Home Meridian Int'l, Inc. v. United States, No. 14-1251 (Fed. Cir. 2014)Annotate this Case
The U.S. Department of Commerce published an antidumping duty order on wooden bedroom furniture from China. AFMC requested an administrative review of certain companies exporting such furniture to the U.S. in 2009. After Commerce selected it as the mandatory respondent, Huafeng provided Commerce with data related to its 2008 purchases of wood inputs from market economy suppliers relevant to the subject merchandise. Commerce assigned Huafeng a dumping margin of 41.75% using 2009 import data from the Philippines (surrogate values), a market economy, to value the wood inputs as the “best available information” under 19 U.S.C. 1677b(c)(1) because they were contemporaneous with the Period of Review, and the purchases identified by Huafeng were not. After remand Commerce again relied on the surrogate values. On second remand, Commerce determined that it did not need to reopen the record because the “best available information” analysis focuses on the purchase of inputs, not consumption, verified that the market economy purchases were actually from market economy suppliers, and assigned a new dumping margin of 11.79%. The Court of International Trade judgment sustained that valuation. The Federal Circuit reversed, directing direct the Trade Court to reinstate the valuation in the First Redetermination.