Differential Pricing Analysis – One Year Later

Since introducing the Differential Pricing Analysis in Xanthan Gum from Austria and China a little over a year ago, the Department of Commerce’s two-staged test has been employed in over 125 anti-dumping proceedings.  Now that the Department has obtained some experience with this approach they are seeking public comment.

As a replacement for the targeted dumping methodology, Differential Pricing Analysis is marked by the absence of the requirement for any affirmative allegation of targeting or aberrational  pricing patterns.  Instead, the Department’s test has been built into its standard antidumping margin programs and incorporates default group definitions for purchasers, regions and time periods.  The standard test has been applied almost uniformly in all  investigation and annual review anti-dumping proceedings since its introduction. The two-part test employs the statistical measure known as the Cohen’s d ratio. A more detailed description of the methodology can be found here.   Where a large percentage of sales are found to have a high “d” ratio, the Department finds that a significant pattern of price differences exists, and, in certain circumstances, applies an average-to-transaction (zeroing) method  of calculating aggregate dumping margins, instead of the default average-to-average (no zeroing) method.

Results to Date

We have updated our table of cases in which the Commerce Department has applied the differential pricing analysis, and indicated whether some or all of the anti-dumping calculations were zeroed.   Our analysis continues to show that differential pricing was found in the majority of cases.   The results after one year mirror our earlier findings; i.e., In over 80% of the proceedings, the Department has found a meaningful level of differential pricing, that is, in either the > 66% level (all zeroing) or the 33%-66% (partial zeroing) ranges.  In 65 instances in which meaningful levels of differential pricing were found, the Department of Commerce also determined that there was no material difference between calculating dumping margins using partial or full zeroing and no zeroing.  In these cases, no zeroing was applied.   Thus, notwithstanding the high frequency of positive findings of material differential pricing, the Department applied some level of zeroing (full or mixed) only 30% of the time.


Request for Comments

The Department is now seeking public comments on the differential pricing analysis method for the purpose of determining whether to apply an alternative comparison method.

The deadline for comments is June 23, 2014.  See Federal Register.


Detailed Table of Cases

The compilation of results is based on preliminary results/determinations, as the Department typically does not publish its differential pricing findings in final results/determinations.  Contact us to receive the complete list of IA ACCESS Reference Nos.

CaseDateDifferential Pricing Found?% of Differential Pricing FoundZeroing Applied?
Polyester Staple Fiber from Taiwan3/22/2013Yes53.20%No
Polyvinyl Alcohol from Taiwan4/8/2013Yes83.72%No
Certain Steel Threaded Rod from China4/9/2013No29.50%No
Circular Welded Carbon Steel Pipe from Thailand4/9/2013Yes87.44%No
HEDP from India4/26/2013No<33%No
Activated Carbon from China5/2/2013Yes50%Mixed
Activated Carbon from China5/2/2013Yes44.70%No
Frontseating Valves from China5/2/2013Yes79.20%No
Xanthan Gum from China5/29/2013Yes59.95%No
Xanthan Gum from China5/29/2013Yes68.92%No
Xanthan Gum from Austria5/29/2013Yes75.03%No
Pipe from Turkey5/31/2013Yes77.22%Yes
Pipe from Turkey5/31/2013No<33%No
Stainless Steel Plate from Belgium5/31/2013Yes73.37%Yes
Pipe from Taiwan5/31/2013Yes77.15%No
Aluminum Extrusions from China6/3/2013No6.16%No
Citric Acid China6/3/2013No30.80%No
Citric Acid Canada6/3/2013Yes33%-66%Mixed
Silica Bricks and Shapes from China6/13/2013Yes100%No
TRBs from China7/1/2013Yes45.60%Mixed
Chlorinated Isocynaruates from China7/2/2013No25.20%No
Chlorinated Isocynaruates from China7/2/2013Yes52.50%No
Chlorinated Isocynaruates from Spain7/2/2013Yes51.29%No
Solid Urea from Russia Federation7/26/2013Yes89.72%No
PET Film from India7/31/2013Yes69.70%Yes
PET Film from India7/31/2013Yes63.98%No
PET Film from Taiwan8/1/2013Yes89.00%Yes
CMC from Netherlands8/1/2013Yes60.73%Mixed
CMC from Finland8/1/2013Yes48.38%Mixed
Pasta From Italy8/2/2013Yes43.03%Mixed
Pasta From Italy8/2/2013Yes38.28%No
Certain Kitchen Appliance Shelving and Racks from China8/28/2013No0%No
Corrosion-Resistant Carbon Steel Plate from Korea8/30/2013Yes45.80%No
Corrosion-Resistant Carbon Steel Plate from Korea8/30/2013Yes75.26%No
Light Walled Rectangular Pipe and Tube from Mexico8/30/2013Yes69.03%Yes
Light-Walled Rectangular Pipe and Tube from Mexico8/30/2013Yes41.17%No
Frozen Fish Fillets from Vietnam9/3/2013Yes69.90%No
Frozen Fish Fillets from Vietnam9/3/2013Yes61.10%No
Nails from China9/3/2013Yes64.70%Mixed
Nails from China9/3/2013Yes77.20%No
Hardwood and Decorative Plywood from China9/16/2013No20.00%No
Hardwood and Decorative Plywood from China9/16/2013Yes68.60%No
Crawfish from China9/27/2013No<33%No
Crawfish from China9/27/2013No<33%No
Crawfish from China9/27/2013No<33%No
DANP Flat-Rolled Steel from Japan11/8/2013Yes39.11%No
Copper Tube from China11/15/2013Yes38.90%No
Multilayered Wood Flooring from China11/18/2013No18.10%No
Multilayered Wood Flooring from China11/18/2013Yes40.90%Mixed
Multilayered Wood Flooring from China11/18/2013Yes67.70%Yes
Multilayered Wood Flooring from China11/18/2013Yes50.60%No
Hangers from China11/19/2013Yes33%-66%Mixed
Seamless Refined Copper Pipe and Tube From China11/21/2013Yes38.90%No
Diffusion-Annealed Nickel-Plated Flat-Rolled Steel from Japan11/19/2013Yes39.11%No
Certain Circular Welded Carbon Steel Pipes and Tubes Taiwan11/29/2013Yes77.15%No
Frontseating Valves from China12/9/2013Yes79.20%Yes
Prestressed Concrete Steel Rail Tie Wire from China12/12/2013Yes>66%No
Diamond Sawblades and Parts Thereof from China12/20/2013Yes33%-66%Mixed
Diamond Sawblades and Parts Thereof from China12/20/2013Yes33%-66%Mixed
Fresh Garlic from China12/24/2013Yes>66%No
Fresh Garlic from China12/24/2013Yes>66%No
Polyethylene Terephthalate Film, Sheet and Strip from China12/26/2013No<33%No
Lightweight Thermal Paper from Germany12/26/2013Yes33%-66%No
Circular Welded Non-Alloy Steel Pipe from Korea12/26/2013Yes71.55%Yes
Circular Welded Non-Alloy Steel Pipe from Korea12/26/2013Yes42.93%No
Prestressed Concrete Steel Rail Tie Wire from Mexico12/12/2013No<33%No
Seamless Refined Copper Pipe and Tube12/24/2013Yes70.33%Yes
Seamless Refined Copper Pipe and Tube12/24/2013Yes49.53%Mixed
Prestressed Concrete Steel Rail Tie Wire from Thailand12/12/2013Yes>66%No
Hand Trucks and Parts Thereof from China1/23/2014Yes96.80%No
Welded StainlessPressure Pipe from Thailand1/7/2014Yes72.99%No
Welded StainlessPressure Pipe from Vietname1/7/2014Yes94.40%No
Citric Acid and Certain Citrate Salts from Canada2/24/2014Yes>66%Yes
Wooden Bedroom Furniture from China2/26/2014Yes91.70%Yes
Wooden Bedroom Furniture from China2/26/2014No0%No
Steel Threaded Rod from India2/18/2014Yes>66%Yes
OCTG from India2/25/2014Yes60.58%No
OCTG from India2/25/2014No22.54%No
OCTG from the Philippines2/25/2014Yes72.22%No
OCTG from Saudi Arabia2/25/2014Yes72.15%No
OCTG from South Korea2/25/2014Yes84.32%No
OCTG from South Korea2/25/2014Yes82.55%No
OCTG from Taiwan2/25/2014Yes61%No
OCTG from Taiwan2/25/2014Yes74.52%No
OCTG from Turkey2/25/2014Yes36.44%No
OCTG from Turkey2/25/2014Yes62.85%No
OCTG from Ukraine2/25/2014Yes64.33%Mixed
Stainless Steel Bar from Brazil3/24/2014No19.47%No
Small Diameter Graphite Electrodes from China3/24/2014Yes48.70%No
1-Hydroxyethylidene-1 from China3/25/2014No0%No
Stainless Steel Bar From India3/25/2014Yes47.94%No
Certain Frozen Warmwater Shrimp from India3/25/2014Yes65.31%Mixed
Certain Frozen Warmwater Shrimp from India3/25/2014Yes73.30%Yes
Certain Cut-to-Length Carbon-Quality Steel Plate Products from Korea3/10/2014Yes>66%Yes
Ferrosilicon from Russia3/11/2014Yes>66%No
Certain Frozen Warmwater Shrimp from Thailand3/24/2014No<33%No
Certain Frozen Warmwater Shrimp from Thailand3/24/2014Yes33%-66%Mixed
Certain Frozen Warmwater Shrimp from Thailand3/24/2014Yes>66%Yes
Ferrosilicon from Venezuela3/11/2014Yes55.20%No
Certain Frozen Warmwater Shrimp from Vietnam3/24/2014Yes63.40%Mixed
Certain Frozen Warmwater Shrimp from Vietnam3/24/2014Yes69.40%Yes
Citric Acid from China4/28/2014Yes95.40%No
Citric Acid from China4/28/2014Yes82.50%Yes
Chlorinated Isocyanurates from Japan4/24/2014Yes33%-66%No
Chlorinated Isocyanurates from Japan4/24/2014Yes>66%No
Steel Concrete Reinforcing Bar from Mexico4/24/2014Yes92.09%No
Steel Concrete Reinforcing Bar from Mexico4/24/2014Yes80.60%No
Stainless Steel Bar from Spain4/23/2014No0%No
Circular Welded Carbon Steel Pipes and Tubes from Thailand4/24/2014Yes83.98%Yes
Steel Concrete Reinforcing Bar from Turkey4/23/2014Yes94.20%No
Steel Concrete Reinforcing Bar from Turkey4/23/2014Yes72.40%Yes
Light-Walled Rectangular Pipe and Tube from Turkey4/28/2014No0%No
Certain Frozen Fish Fillets from Vietnam4/7/2014Yes52.30%Mixed
Monosodium Glutamate from China5/8/2014Yes>66%No
Activated Carbon from China5/22/2014Yes52.60%No
Activated Carbon from China5/22/2014No0%No
Frontseating Valves from China5/27/2014Yes86.30%Yes
Certain Steel Threaded Rod from China5/27/2014Yes58.60%No
1,1,1,2-Tetrafluroethane from China5/27/2014Yes75%No
1,1,1,2-Tetrafluroethane from China5/27/2014Yes34%No
Grain-Oriented Electrical Steel from the Czech Republic5/9/2014No<33%No
Grain-Oriented Electrical Steel from the Czech Republic5/9/2014Yes>66%No
Monosodium Glutamate from Indonesia5/8/2014Yes>66%No
Grain-Oriented Electrical Steel from Korea5/12/2014Yes68.20%Yes
Non-Oriented Electrical Steel from Korea5/22/2014Yes50.32%No
Non-Oriented Electrical Steel from Taiwan5/22/2014Yes73.04%No

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