NOTICES
DEPARTMENT OF COMMERCE
[C-351-021]
Cold-Rolled Carbon Steel Sheet From Argentina: Preliminary Affirmative
Countervailing Duty Determination
Friday, February 10, 1984
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AGENCY: International Trade Administration, Commerce.
ACTION: Notice.
SUMMARY: We preliminarily determine that certain benefits which constitute bounties
or grants within the meaning of the countervailing duty law are being provided to
manufacturers, producers, or exporters in Argentina of cold-rolled carbon steel sheet.
The estimated net bounty or grant is 6.03 percent ad valorem. We are directing the U.S.
Customs Service to suspend liquidation of all entries of cold-rolled carbon steel sheet
from Argentina which are entered, or withdrawn from warehouse, for consumption, and
to require a cash deposit or bond on this product in the amount equal to the estimated net
bounty or grant.
If this investigation proceeds normally, we will make our final determination by April 18,
1984.
EFFECTIVE DATE: February 10, 1984.
FOR FURTHER INFORMATION CONTACT: Andrew Debicki or Barbara Tillman: Office of
Investigations, Import Administration, International Trade Administration, U.S.
Department of Commerce, 14th Street and Constitution Avenue, N.W., Washington, D.C.
20230, telephone: (202) 377-5403-0192.
SUPPLEMENTARY INFORMATION: .
Preliminary Determination
Based upon our investigation, we preliminarily determine that there is reason to believe
or suspect that certain benefits which constitute bounties or grants within the meaning of
section 303 of the Tariff Act of 1930, as amended (the Act), are being provided to
manufacturers, producers, or exporters in Argentina of cold-rolled carbon steel sheet.
For purposes of this investigation, the following programs are preliminarily found to
confer bounties or grants:
"Reembolso"--tax rebate on exports.
Post-financing of exports under Circular OPRAC 1-9.
Government equity infusions.
Loan guarantees.
We estimate the net bounty or grant to be 6.03 percent ad valorem.
Case History
On November 10, 1983, we received petitions from the United States Steel Corporation
(U.S. Steel). Pittsburgh, Pennsylvania, filed on behalf of the hot-rolled and cold-rolled
carbon steel sheet industries. The petition relating specifically to hot-rolled carbon steel
sheet was subsequently withdrawn. In compliance with the filing requirements of §
355.26 of the Commerce Regulations (19 CFR 355.26), the remaining petition alleges that
manufacturers, producers, or exporters in Argentina of cold-rolled carbon steel sheet
receive directly or indirectly, benefits which constitute bounties or grants within the
meaning of section 303 of the Act.
We found the petition to contain sufficient grounds upon which to initiate a
countervailing duty investigation, and on November 22, 1983, we initiated such an
investigation (48 FR 55012). We stated we expected to issue a preliminary determination
by February 3, 1984.
Argentina is not a "country under the Agreement" within the meaning of section 701(b)
of the Act; therefore, section 303 of the Act applies to this investigation. the merchandise
being investigated is dutiable. Therefore, the domestic industry is not required to allege
that, and the U.S. International Trade Commission is not required to determine whether,
imports of this product cause or threaten material injury to a U.S. industry.
We presented a questionnaire concerning the allegations to the government of
Argentina in Washington, D.C., on December 16, 1983. On January 16, 1984, we
received responses to the questionnaire.
Scope of Investigation
The product covered by this investigation is cold-rolled carbon steel sheet which is
described in Appendix I to the notice of "Certain Carbon Steel Products from Mexico;
Preliminary Affirmative Countervailing Duty Determinations" in this issue of the
Federal Register.
There are two known producers and exporters in Argentina of cold-rolled carbon steel
sheet to the United States. We have received information from the government of
Argentina regarding Somisa-Sociedad Mixta Sideru>=1rgica Argentina (Somisa) and
Propulsora Sideru>=1rgica Saic (Propulsora) which represented over 85 percent of
exports of this product to the United States during the period for which we are measuring
bounties or grants, July 1982 through June 1983.
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Analysis of Programs
Throughout this notice, references are made to general principles applied by the
Department of Commerce to the facts of the current investigation. These general
principles are described in detail in Appendix II of the notice of "Certain Steel Products
from Mexico; Preliminary Affirmative Countervailing Duty Determinations" in this
issue of the Federal Register (Appendix II). For purposes of this preliminary
determination, we are calculating a country-wide ad valorem rate for the estimated net
bounty or grant. We allocated the benefits received by respondents between July 1982
and June 1983 over the total sales value or export value, as appropriate, of all
respondents.
As described in Appendix II, several programs alleged by the petitioner-- government
provisions of equity capital, long-term loans and loan guarantees-- require an assessment
of the producers' creditworthiness before we can determine if, and in what magnitude, a
countervailable benefit has been conferred.
We have consistently held that government provision of, or assistance in, obtaining
capital or debt does not per se confer a subsidy. Government equity purchases or
financial backing bestow a countervailable benefit only when they occur on terms
inconsistent with commercial considerations. To determine if such action is
commercially unsound, we review and assess financial data for the company in question.
Because of time constraints, we were unable to thoroughly assess each company's
financial situation for this preliminary determination. Before reaching our final
determination, we will conduct a considerably more comprehensive review, and also
consider more fully what factors are relevant to a determination of inconsistency with
commercial considerations. For this preliminary determination only, we relied primarily
on sales, cash flow, current, and debt-equity ratios to determine if government equity
infusions, loans, and loan guarantees were not inconsistent with commercial
considerations. For loans and loan guarantees, we determined whether the company was
"creditworthy," and in making this determination we focused on cash flow and other
measures of the ability of each company to meet its long-term debt obligations.
With regard to whether a company was a reasonable equity investment (a condition we
have termed "equityworthiness"), we focused on profitability and the long-term
expectations for the company in question. Throughout the rest of this notice, we will use
the term "creditworthiness" to refer to both a company's equityworthiness and
creditworthiness, even though the two are not precisely the same.
In this preliminary determination, we assessed Propulsora's creditworthiness from 1979
through 1983 and Somisa's creditworthiness from 1974 through 1983. Before reaching
our final determination, we will assess the two companies' creditworthiness in prior years
to determine if residual benefits from those years accrue during the period of
investigation. Propulsora's financial statements indicate that it remained creditworthy
during the whole period. After reviewing financial ratios and other measurements derived
from Somisa's financial statements, we preliminarily found the company to be
uncreditworthy for the period 1976 through 1983.
In its response, the government of Argentina provided data for the applicable period
including financial statements and debt information for both Somisa and Propulsora. In
addition, Propulsora submitted a supplemental response containing information on
Propulsora's use of the alleged programs. Based upon our analysis to date of the petition
and the responses to our questionnaire, we preliminarily determine the following:
I. Programs Preliminarily Determined To Confer Bounties or Grants
We preliminarily determine that bounties or grants are being provided to manufacturers,
producers, or exporters in Argentina of cold-rolled carbon steel sheet under the
following programs.
A. "Reembolso"--Tax Rebate on Exports
The reembolso program was established in 1971. It authorized a refund by cash payment
on export, of taxes "that bear directly or indirectly" on exported products and/or their
component raw materials for the purpose of promoting exports. The amount of the
reimbursement is equal to a fixed percentage of the f.o.b. value of the exported
merchandise. This percentage varies by product.
Under the Act, the non-excessive rebate of indirect taxes levied at the final stage, and of
prior stage cumulative indirect taxes borne by inputs that are physically incorporated
into the final product, is not considered a subsidy. With respect to such non-VAT rebates,
in order to determine whether a cash payment on export is a bona fide rebate of indirect
taxes, we examine whether: (1) The program involved operates for the purpose of
rebating indirect taxes; (2) whether there is a clear link between eligibility for payments
on exports and indirect taxes paid; and (3) whether the government has reasonably
calculated and documented the actual tax incidence borne by the product concerned and
has demonstrated a clear link between such tax incidence and the rebate amount paid on
export.
The reembolso program is designed to refund taxes that "bear directly or indirectly on
export products." We view taxes borne by a product as indirect, and taxes on, for
example, income and labor as direct.
Based on our review of the total tax incidence which the reembolso is designed to rebate,
we are satisfied that the reembolso operates "for the purpose of rebating indirect taxes,"
and that it meets our first test.
Following a general reorganization of the reembolso program in 1976, the rate of
reembolso on cold-rolled carbon steel sheet was set at five percent. At the time, the
government of Argentina analyzed the steps of production and value added at each
stage for each major sector of Argentine industry. The reembolso rate for each sector was
then based on the estimated tax incidence derived from the analysis. This procedure
provided the government of Argentina only a general model upon which the tax
incidence for specific sectors could be estimated. Without more precise evidence of the
indirect taxes levied on cold- rolled carbon steel sheet, we would not find the requisite
link between indirect taxes actually paid and the reembolso payments (the second
prerequisite for considering the reembolso not to be a bounty or grant).
In 1980, the Value Added Tax was established (Law 22.294/80) and in 1981, minor taxes
were suspended (Law 22.374/81). As a result of these modifications to the Argentine tax
system, the government reviewed the studies on the fiscal incidence of taxes in order to
reevaluate the levels of the reembolso. This detailed review of specific taxes levied on
cold-rolled carbon steel sheet. When considered in conjunction with the more general
1976 study, provides a sufficient basis for our preliminarily determining that the
reembolso program meets the second test of a clear link between eligibility for the
reembolso and indirect taxes paid.
In the questionnaire response, the government of Argentina provided us with data from
its most recent analysis of the tax incidence on cold-rolled carbon steel sheet. This
analysis shows that the taxes levied on cold-rolled
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carbon steel sheet, which the
reembolso is designed to rebate, total 16.14 percent of the f.o.b. value of the exports.
Seven categories are included in the analysis: domestic raw material inputs, imported raw
material inputs, variable costs, labor, indirect expenses, taxes paid directly, and export
taxes.
The taxes on variable costs, labor and indirect expenses, which total 1.79 percent, do not
meet our standard for physical incorporation into the final product. In addition, in its
questionnaire response, the government of Argentina did not itemize certain taxes on
domestic raw material inputs when calculating the indirect tax incidence. Since the taxes
and their fiscal incidence on inputs are not itemized, we preliminarily determine that, for
these taxes on domestic raw material inputs, our third test is not met; that is, the
government has not reasonably calculated and documented the actual tax incidence
borne by the product concerned and has not demonstrated a clear link between such tax
incidence and the rebate paid on export. The incidence of these taxes on domestic raw
materials equals 6.95 percent.
The other taxes itemized in the fiscal incidence calculation for domestic raw material
inputs do meet our third test. In addition, the taxes in each of the three remaining
categories--imported raw material inputs, taxes paid directly, and export taxes--meet our
third test because they are itemized, and the rate of each tax and its incidence are
calculated. These taxes, which include the stamp tax, the tax on transfer of foreign
currency, insurance taxes, municipal taxes and the export contract stamp tax, are all
indirect taxes.
Therefore, of the total 16.14 percent tax incidence claimed by the government of
Argentina for cold-rolled carbon steel sheet, we have allowed 7.40 percent and
disallowed 8.74 percent.
In order to determine whether the reembolso confers a bounty or grant on cold- rolled
carbon steel sheet, we must compare what we have preliminarily determined as allowable
to the reembolso rate currently in effect for cold- rolled carbon steel sheet. Since May 7,
1982, the reembolso for cold-rolled carbon steel sheet has been 10 percent (Resolution
M.E. 8/82). In addition to the normal reembolso, the petitioner alleges the existence of
bounties or grants through two additional reembolsos. Decree No. 1691 temporarily
established an additional reembolso of 15 percent. This reembolso was abolished in April
1982 and, thus, was not in effect during the period for which we are measuring bounties or
grants, July 1982 through June 1983. Decree No. 2863/72 granted an additional
reembolso of five percent for exports to new markets. In its response, the government of
Argentina stated that this program, which was abolished in April 1983, was not used for
exports of cold- rolled carbon steel sheet to the United States.
Therefore, only the 10 percent reembolso is currently received by Somisa and
Propulsora. To calculate the bounty or grant, we use the amount by which the reembolso
payment of 10 percent exceeds the total allowable indirect taxes of 7.40 percent. This
results in a bounty or grant on exports of 2.60 percent ad valorem.
B. Post-Financing of Exports Under Circular OPRAC 1-9
On September 24, 1982, the Central Bank of Argentina established a post- financing
program for exports under Circular OPRAC 1-9. OPRAC 1-9 loans are granted for up to 30
percent of the peso equivalent of the foreign currency in which the export transaction
was paid. The term of the loan is 180 days. According to the response, the interest rate on
OPRAC 1-9 loans is the indexed market rate used by the commercial banks as required
under Central Bank Regulations. Both Somisa and Propulsora received OPRAC 1-9 loans.
Although Appendix II states that the benchmark for short-term loans is the national
average commercial rate, we do not have sufficient information available to determine
this rate for Argentina for purposes of this preliminary determination. Instead, we are
using as the benchmark the unregulated interest rates for short-term commercial bank
loans, which are published in the "Indicadores de Conyuntura" (Current Economic
Indicators) by the Fundacio>=1n de Investigaciones Eco>=1nomicas Latino-Americanas
(FIEL). We are using the unregulated rates because we consider them a better reflection of
average commercial rates than the regulated commercial bank rates. Using this
benchmark, we calculate a bounty or grant on exports of 2.42 percent ad valorem.
C. Government Equity Infusions
Petitioner alleges that equity infusions into Somisa by the government of Argentina
were on terms inconsistent with commercial considerations. In its response, the
government of Argentina stated that, as a result of the June 1975 devaluation which
negatively altered Somisa's financial structure, Somisa requested capital contributions
from the government. An agreement was worked out in 1976 that provided, in effect, a
capital infusion of U.S. $80 million. The terms of the agreement specified that Somisa
would obtain long/term loans totalling U.S. $80 million, and the government would pay
the debt in exchange for stock issued at par value. Through June 1983, the government
had contributed almost half the amount due Somisa under this agreement. This amount
was authorized by Decrees 2.887/78 and 1.832/81.
We also received information from the government and directly from Propulsora
concerning the government's equity participation in Propulsora. The Banco National de
Desarrollo (Banade), an entity controlled by the government of Argentina, participated
in the original issuance of Propulsora's share capital in 1969. Propulsora bought out the
bank's shares in 1980. The dollar price paid by Propulsora, which reflected an equivalent
annual rate of return of 9.3 percent, took into account the cash dividends received by the
bank and the alternative investment opportunities the bank could have undertaken.
In determining whether the government's equity participation in Somisa and Propulsora
was on terms inconsistent with commercial considerations, we followed the guidelines
outlined in Appendix II. After examining the financial ratios, operating profits or losses
and other relevant data found in each company's annual reports, we preliminarily
determine that Propulsora has been and continues to be a reasonable commercial
investment. Although it is not directly relevant to our determination, we note the fact
that the government- controlled bank received a 9.3 percent return on its investment,
reinforcing our preliminary determination that the equity infusion into Propulsora was
not on terms inconsistent with commercial considerations.
On the other hand, based on our review of Somisa's financial ratios, operating profits and
losses and other relevant data, we preliminarily determine Somisa was not a reasonable
commercial investment at the time of the 1976 agreement. We followed the methodology
outlined in Appendix II for calculating the countervailable benefit from equity infusions
made on terms inconsistent with commercial considerations when a firm's shares are not
publicly traded, and calculated an estimated net bounty or grant of 0.34 percent ad
valorem.
D. Loan Guarantees
Petitioner alleges the government of argentina has guaranteed loans to the steel
industry. In the responses, Propulsora indicated that, during the
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period of review,
one of its supplier credits was guaranteed by the banco Ciudad de Buenos Aires, a
government-controlled institution. Propulsora paid a guarantee fee to Banco Ciudad de
Buenos Aires that was higher than the guarantee fees it paid to private banks for
comparable supplier credits. Therefore, we preliminarily determine that the loan
guarantee to Propulsora does not confer a bounty or grant.
Somisa reported that the Secretary of Finance guaranteed a number of medium-term
loans during the period we consider Somisa to have been uncreditworthy. For purposes
of this preliminary determination, based upon our review of Somisa's financial
statements, access to non-guaranteed private debt and relevant financial ratios, we are
treating these guaranteed loans in the same manner as we treat loans to uncreditworthy
companies (see Appendix II). Under the methodology outlined in Appendix II, we would
compare the interest rate paid by the company to the sum of the highest interest rate
commonly available in Argentina and the risk premium. However, all but one of these
loans are denominated in U.S. dollars, and the interest rates are quoted as a percentage
above the London Interbank Offered Rate (Libor). Because these are non-peso loans with
nonArgentine interest rates, it would be inappropriate to apply Argentine interest rates in
calculating the benefits. Therefore, for purposes of this preliminary determination, we are
using the Libor rate in effect at the time the loan was awarded, plus the spread that
prevailed in argentina for medium-term loans denominated in U.S. dollars during that
time, plus the risk premium. Using this rate as the benchmark, we calculated a net bounty
or grant of 0.67 percent ad valorem.
II. Programs Preliminarily Determined Not To Confer Bounties or Grants
We preliminarily determine bounties or grants are not being provided to manufacturers,
producers, or exporters in Argentina of cold-rolled carbon steel sheet under the
following programs.
A. Subsidized Purchases of Inputs From Somisa
The petitioner alleges that Somisa, a state-owned company, offers semi- finished products
at special discounts to other Argentine steel producers, particularly Propulsora, who use
them to manufacture finished steel products for export.
Our information indicates that Propulsora purchases approximately 50 percent of its
input requirements for cold-rolled carbon steel sheet from Somisa. These purchases were
at prices comparable to those paid by Propulsora to its foreign suppliers. Furthermore,
we have no indication that Propulsora receives special discounts on purchases of inputs
intended for export production from Somisa. Consequently, we preliminarily determine
that Propulsora receives no countervailable benefits through its purchases of inputs from
Somisa.
B. Pre-Financing of Exports Through Dollar-Indexed Pesos
This program provides exporters with pre-export financing through peso loans
denominated in U.S. dollars. The loans are given in pesos but denominated in U.S. dollars
at the exchange rate prevailing at the time of the loan. Repayment must also be in pesos,
but the peso amount is established by the exchange rate prevailing at the time of
repayment. In addition to repaying the peso amount of the loan at the exchange rate
prevailing at the time of repayment, the borrower must also pay a one percent interest
rate.
The funds are drawn from the Central Bank of Argentina and then loaned through
private commercial banks to individual corporate borrowers. The Central Bank currently
limits these loans to 60 percent of the export's f.o.b. value. The maximum length of the
loan is 120 days, but repayment must take place no later than 60 days from the effective
export date. Prior to August 1981, the loans could be for 40 percent of the export's f.o.b.
value and for up to 90 days.
The government of Argentina states that Somisa used this program to finance its
exports during the period of review, while Propulsora did not. The government identified
one loan to Somisa that was outstanding during the period for which we are measuring
bounties or grants. When we compared what Somisa paid for this loan with what Somisa
would have paid for the same loan, using as the benchmark, the unregulated rate for
short-term commercial bank loans published by FIEL described supra, we found no
benefit. Therefore, we preliminarily determine that this program does not confer a
bounty or grant.
III. Programs Preliminarily Determined Not To Be Used
We preliminarily determine that the following programs listed in the notice of "Initiation
of Countervailing Duty Investigation," were not used by the manufacturers,
producers, or exporters in Argentina of cold-rolled carbon steel sheet.
A. Forgiveness or Assumption of Debt
Petitioner alleges there are indications that the Argentine government may have
undertaken to pay the interest on at least a portion of debt. The responses indicate the
government of Argentina has never forgiven or mandated, directly or indirectly, the
forgiveness of any debt or interest on debt contracted by Somisa or Propulsora, except
for the 1976 agreement with Somisa discussed in the section on "Government Equity
infusions" supra. Therefore, we preliminarily determine that, except for the 1976
agreement with Somisa, neither Propulsora nor Somisa has received countervailable
benefits as a result of direct or indirect government action to assume or forgive its debt.
B. Trade Promotion Programs
Petitioner alleges the Argentine steel industry receives countervailable benefits through
export promotion programs conducted by the government. The response indicates
neither Somisa nor Propulsora has participated in these programs.
C. Tax Incentives
Petitioner alleges the Argentine steel industry benefits from a variety of special tax
incentives, including those provided under the Industrial Promotion Law of 1977, special
treatment for state-owned enterprises, and certain exemptions available to firms locating
in specified areas of Buenos Aires Province. The response indicates neither Somisa nor
Propulsora has received benefits under these programs.
D. Pre-Financing of Exports Under Circular OPRAC 1-1
Circular OPRAC 1-1 instituted a pre-financing program for Argentine exports as a
alternative to the Circular RF 153 program for pre-financing of exports through dollar
indexed pesos described supra. This program was initiated on August 21, 1981, and
terminated on March 31. Under Circular OPRAC 1-1, loans could not exceed one year, and
firms receiving OPRAC 1-1 loans could not also receive Circular RF-153 loans. The
government of Argentina has indicated that Propulsora used this program, but that no
loans under Circular OPRAC 1-1 were outstanding during the period for which we are
measuring bounties or grants. Somisa did not use this program.
E. Multiple Exchange Rate System
Petitioner asked us to investigate whether the Argentine system of multiple exchange
rates operates to provide countervailable benefits based
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on export performance
to the steel industry.
In its response, the government of Argentina stated that a single exchange rate has been
in effect since November 1, 1982. Therefore, we preliminarily find no bounty or grant.
F. Additional Programs Not Alleged
In the notice announcing the initiaton of this investigation, we stated our intent to
investigate whether certain programs not specifically alleged by petitioner are providing
bounties or grants to manufacturers, producers or exporters in Argentina of cold-rolled
carbon steel sheet. The programs in question are:
Grants from the Government of Argentina.
Benefits provided under the Anti-Pollution Law of 1979.
Additional Reembolso for exports from southern ports.
Our decision to investigate these programs was prompted by experience developed in
prior Argentine investigations and our view that they might by relevant to this
investigation. After analyzing the questionnaire responses regarding these programs, we
preliminarily determine that these programs were not used by respondents.
IV. Programs for Which we Need Additional Information
A. Medium- and Long-Term Loans on Terms Inconsistent With Commercial
Considerations
Petitioner alleges that the Argentine steel industry, particularly Somisa, has benefited
from government programs providing medium- and long-term loans on terms
inconsistent with commercial considerations. It further alleges the Argentine Treasury
and the state-controlled Banco Nacional de Desarollo (Banade) are the primary sources of
such loans and cites several decrees and laws as authorizing these programs.
The response indicates that neither Somisa nor Propulsora has received medium- or
long-term loans related to any government regulations. In addition, the petition does not
provide sufficiently detailed information to determine preliminarily that specific loans,
on terms inconsistent with commercial considerations, were obtained under one of the
programs cited by the petitioner. Consequently we will seek additional information
regarding these programs.
B. Import Duty Exemptions
Petitioner alleges the Argentine steel industry benefits from preferential exemptions from
import duties on capital equipment and raw materials provided under the industrial
Promotion Law of July 1977.
The response indicates that although Somisa and Propulsora received some exemptions
from import duties, they did so on terms no different than for any other Argentine
industrial firm or industry. Since the drawback of duties on imported capital goods or
other items involved in the production but not physically incorporated in the exported
merchandise is countervailable, we will seek additional information on this program
before making our final determination.
C. Subsidized Inputs of Raw Materials and Capital Equipment
Petitioner alleges the Argentine steel industry receives indirect benefits as a result of
subsidies provided by the government to suppliers of raw materials and capital
equipment used by cold-rolled sheet producers. It specifically alleges that Decree 619
operates to direct benefits such as equity capital, loans, loan gurarantees and tax
deferrals to steel industry suppliers.
The response indicates that neither Somisa nor Propulsora purchases inputs from related
suppliers and that all such purchases are made from independent domestic and foreign
suppliers at prevailing market prices. We will seek additional information regarding this
allegation.
D. Labor Wage Subsidies
Petitioner alleges that recent wage freezes for public employees imposed by the
government of Argentina assure that state-owned firms like Somisa benefit from labor at
subsidized wages.
As a privately owned company. Propulsora is not subject to a wage freeze for public
employees. Somisa indicates that since it is governed by the laws and regulations
applicable to corporations, it too falls outside the coverage of the wage freeze. We will
seek additional information regarding Somisa's status with respect to laws and regulations
governing wages paid public employees.
Verification
In accordance with section 776(a) of the Act, we are directing the U.S. Customs Service to
suspend liquidation of all entries of cold-rolled carbon steel sheet from Argentina which
are entered, or withdrawn from warehouse, for consumption, on or after the date of
publication of this notice in the Federal Register and to require a cash deposit or bond for
each such entry of this merchandise in the amounts of 6.03 percent ad valoerm.
This suspension will remain in effect until further notice.
Public Comment
In accordance with section 355.35 of the Commerce Department Regulations, if
requested, we will hold a public hearing to afford interested parties an opportunity to
comment on this preliminary determination at 10 a.m. on March 23, 1984, at the U.S.
Department of Commerce, Room 3708, 14th Street and Constitution Avenue, N.W.,
Washington D.C. 20230. Individuals who wish to participate in the hearing must submit a
request to the Deputy Assistant Secretary for Import Administration, Room 3099B, at the
above address within 10 days of this notice's publication.
Requests should contain: (1) The party's name, address, and telephone number; 92) the
number of participants; (3) the reason for attending; and (4) a list of the issues to be
discussed. In addition, prehearing briefs in at least 10 copies must be submitted to the
Deputy Asssitant Secretary by March 20, 1984. Oral presentations will be limited to
issues raised in the briefs. All written views should be filed in accordance with 19 CFR
355.34, within 30 days of this notice's publication, at the above address and in at least 10
copies.
Alan F. Holmer,
Deputy Assistant Secretary for Import Administration.
February 3, 1984.
[FR Doc. 84-3701 Filed 2-9-84; 8:45 am]
BILLING CODE 3510-DS-M