Ministry of Commerce: Imposing anti-dumping duties on some steel pipes originating in the United States and the European Union

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 Ministry of Commerce: Imposing anti-dumping duties on some steel pipes originating in the United States and the European Union


[Publishing Unit] Ministry of Commerce of the Peoples Republic of China

Announcement No. 24, 2019

[Release Date] 2019-6-14

On May 9, 2014, the Ministry of Commerce issued Announcement No. 34 of 2014, which decided to impose anti-dumping duties on imported alloy steel seamless steel pipes originating in the United States and the European Union for a period of five years from May 10, 2014.

On June 15, 2018, the Ministry of Commerce issued Announcement No. 52 of 2018 in response to the domestic application for the seamless steel pipe industry of alloy steel for high temperature compression. It decided to review the anti-dumping measures applied to the imported seamless steel pipe of alloy steel for high temperature compression originating in the United States and the European Union during the period of dumping and dumping margin. On May 9, 2019, the Ministry of Commerce issued Announcement No. 20 of 2019, deciding to conduct a final review and investigation on the anti-dumping measures applicable to the imported alloy steel seamless steel tubes for high temperature compression originating in the United States and the European Union from May 10, 2019.

During the period of review and investigation, the products range from alloy steel seamless steel pipes originating in the United States and the European Union for import-related high-temperature compression. The specific description is consistent with the product description stipulated by the Ministry of Commerce Announcement No. 34 of 2014. Specifically as follows:

Name of products investigated: Seamless alloy steel pipe for high temperature and pressure bearing, also known as P92 seamless steel pipe, 10Cr9MoW2VNbBN seamless steel pipe, X10CrWMoVNb9-2 seamless steel pipe, etc.

English Name: Certain Alloy-SteelSeamless Tube and PipesforHighTemperature and Pressure Service.

Specific Description: Outer diameter 127 mm (including 127 mm), chemical composition (wt%) carbon (C) content greater than or equal to 0.07 and less than or equal to 0.13, chromium (Cr) content greater than or equal to 8.5 and less than or equal to 9.5, molybdenum (Mo) content greater than or equal to 0.3 and less than or equal to 0.6, tungsten (W) content greater than or equal to 1.5 and less than or equal to 2.0, tensile strength greater than 620 MPa, yield strength greater. Seamless steel tubes of alloy steel equal to 440 MPa, whether or not further processed.

Main Applications: The alloy steel seamless steel tubes for high temperature and pressure bearing have strong high temperature strength and creep resistance. They are mainly used in supercritical and supercritical power plant boilers and steam and water pipelines.

The product is classified in the Import and Export Taxes of the Peoples Republic of China: 73045110, 73045190, 73045910 and 73045990. Other steel pipe products under the above-mentioned tax code which do not conform to the specific description of the products under investigation do not fall within the scope of this investigation.

According to the results of the investigation, the Ministry of Commerce proposes to the Tariff and Tax Commission of the State Council the implementation of anti-dumping measures. In accordance with Article 50 of the Anti-dumping Regulations of the Peoples Republic of China and the decision of the Tariff and Tax Commission of the State Council, the Ministry of Commerce announces the relevant matters as follows:

I. Re-examination of rulings

The Ministry of Commerce has ruled that the imported alloy steel seamless steel pipes originating in the United States and the European Union have been dumped during the review period.

II. Anti-dumping Measures

In accordance with the relevant provisions of the Anti-dumping Regulations of the Peoples Republic of China, the Tariff and Tax Commission of the State Council has decided to levy anti-dumping duties on import-related high-temperature pressure alloy steel seamless steel pipes originating in the United States and the European Union at the following rates from June 14, 2019:

American Company

1. Wieman Gordon Forging Co., Ltd. 101.0%

(Wyman-Gordon Forgings, Inc.)

2. Other American companies 147.8%

(Allothers)

European Union Corporation

1. Valluric German Company 57.9%

(Vallourec Deutschland GmbH)

2. Valurique French Steel Pipe Company 57.9%

(VALLOURECTUBESFRANCE)

3. IBF Italy 60.8?%

(IBFS.P.A.)

4. Other EU companies 60.8?%

(Allothers)

III. Methods of levying anti-dumping duties

Since June 14, 2019, import operators shall pay corresponding anti-dumping duties to the Customs of the Peoples Republic of China when importing high-temperature pressure alloy steel seamless steel pipes originating in the United States and the European Union. Anti-dumping duties are levied at ad valorem tariff of customs-approved dutiable price. The calculation formula is as follows: anti-dumping duty amount = customs dutiable price * anti-dumping duty rate. Value-added tax in import link is levied on ad valorem basis with customs-approved customs value plus tariffs and anti-dumping duties.

IV. Administrative Reconsideration and Administrative Litigation

According to the provisions of Article 53 of the Anti-dumping Regulations of the Peoples Republic of China, those who refuse to accept the decision of review may apply for administrative review according to law or bring a lawsuit in a peoples court according to law.

5. This bulletin shall be implemented as of June 14, 2019.

Ministry of Commerce of the Peoples Republic of China

June 14, 2019

Enclosure

Ruling of the Ministry of Commerce of the Peoples Republic of China on the Dumping and Dumping Range Period of Import-related Seamless Alloy Steel Pipes for High Temperature Pressure Used in the United States and the European Union

In accordance with the provisions of the Anti-dumping Regulations of the Peoples Republic of China (hereinafter referred to as the Anti-dumping Regulations) and the Regulations of the Ministry of Commerce on the Review of Dumping and Dumping Range Period, on June 15, 2018, the Ministry of Commerce (hereinafter referred to as the investigative organ) issued a case filing announcement, deciding to suit the import-related seamless steel tubes of high temperature bearing steel (hereinafter referred to as the products under investigation) originating in the The anti-dumping measures are used to conduct a review investigation during the period of dumping and dumping margin.

The investigating organ has investigated the dumping and the extent of dumping of the products under investigation during the period of review and investigation. Based on the results of the investigation, and in accordance with the provisions of the Anti-dumping Regulations and the Rules for Review of Dumping and Dumping Range Period, the investigating organs make the following decisions for review:

I. Investigation Procedure

(1) The original anti-dumping measures.

On May 9, 2014, the Ministry of Commerce issued Announcement No. 34 of 2014, which decided to impose anti-dumping duties on imported alloy steel seamless steel pipes originating in the United States and the European Union for a period of five years from May 10, 2014. Among them, the anti-dumping rate applied by American companies is 14.1%, and that applied by European companies is 13.0% - 13.2%. On May 9, 2019, the Ministry of Commerce issued Announcement No. 20 of 2019, deciding to conduct a final review and investigation on the anti-dumping measures applicable to the imported alloy steel seamless steel tubes for high temperature compression originating in the United States and the European Union from May 10, 2019.

(2) Application for reexamination.

On May 10, 2018, Inner Mongolia Northern Heavy Industry Group Co., Ltd. (hereinafter referred to as the applicant) submitted an application to the Ministry of Commerce, advocating that after the implementation of anti-dumping measures, the import-related high-temperature pressure alloy steel seamless steel pipes originating in the United States and the European Union still have dumping, and the dumping extent has further increased, which has obviously exceeded the current applicable anti-dumping tax rate, and requests that the seamless steel pipes originating in the United States be dumped The anti-dumping measures applied to seamless steel tubes made of alloy steel for high temperature and pressure imported by China and EU shall be reviewed and investigated during the period of dumping and dumping margin.

According to Article 49 of the Anti-dumping Regulations and the Re-examination Rules for Dumping and Dumping Range Period, the investigating authorities have examined the qualifications of the applicants, the export prices and normal values of the products under investigation, and the necessity of continuing to implement anti-dumping measures in accordance with the form and level of the original measures.

(3) Notification before filing a case.

On May 14, 2018, the investigating authorities notified the U.S. Embassy in China and the European Union Mission in China about the application for review during the period of dumping and dumping margin, and transmitted to them the open text of the application for review during the period and the non-confidential summary of the confidential information.

(4) Comments on the filing of a case.

On May 31, 2018, the European Commission applied to the investigative authorities for an extension of submission of comments and stated the relevant reasons. After examination, the investigating organ agreed to grant an appropriate postponement. On June 11, 2018, the European Commission submitted comments to the Ministry of Commerce. It disagreed with the European market prices, dumping margins and domestic industrial damage in the application. It argued that the European market prices quoted in the market survey report in the application were not in line with the actual situation. In the opinion of the investigating authorities, the comments of the European Commission did not specify the source of relevant data or provide other evidence to support it, while the applicant provided relevant information that could be reasonably obtained. In addition, this review only reviews the anti-dumping measures applied to the products under investigation during the period of dumping and dumping margin, and does not investigate the damage to the industry.

(5) Filing a case.

After examination, the investigating organ considers that the application meets the filing conditions stipulated in the Anti-dumping Regulations and the Rules for Review of Dumping and Dumping Range Period.

On June 15, 2018, the Ministry of Commerce issued a bulletin, deciding to review the anti-dumping measures applied to seamless steel tubes made of alloy steel for high-temperature compression originating in the United States and the European Union during the period of dumping and dumping margin. On the same day, the investigating authorities notified the U.S. Embassy in China, the European Union Mission in China, the U.S. and European Union companies and applicants listed in the application, and made public the non-confidential version of the application submitted by the applicant through the website of the Ministry of Commerce and the Trade Relief Public Information Reference Room of the Ministry of Commerce.

Within the specified time, the European Union delegation to China, Wyman-Gordon Forgings, Inc., Vallourec Deutschland GmbH, VALLOURECTUBESFRANCE and IBF of Italy (IBFS.P.A.) registered with the investigating authorities to participate in the investigation.

(6) Questionnaire survey.

On July 6, 2018, the investigative authorities sent questionnaires to American and European companies registered to participate in the survey, and published the questionnaires through the website of the Ministry of Commerce.

Within the prescribed time, Wieman Gordon Forging Co., Ltd., Wallerick Germany Co., Wallerick French Steel Tube Co., Ltd., and IBF Co. of Italy applied to the investigative authorities for an extension of the submission of the answer sheet and stated the relevant reasons. After examination, the investigating organ agreed to grant an appropriate postponement. Within the prescribed time, the investigative authorities received the questionnaire submitted by the four companies. On January 31, 2019, Wieman Gordon Forging Co., Ltd. of the United States submitted a reply to supplementary questions to the investigation authorities.

(7) Receiving comments from stakeholders.

On August 20, 2018, Wallerick German Company and Wallerick French Steel Pipe Company submitted their Preliminary Opinions on the Anti-dumping Investigation of Seamless Steel Pipes Made of Alloy Steel for High Temperature and Pressure. The commentary argues that the European market price data in the application form are not factual and that the applicant did not disclose the source of his Market Research on the grounds of confidentiality. After examination, the investigating organ considers that the data and evidentiary materials provided by the application conform to the relevant provisions of the Anti-dumping Regulations and the Rules for the Review of Dumping and Dumping Range Period, and the confidentiality requests and non-confidentiality summaries conform to the relevant provisions of the Anti-dumping Regulations and the Rules for the Review of Dumping and Dumping Range Period.

On November 30, 2018, the Valurik Group met with the investigative authorities on the case.

On January 10, 2019, Valurik submitted a statement of his visit to the Ministry of Commerce.

On April 29, 2019, the Valluric Group met with the investigative authorities on the case.

(8) On-the-spot verification.

In order to verify the completeness, authenticity and accuracy of the materials submitted by the company, the investigative authorities carried out on-the-spot inspections on the French Steel Pipe Company and the German Steel Pipe Company of Wallerick from 15 to 20 February 2019, on-the-spot inspections on the Italian IBF Company from 25 to 26 February, on-the-spot inspections on the Wieman Gordon Forging Co., Ltd. of the United States from 28 February to 1 March, and from 13 to 15 March 2009. Japan carried out on-the-spot verification on Vallurick (China) Co., Ltd., an affiliated company of Vallurick Group in Changzhou.

During the period of verification, the investigating organ inquired the financial, sales, production and management personnel of the company being checked, and investigated the completeness, authenticity and accuracy of the materials submitted by the company. The investigating organ has checked the overall situation of the company, the sales of similar products of the products under investigation in the country (region), the export sales of the products under investigation to China, the cost of producing the products under investigation and the related expenses of the products under investigation. On May 23, 2019, the investigative authorities disclosed the basic facts of on-site verification to the company being verified.

The investigative organs have considered the materials and information collected in the field verification according to law in their rulings.

(9) Disclosure before adjudication.

According to the Anti-dumping Regulations and the Interim Rules for Disclosure of Anti-dumping Investigation Information of the Ministry of Commerce, on May 23, 2019, the investigative authorities disclosed and explained the basis for calculating the dumping margin to the US Embassy in China, the European Union Mission in China, the Wieman Gordon Forging Co., Ltd., the Wallerick German Company, the Wallerick French Steel Pipe Company and the Italian IBF Company. This fact, and give them the opportunity to comment. On June 3, 2019, Wieman Gordon Forging Co., Ltd., Wallerick Germany Co., Wallerick French Steel Tube Co. and IBF Co. of Italy submitted their comments on the disclosure to the investigating authorities. The investigative organs have considered the relevant comments.

(10) Publicizing information.

According to the Provisional Rules for Access to Public Information in Anti-dumping Investigation of the Ministry of Commerce, the investigating organs shall send all the public materials in the course of investigation to the Trade Relief Public Information Reference Room of the Ministry of Commerce in time for searching, reading, extracting and copying by various stakeholders.

II. Investigated Products

The product range of this review survey is imported alloy steel seamless steel tubes originating in the United States and the European Union. The specific description is consistent with the product description stipulated by the Ministry of Commerce Announcement No. 34 of 2014.

Name of products investigated: Seamless alloy steel pipe for high temperature and pressure bearing, also known as P92 seamless steel pipe, 10Cr9MoW2VNbBN seamless steel pipe, X10CrWMoVNb9-2 seamless steel pipe, etc.

English Name: Certain Alloy-SteelSeamless Tube and PipesforHighTemperature and Pressure Service.

Specific Description: Outer diameter 127 mm (including 127 mm), chemical composition (wt%) carbon (C) content greater than or equal to 0.07 and less than or equal to 0.13, chromium (Cr) content greater than or equal to 8.5 and less than or equal to 9.5, molybdenum (Mo) content greater than or equal to 0.3 and less than or equal to 0.6, tungsten (W) content greater than or equal to 1.5 and less than or equal to 2.0, tensile strength greater than 620 MPa, yield strength greater. Seamless steel tubes of alloy steel equal to 440 MPa, whether or not further processed.

Main Applications: The alloy steel seamless steel tubes for high temperature and pressure bearing have strong high temperature strength and creep resistance. They are mainly used in supercritical and supercritical power plant boilers and steam and water pipelines.

The product is classified in the Import and Export Taxes of the Peoples Republic of China: 73045110, 73045190, 73045910 and 73045990. Other steel pipe products under the above-mentioned tax code which do not conform to the specific description of the products under investigation do not fall within the scope of this investigation.

III. Review and Investigation Period

The dumping investigation period for this review is from April 1, 2017 to March 31, 2018.

IV. Dumping and Dumping Range

(1) Normal value, export price, adjustment items and CIF price.

American Company

Wyman-Gordon Forgings, Inc.

1. Normal value.

The investigative authorities have examined the type classification of the products under investigation and similar products of the company. In the answer sheet, the company advocated that the products under investigation and similar products should be single model products. After examination, the investigating organ decided to accept the companys proposition on product type classification.

Investigators reviewed the companys sales of similar products in the United States. After review, the company did not sell in the United States during the review period. According to Article 4 of the Anti-dumping Regulations, the investigating organ decides to determine its normal value by means of production cost plus reasonable expenses and profits.

The investigative organ has examined the production cost and cost data submitted by the company.

Regarding the cost of raw materials, the questionnaire shows that the company uses the standard cost method to calculate the production cost of the products investigated. The cost of raw materials in tables 6-1 and 6-4 is the standard cost, and the actual cost of raw materials in tables 6-3 is adjusted by the standard cost. During the on-site inspection, the company stated that the adjustment ratio used in Table 6-3 was the difference rate between the actual purchase cost of raw materials and the standard cost of all products of the company. During the on-site inspection, the company also indicated that the actual cost and standard cost of raw material procurement could be inquired from the companys financial system for each product under investigation sold. In the course of verification, the investigating authorities randomly selected the purchase records of raw materials during the investigation period. In its comments on the disclosure of basic facts, the company argued that the difference rate used in the answers was consistent with the General Accounting Standards of the United States and with the companys financial statements, which reasonably reflected the costs associated with the production and sale of the products under investigation. According to the investigation authorities, the actual cost of raw materials for the products under investigation and similar products is clearly required in the questionnaires 6-1 and 6-4. The company does not provide the actual cost in the case of the actual purchase cost of raw materials. Although the standard cost is adjusted to the actual cost in Table 6-3, the standard cost is adjusted by using the overall difference rate of the company mentioned above. Investigators do not deny that the difference rate used in the questionnaire is the overall difference rate of the company, which conforms to the General Accounting Standards of the United States and the companys financial statements, but the consistency and consistency are the overall difference rate of the companys products. There are many kinds of products in the company, and the products under investigation are only one of the products of the company. Based on the purpose of the anti-dumping investigation of the products under investigation, the investigating organ believes that the adjustment of the standard cost of the products under investigation by the overall difference rate distorts the actual cost of the raw materials under investigation and cannot reasonably reflect the cost related to the production and sale of the products under investigation. The investigating authorities decided to use on-the-spot verification to check the actual cost of raw materials procurement and the standard cost variance rate of raw materials in Table 6-3.

In its comments on the disclosure of the basic facts of the award, the company also argued that the discrepancy rate of the transaction did not conform to the companys actual and verified cost data. In this regard, the investigation authorities believe that the questionnaire clearly requires the actual cost of the products and raw materials of the same kind of products to be investigated. The investigation authorities also extended the response to the companys request, but the company did not provide the actual purchase cost as required by the questionnaire. Before the onset of on-site verification, the investigative authorities took the initiative to ask the company whether minor corrections were made to the contents of the answer sheet, and the company did not submit the actual procurement cost. The investigating organ considers that the actual procurement cost is the necessary information for the investigation. The company does not provide the necessary information in the presence of actual specific information, but the actual situation discovered by the investigating organ after on-the-spot verification. Moreover, by comparing the actual procurement cost found in the field verification, the investigating authorities found that the overall difference rate used in the companys questionnaire 6-3 was contrary to the adjustment direction of the standard cost by the actual procurement cost found in the verification. The method used in the questionnaire artificially resulted in the underestimation of the cost of the products under investigation and the raw materials of the same kind of products. After examination, in accordance with Article 21 of the Anti-dumping Regulations, considering that the company has relevant investigation information but has not provided the above-mentioned information truthfully, the investigating organ considers that the difference rate between the actual cost and standard cost of a raw material procurement with the largest number of transactions extracted on the spot is the difference rate calculated by the largest transaction procurement volume, and it is the actual and process of the company. For the cost data of verification, the investigating organ decides to use the standard cost of raw materials in Table 6-3 of the variance rate adjustment.

Regarding the commissioned processing profit, the questionnaire clearly requests that all related companies of the company concerned with the production and sale of the products under investigation be provided, and that the activities of the related companies in the process of producing and selling the products under investigation be explained. In the original questionnaire, the company said that there were three subsidiaries, but they had nothing to do with the production of the products under investigation. Under the supplementary questioning from the investigating authorities, the company pointed out in the supplementary reply that a subsidiary company provided processing services for some products, but did not specify the specific relationship between the aforementioned activities and the products under investigation. In the field verification, the investigating authorities should ask that the company explain that the subsidiary company is an independent legal entity and provides processing services for the products under investigation, but the subsidiary company is recorded in the companys accounting system as a cost center. After review, the company did not report the commissioned processing profit in Tables 6-3 and 6-4. In its comments on the disclosure of the basic facts of the ruling, the company maintains that the subsidiary company is an independent legal person on the spot, but does not operate independently. It is unreasonable for the company to pay the cost and expenses of the subsidiary company for the processing of incoming materials. It is also unreasonable for the company to incorporate the processing profit into the production cost. It is also unreasonable to calculate the profit by the manufacturing cost reported in Table 6-3. The investigating organ considers that the company and the subsidiary company are independent legal persons whether they operate independently or not. The transactions between them, including the entrusted processing transactions, should be handled in accordance with the principle of dealing with the independent enterprises. According to the usual commercial practices, the entrusted processing party, in addition to recovering the entrusted processing costs, also needs to collect reasonable processing profits, and lacks the investigated products with the entrusted processing profits. The production cost of similar products is incomplete. Moreover, it is necessary for affiliated subsidiaries to provide incoming processing services for the products under investigation. Although the company has the information, it does not provide the necessary information truthfully in the replies and supplementary replies. Before the onset of field verification, the investigating authorities asked the company whether it had made minor corrections to the contents of the answers, and the company did not mention the situation. It was the actual situation discovered by the investigating authorities after field verification that the actual situation had seriously hindered the investigating authorities from further grasping the whole situation of the subsidiary companys processing services for the products under investigation. Condition. After examination, in accordance with Article 21 of the Anti-dumping Regulations, considering that the company has mastered the information of the investigation but has not provided it truthfully and seriously hinders further investigation, the investigating organ decided to determine the commissioned processing profit based on the manufacturing cost and cost-profit margin provided by the companys response sheet, and accordingly adjusted the production cost of the same kind of products of the company under investigation.

For other production costs, the investigative authorities decided to accept the data submitted in the questionnaire 6-3.

Regarding expenses, the answer sheet shows that the management expenses and sales expenses in Table 6-5 are indirect expenses, and the company shares them among products and sales markets according to sales revenue. For the bad debts in the management fees (negative costs, actual revenue), the company allocates the proportion of sales revenue to all products in the companys sales markets. During the on-site inspection, the company explained that it was actually transferring bad debts to an American customer, involving the sale of other products of the company. After examination, the investigating organ believed that the content of bad debts had nothing to do with the products under investigation and should not be apportioned to the products under investigation and similar products. The investigating organ decided not to accept the content. For other costs, the company does not sell similar products in the United States. In the field inspection, the investigative authorities found that the company sells P91 steel pipes in the United States, and extracted the sales price and cost data as verification materials. In its comments on the disclosure of the basic facts of the ruling, the company maintains that P91 steel pipe is not a product under investigation, different from P92 steel pipe. There is no reason to calculate P92s sales and management expenses based on P91 data. P92s sales and management expenses exported to China should be used instead of P92s domestic sales and management expenses. In this regard, the investigation authorities do not deny that there are differences between P91 steel pipe and P92? Steel pipe, and that P91 steel pipe is not the product under investigation. Investigators believe that since P92 is not sold in the United States, but in China, the company does not have actual data on the costs associated with the production and sale of P92 steel pipes in the United States. It is unacceptable that the company advocates using the relevant fees of P92 exported to China as the domestic related fees in the United States, which is inconsistent with the purpose of domestic related fees that need to be sought here for the normal value of the structure. After further investigation, the investigating authorities believe that although there are differences between P91 steel pipe and P92 steel pipe, both P91 steel pipe and P92 steel pipe belong to the same business department of the company and use the same production equipment, which are produced through similar processes and have similarities in sales purposes. They belong to the same category of products. The company produces and sells P91 steel pipe in the United States. The amount of related expenses incurred represents the actual amount produced and realized by the company in producing and selling the same kind of products in the domestic market. Therefore, the investigating organ decided to use the amount of other expenses that should be apportioned in the sale of P91 steel pipes during the verification as the cost amount of the normal value of the structure in the adjudication.

With regard to profit margin, in the field verification, the investigative authorities found that the company sold P91 steel pipe in the United States, and extracted the sales price and cost data as verification materials. The company claimed that the transaction was an urgent order. In the comment on the disclosure of the basic facts of the ruling, the company not only put forward the same claim as the previous paragraph, but also advocated that the profit of exporting P92 to China was more reasonable. The company also maintains that the order is urgent, so the selling price is higher than the normal order, and is the only transaction in the survey period, and the quantity is limited, not representative and comparable. The company also advocates that the P91 standard cost should not be adjusted to the actual cost according to the standard cost and the actual cost difference rate of the company as a whole. The company also advocates that the profit margin calculated by using P91 transaction does not accord with the normal industry profit margin of P92 sales, and this profit margin is also inconsistent with the total profit margin of the companys sales and the profit margin of finished components completed by using integrated production devices.

In this regard, the investigation authorities believe that, first of all, because P92 does not sell in the United States, but only in China, the company does not have the actual data of the profits of domestic production and sales of P92 steel pipes in the United States. The companys assertion that the profits of P92 exported to China are the domestic profits of the United States is inconsistent with the purpose of domestic profits that need to be sought here for the normal value of the structure, and the investigative authorities can not accept this assertion. Secondly, the investigating authorities believe that there is no evidence that any additional cost incurred due to the urgency of the order will affect the sale price. Moreover, the investigative authorities also found that the P92 steel pipe was delivered within the same time or even shorter than that time. Thirdly, in the field inspection, the investigative authorities requested to withdraw all the P91 domestic sales, but the company said that only this transaction, there is no evidence that the order is not representative and comparable, and the calculated profit margin does not meet the normal industry profit margin of P92 steel pipe sales in the United States. On the premise that the company does not sell P92 steel pipes in the United States, and for the purpose of normal structural value, the investigating authorities need the actual profit data of domestic sales in the United States. Whether the companys total sales profits or the profits of finished products and components completed by integrated production facilities, the profits of the export market are not comparable with those of the United States, and the inconsistency of profits is not consistent. Can we deny the authenticity of P91 trading profit in the United States? In the field inspection, the investigative authorities had asked the company to subdivide the sales data of the finished product parts completed by the integrated production device into the sales market, but the company said it could not provide the subdividing data. After further investigation, the investigating organ thinks that although there are differences between P91 steel pipe and P92 steel pipe, P91 steel pipe and P92 steel pipe belong to the same business department of the company, they all use the same production equipment, and are produced through similar processes. They also have similarities in sales purposes and belong to the same category of products. The company produces and sells P91 steel pipe in the United States. The actual profit of the company represents the actual amount of profit generated and realized by the production and sale of the same category of products in the domestic market. Therefore, the investigative organs hold that the companys claim is not valid. The P91 sales cost extracted in the verification is the standard cost, and the investigating organ needs to adjust it to the actual cost to determine the actual profit. Because there is no difference between the standard cost and the actual cost of P91 raw material procurement, the investigating authorities decided to adjust the standard cost of P91 raw material to the actual cost by using the overall cost difference rate of P91 raw material, which is verified and consistent with the companys financial statements, and calculate the profit margin of P91 steel pipe sales as the profit margin of the normal value of the structure.

2. Export price.

The investigative authorities have preliminarily examined the situation of the companys export and sale of the products under investigation to China. During the period of dumping investigation, all the products investigated by the company were sold directly to non-affiliated customers in China. In accordance with the provisions of Article 5 of the Anti-dumping Regulations, the investigating organ has decided to use the price of the company sold to non-related customers in China as the basis for determining the export price.

3. Price adjustment.

In accordance with the provisions of Article 6 of the Anti-dumping Regulations, for fair and reasonable comparison, the investigating authorities have examined the adjustment items affecting price comparability of the company one by one.

(1) The normal value part.

On the normal value of the structure, after examination, the answer did not advocate the adjustment of the normal value of the structure. In the commentary on the disclosure of the basic facts of the award, the company maintains that direct expenses should be deducted from the normal value. In this regard, the investigation authorities believe that the P91 steel pipe sales conditions extracted during the verification are factory delivery, and no direct sales costs have occurred. The investigation authorities decided not to adjust the price of the normal value of the structure.

(2) Export price.

After examining the items of export price adjustment, the investigating organ decided to accept the companys proposals for inland freight, such as factory to distribution warehouse, ex-factory loading and unloading fee, international freight, international transportation insurance fee, packing fee and credit fee.

During the on-site inspection, the investigation authorities found that the Beijing office under the company was specially responsible for providing services for Chinese market sales. In the comment on the disclosure of the basic facts of the ruling, the company maintains that the Beijing office also provides other services besides sales in the Chinese market, which is related to the companys long-term interests and not only serves specific transactions or products; the Beijing office also involves the sale of other products besides the products under investigation; the office expenses also include office expenses, which should not belong to direct sales expenses; and the normal price of the structure. The cost of using P91 steel pipe inevitably includes all indirect costs. In response, the investigative authorities believe that regarding the Beijing office, the companys on-site verification clearly indicated that it is responsible for the sales business in China, and the vast majority of the products under investigation are responsible for the sales in China, providing services and information, etc. In particular, the company pointed out that the Beijing office participated in bidding for each sale. The questionnaire clearly requests the company to answer the whole process of sales, the parties involved and the role they play in Chinas export sales of the products under investigation. However, the company has not yet provided the necessary information for investigation according to the requirements under the circumstances of having information from the Beijing office, nor has it explained the situation truthfully in the minor correction link before the field verification. Only through the field verification can the company be investigated. Relevant content of Guans discovery. In the field verification, it was found that this situation has seriously hampered the investigation organs comprehensive investigation of the Beijing office. Moreover, after examination, in accordance with Article 21 of the Anti-dumping Regulations, considering the fact that the company has not faithfully provided investigative information and seriously hindered further investigation, as well as the specific description of the Beijing office in the companys on-site verification, the investigating authorities consider that the companys other services, other products and indirect sales expenses disclosed in the award are not only unsupported by evidence. It is also inconsistent with the companys explanation in the verification. The companys explanation in the field verification shows that the expenses of the Beijing office are directly related to the sales of the products under investigation, but there is no evidence that the direct sales expenses are included in the normal value of the structure. Based on the consideration of fair comparison, the investigating organ decides to take the cost data of the Beijing office during the investigation period extracted from the verification as the cost data of the Beijing office during the investigation period. Adjustment items shall be deducted.

In the process of collecting the cost data of Beijing office, the investigating authorities also found that the company had to pay the tender service fee for the sales of the products under investigation. In the comment on the disclosure of the basic facts of the award, the company argued that all export transactions should not be adjusted. At the time of on-site verification, it had been informed that only part of the transactions had competitive service fees. In response, the investigative authorities believe that, in the case of clear requirements of the questionnaire, the company has financial records, but it has not truthfully filled in the necessary information for the investigation, nor has it been truthfully explained in the minor correction link before the field verification, which is the relevant content discovered by the investigative authorities only through the field verification. In the field verification, it was found that this situation has seriously hampered the investigation authorities to further fully verify the overall actual situation of the companys payment of tender service fees for the sale of the products under investigation. Although the investigative organ has transferred the tender service fee paid under one account during the verification, it can not exclude the case that the tender service fee paid by the company for the products under investigation is recorded under other accounts but not transferred. After examination, in accordance with Article 21 of the Anti-dumping Regulations, considering that the company has the information of investigation but has not provided it truthfully and seriously hinders further investigation, the investigating organ has decided to adjust all export transactions by using the proportion of service fees stated by the company in the field verification.

4. About CIF price.

After examination, the existing evidence shows that the CIF price reported by the company is reasonable, and the investigating organ has decided to accept the CIF price data.

Other American companies (Allothers)

On June 15, 2018, the investigation authorities reviewed and investigated the anti-dumping measures applied to the imported high temperature bearing alloy steel seamless steel pipes originating in the United States and the European Union during the period of dumping and dumping margin. On that day, the investigative authorities notified the US Embassy in China and posted the case filing announcement on the website of the Ministry of Commerce. Any interested party can consult the case filing announcement on the website of the Ministry of Commerce. After filing a case, the investigating organ gives each stakeholder 20 days to register and participate in the investigation period, and gives all stakeholders a reasonable time to know the relevant situation of filing a case. After filing the case, the investigating organ will publish the questionnaire on the website of the Ministry of Commerce. Any interested party can consult and download the questionnaire on the website of the Ministry of Commerce.

The investigating organ has notified all known stakeholders to the best of its ability, and has also reminded all known stakeholders of the consequences of not cooperating with the investigation. For companies that have fulfilled their duty of notification but have not provided necessary information to cooperate with the investigation, the investigating authorities, in accordance with the provisions of Article 21 of the Anti-dumping Regulations, determine the dumping margin on the basis of the facts already obtained and the best information available. By comparing and analyzing the information obtained in the investigation, the investigating authorities decided to determine the dumping margin of other American companies based on the information submitted by Wieman Gordon Forging Co., Ltd.

European Union Corporation

Vallourec Deutschland GmbH

VALLOURECTUBESFRANCE

The answer sheet was submitted jointly by Wallerick Germany and Wallerick France Steel Pipe Company (hereinafter referred to as the two companies). According to the answer sheet, both companies are wholly controlled by the Valuarik Group, and the two companies conduct a two-way exchange of finished products between the sales legal entity and the production legal entity. In view of the close relationship between the French Steel Pipe Company and the German Steel Pipe Company, and the close connection between the production and sales of the products under investigation and their similar products, the investigating authorities decided to merge the two companies as an entity to calculate their dumping margins.

1. Normal value.

The investigating organs have examined the types of the products under investigation and similar products of the two companies. The two companies advocate that the products under investigation should be divided into several types according to the different standards of fine processing of steel pipes, delivery of products, the range of outer diameter of steel pipes, the range of wall thickness, the surface condition of steel pipes (only applicable to finished products), and the type of length of steel pipes. The two companies have a product code for each model. The code is only applicable to this anti-dumping investigation and is not used in the daily business of Valluric Group. After investigation and on-the-spot verification, the investigating authorities found that the model classification method advocated by the two companies was not the method consistently adopted in the production and operation practice of the two companies. Some of the standards for model classification were only applicable to some of the investigated products and similar products. The two companies also did not provide evidence of the differences in production costs, sales channels and sales prices of each model. Therefore, the investigating authorities decided not to accept the proposition of model division of the two companies. According to the differences in production technology, production cost, sales channels and sales price between the two companiesinvestigated products and similar products, the investigating products and similar products will be merged into F and S models on the basis of their models.

Before the onset of on-the-spot verification, the company applied for minor corrections for individual transactions. After examination, the investigative authorities decided to accept minor corrections from the company. The investigation authorities examined the sales of similar products of the two companies in the EU during the period of review and investigation. According to the answer sheet, according to the arrangement of the two companies, the German company of Wallerick is responsible for sales in the EU, while the French steel pipe company of Wallerick is not sold in the EU. During the period of review and investigation, the proportion of similar products sold in EU to China in the same period was less than 5%, which did not meet the quantity requirement as the basis for determining normal value. According to Article 4 of the Anti-dumping Regulations, the investigating organ decides to determine its normal value by means of production cost plus reasonable expenses and profits.

The investigative organs examined the production cost, sales, management and financial expenses reported by the two companies.

According to the two companiesanswers, the two companies did not provide the production costs and sales, management and financial costs of sub-models, sub-markets according to the requirements of the questionnaire Table 6-3 Production Costs and Costs. In Table 6-3, only the production costs and cost data of category F products were provided.

The investigating organ first examined the production cost of the same kind of products under investigation. Both companies adopt standard cost method. The two companies submitted production cost data of their F-type products. Because the two companies exchanged products during the investigation period, the investigation authorities decided to consider their production cost comprehensively. Based on the output of their respective companies during the investigation period, the weighted average production cost of F-type products was calculated, which was used as the production cost of F-type products.

Because the company did not provide the production cost of class S products according to the requirements of the questionnaire and did not provide the necessary information within the prescribed time, the investigating organ could not calculate the production cost of this type of products according to the actual production cost data of the company. After investigation, the investigating organ decided to adopt the weighted average production cost of class F products of the two companies to deduct the processing cost of their Changzhou affiliated companies. The cost of production for class S products.

The investigative authorities then examined the sales, management and financial costs of the products of the same kind investigated by the German company Wallerick, which sells the products in the EU. The survey found that there was a significant difference between the sales, management and financial expenses data in Table 6-3 and the profitability data in Table 6-5. The company could not explain the reasons for the difference. Moreover, the relevant cost data in Table 6-5 are obviously inconsistent with the other parts of the companys questionnaire. After examination, the investigating authorities decided to use the relevant data in Table 6-3 of the company as the actual sales, management and financial expenses of the products under investigation.

Finally, the investigative authorities examined the profits reported by the two companies. According to the answer sheet, the profit margins of the two companies in the EU, the same category of products and the company as a whole are negative. In the opinion of the investigating authorities, since the profit margins of the two companies are negative and can not reflect the normal production and operation conditions, the investigating authorities decided to adopt the profit margin of sales transactions to non-affiliated companies not less than costs and expenses in the EU as the basis for determining the normal value of the structure.

In its pre-ruling comments, the company argued that the method used by the investigating authorities to calculate profit margins violated Chinas anti-dumping regulations and WTO anti-dumping agreements, and that it was unreasonable and illogical to use the very small amount of special transaction profit margins sold in the EU, as well as the very low profit margins of the same industry in China. First of all, the profit margin data used by the investigating authorities is the profit margin of the companys sales to non-affiliated companies not less than the cost and cost in the EU, which is the actual data of the companys production and sales of similar products in the normal trade process. Because it is based on the companys actual data, the investigating authorities do not need to consider the difference in profit margins between the same category of products sold by other exporters or producers in the European market, nor do they need to consider the level of profit margins of the same industry in China. Secondly, since the investigative authorities use the actual data that the company sells in the EU at no less than the cost and cost, the number and quantity of transactions that meet this requirement cannot negate the reliability of the final results. Thirdly, because the sales volume of similar products in the EU does not meet the quantity requirement as the basis for determining normal value, the investigating organ decides not to use the sales in the EU as the basis for determining normal value, which is not in contradiction with the profit margin of the investigating organs adoption of the required sales in the EU. The contents of the two considerations are different. Finally, the companys claim that the transaction used by the investigating authority to calculate profit margin is a special transaction has no basis. Before the final decision of the investigating authority, the company did not mention that the transaction belongs to a special transaction and belongs to experimental supplies, either in the answer sheet or in the verification process. In the process of verification, the investigative authorities have extracted the relevant proof documents of the transaction, and the company has not proposed to the investigative authorities any special features of the transaction. The relevant supporting materials submitted by the company in its comments exceed the reasonable time for providing the necessary information, and the investigative organs are unable to verify them. To put it further, even if these materials are not verifiable, it is difficult to prove their special use or design or manufacture according to customer requirements. In summary, the investigative authorities ultimately decided not to accept the companys claims.

2. Export price.

The investigation authorities examined the situation of the two companies exporting the products under investigation to China during the investigation period. According to the companys reply, during the survey period, the two companies arranged by the group company that Wallerick German Company was responsible for export sales to China, while Wallerick French Steel Pipe Company did not sell to China. The export of Wallerick Germany Company to China is accomplished through two channels, one is to sell directly to non-related customers in China, the other is to sell to Wallerick China Company, its affiliated company in Changzhou, China, which is processed and sold in China.

For the direct sale of Wallerick German Company to non-affiliated customers in China, the investigative authorities decided to use the transaction price sold to non-affiliated customers as the basis for determining the export price. After examination, the investigating organ decided to accept the export data of Wallerick German Company to Wallerick Chinese Company, which was sold to Wallerick Chinese Company and then processed and resold by Wallerick German Company, as the basis for determining the export price.

3. Price adjustment.

According to Article 6 of the Anti-Dumping Regulations, in order to make a fair and reasonable comparison, the investigating organs have examined the adjustment items affecting the price comparability of the company one by one.

(1) The normal value part.

In calculating the normal value of the structure, the investigating authorities took into account the factors of the cost of selling similar products within the companys EU, and adjusted them accordingly.

(2) Export price.

For the inland freight (factory/warehouse to export port), international freight, international transport insurance, port handling charges, credit charges, guarantee charges, commissions, letter of credit fees and other adjustment items advocated by the company, the investigating authorities have decided to adopt the data submitted by the company and accept its adjustment proposals.

4. About CIF price.

After examination, the existing evidence shows that the CIF price reported by the company is reasonable, and the investigating organ has decided to accept the CIF price data.

IBF Italy (IBFS.P.A.)

1. Normal value.

The investigative authorities have examined the type classification of the products under investigation and similar products of the company. In the answer sheet, the company advocated that the products under investigation and similar products should be single model products. After examination, the investigating organ decided to accept the companys proposition on product type classification.

The investigation authorities examined the companys sales of similar products in the EU. During the review period, the company stated in its response that it did not provide tables 4-2 because it had only a small amount of sales in the EU. In the field inspection, the investigative authorities found that the company had only one transaction in the European Union. The investigative authorities extracted the transaction invoice of the sale and found that the transaction was eventually exported to Japan, not sold in the EU. According to Article 4 of the Anti-dumping Regulations, the investigating organ decides to determine its normal value by means of production cost plus reasonable expenses and profits.

The investigation authorities examined the production cost and cost data reported by the company.

Regarding the production cost, the company did not provide the production cost, sales, management and financial expenses of the sub-market according to the questionnaire Table 6-3 Production Cost and Cost. Before the onset of field verification, the company submitted minor corrections in tables 1-6, 6-1 and 6-4, saying that 11 raw material purchasing transactions were missed in table 1-6, and the number of some transactions in table 6-1 and table 6-4 was modified. For table 6-1 and table 6-4, the company maintained that the units reported in the original form were rice or root, adding unit tons. The investigative authorities examined the minor corrections submitted by the company and decided to accept them. In the field verification, the investigating authorities extracted three raw material purchase invoices corresponding to Chinas export transactions in Table 3-4, and found that the quantity and amount of two actual purchase invoices were inconsistent with the quantity and amount of raw materials purchased in Table 1-6 and Table 6-1. The company explained that Table 1-6 and Table 6-1 were based on the quantity and amount of contracts. According to the investigation authorities, the incorrect data reported by the company in Tables 1-6 and 6-1 also affect the accuracy of the direct data in Tables 6-3 and 6-4. Therefore, the investigating authorities believe that the direct material cost in Table 6-3 should be recalculated using the actual raw material procurement cost of the products under investigation exported by the company to China. The investigating organ decides to accept the claim that the sales revenue of scrap steel and inner mandrel of the company offsets the direct material cost after examination and on-the-spot verification. For other production costs, the investigative authorities decided to accept the data submitted in the questionnaire 6-3.

As for expenses, the company said in the answer that the management expenses and financial expenses should be apportioned according to the sales revenue of steel pipes; in the field verification, the company also said that the indirect expenses (including management expenses and financial expenses) reported by the company were apportioned equally between the two departments of steel pipes and pipe fittings. The investigative organ believes that the companys method of apportionment has the problem of excessive indirect expenses apportioned to the fittings department, and it is inconsistent with the opinions in the answer sheet. Therefore, the investigating organ decides to share the management and financial expenses by the proportion of the steel pipe department to the total sales revenue of the company and the products under investigation to the sales revenue of the steel pipe department. In its comments on the disclosure of the basic facts of the award, the company argued that the steel pipe department should share more expenses than the fittings department. After examination, the investigating organ does not deny that the cost allocated by the steel pipe department is slightly higher than that by the fittings department, but the average allocation method advocated by the company is inconsistent with the claim of the respondents based on sales revenue, and no relevant evidence is provided. Because the sales revenue of the steel pipe department is much larger than that of the fittings department, the average apportionment method will lead to the indirect cost apportioned by the fittings Department far greater than that apportioned according to its sales revenue. Therefore, the investigative authorities decided not to accept the companys claim.

As for other expenses, in the field verification, the company said that the fee was actually other income. It was a tax rebate imposed by the Italian government to encourage enterprises to research and develop. The company admitted that the income had nothing to do with the products under investigation and should not be apportioned to the products under investigation and similar products. Therefore, the investigating authorities decided not to accept the content.

With regard to profit margin, since the company does not sell in the EU, the investigative authorities have decided to adopt the profit margin of other EU companies selling the products under investigation in the EU at the same time as the profit margin of the normal value of the structure. In its comments on the disclosure of the basic facts of the ruling, the company argued that the profit margin had never been achieved in history. In response, the investigative authorities believe that, first of all, similar products of the company under investigation are not sold in the EU, and the company does not produce and sell the actual amount of the same category of products in the EU. On this premise, the profit margin of other EU companies used by the investigating authorities in the same period in selling the products under investigation in the EU does not exceed that of other exporters or producers in selling the same category of products in the EU market. Therefore, the investigative authorities decided not to accept the companys claim.

2. Export price.

The investigative authorities have preliminarily examined the situation of the companys export and sale of the products under investigation to China. During the period of dumping investigation, all the products investigated by the company were sold directly to non-affiliated customers in China. In accordance with the provisions of Article 5 of the Anti-dumping Regulations, the investigating organ has decided to use the price of the company sold to non-related customers in China as the basis for determining the export price.

3. Price adjustment.

In accordance with the provisions of Article 6 of the Anti-dumping Regulations, for fair and reasonable comparison, the investigating authorities have examined the adjustment items affecting price comparability of the company one by one.

(1) The normal value part.

As for the adjustment items of the normal value of the structure, because the company does not sell in the EU, the investigating authorities found that the sales expenses reported in tables 6-3 and 6-5 are both direct sales expenses for exports from China and third countries. Based on fair comparison, the investigating authorities decided not to include sales expenses when the normal value of the structure is considered.

(2) Export price.

After reviewing the export price adjustment items, the company stated in its reply that there were no adjustment items. In the field inspection, the investigative authorities extracted the invoices for all the transactions of the companys exports to China, and found that all of them were transported by air cargo. Due to the fact that the investigating authorities have explicitly asked the company to fill in all the adjustment items and provide the corresponding documents in the questionnaire, the company still fails to fill in the adjustment items according to the requirements of the questionnaire due to the time constraints, and also fails to provide the corresponding transport documents, export declaration documents, shipping invoices, letters of credit, bank payment certificates and other documents. Therefore, the investigating authorities decided to adopt the highest unit price in all export transactions to China to adjust international transport costs.

With regard to credit costs, after examination, the company stated in its reply that its payment terms were 60 days late from the date of delivery, but the company did not report the credit costs, nor did it provide the official short-term interest rate. Therefore, the investigating authorities decided to adjust the credit charges at the official short-term interest rates submitted by other European Union companies according to the date of receipt and delivery of the payment in Forms 3-4. In its commentary on the disclosure of the basic facts of the ruling, the company argues that the credit cost has been included in interest (fee) income, and that the calculation by the investigating authority will duplicate the cost. In this regard, the investigative authorities believe that the company confuses the concepts of credit costs and interest (fee) income. Credit cost is opportunity cost, which is based on the time cost caused by different payment and delivery date of sales products. In the field verification, the certificate of export to China submitted by the company shows that the actual date of receipt of payment is inconsistent with the date of delivery, but the company did not report the credit cost in the original reply. Therefore, the investigative authorities decided not to accept the companys claim.

With regard to discounts and claims, after review, the investigating authorities found that the company had reported discounts and claims for products exported to China during the review period in Table 6-5, but not in Table 3-4. Therefore, the investigative authorities decided to adjust the project accordingly.

4. About CIF price.

After examination, the company said in its response that it was trading at CIF price, but the investigation authorities found in the field verification that all the conditions of delivery of the companys export transactions to China were CFR. Since the company did not provide international insurance rates, the investigation authorities decided to adjust the CFR price to CIF price using the international insurance rates submitted by other European Union companies.

Other European Union companies (Allothers)

On June 15, 2018, the investigation authorities reviewed and investigated the anti-dumping measures applied to the imported high temperature bearing alloy steel seamless steel pipes originating in the United States and the European Union during the period of dumping and dumping margin. On that day, the investigative authorities notified the EU Embassy in China and posted the case filing announcement on the website of the Ministry of Commerce. Any interested party can consult the case filing announcement on the website of the Ministry of Commerce. After filing a case, the investigating organ gives each stakeholder 20 days to register and participate in the investigation period, and gives all stakeholders a reasonable time to know the relevant situation of filing a case. After filing the case, the investigating organ will publish the questionnaire on the website of the Ministry of Commerce. Any interested party can consult and download the questionnaire on the website of the Ministry of Commerce.

The investigating organ has notified all known stakeholders to the best of its ability, and has also reminded all known stakeholders of the consequences of not cooperating with the investigation. For companies that have fulfilled their duty of notification but have not provided necessary information to cooperate with the investigation, the investigating authorities, in accordance with the provisions of Article 21 of the Anti-dumping Regulations, determine the dumping margin on the basis of the facts already obtained and the best information available. By comparing and analyzing the information obtained in the investigation, the investigating authorities decided to determine the dumping margins of other EU companies based on the information submitted by IBFS.P.A.

(2) Price comparison.

According to the provisions of Article 6 of the Anti-dumping Regulations, the investigating organ, on the basis of the certification materials submitted by the company, takes into account various comparable factors affecting the price, and adjusts the export price and normal value of the products investigated by the company to the same level in a fair and reasonable manner. When calculating the dumping margin, the investigating organ compares the weighted average normal value with the weighted average export price and obtains the dumping margin.

V. Re-examination of rulings

According to the investigation results, the investigation authorities ruled that the import-related high-temperature pressure alloy steel seamless steel pipes originating in the United States and the European Union were dumped during the review and investigation period, with the dumping margin as follows:

American Company

1. Wieman Gordon Forging Co., Ltd. 101.0%

(Wyman-Gordon Forgings, Inc.)

2. Other American companies 147.8%

(Allothers)

European Union Corporation

1. Valluric German Company 57.9%

(Vallourec Deutschland GmbH)

2. Valurique French Steel Pipe Company 57.9%

(VALLOURECTUBESFRANCE)

3. IBF Italy 60.8%

(IBFS.P.A.)

4. Other EU companies 60.8%

(Allothers)

Source: Responsible Editor of Ministry of Commerce: Yang Yi_NBJ10647