| Atlantic Seacove Inc.
Boston, Massachusetts 02118
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,
Atlantic Seacove Inc 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.
Atlantic Seacove Inc 20 Newmarket Square Boston 02118
24 employees established 1955
.
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 Atlantic
Seacove, 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.
Atlantic Seacove 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 Atlantic Seacove 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, Atlantic Seacove 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.
Sincerely,
John Wojtasinski
President
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