| Berdex
Seafood, Inc.
San Francisco, California 94111
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,
Berdex
Seafood, 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 National Fisheries
Institute, of which we are a member, 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.
We have been in business
since 1989, based in California with sales offices in San Francisco, New Jersey and Washington and import approx. 350 containers for frozen seafood per year,
mainly from Thailand, with a yearly sales of approx. $44 Mill.
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 Berdex 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.
Berdex Seafood, Inc. 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 Berdex Seafood, Inc 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 selecting individual sales transactions that fit the
pattern of dumping. 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, Berdex Seafood,
Inc would like to register their 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
Peter Dekker, Controller of Berdex Seafood, Inc., with any questions.
Sincerely,
Peter Dekker
Controller | |