| Association of Equipment Manufacturers
February 7, 2007
The
Honorable Charles B. Rangel
Chairman
Committee
On Ways And Means
1102
Longworth House Office Building
Washington
D.C. 20515
Dear
Mr. Chairman:
On
behalf of the Association of Equipment Manufacturers (AEM), I am writing to
address support to abandoning the WTO-illegal
practice of “zeroing,” in which “negative” price comparisons are inaccurately
treated as though they were zero.
AEM is the North American-based
international trade group providing innovative business development resources
for manufacturers of equipment, products and services used worldwide in the
construction, agriculture, forestry, mining and utility fields. AEM also owns
or co-owns and produces several international trade exhibitions which are the
industry leaders for their market segments.
AEM
supports free and fair trade and recommends that the Department of Commerce
eliminates this practice in original investigations and adhere to its WTO
obligations. The WTO decisions on zeroing are entirely in keeping with the
letter of the WTO Antidumping Agreement, properly concluding that a product “as
a whole” under investigation or review is the subject of a dumping margin
calculation, and not individual sales transactions.
The
effect of zeroing significantly impacts the systemic overestimation of dumping
margins and subsequent application of inflated antidumping duties. The WTO has
ruled in multiple cases against the U.S. for the illegal practice of zeroing
and it’s time for the U.S. to practice what it teaches other nations to do,
level the playing field and compete fairly. Having countries play by the rules
reduces red tape, reduces corruption, and provides greater certainty and
transparency for exporters, importers, and consumers.
The
U.S. Trade Representative Susan C. Schwab announced recently that the United
States has requested World Trade Organization (WTO) dispute settlement
consultations with the People’s Republic of China (China) regarding its
provision of subsidies that appear to be prohibited by WTO rules. “We are
committed to challenging China’s WTO-inconsistent practices that harm American
workers and businesses,” said Ambassador Schwab. “China’s use of
market-distorting subsidies creates an uneven playing field and subverts
China’s own efforts to foster consumption-led growth.” If America wants
countries like China to play fair, we have to be that example of a country
living up to its WTO commitments. When America fails to do so, what
obligations do other countries have to open its market and reform its trade
practices?
AEM
urges the Department of Commerce to continue being fair traders by abandoning
zeroing in all phases of antidumping proceedings, including investigations,
administrative reviews, sunset reviews and changed circumstances reviews. American
has established a reputation of being leaders in the global community and it
can’t continue this tradition refusing to fore fill its WTO obligations while
expected other to do so.
I thank you in advance for the
consideration of our recommendations as you begin to discuss this matter in the
weeks ahead. AEM looks forward to working with you to address any of our above
recommendations and providing further information.
Sincerely,
Dennis
J. Slater
President
and Secretary
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