PUBLIC VERSION
underselling ranging from [ ] to [ ]. 154 In addition, in the investigations of both QSP from China and QSP from India and Turkey, the Commission has found universal underselling in every quarterly comparison of every product for which it collected pricing information.
A comparison of the domestic industry’ s COGS to the AUVs of all imports underscores the dilemma being faced by domestic producers:
Item
Domestic Industry COGS
Comparison of Domestic Industry COGS to Import AUVs Calendar year 2020 2021 2022 2023 2024 Unit Price( in $/ SQF)
[
Total Imports |
|
|
|
|
|
AUV |
9.29 |
9.37 |
9.27 |
8.16 |
7.50 |
]
As shown in the table above, import AUVS are [ ] the domestic industry’ s COGS throughout the entire POI, with the gap widening from [
].
Because QSP from all sources is highly fungible and sold primarily on the basis of price, this underselling allowed imports to capture sales and market share from the domestic industry. As imports surged, the domestic industry was also forced to compete for sales at lower prices and accept lower prices in contracts. Consequently, the domestic industry experienced a costprice squeeze, leading to price depression and suppression, and poor and worsening financial results.
154 Underselling Analysis, attached as Exhibit 18.
55