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CIT Sustains Surrogate Manufacturing Overhead Ratio, Hourly Labor Value in AD Review

The Court of International Trade in an Oct. 30 opinion sustained the Commerce Department's remand results in a case on the 2017-18 antidumping review of multilayered wood flooring from China. Judge Richard Eaton said Commerce properly calculated the surrogate manufacturing overhead ratio by using the indirect production expenses amount in the numerator and listing its reasons for taking out energy costs and putting them in the denominator. The judge also upheld the use of Romania's International Labor Organization data to calculate the surrogate's hourly labor value, saying "the data reflects hours actually worked in the surrogate country."