Petition QMAA 15 Sept | Page 51

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.
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