PUBLIC VERSION
comparisons based on Petitioner’ s average unit values(“ AUVs”) of U. S. shipments and |
importers’ AUVs for the period 2019 to 2023 demonstrate that imports are priced lower than the |
domestic product. As shown in the table below, cumulated imports undersold Petitioner in every |
year for the last five years by margins of at least [ |
] and steadily increasing up to [ |
] in |
2024. |
|
|
Item
Domestic Industry
[
Underselling Analysis Calendar year 2020 2021 2022 2023 2024 Unit Price( in $/ SQF)
Total imports 9.29 9.37 9.27 8.16 7.50 Margin of
[ Underselling
]
] Notably, the degree of underselling by imports has intensified over the past five years, allowing imports to gain further market share at the domestic industry’ s expense. Moreover, the average price of imports has steadily fallen over the last five years from $ 9.29 / SQF in 2020 to $ 7.50 / SQF in 2024.
The Commission observed similar underselling when conducting the AD / CVD investigations of QSP from China and QSP from India and Turkey. In the first set of investigations on QSP from China, the Commission found that“{ s } ubject imports undersold the domestic product in all 180 quarterly price comparisons … at underselling margins that ranged from 4.3 percent to 85.3 percent and averaged 49.2 percent.” 118 Moreover, the Commission explained that the underselling“ enabled the subject imports to capture a growing share of the U. S. market” and that subject imports“ also suppressed domestic prices to a significant
118 QSP from China Inv Final at 27.
44