| Pacific
Seafood
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,
Pacific Seafood 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.
Pacific Seafood encompasses
processing, distribution, importing, exporting, marketing and transportation of
fresh and frozen seafood nationally and internationally. As the largest
independently owned and vertically integrated seafood company in North America,
we own and operate processing and distribution facilities from Alaska to
Northern California and Salt Lake. Headquartered in Clackamas, Oregon, Pacific
Seafood employs over 800 people.
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 Pacific Seafood,
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.
Pacific 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 Pacific Seafood’s
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, Pacific Seafood 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 me at the contact information
below with any questions.
Sincerely,
Miles Atchison
Central
Procurement
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