| King & Prince Seafood Corporation
Brunswick, Georgia 31521
February 7, 2007
Honorable Charles B. Rangel
Chairman
House Committee on
Ways & Means
1102 Longworth House
Office Building
Washington, D.C. 20515
Dear Chairman Rangel,
King & Prince Seafood
Corporation appreciates the opportunity to provide the House Ways and Means
Committee with written comments on proposed modifications to the U.S.
Department of Commerce’s calculation of weighted average dumping margins, or
(“Zeroing”) in investigations and administrative reviews. Specifically, we
oppose the practice of zeroing and agree with the rulings and regulations of
the World Trade Organizations Dispute Settlement Body. In the dispute “United
States – Laws”, regulations and methodology for calculating dumping margins
(“Zeroing) (WT/DS294), we believe the Department of Commerce is correct in
its policy of eliminating zeroing and should do so for all current and future
cases.
The King & Prince
Seafood Corporation is a leading manufacturer of value added seafood for
foodservice restaurants and other foodservice operations. We have been
producing seafood products for fifty-seven years and in 2005 we employed 1017
people. Due to the market disruptions caused by the anti-dumping duties on
shrimp from major exporting countries, our employment has decreased to 747, a
27% reduction. Our company and other domestic processors of value added seafood
have moved the production of millions of pounds of breaded shrimp off shore. In
our case it cost 270 jobs and this number will increase as more production
moves off shore because these tariffs. Tariffs that were computed in a
methodology ruled illegal by the WTO.
Companies like ours rely on
the ability to acquire supplies and raw materials at competitive prices.
Excessive taxation in the form of antidumping duties makes it much harder to
compete, and permits the entrance into the market of more competitive foreign
producers. The entry of these foreign businesses costs Americans their jobs.
Fish and seafood products
are among the most globally traded of all commodities. Our products are
exported to Mexico, the United Kingdom, Canada, and other foreign countries in
Europe and the Caribbean. Since nearly 80% of seafood that Americans eat is
imported, the issue of a more liberalized international trade environment is of
key and strategic importance to King & Prince Seafood and our customers.
King & Prince Seafood is
pleased that the committee is taking time to look closely at and examine the
challenges associated with the WTO - illegal practice of zeroing in which negative
price comparisons are inaccurately treated as though they were zero. This
practice is one of the U.S. Seafood communities continuing challenges to secure
cost effective and safe fishery products from the International market for
processing and distribution to the U.S. consumer. By complying with the WTO
and eliminating the practice of zeroing, the United States will be working
toward a more accurate implementation of the WTO antidumping agreement by
concluding that a product “as a whole” under review is the subject and not
individual sales transactions. Because the demand for fresh seafood continues
to rise in our country, we must be vigilant that the global economy remains
fair and open to importing as well as exporting.
At a time when the Federal
Government is encouraging Americans to consume seafood at least twice a week
for many health benefits, we should be working toward making heart healthy
seafood products more readily available and affordable to the average American
family. It is time for our government to put an end to the practice of zeroing
so we can take one more important step in this direction.
Once again, King &
Prince Seafood would like to register our opposition to zeroing. We strongly
encourage the committee to work with its colleagues in the senate and the
administration to ensure our nation is complaint with the WTO rules to which we
agree, by putting an end to zeroing.
We encourage you to use the
Seafood example when working to highlight the unintended negative impacts that
the practice of zeroing has had on the U.S. manufacturing sector specifically
and the U.S. consuming public in general.
Please fee free to contact
me directly should you or your staff have any additional questions.
Sincerely,
Russell S. Mentzer
President & CEO
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