| Mseafood Corporation
February 7, 2007
The Honorable Charles B. Rangel
Chairman
House Committee on Ways and Means
1102 Longworth House Office Building
Washington, D.C. 20515
Dear Chairman Rangel,
Mseafood Corporation appreciates
the opportunity to provide the House Ways and Means Committee with written
comments on proposed modification to the U.S. Department of Commerce’s
calculation of weighted average dumping margins, or “zeroing”, in
investigations and administrative reviews. Specifically, the NFI strongly
opposes the practice of zeroing and agrees with the rulings and regulations of
the World Trade Organization’s World 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.
Mseafood Corporation is a private held seafood
importer that has been in business for over 3 years. We are located in Garden
Grove, California and employ four people. We have seen out bottom line
profitability negatively impacted as a result of the April dumping suit on
shrimp. Our seafood import exceeds 100 million on an annual basic.
Fish and seafood products are among the most globally traded
of all commodities. Many of our nation’s large seafood companies export two
thirds of their products to the European Union and Asia. And since nearly
eighty percent of seafood that Americans eat is imported, the issue of a more liberalized
international trade environment is of key and strategic importance to the
seafood community and its consumers.
Approximately 1,000 U.S. firms, including Mseafood
Corporation, are in the business of importing fish and shellfish. Top
imports included shrimp, salmon, tilapia, and tuna. American families enjoy
seafood products from more than 130 nations. Major sources include Canada,
Thailand, China, Ecuador, Chile and Mexico. Although a large proportion of
imports are from ocean harvests, an increasing percentage is produced through
aquaculture, particularly in developing nations.
Mseafood Corporation 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 Mseafood
Corporation continuing challenges to securing 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 towards a more accurate
implementation of the WTO Antidumping Agreement by concluding that a product
“as a whole” under review is the subject of a dumping margin calculation, and
not individual sales transactions. As the demand for fresh seafood continues
to rise in our country, we must be vigilant in ensuring that the global economy
remains fair and open to our importers, as well as our exporters.
At a time when the federal government is encouraging
Americans to consume seafood at least twice a week for its many health
benefits, we should be working towards 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, Mseafood Corporation would like to
register our opposition to zeroing. We strongly encourage the Committee to work
with its colleagues in the Senate and with the Administration to ensure our
nation is compliant with the WTO rules to which we agreed by putting an end
zeroing. We encourage you to use the seafood example when working to highlight
the unintended negative impacts that the practice of zeroing has on the U.S.
manufacturing sector specifically and the American consuming public in general.
Please feel free to contact George Ngo – Importing Manager with any questions.
Sincerely,
George Ngo
Importing Manager
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