID  TABULAR APPROACH:  GRAPHICAL ILLUSTRAT IONS OF THE FAILURE  
TO MEET THE PARALLEL  TRENDS ASSUMPTION  PROVIDED BY  THE UNITED STATES  
 
 
 
 
WT/DS471/ ARB/Add.1  
 
- 39 - 
 
  ANNEX  D-2 
UNITED STATES' PROPO SED ARMINGTON  MODEL: RELATIONSHIP BETWEEN THE CHANGE I N THE 
MARKET SHARE OF CHIN ESE EXPORT ERS WITHIN THE PRC -WIDE ENTITY AND THE D URATION OF 
THE ANTI -DUMPING ORD ERS 
 
 
 
 
 
-100.000%-99.000%-98.000%-97.000%-96.000%-95.000%-94.000%-93.000%
0 2 4 6 8 10 12 14 16Percentage change of the market share of 
Chinese exporters within the PRC -wide entity
Number of years between the year prior to the imposition of the anti -dumping order and 2017WT/DS471/ ARB/Add.1  
 
- 40 - 
 
  ANNEX  D-3 
UNITED STATES' PROPO SED ARMINGTON MODEL:  RELATIONSHIP BETWEE N THE CHANGE IN THE 
MARKET SHARE OF CHIN ESE EXPORTERS WITHIN  THE PRC -WIDE ENTITY  AND THE LEVEL OF THE  
WTO-INCONSISTENT PRC -WIDE DUTY RATES  
 
 
 
 
_______________  
 
WT/DS471/ ARB/Add.1  
 
- 41 - 
 
  ANNEX  E 
DATA INPUTS AND CALC ULATIONS OF THE ARBI TRATOR  
Contents  Page  
Annex E -1 Data inputs for US market values in the year prior to the imposition of the 
anti-dumping orders  42 
Annex E -2 Data inputs for the share of US imports from China covered by different 
Chinese exporters in the year prior to the imposition of the anti -dumping 
orders  49 
Annex E -3 List of Chinese exporters outside the PRC -wide entity used to estimate the 
share of different Chinese exporters for six anti -dumping orders  57 
Annex E -4 List of Chinese exporters subject to  the WA -T duty rate s and other Chinese 
exporters outside the PRC -wide entity used to estimate the share of different 
Chinese exporters for three anti -dumping orders  70 
Annex E -5 Data inputs for elasticities  74 
Annex E -6 Data inputs for the actual anti -dumping duty rates 76 
Annex E -7 List of anti -dumping duty rates used for two anti -dumping orders  81 
Annex E -8 Data inputs for US market values in 2017  85 
Annex E -9 Code and text version of the Armington model  91 
Annex E -10 Data inputs used to implement the Armington model under the two steps  96 
Annex E -11 Results of implementing the Armington model under the first step  99 
 
 
 
  
  WT/DS471/ARB/Add.1  
 
- 42 - ANNEX  E-1 
DATA INPUTS FOR US MARKET VALUES IN THE YEAR PRIOR TO TH E IMPOSITION OF THE ANTI-DUMPING ORDERS  
Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Aluminum Extrusions  2010 4,606,386  3,557,906  537,498  510,982  All data from USITC publication 4677.  
Bags 2003 995,491  772,295  [[***]] [[***]] Data on  the value of US shipments from 
USITC publication 3710. Aggregated  value of 
US imports from China based on company -
specific data from US Customs (Exhibit 
USA-94 (BCI)) . Value of US imports from the 
rest of the world estimated by subtracting 
the value of US imports from China, based on 
data from US Customs (Exhibit  USA-94 
(BCI)), from the total value of  US imports 
reported in USITC publication 3710.  
Coated Paper  2009 1,742,20 4 1,023,688  297,527  420,989  All data from USITC publication 4192.  
Diamond Sawblades  2009 [[***]] 73,000  [[***]] 63,300  Value of US shipments provided by the 
United States based on adjusted data from 
USITC publication 4559  (Exhibit USA -58). 
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94 (BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57).  
                                                
1 The value of the total US market is obtained by adding the value of US shipments, the value of US im ports from China, and the value of US imports from the 
rest of the world.   
  WT/DS471/ARB/Add.1  
 
- 43 - Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Furniture  2003 4,666,667  1,878,740  [[***]] [[***]] Data on  the value of US shipments from 
USITC publication 3743. Aggregated  value of 
US imports from China based on company -
specific data  from US Customs (Exhibit USA -
94 (BCI)) . Value of US imports from the rest 
of the world estimated by subtracting the 
value of US imports from China, based on 
data from US Customs (Exhibit USA -94 
(BCI) ), from the total value of US imports 
reporte d in USITC publication 3743.  
OCTG  2009 [[***]] 1,844,564  [[***]] 1,338, 100 Annualized value of US shipments  based on 
data from USITC publication 4124.  
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94 (BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57). 
OTR Tires  2007 1,794,409  1,006,044  282,390  505,975 All data from USITC publication 4 031. 
PET Film  2007 [[***]] 1,157,356  [[***]] 259,200  Annualized value of US shipments based on 
data from USITC publication 3962 . 
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94 (BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57).  
  WT/DS471/ARB/Add.1  
 
- 44 - Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Ribbons  2009 650,438  580,172  [[***]] [[***]] Value of US shipments provided by the 
United States based on adjusted data from 
the US Census Bureau's Annual Survey of 
Manufactures and USITC Data Web (Exhibit 
USA-58). Aggregated  value of US imports 
from China based on company -specific data 
from US Customs (Exhibit USA -94 (BCI )). 
Value of US imports from the rest of the 
world estimated by subtracting the value of 
US imports from China, based on data from 
US Customs (Exhibit -94 (BCI)), from the 
total value of US imports reported in USITC 
publication 4634.  
Shrimp  2004 [[***]] 407,484  [[***]] 3,249,100 Annualized value of US shipments  based on 
data from USITC publication 3748.2 
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94 (BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57). 
Solar Panels  2011 [[***]] 804,853  [[***]] 2,748,200 Data on the value of US shipment s from 
USITC publication 4360. Aggregated  value of 
US imports from China based on company -
specific data from US Customs (Exhibit 
USA-94 (BCI)). Value of US imports from the 
rest of the world based on HTS aggregated 
data from the US Census Bureau (Exhibit 
USA-57). 
                                                
2 China proposes to annualize the value of USD 12,434,000  of US shipments of selected US processors  from USITC publication 3748 for January to June 2004 
(USITC publication 3748, Tabl e C-3). However, we note that according to the USITC report, this value excludes data for previously excluded, targeted related parties . 
For consistency, we use the annualized value of USD 407,484 ,000 of US shipments from USITC publication 3748 (USITC publ ication 3748, Table C -1).  
  WT/DS471/ARB/Add.1  
 
- 45 - Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Steel Cylinders  2011 [[***]] 87,675  [[***]] 3,800 Value of US shipments provided by the 
United States based on  data from the annual 
report by the only US producer,  TriMas 
Corporation  (Exhibit USA -58). Aggregated  
value of US imports from China based on 
company -specific data from US Customs 
(Exhibit USA -94 (BCI)). Value of US imports 
from the rest of the world based on HTS 
aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Wood Flooring  2010 783,896  341,130  326,981  115,785  All data from  USITC publication 4970.  
Copper Pipe and Tube  2009 2,110,170  1,602,849  244,101  263,220  All data from USITC publication 4193.  
Iron Pipe Fittings  2002 [[***]] 276,200  [[***]] 43,900  Value of US shipments based on data from 
the US Census Bureau's Annual Survey of 
Manufactures and USITC Data Web adjusted 
by the United  States  (Exhibit USA -58). 
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit  USA-94 (BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57). 
Passenger Vehicle and 
Light Truck Tires  2014 22,154,265  11,740,621  2,561,898  7,851,746  All data from USITC publication 4545.   
  WT/DS471/ARB/Add.1  
 
- 46 - Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Residential Washers  2016 [[***]] [[***]] [[***]] 639,000  Value of US shipments estimated by 
subtracting the value of US imports, based 
on data from US Customs (Exhibit USA -94 
(BCI)) and data from the US Census Bureau 
(Exhibit USA -57), from the total value of the 
US market , based on data  from the 
Association of H ome Appliance Manufacturers  
(Exhibit CHN -56 (BCI)). Aggregated  value of 
US imports from China based on data from 
US Customs (Exhibit USA -94(BCI)). Value of 
US imports from the rest of the world based 
on HTS aggregated data from the US Census 
Bureau (Exhibi t USA -57). 
Sheet and Strip  2016 [[***]] 2,998,837  [[***]] 757,300 Annualized value of US shipments  based on 
data from USITC publication 4676.  
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94(BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57). 
Steel Flat Products  2015 8,405,722  6,794,385  295,705  1,315,632  All data from USITC publication 4619.  
Steel Line Pipe  2008 [[***]] 1,065,369  [[***]] 582,400 Annualized value of US shipments based on 
data from USITC publication 4055.3 
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94 (BCI)). Value of US 
imports from the rest of the world based on 
HTS aggregated data from the US Census 
Bureau (Exhibit USA -57). 
                                                
3 We note that, although 2008 is the year prior to the imposition of the anti -dumping order, China proposes to use data on the value of US shipments in 2007 
reported in USITC publication 4055  (Exhibit CHN -55 (BCI)). We consider th is an inadvertent error and instead annualize the value of US shipments for January to 
September 2008 reported in USITC publication 4055.   
  WT/DS471/ARB/Add.1  
 
- 47 - Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Steel Nails  2007 984,270  220,411  [[***]] [[***]] Data on  the value of US shipments from 
USITC publication 4022. Aggregated value of 
US imports from China based on company -
specific data from US Customs (Exhibit USA -
94 (BCI)). Value of US imports from the rest 
of the world estimated by subtracting the 
value of US  imports from China, based on 
data from US Customs (Exhibit USA -94 
(BCI)), from the total value of US imports 
reported in USITC publication 4022.  
Steel Pipe  2007 2,185,379  1,350,791  470,787  363,801  All data from USITC publication 4435.  
Steel Products  2015 17,055,633  13,451,548  [[***]] [[***]] Data on  the value of US shipments from 
USITC publication 4620.4 Aggregated  value 
of US imports from China based on company -
specific data from US Customs (Exhibit USA -
94 (BCI)). Value of US imports from the rest 
of the world estimated by subtracting the 
value of US imports from China, based on 
data from US Customs (Exhibit USA -94 
(BCI)), from the total value of US imports 
reported in USITC p ublication 4620.  
Steel Standard, Line, and 
Pressure Pipe  2009 683,206  199,357  135,240  348,609  All data from USITC publication 4595.  
                                                
4 We note that China proposes to use a value of USD  13,451,548 as the value of 2015 US shipments reported by the USITC  (Exhibit CHN -55 (BCI)). However, 
USITC publication 4620 reports the value of 2015 US domestic shipments as USD 13,451,548,000. We consider China's proposed va lue to be an inadvertent error and 
use the value reported in USITC publication.   
  WT/DS471/ARB/Add.1  
 
- 48 - Anti-dumping order  Year prior to 
the imposition 
of the anti -
dumping order  Total US 
market1 
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)  Data sources  
Steel Wire Rod  2014 [[***]] 2,682,510  [[***]] 970,200  Annualized value of US shipments based on 
data from USITC publication 4509. 
Aggregated  value of US imports from China 
based on company -specific data from US 
Customs (Exhibit USA -94 (BCI)). Data on the 
value of US imports from the rest of the 
world based on HTS aggregated data from 
the US Census Bureau (Exhibit USA -57). 
Note:  The values in this table have been rounded for display purposes only. The actual values were used when implementing the Armin gton model under the two 
steps to estimate the level of nullification or impairment.   
  WT/DS471/ARB/Add.1  
 
- 49 - ANNEX  E-2 
DATA INPUTS FOR THE SHARE OF US IMPORTS FROM CHINA COVERED B Y DIFFERENT CHINESE EXPORTERS IN THE YEA R PRIOR TO THE 
IMPOSITION OF THE AN TI-DUMPING ORDERS  
Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Aluminum Extrusions  n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the shar e of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (United States' response to 
Arbitrator question No. 62 , paras. 70 -72). 
Bags n/a  [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rat e estimated 
by the United Stat es by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ).   
  WT/DS471/ARB/Add.1  
 
- 50 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Coated Paper  [[***]]% [[***]]% [[***]]% Share of Chinese exporters subject to the PRC-wide duty rate 
estimated by the United States by subtracting the value of US 
imports from Chinese exporters outside the PRC -wide entity, 
based on company -specific trade data reported by the 
exporters, from the total value of US imports from China, 
based on HTS aggregated monthly trade data from USITC 
Dataweb ( Exhibit USA -54 (BCI) ). Share of Chinese exporters 
subject to WA -T duty rate estimated  by identifying  their 
name s based on USDOC records for investigation A-570-958 
(Annex E-4), and their corresponding shipments values  based 
on confidential company -specific trade data compiled by US 
Customs (Exhibit USA -94 (BCI)) . Share of remaining Chinese 
exporters estimated by identifying their names based on 
USDOC records for investigation A-570-958 (Annex E-4), and 
their corresponding shipments values  based on confidential 
company -specific trade data compiled by US Customs (Ex hibit 
USA-94 (BCI)).  
Diamond Sawblades  n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC -wide duty rate 
estimated by subtracting the aggregated value of shipments 
by Chinese exporters outside the PRC -wide entity from the 
total value of US im ports from China. The aggregated value of 
shipments by Chinese exporters outside the PRC -wide entity 
estimated by identifying  the name s of all Chinese exporters 
outside the PRC -wide entity, based on USDOC records for 
investigation A-570-900 (Annex E-3), and their corresponding 
shipments values , based on confidential company -specific 
trade data compiled by US Customs (Exhibit USA -94 (BCI)). 
Share of remaining Chinese exporters estimated as the 
residual share.   
  WT/DS471/ARB/Add.1  
 
- 51 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Furniture  n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC -wide duty rate 
estimated by subtracting the aggregated value of shipments 
by Chinese exporters outside the PRC -wide entity from the 
total value of US imports from China. The aggregated value of 
shipments by Chinese  exporters outside the PRC -wide entity 
estimated by identifying  the name s of all Chinese exporters 
outside the PRC -wide entity, based on USDOC records for 
investigation A-570-890 (Annex E-3), and their corresponding 
shipments values , based on confidential company -specific 
trade data compiled by US Customs (Exhibit USA -94 (BCI)). 
Share of remaining Chinese exporters estimated as the 
residual share.  
OCTG  [[***]]% [[***]]% [[***]]% Share of Chinese exporters subject to the PRC-wide duty rate 
estimated by the United States by subtracting the value of US 
imports from Chinese exporters outside the PRC -wide entity, 
based on company -specific trade data reported by the 
exporters, from the total value of US imports from China, 
based on HTS aggregated monthly trade data from USITC 
Dataweb (Exhibit USA -54 (BCI) ). Share of Chinese exporters 
subject to WA -T duty rate estimated  by identifying  their 
name s based on USDOC records for investigation A-570-943 
(Annex E-4), and their correspond ing shipments values  based 
on confidential company -specific trade data compiled by US 
Customs (Exhibit USA -94 (BCI)) . Share of remaining Chinese 
exporters estimated by identifying their names based on 
USDOC records for investigation A-570-943 (Annex E-4), and 
their corresponding shipments values  based on confidential 
company -specific trade data compiled by US Customs (Exhibit 
USA-94 (BCI)).  
OTR Tires   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the tot al value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ).  
  WT/DS471/ARB/Add.1  
 
- 52 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
PET Film   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Ribbons  n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC -wide duty rate 
estimated by subtracting the aggregated value of shipments 
by Chinese exporters outside the PRC -wide entity from the 
total value of US imports from China. The aggregated value of 
shipments by Chinese exporters outside the PRC -wide entity 
estimated by identifying  the name s of all Chinese exporters 
outside  the PRC -wide entity, based on USDOC records for 
investigation A-570-952 (Annex E-3), and their corresponding 
shipments values , based on confidential company -specific 
trade data compiled by US Customs (Exhibit USA -94 (BCI)). 
Share of remaining Chinese expo rters estimated as the 
residual share.  
Shrimp   n/a [[***]]% [[***]]% Share of Chinese exporters subject to PRC -wide duty rate 
estimated by subtracting the aggregated value of shipments 
by Chinese exporters outside the PRC -wide entity from the 
total value of US imports from China. The aggregated value of 
shipments by Chinese exporters outside the PRC -wide entity 
estimated by identifying  the name s of all Chinese exporters 
outside the PRC -wide entity, based on USDOC records for 
investigation A-570-893 (Annex E-3), and their corresponding 
shipments values , based on confidential company -specific 
trade data compiled by US Customs (Exhibit USA -94 (BCI)). 
Share of remaining Chinese exporters estimated as the 
residual share.   
  WT/DS471/ARB/Add.1  
 
- 53 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Solar Panels   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by  subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Cylinders  [[***]]% [[***]]% [[***]]% Share of Chinese exporters subject to PRC -wide duty rate 
estimated by subtracting the aggregated value of shipments 
by Chinese exporters outside the PRC -wide entity from the 
total value of US imports from China. The aggregated value of 
shipments by Chinese  exporters outside the PRC -wide entity 
estimated by identifying  the name s of all Chinese exporters 
outside the PRC -wide entity, based on USDOC records for 
investigation A-570-977 (Annex E-3), and their corresponding 
shipments values , based on confidential company -specific 
trade data compiled by US Customs (Exhibit USA -94 (BCI)). 
Share of Chinese exporters subject to WA -T duty rate 
estimated  by identifying  their name s based on USDOC records 
for investigation A-570-977 (Annex E-4), and their 
corresponding shipments values  based on confidential 
company -specific trade data compiled by US Customs (Exhibit 
USA-94 (BCI)) . Share of remaining Chinese exporters 
estimated by identifying their names based on USDOC records 
for investigation A-570-977 (Annex E-4), and their 
corresponding shipments values  based on confidential 
company -specific trade data compiled by US Customs (Exhibit 
USA-94 (BCI)).  
Wood Flooring   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide en tity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ).  
  WT/DS471/ARB/Add.1  
 
- 54 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Copper Pipe and Tube   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide en tity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Iron Pipe Fittings   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide en tity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Passenger Vehicle and Light Truck Tires   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the shar e of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Residential Washers   n/a [[***]]% [[***]]% Share of Chinese exporters s ubject to PRC -wide duty rate 
estimated by subtracting the aggregated value of shipments 
by Chinese exporters outside the PRC -wide entity from the 
total value of US imports from China. The aggregated value of 
shipments by Chinese exporters outside the PRC -wide entity 
estimated by identifying  the name s of all Chinese exporters 
outside the PRC -wide entity, based on USDOC records for 
investigation A-570-033 (Annex E-3), and their corresponding 
shipments values , based on confidential company -specific 
trade data compiled by US Customs (Exhibit USA -94 (BCI)). 
Share of remaining Chinese exporters estimated as the 
residual share.   
  WT/DS471/ARB/Add.1  
 
- 55 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Sheet and Strip   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the  PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide en tity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Flat Products   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide en tity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Line Pipe  n/a  [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Nails  n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS ag gregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ).  
  WT/DS471/ARB/Add.1  
 
- 56 - Anti-dumping order  Share of 
Chinese 
exporters 
subject to 
WA-T duty 
rate Share of 
Chinese 
exporters 
subject to 
PRC-wide duty 
rate Share of 
remaining 
Chinese 
exporters  Data sources  
Steel Pipe   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS ag gregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Products   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS ag gregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Standard, Line, and Pressure Pipe   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
Steel Wire Rod   n/a [[***]]% [[***]]% Share of remaining Chinese exporters outside the PRC-wide 
entity estimated by the United States based on company -
specific trade data  reported by the exporters. Share of 
Chinese exporters subject to the PRC-wide duty rate estimated 
by the United States by subtracting the share of Chinese 
exporters outside the PRC -wide entity from the total value of 
US imports from China, based on HTS aggregated monthly 
trade data from USITC Dataweb (Exhibit USA -54 (BCI) ). 
 WT/DS471/ARB/Add.1  
 
- 57 - 
 
  ANNEX  E-3 
LIST OF CHINESE EXPO RTERS OUTSIDE THE PRC-WIDE ENTITY USED  TO ESTIMATE THE SHA RE 
OF DIFFERENT CHINESE  EXPORTERS FOR SIX A NTI-DUMPING ORDERS  
Anti-dumping order  Exporter  Producer  Data source  
Diamond Sawblades  Advanced Technology & 
Materials Co., Ltd.   
 
Bosun Tools Group Co., 
Ltd.  
 
Danyang Huachang 
Diamond Tools 
Manufacturing Co., Ltd.  
  
Danyang NYCL Tools 
Manufacturing Co., Ltd.  
 
Danyang Youhe Tool 
Manufacturer Co., Ltd  
 
Fujian Quanzhou 
Wanlong Stone Co., Ltd.  
 
Guilin Tebon Superhard 
Material Co., Ltd.  
 
Hebei Jikai Industrial 
Group Co., Ltd.  
 
Huzhou Gu 's Import & 
Export Co., Ltd.  
 
Huzhou Gu 's Import & 
Export Co., Ltd.  
 
 
Jiangsu Fengtai Diamond 
Tool Manufacture Co., 
Ltd. 
 
Jiangyin Likn Industry 
Co., Ltd.  
 
 
Jiangyin Likn Industry 
Co., Ltd.  
 
Qingdao Shinhan 
Diamond Industrial Co., 
Ltd. 
 
Quanzhou Zhongzhi 
Diamond Tool Co., Ltd.  
 
Rizhao Hein Saw Co., 
Ltd.  
 
Shanghai Deda Industry 
& Trading Co., Ltd.  
 
 Advanced Technology & 
Materials Co., Ltd.  
 
Bosun Tools Group Co. , 
Ltd 
 
Danyang Huachang 
Diamond Tools 
Manufacturing Co., Ltd.  
 
Danyang NYCL Tools 
Manufacturing Co., Ltd.  
 
Danyang Youhe Tool 
Manufacturer Co., Ltd.  
 
Fujian Quanzhou 
Wanlong Stone Co., Ltd.  
 
Guilin Tebon Superhard 
Material Co., Ltd.  
 
Hebei Jikai Industrial 
Group Co., Ltd.  
 
Danyang Aurui Hardware 
Products Co., Ltd.  
 
Danyang Huachang 
Diamond Tools 
Manufacturing Co., Ltd.  
 
Jiangsu Fengtai Diamond 
Tool Manufacture Co., 
Ltd.  
 
Jiangsu Fengtai Diamond 
Tool Manufacture Co., 
Ltd. 
 
Wuhan Wanbang Laser 
Diamond Tools C o. 
 
Qingdao Shinhan 
Diamond Industrial Co., 
Ltd. 
 
Quanzhou Zhongzhi 
Diamond Tool Co., Ltd.  
 
Rizhao Hein Saw Co., 
Ltd.  
 
Hua Da Superabrasive 
Tools Technology Co., 
Ltd. 
 USDOC records for 
investigation A-570-900 
(Exhibit USA -50) WT/DS471/ARB/Add.1  
 
- 58 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Shanghai Robtol Tool 
Manufacturing Co., Ltd.  
 
Shijiazhuang Global New 
Century Tools Co., Ltd.  
 
Sichuan Huili Tools Co.  
 
 
Sichuan Huili Tools Co.  
 
Weihai Xiangguang 
Mechanical Industrial 
Co., Ltd.  
 
Wuhan Wanbang Laser 
Diamond Tools Co.  
 
Xiamen ZL Diamond 
Tools Co., Ltd.  
 
Zhejiang Tea Import & 
Export Co., Ltd.  
 
 
Zhejiang Tea Import & 
Export Co., Ltd.  
 
Zhejiang Tea Import & 
Export Co., Ltd.  
 
Zhejiang Wanli Tools 
Group Co., Ltd.  
 
Zhenjiang Inter –China 
Import & Export Co., 
Ltd.  Shanghai Robtol Tool 
Manufacturing Co., Ltd.  
 
Shijiazhuang Global New 
Century Tools Co., Ltd.  
 
Chengdu Huifeng 
Diamond Tools Co., Ltd.  
 
Sichuan Huili Tools Co.  
 
Weihai Xiangguang 
Mechanical Industrial 
Co., Ltd.  
 
Wuhan Wanbang Laser 
Diamond Tools Co.  
 
Xiamen ZL Diamond 
Tools Co., Ltd.  
 
Danyang Dida Diamond 
Tools Manufacturing Co., 
Ltd. 
 
Danyang Tsunda 
Diamond Tools Co., Ltd.  
 
Wuxi Lianhua Superhard 
Material Tools Co., Ltd.  
 
Zhejiang Wanli Super –
hard Materials Co., Ltd.  
 
Danyang Weiwang Tools 
Manufacturing Co., Ltd.  
 
Furniture  Dongguan Lung Dong 
Furniture Co., Ltd., or 
Dongguan Dong He 
Furniture Co., Ltd (Lung 
Dong)  
 
Rui Feng Woodwork Co., 
Ltd., or Rui Feng Lumber 
Development Co., Ltd. or 
Dorbest Limited 
(Dorbest)  
 
Lacquer Craft Mfg. Co., 
Ltd 
 
Markor  International 
Furniture (Tianjin) 
Manufacturing Company, 
Ltd 
 
Shing Mark Enterprise 
Co., Ltd., or Carven 
Industries Limited (BVI), 
or Carven I Industries 
Limited (HK), or 
Dongguan Zhenxin 
Furniture Co., Ltd., or 
Dongguan Yongpeng 
Furniture Co., Ltd (Shing  
Mark)  n/a 
 
 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
 
 
 
 
 
 
 USDOC records for 
investigation A-570-890 
(Exhibit USA -50) WT/DS471/ARB/Add.1  
 
- 59 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
 
Starcorp Furniture 
(Shanghai) Co., Ltd., or 
Orin Furniture 
(Shanghai) Co., Ltd., or 
Shanghai Starcorp 
Furniture Co., Ltd.  
 
Alexandre International 
Corp., or Southern Art 
Development Ltd., or 
Alexandre Furniture 
(Shenzhen) Co., Ltd., or 
Southern Art Furniture 
Factory  
 
Art Heritage 
International, Ltd., or 
Super Art Furniture Co., 
Ltd., or Artwork Metal & 
Plastic Co., Ltd., or 
Jibson Industries Ltd., or 
Always Loyal 
International  
 
Billy Wood Industrial 
(Dong Guan) Co., Ltd., 
or Great Union Industrial 
(Dongguan) Co., Ltd., or 
Time Faith Ltd  
 
Changshu HTC Import & 
Export Co., Ltd  
 
Cheng Meng Furniture 
(PTE) Ltd., or China 
Cheng Meng Decoration 
& Furniture Co., Ltd  
 
Chuan Fa Furniture 
Factory  
 
Classic Furniture Global 
Co., Ltd  
 
Clearwise Co., L td 
 
COE Ltd  
 
Dalian Guangming 
Furniture Co., Ltd  
 
Dalian Huafeng Furniture 
Co., Ltd  
 
Dongguan Cambridge 
Furniture Co., or Glory 
Oceanic Co., Ltd  
 
Dongguan Chunsan 
Wood Products Co., Ltd  
 
Dongguan Creation 
Furniture Co., Ltd., or 
Creation Industries Co., 
Ltd 
  
 
n/a 
 
 
 
 
 
 
n/a 
 
 
 
 
 
 
 
n/a 
 
 
 
 
 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
n/a 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
 WT/DS471/ARB/Add.1  
 
- 60 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Dongguan Grand Style 
Furniture, or Hong Kong 
Da Zhi Furniture Co., Ltd  
 
Dongguan Great 
Reputation Furniture 
Co., Ltd  
 
Dongguan Hero Way 
Woodwork Co., Ltd., or 
Dongguan Da Zhong 
Woodwork Co., Ltd., or 
Hero Way Enterprises 
Ltd., or Well Earth 
International Ltd  
 
Dongguan Hung Sheng 
Artware Products Co., 
Ltd., or Coronal 
Enterprise Co., Ltd  
 
Dongguan Kin Feng 
Furniture Co., Ltd  
 
Dongguan Kingstone 
Furniture Co., Ltd., or 
Kingstone Furniture Co., 
Ltd 
 
Dongguan 
Liaobushangdun Huada 
Furniture Factory, or 
Great Rich (HK) 
Enterprise Co. Ltd  
 
Dongguan Qingxi Xinyi 
Craft Furniture Factory 
(Joyce Art Factory)  
 
Dongguan Singways 
Furniture Co., Ltd  
 
Dongguan Sunrise 
Furniture Co., or Taicang 
Sunrise Wood Industry 
Co., Ltd., or Shanghai 
Sunri se Furniture Co., 
Ltd., or Fairmont 
Designs  
 
Dongying Huanghekou 
Furniture Industry Co., 
Ltd 
 
Dream Rooms Furniture 
(Shanghai) Co., Ltd  
 
Eurosa (Kunshan) Co., 
Ltd., or Eurosa Furniture 
Co., (PTE) Ltd  
 
Ever Spring Furniture 
Co. Ltd., or S.Y.C. 
Family Enterprise Co., 
Ltd 
 n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
 
 
 
 
 
n/a 
 
 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
 
 
 WT/DS471/ARB/Add.1  
 
- 61 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Fine Furniture 
(Shanghai) Ltd  
 
Foshan Guanqiu 
Furniture Co., Ltd  
 
Fujian Lianfu Forestry 
Co., Ltd., or Fujian 
Wonder Pacific Inc  
 
Gaomi Yatai Wooden 
Ware Co., Ltd., or Team 
Prospect International 
Ltd., or Money Gain 
International Co  
 
Garri Furniture (Dong 
Guan) Co., Ltd., or 
Molabile International, 
Inc., or Weei Geo 
Enterprise Co., Ltd  
 
Green River Wood 
(Dongguan) Ltd  
 
Guangming Group 
Wumahe Furniture Co., 
Ltd 
 
Hainan Jong Bao Lumber 
Co., Ltd., or Jibbon 
Enterprise Co., Ltd  
 
Hamilton & Spill Ltd  
 
Hang Hai Woodcraft’s Art 
Factory  
 
Hualing Furniture 
(China) Co., Ltd., or 
Tony House Manufacture 
(China) Co., Ltd., or 
Buysell Investments 
Ltd., or Tony House 
Industries Co., Ltd  
 
Jardine Enterprise, Ltd  
 
Jiangmen Kinwai 
Furniture Decoration 
Co., Ltd  
 
Jiangmen Kinwai 
International Furniture 
Co., Ltd  
 
Jiangsu Weifu Group 
Fullhouse Furniture 
Manufacturing Corp  
 
Jiangsu Yuexing 
Furniture Group Co., Ltd  
 
Jiedong Lehouse 
Furniture Co., Ltd  
 n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
n/a 
 
 
n/a 
 
 
 
 
 
 
 
n/a 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 WT/DS471/ARB/Add.1  
 
- 62 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
King's Way Furniture 
Industries Co., Ltd., or 
Kingsyear Ltd  
 
Kuan Lin Furniture 
(Dong Guan) Co., Ltd., 
or Kuan Lin Furniture 
Factory, or Kuan Lin 
Furniture Co., Ltd  
 
Kunshan Lee Wood 
Product Co., Ltd  
 
Kunshan Summit 
Furniture Co., Ltd  
 
Langfang Tiancheng 
Furniture Co., Ltd  
Leefu Wood (Dongguan) 
Co., Ltd., or King Rich 
International, Ltd  
 
Link Silver Ltd. (V.I.B.), 
or Forward Win 
Enterprises Co. Ltd., or 
Dongguan Haoshun 
Furniture Ltd  
 
Locke Furniture Factory, 
or Kai Chan Furniture 
Co., Ltd., or Kai Chan 
(Hong Kong) Enterprise 
Ltd., or Taiwan Kai Chan 
Co., Ltd  
 
Longrange Furniture Co., 
Ltd  
 
Nanhai Baiyi Woodwork 
Co., Ltd  
 
Nanhai Jiantai Woodwork 
Co., Ltd  
 
Nantong Dongfang 
Orient Furniture Co., Ltd  
 
Nantong Yushi Furniture 
Co., Ltd  
 
Nathan International 
Ltd., or Nathan Rattan 
Factory  
 
Orient International 
Holding Shanghai 
Foreign Trade Co., Ltd  
 
Passwell Corporation, or 
Pleasant Wave Ltd  
 
Perfect Line Furniture 
Co., Ltd  
 
Prime Wood 
International Co., Ltd., 
or Prime Best n/a 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 WT/DS471/ARB/Add.1  
 
- 63 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Internatio nal Co., Ltd., 
or Prime Best Factory, or 
Liang Huang (Jiaxing) 
Enterprise Co., Ltd  
 
PuTian JingGong 
Furniture Co., Ltd  
 
Qingdao Liangmu Co., 
Ltd  
 
Restonic (Dongguan) 
Furniture Ltd., or 
Restonic Far East 
(Samoa) Ltd  
 
RiZhao SanMu 
Woodworking Co., Ltd  
 
Season Furniture 
Manufacturing Co., or 
Season Industrial 
Development Co  
 
Sen Yeong International 
Co., Ltd., or Sheh Hau 
International Trading Ltd  
 
Shanghai Jian Pu Export 
& Import Co., Ltd  
 
Shanghai Maoji Imp and 
Exp Co., Ltd  
 
Sheng Jing Wood 
Products (Beijing) Co., 
Ltd., or Telstar 
Enterprises Ltd  
 
Shenyang Shining 
Dongxing Furniture Co., 
Ltd  
 
Shenzhen Forest 
Furniture Co., Ltd  
 
Shenzhen Jiafa High 
Grade Furniture Co., 
Ltd., or Golden Li on 
International Trading Ltd  
  
Shenzhen New Fudu 
Furniture Co., Ltd  
 
Shenzhen Wonderful 
Furniture Co., Ltd  
 
Shenzhen Xiande 
Furniture Factory  
 
Shenzhen Xingli 
Furniture Co., Ltd  
 
Shun Feng Furniture Co., 
Ltd  
 n/a 
 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 WT/DS471/ARB/Add.1  
 
- 64 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Songgang Jasonwood 
Furniture Factory, or 
Jasonwood Industrial 
Co., Ltd. S.A  
 
Starwood Furniture 
Manufacturing Co. Ltd  
 
Starwood Industries Ltd  
 
Strongson Furniture 
(Shenzhen) Co., Ltd., or 
Strongson Furniture Co., 
Ltd., or Strongson (HK) 
Co  
 
Sunforce Furniture (Hui -
Yang) Co., Ltd., or Sun 
Fung Wooden Factory, or 
Sun Fung Co., or Shin 
Feng Furniture Co., Ltd., 
or Stupendous 
International Co., Ltd  
 
Superwood Co., Ltd., or 
Lianjin Zongyu Art 
Products Co., Ltd  
Tarzan Furniture 
Industries Ltd., or 
Samso Industries Ltd  
 
Teamway Furniture 
(Dong Guan) Ltd., or 
Brittomart Inc  
 
Techniwood Industries 
Ltd., or Ningbo Furniture 
Industries Limited, or 
Ningb o Hengrun 
Furniture Co., Ltd  
 
Tianjin Fortune Furniture 
Co., Ltd  
 
Tianjin Master Home 
Furniture  
 
Tianjin Phu Shing 
Woodwork Enterprise 
Co., Ltd  
 
Tianjin Sande Fairwood 
Furniture Co., Ltd  
 
Tube-Smith Enterprise 
(ZhangZhou) Co., Ltd., 
or Tube -Smith 
Enterprise (Haimen) Co., 
Ltd., or Billonworth 
Enterprises Ltd  
 
Union Friend 
International Trade Co., 
Ltd  
 n/a 
 
 
 
 
n/a 
 
 
n/a 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
 
 
 
 
n/a 
 
 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
 
 
 
n/a 
 
 
 
 
 WT/DS471/ARB/Add.1  
 
- 65 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
U-Rich Furniture 
(Zhangzhou) Co., Ltd., 
or U-Rich Furniture Ltd  
 
Wanhengtong Nueevder 
(Furniture) Manufacture 
Co., Ltd., or Dongguan 
Wanengtong Industry 
Co., Ltd  
 
Woodworth Wooden 
Industries (Dong Guan) 
Co., Ltd  
 
Xiamen Yongquan Sci -
Tech Development Co., 
Ltd  
 
Jiangsu XiangSheng 
Bedtime Furniture Co., 
Ltd  
 
Xingli Art s & Crafts 
Factory of Yangchun  
 
Yangchun Hengli Co. Ltd  
 
Yeh Brothers World 
Trade, Inc  
 
Yichun Guangming 
Furniture Co., Ltd  
 
Yida Co., Ltd., or Yitai 
Worldwide, Ltd., or Yili 
Co., Ltd., or Yetbuild 
Co., Ltd  
 
Yihua Timber Industry 
Co., Ltd  
 
Zhang Zhou  Sanlong 
Wood Product Co., Ltd  
 
Zhangjiagang Zheng Yan 
Decoration Co., Ltd  
 
Zhangjiagang Daye 
Hotel Furniture Co., Ltd  
 
Zhangzhou Guohui 
Industrial & Trade Co. 
Ltd  
 
Zhanjiang Sunwin Arts & 
Crafts Co., Ltd  
 
Zhong Shan Fullwin 
Furniture Co., Ltd  
 
Zhongshan Fookyik 
Furniture Co., Ltd  
 
Zhongshan Golden King 
Furniture Industrial Co., 
Ltd  
 n/a 
 
 
 
n/a 
 
 
 
 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 WT/DS471/ARB/Add.1  
 
- 66 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Zhoushan For -Strong 
Wood Co., Ltd  
 n/a 
 
Residential Washers  Nanjing LG -Panda 
Appliances Co., Ltd  
 
Suzhou Samsung 
Electronics Co., 
Ltd./Suzhou Samsung 
Electronics Co. Ltd -
Export  
 Nanjing LG -Panda 
Appliances Co., Ltd  
 
Suzhou Samsung 
Electronics Co., 
Ltd./Suzhou Samsung 
Electronics Co. Ltd -
Export  USDOC records for 
investigation A-570-033 
(Exhibit USA -50) 
Ribbons  Yama Ribbons and Bows 
Co., Ltd (Yama)  
 
Beauty Horn Investment 
Limited  
 
Fujian Rongshu Industry 
Co., Ltd  
 
Guangzhou Complacent 
Weaving Co., Ltd  
 
Ningbo MH Industry Co., 
Ltd 
 
 
Ningbo V.K. Industry & 
Trading Co., Ltd  
 
Stribbons (Guangzhou) 
Ltd 
 
Stribbons (Guangzhou) 
Ltd 
 
Sun Rich (Asia) Limite d 
 
 
Tianjin Sun Ribbon Co., 
Ltd 
 
Weifang Dongfang 
Ribbon Weaving Co., 
Ltd. 
 
Weifang Yu Yuan Textile 
Co., Ltd.  
 
Xiamen Yi He Textile 
Co., Ltd  
 
Yangzhou Bestpak Gifts & 
Crafts Co., Ltd (Bestpak)  
 Yama Ribbons and Bows 
Co., Ltd. (Yama)  
 
Tianjin Sun Ribbon Co., 
Ltd 
 
Fujian Rongshu Industry 
Co., Ltd.  
 
Guangzhou Complacent 
Weaving Co., Ltd.  
 
Hangzhou City Linghu 
Jiacheng Silk Ribbon Co., 
Ltd 
 
Ningbo Yinzhou Jinfeng 
Knitting Factory  
 
Stribbons (Guangzhou) 
Ltd 
 
Stribbons (Nanyang) 
MNC Ltd  
 
Dongguan Yi Sheng 
Decoration Co., Ltd  
 
Tianjin Sun Ribbon Co., 
Ltd 
 
Weifang Dongfang 
Ribbon Weaving Co., Ltd  
 
 
Weifang Yu Yuan Textile 
Co., Ltd  
 
Xiamen Yi He Textile 
Co., Ltd  
 
Yangzhou Bestpak Gifts 
& Crafts Co., Ltd  USDOC records for 
investigation A-570-952 
(Exhibit USA -50) 
Shrimp  Allied Pacific Group 
(Allied)  
 
Yelin Entprise Co Hong 
Kong (Yelin)  
 
Shantou Red Garden 
Foodstuff Co., Ltd. (Red 
Garden)  
 n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 USDOC records for 
investigation A-570-893 
(Exhibit USA -50) WT/DS471/ARB/Add.1  
 
- 67 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Zhanjiang Guolian 
Aquatic Products Co., 
Ltd. (Zhanjiang Guolian)  
 
Asian Seafoods 
(Zhanjiang) Co., Ltd.  
 
Beihai Zhengwu Industry 
Co., Ltd.  
 
Chaoyang Qiaofeng 
Group Co., Ltd. 
(Shantou Qiaofeng 
(Group) Co., Ltd.)  
(Shantou/Chaoyang 
Qiaofeng)  
 
Chenghai Nichi Lan Food 
Co., Ltd.  
 
Dalian Ftz Sea -Rich 
International Trading 
Co., Ltd.  
 
Dongri Aquatic Products 
Freezing Plants  
 
Fuqing Dongwei Aquatic 
Products Industry Co.,  
Ltd. 
 
Gallant Ocean 
(Liangjiang) Co., Ltd.  
 
Hainan Fruit Vegetable 
Food Allocation Co., Ltd.  
 
Hainan Golden Spring 
Foods Co., Ltd./Hainan 
Brich Aquatic Products 
Co., Ltd.  
 
Kaifeng Ocean Sky 
Industry Co., Ltd.  
 
Leizhou Zhulian Frozen 
Food Co., Ltd.  
 
Pingyang Xinye Aquatic 
Products Co., Ltd.  
 
Savvy Seafood Inc.  
 
Shanghai Taoen 
International Trading 
Co., Ltd  
 
Shantou Long Feng 
Foodstuffs Co., Ltd. 
(Shantou Longfeng 
Foodstuffs Co., Ltd.)  
 
Shantou Wanya Food 
Factory Co., Ltd.  
 n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
n/a 
 
 
 
n/a 
 
 
 
 
n/a 
 
 
 
 WT/DS471/ARB/Add.1  
 
- 68 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Shantou Jinyuan District 
Mingfeng Quick -Frozen 
Factory  
 
Shantou Ocean Freezing 
Industry and Trade 
General Corporation  
 
Shantou Shengping 
Oceanstar Business Co., 
Ltd. 
 
Shantou Yuexing 
Enterprise Company  
 
Shantou Ruiyuan 
Industry Co., Ltd.  
 
Shantou Freezing 
Aquatic Product Food 
Stuffs Co.  
 
Shantou Jinhang Aquatic 
Industry Co., Ltd.  
 
Xuwen Hailang Breeding 
Co., Ltd.  
 
Yantai Wei -Cheng Food 
Co., Ltd.  
 
Zhangjiang Newpro Food 
Co., Ltd.  
 
Zhangjiang Bobogo 
Ocean Co., Ltd.  
 
Zhanjiang Runhai Foods 
Co., Ltd.  
 
Zhanjiang Go-Harvest 
Aquatic Products Co., 
Ltd. 
 
Zhanjiang Universal 
Seafood Corp.  
 
Zhanjiang Evergreen 
Aquatic Product Science 
and Technology Co., Ltd.  
 
Zhoushan Huading 
Seafood Co., Ltd.  
 
Zhoushan Cereals Oils 
and Foodstuffs Import 
and Export Co., Ltd.  
 
Zhoushan L izhou Fishery 
Co., Ltd. n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
 
n/a 
 
 
 
n/a 
 
Steel Cylinders  Beijing Tianhai Industry 
Co., Ltd . (BTIC)  
 
Beijing Tianhai Industry 
Co., Ltd . (BTIC) 
 
 Beijing Tianhai Industry 
Co., Ltd.  
 
Tianjin Tianhai High 
Pressure Container Co., 
Ltd. 
 USDOC records for 
investigation A-570-977 
(Exhibit USA -50) WT/DS471/ARB/Add.1  
 
- 69 - 
 
  Anti-dumping order  Exporter  Producer  Data source  
Beijing Tianhai Industry 
Co., Ltd . (BTIC ) 
 
 
Shanghai J.S.X. 
International Trading 
Corporation (J.S.X) 
 
Zhejiang Jindun Pressure 
Vessel Co., Ltd. (Jindun)  
 
Shijiazhuang Enric Gas 
Equipment Co., Ltd. 
(Enric)  
 Langfang Tianhai High 
Pressure Container Co., 
Ltd. 
 
Shanghai High Pressure 
Special Gas Cylinder Co., 
Ltd. 
 
Zhejiang Jindun Pressure 
Vessel Co., Ltd.  
 
Shijiazhuang Enric Gas 
Equipment Co., Ltd.  
 
 
 WT/DS471/ARB/Add.1  
 
- 70 - 
 
  ANNEX  E-4 
LIST OF CHINESE EXPO RTERS SUBJECT TO THE  WA-T DUTY RATES AND  OTHER CHINESE 
EXPORTERS OUTSIDE TH E PRC -WIDE ENTITY US ED TO ESTIMATE THE S HARE OF DIFFERENT 
CHINESE EXPORTERS FOR THREE ANTI -DUMPING O RDERS  
Anti-
Dumping 
order  Exporter  Producer  Data source  
    
    
Coated Paper  Exporters subject the WA -T duty rate  USDOC 
records for 
investigation 
A-570-958  APP-China covering:  
 Gold East Paper (Jiangsu) Co., Ltd.  Gold East Paper (Jiangsu) Co., Ltd.  
 Gold Huasheng Paper Co., Ltd.  Gold Huasheng Paper Co., Ltd.   
 Ningbo Zhonghua Paper Co., Ltd.  Ningbo Asia Pulp and Paper Co., Ltd.   
 Gold East (Hong Kong) Trading Co., 
Ltd. n/a  
 Shandong Chenming Paper 
Holdings Ltd . Shandong Chenming Paper 
Holdings Ltd.   
 
Remaining exporters outside the PRC -wide entity   
 n/a n/a  
OCTG  Exporters  subject the WA -T duty rate  USDOC 
records for 
investigation 
A-570-943  Tianjin Pipe International Economic 
and Trading Corp. (TPCO)  Tianjin Pipe (Group) Corporation 
(TPCO)  
 Angang Group Hong Kong Co., Ltd.  Angang Steel Co. Ltd.  
 Angang Steel Co., Ltd., and 
Angang Group International Trade 
Corporation  Angang Steel Co. Ltd.  
 Anhui Tianda Oil Pipe Co., Ltd.  Anhui Tianda Oil Pipe Co., Ltd.   
 Anshan Zhongyou Tipo Pipe & 
Tubing Co., Ltd.  Anshan Zhongyou Tipo Pipe & 
Tubing Co., Ltd.   
 Baotou Steel International 
Economic and Trading Co., Ltd.  Seamless Tube Mill of Inner 
Mongolia Baotou Steel  Union Co., 
Ltd.  
 Benxi Northern Steel Pipes Co., 
Ltd. Benxi Northern Steel Pipes Co., Ltd.   
 Chengdu Wanghui Petroleum Pipe 
Co. Ltd.  Chengdu Wanghui Petroleum Pipe 
Co. Ltd.   
 Dalipal Pipe Company  Dalipal Pipe Company   WT/DS471/ARB/Add.1  
 
- 71 - 
 
  Anti-
Dumping 
order  Exporter  Producer  Data source  
    
    
 Faray Petroleum Steel Pipe Co. Ltd.  Faray Petroleum Steel Pipe Co. Ltd.   
 Freet Petroleum Equipment Co., 
Ltd. of Shengli Oil Field, The 
Thermal Recovery Equipment, Zibo 
Branch  Freet Petroleum Equipment Co., 
Ltd. of Shengli Oil Field, The 
Thermal Recovery Equipment, Zibo 
Branch   
 Hengyang Steel Tube Group 
International Trading, Inc.  Hengyang Valin MPM Tube Co., 
Ltd.; Hengyang Valin Steel Tube 
Co., Ltd.   
 Huludao Steel Pipe Industrial Co., 
Ltd./Huludao City Steel Pipe 
Industrial Co., Ltd.  Huludao Steel Pipe Industrial Co., 
Ltd./Huludao City Steel Pipe 
Industrial Co., Ltd.   
 Jiangyin City Changjiang Steel Pipe 
Co., Ltd.  Jiangyin City Changjiang Steel Pipe 
Co., Ltd.   
 Pangang Group Beihai Steel Pipe 
Corporation  Pangang Group Beihai Steel Pipe 
Corporation   
 Pangang Group Chengdu Iron & 
Steel Pangang Group Chengdu Iron & 
Steel  
 Qingdao Bonded Logistics Park 
Products International Trading Co., 
Ltd. Shengli Oilfield Highland Petroleum 
Equipment Co., Ltd.; Shandong 
Continental Petroleum Equipment 
Co., Ltd.; Aofei Tele Dongying 
Import & Export Co., Ltd.; 
Highgrade Tubular Manufacturing 
(Tianjin) Co., Ltd.; Cangzhou City 
Baohai Petroleum Material Co., Ltd.   
 Qiqihaer Haoying Iron and Steel 
Co., Ltd. of Northeast Special Steel 
Group  Qiqihae r Haoying Iron and Steel 
Co., Ltd. of Northeast Special Steel 
Group   
 Shandong Dongbao Steel Pipe Co., 
Ltd. ShanDong HuaBao Steel Pipe Co., 
Ltd.  
 ShanDong HuaBao Steel Pipe Co., 
Ltd. ShanDong HuaBao Steel Pipe Co., 
Ltd.  
 Shandong Molong Petroleum 
Machinery Co., Ltd.  Shandong Molong Petroleum 
Machinery Co., Ltd.   
 Shanghai Metals & Minerals Import 
& Export Corp. / Shanghai 
Minmetals Materials & Products 
Corp.  Jiangsu Changbao Steel Pipe Co., 
Ltd.; Huludao Steel Pipe Industrial 
Co., Ltd.; Northeast Special Steel 
Group Qiqihaer Haoying Steel and 
Iron Co., Ltd.; Beijing Youlu Co., 
Ltd.  
 Shanghai Zhongyou Tipo Steel Pipe 
Co., Ltd.  Freet Petroleum Equipment Co., 
Ltd. of Shengli Oil Field, The 
Thermal Recovery Equipment, Zibo 
Branch; Faray Petroleum Steel Pipe 
Co., Ltd.; Shengli Oil Field Freet 
Petroleum Steel Pipe Co., Ltd.   WT/DS471/ARB/Add.1  
 
- 72 - 
 
  Anti-
Dumping 
order  Exporter  Producer  Data source  
    
    
 Shengli Oil Field Freet Petroleum 
Steel Pipe Co., Ltd.  Freet Petroleum Equipment Co., 
Ltd. of Shengli Oil Field, The 
Thermal Recovery Equipment, Zibo 
Branch; An hui Tianda Oil Pipe Co., 
Ltd; Wuxi Fastube Dingyuan 
Precision Steel Pipe Co., Ltd.   
 Shengli Oilfield Highland Petroleum 
Equipment Co., Ltd.  Tianjin Pipe Group Corp.; Goods & 
Materials Supply Dept. of Shengli 
Oilfield SinoPEC; Dagang Oilfield 
Group New Century Machinery Co. 
Ltd.;Tianjin Seamless Steel Pipe 
Plant; Baoshan Iron & Steel Co. 
Ltd.  
 Shengli Oilfield Shengji Petroleum 
Equipment Co., Ltd.  Shengli Oilfield Shengji Petroleum 
Equipment Co., Ltd.   
 Tianjin Xingyuda Import and 
Export Co., Ltd. & H ong Kong 
Gallant Group Limited  Tianjin Lifengyuanda Steel Group 
Co., Ltd.   
 Tianjin Seamless Steel Pipe Plant  Tianjin Seamless Steel Pipe Plant   
 Tianjin Tiangang Special Petroleum 
Pipe Manufacturer Co., Ltd.  Tianjin Tiangang Special Petroleum 
Pipe Manufacturer Co., Ltd.   
 Wuxi Baoda Petroleum Special Pipe 
Manufacturing Co., Ltd.  Wuxi Baoda Petroleum Special Pipe 
Manufacturing Co., Ltd.   
 Wuxi Seamless Oil Pipe Co., Ltd.  Wuxi Seamless Oil Pipe Co., Ltd.   
 Wuxi Sp. Steel Tube Manufacturing 
Co., Ltd.  Wuxi Precese Special Steel Co., Ltd.   
 Wuxi Zhenda Special Steel Tube 
Manufacturing Co., Ltd.  Huai'an Zhenda Steel Tube 
Manufacturing Co., Ltd.   
 Xigang Seamless Steel Tube Co., 
Ltd. Xigang Seamless Steel Tube Co., 
Ltd.; Wuxi Seamless Special Pipe 
Co., Ltd.   
 Yangzhou Lontrin Steel Tube Co., 
Ltd. Yangzhou Lontrin Steel Tube Co., 
Ltd.  
 Zhejiang Jianli Co., Ltd. & Zhejiang 
Jianli Steel Tube Co., Ltd.  Zhejiang Jianli Co., Ltd.; Zhejiang 
Jianli Steel Tube Co., Ltd.   
 
Remaining exporters outside the PRC -wide entity   
 Chengde Group covering:   
 (i) Jiangsu Chengde Steel Tube 
Share Co., Ltd.;  n/a  
 (ii) Taizhou Chengde Steel Tube 
Co., Ltd.; and  n/a  
 (iii) Yangzhou Chengde Steel Tube 
Co., Ltd.  n/a  WT/DS471/ARB/Add.1  
 
- 73 - 
 
  Anti-
Dumping 
order  Exporter  Producer  Data source  
    
    
Steel 
Cylinders  Exporters subject the WA -T duty rate  USDOC 
records for 
investigation 
A-570-977  Shanghai J.S.X. International 
Trading Corporation  Shanghai High Pressure Special Gas 
Cylinder Co., Ltd.  
 Zhejiang Jindun Pressure Vessel 
Co., Ltd.  Zhejiang Jindun Pressure Vessel 
Co., Ltd.  
 Shijiazhuang Enric Gas Equipment 
Co., Ltd. (Enric)  Shijiazhuang Enric Gas Equipment 
Co., Ltd.   
 
Remaining exporters outside the PRC -wide entity   
 Beijing Tianhai Industry Co., Ltd. 
(BTIC)  Beijing Tianhai Industry Co., Ltd. 
(BTIC)   
 Beijing Tianhai Industry Co., Ltd. 
(BTIC)  Tianjin Tianhai High Pressure 
Container Co., Ltd.   
 Beijing Tianhai Industry Co., Ltd. 
(BTIC)  Langfang Tianhai High Pressure 
Container Co., Ltd.   
 
  
  WT/DS471/ARB/Add.1  
 
- 74 - ANNEX  E-5 
DATA INPUTS FOR ELASTICIT IES1 
Anti-dumping order  Total 
demand 
elasticity  Domestic 
supply 
elasticity  Elasticity of 
substitution  Data sources  
Aluminum Extrusions  -0.375  4.000  5.000  Midpoint values from USITC publication 4677  (Exhibit 
USA-16). 
Bags -0.450  3.000  5.000  Midpoint values from USITC publication 4605  (Exhibit 
USA-16). 
Coated Paper  -1.000  4.000  3.000  Midpoint values from USITC publication 4656 (Exhibit 
USA-16). 
Diamond Sawblades  -0.750  5.000  3.000  Midpoint values from USITC publication 4559 (Exhibit 
USA-16). 
Furniture  -0.750  4.500  4.500  Midpoint values from USITC publication 4665  (Exhibit 
USA-16). 
OCTG  -0.875  3.000  4.000  Midpoint values from USITC publication 4124  (Exhibit 
USA-16). 
OTR Tires  -0.250  7.500  4.000  Midpoint values from USITC publication 4031  (Exhibit 
USA-16). 
PET Film  -0.750  3.500  4.500  Midpoint values from USITC publication 4512  (Exhibit 
USA-16). 
Ribbons  -1.250  5.000  4.000  Midpoint values from USITC publication 4634  (Exhibit 
USA-16). 
Shrimp  -2.000  3.500  4.000  Midpoint values from USITC publication 4688  (Exhibit 
USA-16). 
Solar Panels  -0.875  6.000  4.000  Midpoint values from USITC publication 4360  (Exhibit 
USA-16). 
Steel Cylinders  -0.500  7.500  4.000  Midpoint values from USITC publication 4328  (Exhibit 
USA-16). 
                                                
1 As discussed in paragraph 7.37 of the Decision, the  supply elasticity for (i) US imports from the Chinese exporters subject to the WTO -inconsistent PRC -wide 
duty rates, (ii) US imports from the remaining Chinese exporters, and (iii) US imports from the re st of the world  are all set to 10 for all of the anti -dumping orders at 
issue.   
  WT/DS471/ARB/Add.1  
 
- 75 - Anti-dumping order  Total 
demand 
elasticity  Domestic 
supply 
elasticity  Elasticity of 
substitution  Data sources  
Wood Flooring  -1.000  5.500  4.000  Midpoint values from USITC publication 4746  (Exhibit 
USA-16). 
Copper Pipe and Tube  -0.875  2.000  4.000  Midpoint values from USITC publication 4650  (Exhibit 
USA-16). 
Iron Pipe Fittings  -1.250  4.500  4.500  Midpoint values from USITC publication 3586  (Exhibit 
USA-16). 
Passenger Vehicle and Light Truck 
Tires -0.375  3.000  4.000  Midpoint values from USITC publication 4545  (Exhibit 
USA-16). 
Residential Washers  -0.550  7.000  4.000  Midpoint values from USITC publication 4666  (Exhibit 
USA-16). 
Sheet and Strip  -0.750  5.000  4.000  Midpoint values from USITC publication 4676  (Exhibit 
USA-16). 
Steel Flat Products  -0.500  6.000  4.000  Midpoint values from USITC publication 4619  (Exhibit 
USA-16). 
Steel Line Pipe  -0.375  4.000  3.000  Midpoint values from USITC publication 4055  (Exhibit 
USA-16). 
Steel Nails  -0.375  4.000  4.000  Midpoint values from USITC publication 4022  (Exhibit 
USA-16). 
Steel Pipe  -0.625  4.000  5.000  Midpoint values from USITC publication 4019  (Exhibit 
USA-16). 
Steel Products  -0.750  6.000  4.000  Midpoint values from USITC publication 4620  (Exhibit 
USA-16). 
Steel Standard, Line, and Pressure 
Pipe -0.750  7.500  3.000  Midpoint values from USITC publication 4190  (Exhibit 
USA-16). 
Steel Wire Rod  -0.625  2.000  4.000  Midpoint values from USITC publication 4509  (Exhibit 
USA-16). 
 
  
  WT/DS471/ARB/Add.1  
 
- 76 - ANNEX  E-6 
DATA INPUTS FOR THE ACTUAL ANTI -DUMP ING DUTY RATES  
Product  WA-T duty 
rate PRC-wide 
duty rate  Duty rate 
for 
remaining 
exporters  Data sources  
Aluminum Extrusions  n/a 85.96%  [[***]]% PRC-wide duty rate obtained from USDOC records for 
investigation A-570-967 (Annex E-7). Duty rate for 
remaining exporters outside the PRC -wide entity estimated 
as a simple average based on USDOC records for 
investigation A-570-967 (Annex E-7). 
Bags n/a 77.57%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-886 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-886 (Exhibit USA -92 (BCI)).  
Coated Paper  7.62%  135.8%  [[***]]% WA-T duty rate provided by the United States based on 
USDOC records for investigation A-570-958 (United States' 
written submission, para.  104). PRC -wide duty rate provided 
by the United  States based on USDOC records for 
investigation A-570-958 (Exhibits US A-77 (BCI) and USA -92 
(BCI)) . Duty rate for remaining exporters outside the PRC -
wide entity estimated as a simple average based on USDOC 
records for investigation A-570-958 (Exhibit USA -92 (BCI)).  
Diamond Sawblades  n/a 82.05%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-900 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-900 (Exhibit USA -92 (BCI)).   
  WT/DS471/ARB/Add.1  
 
- 77 - Product  WA-T duty 
rate PRC-wide 
duty rate  Duty rate 
for 
remaining 
exporters  Data sources  
Furniture  n/a 216%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-890 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-890 (Exhibit USA -92 (BCI)).  
OCTG  32.07%  99.14%  [[***]]% WA-T duty rate provided by the United States based on 
USDOC records for investigation A -570-943 (United States' 
written submission, para. 108; and Exhibit USA -14). PRC -
wide duty rate provided by the United States based on 
USDOC records for investigation A-570-943 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated as a simple 
average based on USDOC records for investigation A-570-
943 (Exhibit USA -92 (BCI)).  
OTR Tires  n/a 105.3%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-912 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-912 (Exhibit USA -92 (BCI)).  
PET Film  n/a 76.72%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-924 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-924 (Exhibit USA -92 (BCI)).  
Ribbons  n/a 247.3%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-952 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-952 (Exhibit USA -92 (BCI)).   
  WT/DS471/ARB/Add.1  
 
- 78 - Product  WA-T duty 
rate PRC-wide 
duty rate  Duty rate 
for 
remaining 
exporters  Data sources  
Shrimp  n/a 112.8%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-893 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-893 (Exhibit USA -92 (BCI)).  
Solar Panels  n/a 239%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-979 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-979 (Exhibit USA -92 (BCI)).  
Steel Cylinders  6.62%  31.21%  [[***]]% WA-T duty rate provided by the United States based on 
USDOC records for investigation A -570-977 (United States' 
response to Arbitrator question No. 7, para. 33; and Exhibit 
USA-50). PRC -wide duty rate provided by the United States 
based on USDOC records for investigation A-570-977 
(Exhibits USA -77 (BCI) and USA -92 (BCI)) . Duty rate for 
remaining exporters outside the PRC -wide entity estimated 
as a simple average based on USDOC records for 
investigation A-570-977 (Exhibit USA -92 (BCI)).  
Wood Flooring  n/a 25.62%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-970 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-970 (Exhibit USA -92 (BCI)).  
Copper Pipe and Tube  n/a 60.85%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-964 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-964 (Exhibit USA -92 (BCI)).   
  WT/DS471/ARB/Add.1  
 
- 79 - Product  WA-T duty 
rate PRC-wide 
duty rate  Duty rate 
for 
remaining 
exporters  Data sources  
Iron Pipe Fittings  n/a 75.5%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-875 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-875 (Exhibit USA -92 (BCI)).  
Passenger Vehicle and Light Truck Tires  n/a 76.46%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-016 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple avera ge based on USDOC records 
for investigation A-570-016 (Exhibit USA -92 (BCI)).  
Residential Washers  n/a 49.72%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-033 (Exhibits USA -
77 (BCI) and USA -92 (BC I)). Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-033 (Exhibit USA -92 (BCI)).  
Sheet and Strip  n/a 76.64%  [[***]]% PRC-wide duty rate obtained from USDOC records for 
investigation A-570-042 (Annex E-7). Duty rate for 
remaining exporters outside the PRC -wide entity estimated 
as a simple average based on USDOC records for 
investigation A-570-042 (Annex E-7). 
Steel Flat Products  n/a 199.8%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-029 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-029 (Exhibit USA -92 (BCI)).  
Steel Line Pipe  n/a 101.1%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-935 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-935 (Exhibit USA -92 (BCI)).   
  WT/DS471/ARB/Add.1  
 
- 80 - Product  WA-T duty 
rate PRC-wide 
duty rate  Duty rate 
for 
remaining 
exporters  Data sources  
Steel Nails  n/a 118%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-909 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-909 (Exhibit USA -92 (BCI)).  
Steel Pipe  n/a 85.55%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-910 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-910 (Exhibit USA -92 (BCI)).  
Steel Products  n/a 199.4%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-026 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty  rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-026 (Exhibit USA -92 (BCI)).  
Steel Standard, Line, and Pressure Pipe  n/a 98.74%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-956 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average b ased on USDOC records 
for investigation A-570-956 (Exhibit USA -92 (BCI)).  
Steel Wire Rod  n/a 97.24%  [[***]]% PRC-wide duty rate provided by the United States based on 
USDOC records for investigation A-570-012 (Exhibits USA -
77 (BCI) and USA -92 (BCI)) . Duty  rate for remaining 
exporters outside the PRC -wide entity estimated by the 
United States as a simple average based on USDOC records 
for investigation A-570-012 (Exhibit USA -92 (BCI)).  
 
  
  WT/DS471/ARB/Add.1  
 
- 81 - ANNEX  E-7 
LIST OF ANTI -DUMPING  DUTY RATES USED FOR  TWO ANTI -DUMPING OR DERS  
Anti-dumping order  Exporter   Producer  Duty rate  Data source  
Aluminium Extrusions  United States Square Industrial Limited  Zhaoqing United States Square Industry Limited  32.79 % USDOC records for 
investigation A -570-
967 North United States Aluminum Co., Ltd  North United States Aluminum Co., Ltd  32.79 % 
PanAsia Aluminium (United States) Limited  PanAsia Aluminium (United States) Limited  32.79 % 
Pingguo United States Aluminum Co., Ltd  Pingguo United States Aluminum Co., Ltd  32.79 % 
Skyline Exhibit Systems (Shanghai) Co., 
Ltd n/a 32.79 % 
Gold Mountain International Development 
Limited  n/a 32.79 % 
Shenzhen Jiuyuan Co., Ltd  n/a 32.79 % 
Dynamic Technologies China Ltd  n/a 32.79 % 
Zhejiang Xinlong Industry Co., Ltd  n/a 32.79 % 
Changzhou Tenglong Auto Parts Co., Ltd  n/a 32.79 % 
Xin Wei Aluminum Company Limited  n/a 32.79 % 
Classic & Contemporary Inc  n/a 22.28 % 
Dynabright Int'l Group (HK) Limited  n/a 22.28 % 
Hanyung Metal (Suzhou) Co., Ltd  n/a 22.28 % 
Global Point Technology (Far East) Limited  n/a 22.28 % 
Jiangsu Changfa Refrigeration Co., Ltd  n/a 27.22 % 
Jiaxing Jackson Travel Products Co., Ltd  n/a 27.22 %  
  WT/DS471/ARB/Add.1  
 
- 82 - Anti-dumping order  Exporter   Producer  Duty rate  Data source  
Midea International Trading Co., Ltd  n/a 27.22 % 
Shanghai Tongtai Precise Aluminum Alloy  n/a 27.22 % 
Sincere Profit Limited  n/a 27.22 % 
Guang Ya Aluminium Industries Co., Ltd.; 
Foshan Guangcheng Aluminium Co., Ltd.; 
Kong Ah International Company Limited; 
Guang Ya Aluminium Industries (Hong 
Kong) Limited; Zhaoqing New Zhongya 
Aluminum Co., Ltd.; Zhongya Shaped 
Aluminium (HK) Holding Limited; Karlton 
Aluminum Company Ltd  Guang Ya Aluminiu m Industries Co., Ltd.; Foshan 
Guangcheng Aluminium Co., Ltd.; Kong Ah 
International Company Limited; Guang Ya 
Aluminium Industries (Hong Kong) Limited; 
Zhaoqing New Zhongya Aluminum Co., Ltd.; 
Zhongya Shaped Aluminium (HK) Holding 
Limited; Karlton Aluminu m Company Ltd.; Xinya 
Aluminum & Stainless Steel Product Co., Ltd. 
(A.K.A. New Asia Aluminum & Stainless Steel 
Product Co., Ltd.)  33.02 % 
Alnan Aluminium Co., Ltd  Alnan Aluminium Co., Ltd  0.00% 
Changshu Changsheng Aluminium Products 
Co., Ltd  Changshu Changsheng Aluminium Products Co., 
Ltd 0.00% 
China Square Industrial Limited  China Square Industrial Limited  0.00% 
Cosco (J.M.) Aluminium Co., Ltd  Cosco (J.M.) Aluminium Co., Ltd  0.00% 
First Union Property Limited  First Union Property Limited  0.00% 
Foshan Jinlan Non -ferrous Metal Product 
Co. Ltd  Foshan Jinlan Non -ferrous Metal Product Co. Ltd  0.00% 
Foshan Sanshui Fenglu Aluminium Co., Ltd  Foshan Sanshui Fenglu Aluminium Co., Ltd  0.00% 
Guangdong Hao Mei Aluminium Co., Ltd  Guangdong Hao Mei Aluminium Co., Ltd  0.00% 
Guangdong Weiye Aluminium Factory Co., 
Ltd Guangdong Weiye Aluminium Factory Co., Ltd  0.00% 
Guangdong Xingfa Aluminium Co., Ltd  Guangdong Xingfa Aluminium Co., Ltd  0.00% 
Hanwood Enterprises Limited  Hanwood Enterprises Limited  0.00% 
Honsense Development Company  Honsense Development Company  0.00%  
  WT/DS471/ARB/Add.1  
 
- 83 - Anti-dumping order  Exporter   Producer  Duty rate  Data source  
Innovative Aluminium (Hong Kong) Limited  Innovative Aluminium (Hong Kong) Limited  0.00% 
Jiangyin Trust International Inc  Jiangyin Trust International Inc  0.00% 
Longkou Donghai Trade Co., Ltd  Longkou Donghai Trade Co., Ltd  0.00% 
Ningbo Yili Import and Export Co., Ltd  Ningbo Yili Import and Export Co., Ltd  0.00% 
North China Aluminum Co., Ltd  North China Aluminum Co., Ltd  0.00% 
PanAsia Aluminium (China) Limited  PanAsia Aluminium (China) Limited  0.00% 
Pingguo Asia Aluminum Co., Ltd  Pingguo Asia Aluminum Co., Ltd  0.00% 
Popular Plastics Co., Ltd  Popular Plastics Co., Ltd  0.00% 
Press Metal International Ltd  Press Metal International Ltd  0.00% 
Shenyang Yuanda Aluminium Industry 
Engineering Co. Ltd  Shenyang Yuanda Aluminium Industry 
Engineering Co. Ltd  0.00% 
Tai-Ao Aluminium (Taishan) Co., Ltd  Tai-Ao Aluminium (Taishan) Co., Ltd  0.00% 
Tianjin Ruixin Electric Heat Transmission 
Technology Co., Ltd  Tianjin Ruixin Electric Heat Transmission 
Technology Co., Ltd  0.00% 
USA Worldwide Door Components (Pinghu) 
Co., Ltd.; Worldwide Door Components 
(Pinghu) Co  USA Worldwide Door Components (Pinghu) Co., 
Ltd.; Worldwide Door Components (Pinghu) Co  0.00% 
Zhejiang Yongkang Listar Aluminium 
Industry Co., Ltd  Zhejiang Yongkang Listar Aluminium Industry 
Co., Ltd  0.00% 
Zhongshan Gold Mountain Aluminium 
Factory Ltd  Zhongshan Gold Mountain Aluminium Factory Ltd  0.00% 
Justhere Co., Ltd  n/a 85.73 % 
Kromet International Inc  n/a 85.66 % 
Permasteelisa Hong Kong Ltd  30 n/a 85.73 % 
Union Industry (Asia) Co., Ltd  n/a 85.73 %  
  WT/DS471/ARB/Add.1  
 
- 84 - Anti-dumping order  Exporter   Producer  Duty rate  Data source  
Allied Maker Limited  n/a 85.94 % 
Birchwoods (Lin'an) Leisure Products Co., 
Ltd n/a 85.94 % 
Changzhou Changzheng Evaporator Co., 
Ltd n/a 85.94 % 
Dongguan Aoda Aluminum Co., Ltd  n/a 85.94 % 
JMA (HK) Company Limited  n/a 85.94 % 
Kam Kiu Aluminium Products Sdn Bhd  n/a 85.94 % 
Metaltek Group Co., Ltd  n/a 85.94 % 
Tianjin Jinmao Import & Export Corp., Ltd  n/a 85.94 % 
tenKsolar (Shanghai) Co., Ltd  n/a 85.96 % 
PRC-wide entity  n/a 85.96 % 
Sheet and Strip  Taiyuan Ridetaixing Precision Stainless 
Steel Incorporated Co., Ltd  Taiyuan Ridetaixing Precision Stainless Steel 
Incorporated Co., Ltd  45.26 %  
Zhangjiagang Pohang Stainless Steel Co., 
Ltd Zhangjiagang Pohang Stainless Steel Co., Ltd  45.26 % 
PRC-Wide Entity  PRC-Wide Entity  58.04 % 
 
 
 
  
  WT/DS471/ARB/Add.1  
 
- 85 - ANNEX  E-8 
DATA INPUTS FOR US MARKET VALUES  IN 2017  
Anti-dumping order  Total US 
market  
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)1 Data sources  
Aluminum Extrusions  [[***]] 5,537,962  [[***]] 1,077,900  Value of US shipments estimated  by applying annual growth 
rates to the 2015 value of US shipments reported in USITC 
publication 4677.2 Data on the value of US imports from China 
from US Customs ( Exhibit USA -21 (BCI) ). Data on the value of 
US imports from the rest of the world based on HTS aggregated 
data from the US Census Bureau  (United States'  response to 
Arbitrator question No. 62 , para. 73) . 
Bags [[***]] 1,120,838  [[***]] 280,300  Value of US shipments provided by the United States based on 
data from USITC publication 4605 (Exhibit USA -58). Data on the 
value of US imports from China from US Customs (Exhibit USA -
30 (BCI) ). Value of US imports from the rest of the world based 
on HTS aggregated data from the US Census Bureau (Exhibit 
USA-57). 
Coated Paper  [[***]] 1,125,000  [[***]] 1,554,800  Value of US shipments provided by the United States based on 
data from US ITC publicatio n 4656 (Exhibit USA -58). Data on the 
value of US imports from China from US Customs (Exhibit USA -
30 (BCI) ). Value of US imports from the rest of the world based 
on HTS aggregated data from the US Census Bureau (Exhibit 
USA-57). 
                                                
1 The value of 2017 US imports from the rest of the world is derived by subtracting the value of US imports from China from the  total value of US imports from 
the world, both re ported in Exhibit USA -57. 
2 For Aluminum Extrusions,  the United States contends that the 2017 value of US shipments is USD 5.8 billion. (United  States' response to Arbitrator question 
No. 62, para. 65). However, we note that the USITC reports the 2015 valu e of US shipments to be USD 5.28 billion and that the United States proposes to use a 
2015-2016 growth rate of 1.8 % and a 2016-2017 growth rate of 3.1 %. Using these figures, we estimate the 2017 value of US shipments to be USD 5,537,962,000.   
  WT/DS471/ARB/Add.1  
 
- 86 - Anti-dumping order  Total US 
market  
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)1 Data sources  
Diamond Sawblades  [[***]] 79,745  [[***]] 213,500  Value of US shipments estimated by  the United States by 
applying a growth rate to the 2014  value of  US shipments 
reported in USITC publication 4559  (Exhibit USA -58). Data on 
the value of US imports from China from US Customs (Exhibit  
USA-30 (BCI) ). Value of US imports from the rest of the world 
based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Furniture  [[***]] 700,000  [[***]] 1,991,300  Value of US shipments estimated  by the United States by 
applying estimated growth rate s to the 2015 value of US 
shipments reported in USITC publication 4665 (Exhibit USA -58). 
Data on the value of US imports from China from US Customs 
(Exhibit USA -30 (BCI) ). Value of US imports from the rest of the 
world based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
OCTG  [[***]] 4,000,000  [[***]] 2,913,200  Value of US shipments estimated by the United States by 
multiplying the average US price by the corresponding estimated 
US production  quantity based on data from Preston Pipe and 
Tube (Exhibit USA -58). Data on the value of US imports from 
China from US Customs (Exhibit USA -30 (BCI) ). Value of US 
imports from the rest of the world based on HTS aggreg ated 
data from the US Census Bureau (Exhibit USA -57). 
OTR Tires  [[***]] 915,650  [[***]] 9,100  Value of US shipments provided  by the United States based on 
data from USITC publication 4448 (Exhibit USA -58). Data on the 
value of US imports from China from US Customs (Exhibit USA -
30 (BCI) ). Value of US imports from the rest of the world based 
on HTS aggregated data from the US Census Bureau (Exhibit 
USA-57). 
PET Film  [[***]] 766,472  [[***]] 588,200  Value of US shipments provided by the United States ba sed on 
data from USITC publication 4605 (Exhibit USA -58). Data on the 
value of US imports from China from US Customs (Exhibit USA -
30 (BCI) ). Value of US imports from the rest of the world based 
on HTS aggregated data from the US Census Bureau (Exhibit 
USA-57).  
  WT/DS471/ARB/Add.1  
 
- 87 - Anti-dumping order  Total US 
market  
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)1 Data sources  
Ribbons  [[***]] 510,208  [[***]] 31,500  Value of US shipments estimated by the United States by 
applying a  growth  rate to the data published in the US Census 
Bureau's 2016 Annual Survey of Manufactures (Exhibit USA -58). 
Data on the value of US imports from China from US Customs 
(Exhibit USA -30 (BCI) ). Value of US imports from the rest of the 
world based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Shrimp  [[***]] 494,000  [[***]] 5,959,500  Value of US shipments provided  by the United States based on 
data from the 2016 Fisheries of the United  States Report of the 
National Oceanic and Atmospheric Administration (Exhibit USA -
58). Data on the value of US imports from China from US 
Customs (Exhibi t USA -30 (BCI) ). Value of US imports from the 
rest of the world based on HTS aggregated data from the US 
Census Bureau (Exhibit USA -57). 
Solar Panels  [[***]] 325,920  [[***]] 5,652,300  Value of US shipments estimated  by the United States by 
multiplying  the average price reported by the  US Department of 
Energy by the production quantity reported by the  International 
Energy Agency (Exhibit USA -58). Data on the value of US 
imports from China from US Customs (Exhibit USA -30 (BCI)). 
Value of US imports from the rest of the world based on HTS 
aggregated data from the US Census Bureau (Exhibit USA -57). 
Steel Cylinders  [[***]] 64,000  [[***]] 5,200  Value of US shipments estimated by the United States based on 
TriMas Corp oration 's 2017 annual report (Exhibit USA -58). Data 
on the value of US imports from China from US Customs (Exhibit 
USA-30 (BCI) ). Value of US imports from the rest of the world 
based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Wood Flooring  [[***]] 490,000  [[***]] 614,600  Value of US shipments estimated by  the United States by  
applying a growth rate to the 2016 value of US shipments 
reported in USITC publication 4665 (Exhibit USA -58). Data on 
the value of US imports from China from US Customs (Exhibit 
USA-30 (BCI) ). Value of US imports from the rest of the world 
based on HTS aggregated dat a from the US Census Bureau 
(Exhibit USA -57).  
  WT/DS471/ARB/Add.1  
 
- 88 - Anti-dumping order  Total US 
market  
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)1 Data sources  
Copper Pipe and Tube  [[***]] 1,940,000  [[***]] 448,400  Value of US shipments estimated by the United States by 
applying a growth rate to the 2015 US  shipment value reported  
in USITC Publication 4650 (Exhibit USA -58). Data on the value of 
US imports from China from US Customs (Exhibit USA -30 (BCI) ). 
Value of US imports from the rest of the world based on HTS 
aggregated data from the US Census Bureau (Exhibit USA -57). 
Iron Pipe Fittings  [[***]] 481,967  [[***]] 31,800  Value of US shipments estimated by  the United States by  
applying a  growth rate to the estimated 201 6 value of US 
shipment s of all fabricated pipe and pipe fittings based on the US 
Census  Bureau's  2016 Annual Survey of Manufacturers (Exhibit 
USA-58). Data on the value of US imports from China from US 
Customs (Exhibit USA -30 (BCI) ). Value of US imports from the 
rest of the world based on HTS aggregated data from the US 
Census Bureau (Exhibit USA -57). 
Passenger Vehicle and 
Light Truck Tires  [[***]] 11,740,449  [[***]] 8,616,200  Value of US shipments provided by the United States  based on 
data reported in USITC publication 4545 (Exhibit USA -58). Data 
on the value of US imports from China from US Customs (Exhibit 
USA-30 (BCI) ). Value of US imports from the rest of the world 
based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Residential Washers  [[***]] 3,121,197  [[***]] 1,552,500  Value of US shipments estimated by subtracting the total value 
of US imports from total value of the US market based on AHAM 
data (Exhibit CHN -56 (BCI) ). Data on the value of US imports 
from China from US Customs (Exhibit USA -30 (BCI) ). Value of 
US imports from the rest of the world based on HTS aggregated 
data from the US Census Bureau (Exhibit USA -57). 
Sheet and Strip  [[***]] 3,623,089  [[***]] 892,800  Value of US shipments estimated by the United States by 
multiplying the average US price of subject imports , based on 
data from  USITC DataWeb , by the  subject H TS8's share of the 
broader H TS categories related to flat steel products , based on 
data from USITC DataWeb , and by the American Iron and Steel 
Institute 's production estimate for stainless steel sheet and strip 
(Exhibit USA -58). Data on the value of US imports from China 
from US Customs (Exhibit USA -30 (BCI) ). Value of US imports 
from the rest of the world based on HTS aggregated data from 
the US Census Bur eau (Exhibit USA -57).  
  WT/DS471/ARB/Add.1  
 
- 89 - Anti-dumping order  Total US 
market  
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)1 Data sources  
Steel Flat Products  [[***]] 8,216,479  [[***]] 2,002,700  Value of US shipments provided by the United States  based on 
data reported in USITC Publication 4619 (Exhibit USA -58). Data 
on the value of US imports from China from US Customs (Exhibit 
USA-30 (BCI) ). Value of US imports from the rest of the world 
based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Steel Line Pipe  [[***]] 542,483  [[***]] 605,600  Value of US shipments estimated by the United States by  
multiplying the average US price by the 2017 total production 
quantity of w elded line pipe multiplied  by the share of all line 
pipe less than 16 inches , based on data from Preston Pipe and 
Tube (Exhibit USA -58). Data on the value of US imports from 
China from US Customs (Exhibit USA -30 (BCI) ). Value of US 
imports from the rest of the world based on HTS aggregated 
data from the US Census Bureau (Exhibit USA -57). 
Steel Nails  [[***]] 139,285  [[***]] 477,600  Value of US shipments estimated by the United States by 
applying a growth rate and a share reflecting the correct product 
scope to the 2016 value of US shipments based on the US 
Census Bureau's 2016 Annual Survey of Manufacturers  (Exhibit 
USA-58). Data on t he value of US imports from China from US 
Customs (Exhibit USA -30 (BCI) ). Value of US imports from the 
rest of the world based on HTS aggregated data from the US 
Census Bureau (Exhibit USA -57). 
Steel Pipe  [[***]] 923,716  [[***]] 1,461,600  Value of  US shipments estimated by the United States by 
adjusting the data in 2016 reported in USITC publication 4651 
(Exhibit USA -58). Data on the value of US imports from China 
from US Customs (Exhibit USA -30 (BCI) ). Value of US imports 
from the rest of the world  based on HTS aggregated data from 
the US Census Bureau (Exhibit USA -57). 
Steel Products  [[***]] 12,364,944  [[***]] 3,403,900  Value of US shipments estimated by the United States by 
multiplying the average pri ce of subject imports , based on data 
from USITC DataWeb, by the subject H TS8's share of the 
broader H TS categories related to flat steel products , based on 
data from  USITC DataWeb, and by the American Iron and Steel 
Institute's  production estimate for flat steel products (Exhibit 
USA-58). Data on the value of US imports from China from US 
Customs (Exhibit USA -30 (BCI) ). Value of US imports from the  
  WT/DS471/ARB/Add.1  
 
- 90 - Anti-dumping order  Total US 
market  
(1,000 USD)  US 
shipments  
(1,000 USD)  US imports 
from China  
(1,000 USD)  US imports 
from the rest 
of the world  
(1,000 USD)1 Data sources  
rest of the world based on HTS aggregated data from the US 
Census Bureau (Exhibit  USA-57). 
Steel Standard, Line, and 
Pressure Pipe  [[***]] 137,584  [[***]] 680,300  Annualized v alue of US shipments provided by the United States 
based on data from USITC publication 4656 (Exhibit USA -58). 
Data on the value of US imports from China from US Customs 
(Exhibit USA -30 (BCI) ). Value of US imports from the rest of the 
world based on HTS aggregated data from the US Census Bureau 
(Exhibit USA -57). 
Steel Wire Rod  [[***]] 427,645  [[***]] 1,024,280  Value of US shipments estimated by the United States by 
multiplying  the average price of subject imports , based on data 
from USITC DataWeb, by the subject H TS8's share of the 
broader H TS categories related to wire rod , based on data from  
USITC DataWeb, and by the American Iron and Steel Institute's  
production estimate for wire rod (Exhibit USA -58). Data on the 
value of US imports from China from US Customs (Exhibit USA -
30 (BCI) ). Value of US imports from the rest of the world based 
on HTS aggregated data from the US Census Bureau (Exhibit 
USA-57) 
Note:  The values in this table have been rounded for display purposes only. The actual values were used when implementing the Armin gton model under the two 
steps to estimate the level of nullification or impairment.  
 
 
 WT/DS471/ARB/Add.1  
 
- 91 - 
 
  ANNEX  E-9 
CODE AND TEXT VERSIO N OF THE ARMINGTON M ODEL1 
 
clear all 
capture program drop  all 
 
************************* SOLUTION OF THE ARMINGTON MODEL *************************  
 
program nlArmington  
 syntax varlist(min=2 max=2) [ if], at(name)  
 // Specify name  
 local RHS: word 1 of `varlist'  
 local exogenous: word 2 of `varlist'  
 
 // Specify the temporary variable names  
 tempname   p_us p_wat p_prc p_roc p_row epsilon_us epsilon_wat epsilon_prc /// 
   epsilon_roc epsilon_row m_us m_wat m_prc m_roc m_row Y theta /// 
   sigma t0_wat t_wat t0_prc t_prc t0_roc t_roc LHS P Q a_us a_wat /// 
   a_prc a_ro c a_row b_us b_wat b_prc b_roc b_row QS_us QS_wat /// 
   QS_prc QS_roc QS_row QD_us QD_wat QD_prc QD_roc QD_row  
 
 // Specify the endogenous parameters  
 scalar `p_us' = `at'[1, 1]  // US shipments  
 scalar `p_wat' = `at'[1, 2] // US imports from China subject to WA -T rate 
 scalar `p_prc' = `at'[1, 3] // US imports from China subject to PRC -wide rate  
 scalar `p_roc' = `at'[1, 4] // US imports from the rest of China  
 scalar `p_row' = `at'[1, 5] // US imports from the rest of the world  
 
 // Specify the exogenous parameters (i.e. elasticities, initial market  
 // shares, initial total expenditure and initial anti -dumping duties)  
 local i = 1 
 foreach param in epsilon_us epsilon_wat epsilon_prc epsilon_roc /// 
      epsilon_row m_us m_wat m_prc m_roc m_row Y theta sigma /// 
      t0_wat t_wat t0_prc t_prc t0_roc t_roc {  
  levelsof `exogenous' in `i' 
  generate double ``param'' = `r(levels)'  
  local i = `i' + 1 
 } 
  replace `t0_wat' = 0 if `t0_wat' == . 
 
 // Specify the initial market clearance conditions  
  generate  double `LHS' = 0 
 
 // Compute the index price  
  generate  double `P' = (`m_us'/100 * `p_us' ^(1 - `sigma') + /// 
          `m_wat'/100 * `p_wat' ^(1 - `sigma') + /// 
          `m_prc'/100 * `p_prc' ^(1 - `sigma') + /// 
          `m_roc'/100 * `p_roc' ^(1 - `sigma') + /// 
          `m_row'/100 * `p_row' ^(1 - `sigma'))  /// 
          ^(1/(1 - `sigma')) 
 
 // Compute the aggregate demand  
  generate  double `Q' = `Y' * `P' ^`theta' 
 
 local i = 1  
 foreach x in us wat prc roc row {  
 // Compute the shifting factors  
  if "`x'" == "us" | "`x'" == "row" generate double /// 
   `a_`x'' = `Y' * `m_`x''/100 
                                                
1 This Stata c ode (do -file) has been reviewed using STATA 13 (and above).  WT/DS471/ARB/Add.1  
 
- 92 - 
 
    if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double /// 
   `a_`x'' = `Y' * `m_`x''/100 * (1 + `t0_`x'' /100) ^( `epsilon_`x'' ) 
  generate  double `b_`x'' = exp(ln(`m_`x''/100) / `sigma') 
   replace `b_`x'' = 0 if `m_`x'' == 0 | `m_`x'' == . 
 
 // Compute the supply functions  
  if "`x'" == "us" | "`x'" == "row" generate  double /// 
   `QS_`x'' = `a_`x'' * (`p_`x'') ^`epsilon_`x''  
  if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double /// 
   `QS_`x'' = `a_`x'' * ((`p_`x'')/(1 + `t_`x''/100)) ^ `epsilon_`x''  
 
 // Compute the demand functions  
  generate double `QD_`x'' = `Q' * (`b_`x''^`sigma') * /// 
           (`p_`x''/`P')^(-`sigma') 
 
 // Compute the market clearance conditions  
   replace `LHS' = `QD_`x'' - `QS_`x'' in `i' 
   if `i' == 5 replace `LHS' = `QD_`x'' - `QS_`x'' + 1 in `i' 
 
  local i = `i' + 1 
 } 
 // Ensure the market clearance conditions are met  
   replace `RHS' = `LHS' 
end 
 
********************* CORRESPONDING PRICES AND QUANTITIES **********************  
 
program define dPQ  
 // Specify the input variables:  
 * `1': variable with prices  
 * `2': variable with exogenous parameters  
 
 // Specify the temporary variable names  
 tempname  p_us p_wat p_prc p_roc p_row epsilon_us epsilon_wat epsilon_prc /// 
   epsilon_roc epsilon_row m_us m_wat m_prc m_roc m_row Y theta /// 
   sigma t0_wat t_wat t0_prc t_pr c t0_roc t_roc LHS P Q a_us a_wat /// 
   a_prc a_roc a_row  
 
 // Specify the parameters  
 local i = 1 
 foreach param in p_us p_wat p_prc p_roc p_row epsilon_us epsilon_wat /// 
      epsilon_prc epsilon_roc epsilon_row m_us m_wat m_prc /// 
      m_roc m_row Y theta sigma t0_wat t_wat t0_prc t_prc /// 
      t0_roc t_roc {  
  if `i' <= 5 scalar ``param'' = `1' in `i' 
  if `i' > 5 local j = `i' - 5 
  if `i' > 5 scalar ``param'' = `2' in `j' 
  local i = `i' + 1 
 } 
 
 // Compute the index price  
  generate double `P' = (`m_us'/100 * `p_us' ^(1 - `sigma') + /// 
          `m_wat'/100 * `p_wat' ^(1 - `sigma') + /// 
          `m_prc'/100 * `p_prc' ^(1 - `sigma') + /// 
          `m_roc'/100 * `p_roc' ^(1 - `sigma') + /// 
          `m_row'/100 * `p_row' ^(1 - `sigma'))  /// 
          ^(1/(1 - `sigma')) 
 
 // Compute the aggregate demand  
  generate  double `Q' = `Y' * `P' ^`theta' 
 
 local i = 1  
 foreach x in us wat prc roc row {  
 // Compute the shifting factors  
  if "`x'" == "us" | "`x'" == "row" generate double /// 
   `a_`x'' = `Y' * `m_`x''/100 
  if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double /// WT/DS471/ARB/Add.1  
 
- 93 - 
 
     `a_`x'' = `Y' * `m_`x''/100 * (1 + `t0_`x'' /100) ^( `epsilon_`x'' ) 
 
 // Compute the percent changes in prices  
  generate double dp_ `x' = (p_`x' - 1) * 100 in 1  
 
 // Compute the initial equilibrium quantities  
  if "`x'" == "us" | "`x'" == "row" generate double /// 
   iniq_`x' = `a_`x'' * 1 ^`epsilon_`x'' in 1 
  if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double /// 
   iniq_`x' = `a_`x'' * (1 / (1 + `t0_`x'' /100)) ^ `epsilon_`x'' in 1 
 
 // Compute the new equilibrium quantities  
  if "`x'" == "us" | "`x'" == "row" generate double /// 
   newq_`x' = `a_`x'' * (p_`x') ^`epsilon_ `x'' in 1 
  if "`x'" == "wat" | "`x'" == "prc" | "`x'" == "roc" generate double ///  
   newq_`x' = `a_`x'' * ( p_`x' / (1 + `t_`x''/100)) ^`epsilon_ `x'' in 1 
 
 // Compute the percent changes in quantities  
  generate double dq_ `x' = (newq_ `x' - iniq_`x')/iniq_`x' * 100 in 1  
   if dq_`x' == . replace dq_`x' = 0 in 1  
 
 // Compute the new expenditures  
  generate double newX_ `x' = p_`x' * newq_`x' in 1 
 
 // Compute the change in expenditures  
  generate double dX_ `x' = (newX_ `x' - iniq_`x') in 1 
 } 
end 
 
*************************** IMPLEMENTATION OF STEP 1 ***************************  
 
* Import data inputs for each anti -dumping order reported in Appendix Table [XX]  
* Appendix Table [ XX] saved in an Excel file named "Data.xlsx"  
 
 import excel "Data.xlsx" , firstrow clear  
  rename Antidumpingorder  Product 
  drop if Product == "" 
 
* Remove the double brackets for BCI inputs  
  foreach var in m_us m_wat m_prc m_roc m_row Y Y2017 t_wat t_roc {  
   replace `var' = subinstr (`var',"[[","",1) 
   replace `var' = subinstr (`var',"]]","",1) 
   destring  `var', replace force  
  } 
 
* Create additional inputs  
  foreach var in wat prc roc {  
   generate  double epsilon_ `var' = epsilon_import  
   generate  double t0_ `var' = 0 
   rename t_`var' t1_`var' 
  } 
  rename epsilon_import epsilon_row  
 save "Inputs.dta" , replace 
 
* Solve the Armington model for each anti -dumping order at issue in the year  
* prior to the imposition of the anti -dumping duty rates  
 use "Inputs.dta" , clear 
  levelsof  Product, local(Product)  
  foreach product of local Product {  
   use "Inputs.dta" , clear 
    keep if Product == "`product'"  
    display " " 
    display "********************* `product' *********************"  
   quietly { 
   * Create constraints and exogenous variables structure  
    set obs 19 
    generate  double MrktEq = 0  WT/DS471/ARB/Add.1  
 
- 94 - 
 
       replace MrktEq = 1 in 5  
    local i = 1  
    generate  paramname = "" 
    generate  double param = .  
    foreach param in epsilon_us epsilon_wat epsilon_prc /// 
         epsilon_roc epsilon_row m_us m_wat m_prc /// 
         m_roc m_row Y theta sigma t0_wat t1_wat /// 
         t0_prc t1_prc t0_roc t1_roc {  
     levelsof  `param' in 1, local(temp)  
     replace paramname = "`param'" in `i' 
     capture replace param = `temp' in `i' 
     replace param = 0 if param == . in `i' 
     local i = `i' + 1 
    } 
   } 
   * Solve the Armington model with imposition of anti -dumping duties  
    nl  Armington @ MrktEq param, param(p_us p_wat p_prc p_roc p_row) /// 
     initial(p_us 1 p_wat 1 p_prc 1 p_roc 1 p_row 1) eps(1e -12) 
    quietly { 
     matrix B = e(b) 
     svmat double B  
     local i = 1 
     foreach x in us wat prc roc row {  
      rename B`i' p_`x' // New price  
      local i = `i' + 1 
     } 
   * Compute new market shares  
     matrix B = B' 
     svmat double B  
    dPQ B param  
    egen double Y1 = rowtotal(newX_*)  
     foreach x in us wat prc roc row {  
      generate  double m1_ `x' = newX_`x' / Y1 * 100  
     }   
     drop p_* dp_* iniq_* newq_* dq_* newX_* dX_* MrktEq param* B1  
    keep in 1 
    } 
   quietly save "`product'.dta" , replace  
  } 
  quietly keep  if Product == "?" 
  foreach product of local Product {  
   append using "`product '.dta" 
   erase "`product'.dta"  
  } 
 
*************************** IMPLEMENTATION OF STEP 2 ***************************  
 
* Create additional inputs   
  generate  double t2_wat = 0  
   * Brackets should be removed before running the code  
   replace t2_wat = [[ ***]] if Product == "OCTG" // This is BCI  
  generate  double t2_prc = 0  
  generate  double t2_roc = t1_roc  
 save "Inputs.dta" , replace  
 
* Solve the Armington model ifor each anti -dumping order at issue in 2017 by using  
* the simulated market shares associated with the imposition of the anti -dumping 
* duty rates and calculated in step 1  
 use "Inputs.dta" , clear 
  levelsof  Product, local(Product)  
  foreach product of local Product {  
   use "Inputs.dta" , clear 
    keep if Product == "`product'"  
    display " " 
    display "********************* `product' *********************"  
   quietly { 
   * Create constraints and exogenous variables structure  WT/DS471/ARB/Add.1  
 
- 95 - 
 
      set obs 19 
    generate  double MrktEq = 0  
     replace MrktEq = 1 in 5  
    local i = 1  
    generate  paramname = "" 
    generate  double param = .  
    foreach param in epsilon_us epsilon_wat epsilon_prc /// 
         epsilon_roc epsilon_row m1_us m1_wat m1_prc /// 
         m1_roc m1_row Y2017 theta sigma t1_wat t2_wat /// 
         t1_prc t2_prc t1_roc t2_roc {  
     levelsof  `param' in 1, local(temp)  
     replace paramname = "`param'" in `i' 
     capture replace param = `temp' in `i' 
     replace param = 0 if param == . in `i' 
     local i = `i' + 1 
    } 
   } 
   * Solve the Armington model for counterfactual anti -dumping duty rates  
    nl  Armington @ MrktEq param, param(p_us p_wat p_prc p_roc p_row) ///  
     initial(p_us 1 p_wat 1 p_prc 1 p_roc 1 p_row 1) ep s(1e-12) 
    quietly { 
     matrix B = e(b) 
     svmat double B  
     local i = 1 
     foreach x in us wat prc roc row {  
      rename B`i' p_`x' // New price  
      local i = `i' + 1 
     } 
   * Compute the level nullification or impairment  
     matrix B = B' 
     svmat double B  
    dPQ B param  
    generate  double NI = dX_wat + dX_prc + dX_roc  
     keep Product NI  
     keep in 1 
    } 
   quietly save "`product'.dta" , replace  
  } 
  quietly keep if Product == "?" 
  foreach product of local Product {  
   append using "`product'.dta"  
   erase "`product'.dta"  
  } 
 
 
  
  WT/DS471/ARB/Add.1  
 
- 96 - ANNEX  E-10 
DATA INPUTS USED TO IMPLEMENT THE ARMING TON MODEL UNDER THE TWO STEPS1 
Anti-
dumping 
order  theta  epsilon
_us epsilon
_import  sigma  m_us  m_wat  m_prc  m_roc  m_row  Y Y 2017  t_wat  t_prc  t_roc  
Aluminum 
Extrusions  -0.375  4.00 10.00  5.00 77.239  n/a [[***]] [[***]] 11.093  4606386.000  [[***]] n/a 85.96  [[***]] 
Bags -0.450  3.00 10.00  5.00 77.579  n/a [[***]] [[***]] [[***]] 995491.000  [[***]] n/a 77.57  [[***]] 
Coated 
Paper  -1.000  4.00 10.00  3.00 58.758  [[***]] [[***]] [[***]] 24.165  1742204.000  [[***]] [[***]] 135.84  [[***]] 
Diamond 
Sawblades  -0.750  5.00 10.00  3.00 [[***]] n/a [[***]] [[***]] 36.115  [[***]] [[***]] n/a 82.05  [[***]] 
Furniture  -0.750  4.50 10.00  4.50 40.259  n/a [[***]] [[***]] [[***]] 4666667.000  [[***]] n/a 216.01  [[***]] 
OCTG  -0.875  3.00 10.00  4.00 [[***]] [[***]] [[***]] [[***]] 31.560  [[***]] [[***]] [[***]] 99.14  [[***]] 
OTR Tires  -0.250  7.50 10.00  4.00 56.066  n/a [[***]] [[***]] 28.197  1794409.000  [[***]] n/a 105.31  [[***]] 
PET Film  -0.750  3.50 10.00  4.50 [[***]] n/a [[***]] [[***]] 17.791  [[***]] [[***]] n/a 76.72  [[***]] 
Ribbons  -1.250  5.00 10.00  4.00 89.197  n/a [[***]] [[***]] [[***]] 650438.000  [[***]] n/a 247.26  [[***]] 
Shrimp  -2.000  3.50 10.00  4.00 [[***]] n/a [[***]] [[***]] 82.273  [[***]] [[***]] n/a 112.81  [[***]] 
                                                
1 The code (do -file) of the software STATA in Annex E -9 refers to this input table.   
  WT/DS471/ARB/Add.1  
 
- 97 - Anti-
dumping 
order  theta  epsilon
_us epsilon
_import  sigma  m_us  m_wat  m_prc  m_roc  m_row  Y Y 2017  t_wat  t_prc  t_roc  
Solar Panels  -0.875  6.00 10.00  4.00 [[***]] n/a [[***]] [[***]] 41.144  [[***]] [[***]] n/a 238.95  [[***]] 
Steel 
Cylinders  -0.500  7.50 10.00  4.00 [[***]] [[***]] [[***]] [[***]] 2.705  [[***]] [[***]] [[***]] 31.21  [[***]] 
Wood 
Flooring  -1.000  5.50 10.00  4.00 43.517  n/a [[***]] [[***]] 14.770  783896.000  [[***]] n/a 25.62  [[***]] 
Copper Pipe 
and Tube  -0.875  2.00 10.00  4.00 75.958  n/a [[***]] [[***]] 12.474  2110170.000  [[***]] n/a 60.85  [[***]] 
Iron Pipe 
Fittings  -1.250  4.50 10.00  4.50 [[***]] n/a [[***]] [[***]] 12.310  [[***]] [[***]] n/a 75.5 [[***]] 
Passenger 
Vehicle and 
Light Truck 
Tires -0.375  3.00 10.00  4.00 52.995  n/a [[***]] [[***]] 35.442  22154265.000  [[***]] n/a 76.46  [[***]] 
Residential 
Washers  -0.550  7.00 10.00  4.00 [[***]] n/a [[***]] [[***]] [[***]] [[***]] [[***]] n/a 49.72  [[***]] 
Sheet and 
Strip -0.750  5.00 10.00  4.00 [[***]] n/a [[***]] [[***]] 19.791  [[***]] [[***]] n/a 76.64  [[***]] 
Steel Flat 
Products  -0.500  6.00 10.00  4.00 80.830  n/a [[***]] [[***]] 15.652  8405722.000  [[***]] n/a 199.76  [[***]] 
Steel Line 
Pipe -0.375  4.00 10.00  3.00 [[***]] n/a [[***]] [[***]] 33.561  [[***]] [[***]] n/a 101.1  [[***]] 
Steel Nails  -0.375  4.00 10.00  4.00 22.393  n/a [[***]] [[***]] [[***]] 984270.000  [[***]] n/a 118.04  [[***]] 
Steel Pipe  -0.625  4.00 10.00  5.00 61.810  n/a [[***]] [[***]] 16.647  2185379.000  [[***]] n/a 85.55  [[***]]  
  WT/DS471/ARB/Add.1  
 
- 98 - Anti-
dumping 
order  theta  epsilon
_us epsilon
_import  sigma  m_us  m_wat  m_prc  m_roc  m_row  Y Y 2017  t_wat  t_prc  t_roc  
Steel 
Products  -0.750  6.00 10.00  4.00 78.869  n/a [[***]] [[***]] [[***]] 17055633.000  [[***]] n/a 199.43  [[***]] 
Steel 
Standard, 
Line, and 
Pressure 
Pipe -0.750  7.50 10.00  3.00 29.180  n/a [[***]] [[***]] 51.025  683206.000  [[***]] n/a 98.74  [[***]] 
Steel Wire 
Rod -0.625  2.00 10.00  4.00 [[***]] n/a [[***]] [[***]] 25.287  [[***] ] [[***]] n/a 97.24  [[***]] 
Note:  The names used in the table refer to the following: theta: total demand elasticity; epsilon_us: domestic supply elasticity; epsilon_import: import supply 
elasticity; sigma: elasticity of substitution; m_us: market share of US domestic producers in year prior; m_wat: market share  of Chinese exporters subject to 
WTO-inconsistent WA -T duty rate in year prior; m_prc: ma rket share of Chinese exporters subject to WTO -inconsistent PRC -wide duty rate in year prior; m_roc: 
market share of remaining Chinese exporters in year prior; m_row: market share of exporters from rest of the world in year pr ior; Y: total US market value in 
1,000 USD in year prior; Y 2017: total US market value in 1,000 USD in 2017; t_wat: WA -T duty rate; t_prc: PRC -wide  duty rate; and t_roc: duty rate for 
remaining Chinese exporters in 2017.  
 
  
  WT/DS471/ARB/Add.1  
 
- 99 - ANNEX  E-11 
RESULTS OF IMPLEMENT ING THE ARMINGTON MO DEL UNDER THE FIRST STEP 
Anti-dumping order  Simulated market 
share of US 
domestic 
producers  Simulated market 
share of Chinese 
exporters subject 
to the WA -T duty 
rate Simulated market 
share of Chinese 
exporters subject 
to the PRC -wide 
duty rate  Simulated market 
share of remaining 
Chinese exporters  Simulated market 
share of exporters 
from the rest of the 
world  
Aluminum Extrusions  84.3%  n/a [[***]]% [[***]]% 12.6%  
Bags [[***]]% n/a [[***]]% [[***]]% [[***]]% 
Coated Paper  60.0%  [[***]]% [[***]]% n/a 24.8%  
Diamond Sawblades  [[***]]% n/a [[***]]% [[***]]% 40.0%  
Furniture  [[***]]% n/a [[***]]% [[***]]% [[***]]% 
OCTG  [[***]]% [[***]]% [[***]]% [[***]]% 37.9%  
OTR Tires  61.3%  n/a [[***]]% [[***]]% 31.1%  
PET Film  [[***]]% n/a [[***]]% [[***]]% 18.2%  
Ribbons  [[***]]% n/a [[***]]% [[***]]% [[***]]% 
Shrimp  [[***]]% n/a [[***]]% [[***]]% 84.9%  
Solar Panels  [[***]]% n/a [[***]]% [[***]]% 53.0%  
Steel Cylinders  [[***]]% [[***]]% [[***]]% [[***]]% 3.1%  
Wood Flooring  48.9%  n/a [[***]]% [[***]]% 16.9%  
Copper Pipe and Tube  78.7%  n/a [[***]]% [[***]]% 13.2%  
Iron Pipe Fittings  [[***]]% n/a [[***]]% [[***]]% 13.2%   
  WT/DS471/ARB/Add.1  
 
- 100 - Anti-dumping order  Simulated market 
share of US 
domestic 
producers  Simulated market 
share of Chinese 
exporters subject 
to the WA -T duty 
rate Simulated market 
share of Chinese 
exporters subject 
to the PRC -wide 
duty rate  Simulated market 
share of remaining 
Chinese exporters  Simulated market 
share of exporters 
from the rest of the 
world  
Passenger Vehicle and Light Truck Tires   53.9%  n/a [[***]]% [[***]]% 36.4%  
Residential Washers  [[***]]% n/a [[***]]% [[***]]% 15.9%  
Sheet and Strip  [[***]]% n/a [[***]]% [[***]]% 20.1%  
Steel Flat Products  83.4%  n/a [[***]]% n/a 16.2%  
Steel Line Pipe  [[***]]% n/a [[***]]% [[***]]% 34.8%  
Steel Nails  [[***]]% n/a [[***]]% [[***]]% 36.4%  
Steel Pipe  72.8%  n/a [[***]]% [[***]]% 20.9%  
Steel Products  [[***]]% n/a [[***]]% [[***]]% 18.7%  
Steel Standard, Line, and Pressure Pipe  33.2%  n/a [[***]]% [[***]]% 58.4%  
Steel Wire Rod  [[***]]% n/a [[***]]% [[***]]% 26.7%  
Note:  The percentage values in this table have been rounded for display purposes only. The actual percentage values were used when implementing the Armington 
model under the second step to estimate the level of nullification or impairment.  
 
 
__________  