| Maritime Products International
February 7, 2007
The Honorable Charles B.
Rangel
Chairman
House Committee on
Ways and Means
1102 Longworth House Office Building
Washington, DC 20515
Dear Chairman Rangel:
Maritime
Products International appreciates the opportunity to provide the House Ways and Means Committee with 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, Maritime strongly
opposes the practice of zeroing and agrees with the recent rulings from the
WTO’s dispute settlement body in the case United States – Laws, Regulations
and Methodology for Calcluating Dumping Margins (“Zeroing”) (WT/DS 294). We
believe that the Department of Commerce is correct in its policy of eliminating
zeroing – and should do so for all current and future cases.
Maritime
Products International is a family owned and operated seafood company with its
home office in Newport News, Virginia. My great-grandfather began our family’s
legacy in the seafood industry as a Virginia oyster producer over 100 years ago
and we have now evolved into a global provider working to distribute over 20
million pounds of frozen seafood annually to supermarkets, restaurants and
further-processors across the United States. We directly import various
seafood from all over the world and help distribute a variety of sustainable
domestically produced items as well. The positive economic impact of our
company and others like us can be measured in various ways – from the number of
employees in our offices to increased business in a variety of sectors
including port activities, domestic transportation, national warehousing,
banking, insurance and several other service sectors.
Seafood
in general is among the most globally traded of all commodities. Many of our
nation’s seafood companies, including Maritime Products, also export a variety
of products to growing markets in Asia and the European Union. In term of
domestic consumption of seafood, with approximately 80% of the seafood
Americans eat today being imported – the issue of a more liberalized
international trade environment is of significant importance to the continued
economic growth of the seafood community as well as consumers in every region
of the country.
Approximately
1,000 U.S. firms, including Maritime Products, are somehow involved in the
business of importing fish and shellfish today. Top imports include shrimp,
salmon, tilapia and tuna with numerous other opportunities for continued growth
in our industry every year. American consumers in every economic category
enjoy seafood from more than 130 nations including Canada, Thailand, China, South Africa, Chile and Mexico. A significant proportion of imports come from
ocean harvests and an increasing percentage is arriving each year through
well-managed aquaculture – particularly in developing nations.
Maritime Products is pleased that the Committee
is taking the time to closely 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 methodology is one of our company’s
continuing challenges to securing cost effective and high quality seafood for
further processing and distribution to the U.S. consumer. By complying with
the WTO and eliminating the practice of zeroing, the U.S. 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 of a dumping
margin calculation, and not individual sales transactions. As the demand for
quality 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.
Seafood in
general continues to be recognized scientifically as one of the most healthy
food options available, and the federal government has done a nice job helping
encourage Americans to consume seafood at least twice a week for its many
health benefits. We should be working toward making heart-healthy seafood
products more available and affordable to the average American family.
Putting an end to the practice of zeroing is one more important step in this
direction.
Once again,
Maritime Products 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 to zeroing. We encourage you to use the
seafood example when working to highlight the unintended negative impacts that
the practice of zeroing has on various U.S. economic interests, the U.S. manufacturing sector specifically and the American consuming public in general.
Please do not
hesitate to contact me – Matthew Fass, President of Maritime Products
International
- with any questions.
Sincerely,
Matthew Fass
President
| 
