CITAC Letter to the Secretary of the U.S. International Trade Commission
September 19, 2000

The Honorable Donna R. Koehnke
Secretary
U.S. International Trade Commission
500 E Street, S.W.
Washington, D.C. 20436

Re: Certain Carbon Steel Products From Australia, Belgium, Brazil,
Canada, Finland, France, Germany, Japan, Korea, Mexico,
Netherlands, Poland, Romania, Spain, Sweden, Taiwan,
And United Kingdom; Investigations Nos. AA1921-197 (Review),
701-TA-231, 319-320, 322, 325-328, 340, 342, and
348-350 (Review), and 731-TA-573-576, 578, 582-587,
604, 607-608, 612, and 614-618 (Review)

Dear Madame Secretary:

The Consuming Industries Trade Action Coalition ("CITAC"), a group representing the interests of industrial consumers, wishes to make its views known regarding the continuation of antidumping and countervailing duties on cold-rolled, corrosion-resistant and cut to length plate carbon steel products.

CITAC is a coalition of America's consuming industries. Our members use steel, other metal products, electronics and other raw materials to manufacture products in the United States and distribute products to industry and individual consumers. Because steel is such an important product to American manufacturing, CITAC members are interested in cases restricting consuming industries' access to steel.

The current antidumping and countervailing duty orders on carbon quality steel imports have the effect of limiting consuming industries' choices in the United States. These orders lengthen lead times for American manufacturers and often require sacrifices in quality and the exacting specifications needed to make world-competitive products in the global market. Carbon-quality steel is used in thousands of applications, from automobiles to industrial machinery to containers. Therefore, these effects are felt by industries employing millions of American workers.

America's steel users employ more than 40 times as many workers employed by U.S. steel producers. The Commission should realize that the costs to the U.S. economy of continuing antidumping duties will be greater than the benefits of doing so for the nation as a whole.

CITAC recognizes that consuming industry welfare is not now an important consideration in determining whether antidumping or countervailing duties should be continued. We are working to change that, because we believe it is wrong. Under current law, however, the Commission is required to consider whether the U.S. producers of cold-rolled, corrosion-resistant or cut to length carbon-quality steel would be materially injured by the revocation of antidumping duty orders on those products. In making this statutory determination, the Commission should consider that the welfare of America's consuming industries (employers and employees) is riding on their determination.

Thank you for your attention to these comments. This document has been served in accordance with the attached service list.

Very truly yours,

Jon E. Jenson, Chairman
Consuming Industries Trade
Action Coalition