Statement of reasons—Expiry review determination: Copper Tube (CT 2024 ER)

Exclusions

[22] The CITT excluded the following copper tube from its injury findings:

Additional product information

[23] Copper tube sold in Canada is manufactured to a variety of American Society for Testing and Materials (ASTM) standards and grades. These standards, in many instances, dictate the outer diameter, inner diameter, wall thickness and allowable tolerances, among other things, within each of the standards. The outer diameter range of the tube includes diameters that are within the allowable tolerances of each standard.

[24] The standards and grades of copper tube manufactured and sold in Canada is as follows:

Canadian production

[33] The Canadian producer’s share of the apparent Canadian market declined in volume and value over the POR. Despite the declining trend, the Canadian producer held the majority of the domestic market share.

Imports: Named countries

[34] During the POR, the total volume and value of imports of subject goods from the named countries were negligible as a percentage of the apparent Canadian market. In sum, the volume of imports of subject goods during the POR was not material.

Imports: Other countries

[35] During the POR, the total volume and value of imports of subject goods from other countries (i.e., the non-named countries) as a percentage of the apparent Canadian market were trending upwards. In sum, there was a significant up-trend of imports of subject goods from the non-named countries over the POR.

Administrative record

[44] The information considered by the CBSA for purposes of this expiry review investigation is contained in the administrative record. The administrative record includes the information on the CBSA’s exhibit listing, which is comprised of the CBSA exhibits and information submitted by interested parties, including information which the interested parties feel is relevant to the decision as to whether dumping and subsidizing are likely to continue or resume absent the CITT orders. This information may consist of expert analysts’ reports, excerpts from trade magazines and newspapers, orders and findings issued by authorities of Canada or of a country other than Canada, documents from international trade organizations such as the World Trade Organization (WTO) and responses to the ERQs submitted by domestic producers, importers, exporters and foreign producers and governments.

[45] For purposes of an expiry review investigation, the CBSA sets a date after which no new information submitted by interested parties will be placed on the administrative record or considered as part of the CBSA’s investigation. This is referred to as the “closing of the record date” and is set to allow participants time to prepare their case briefs and reply submissions based on the information that is on the administrative record as of the closing of the record date. For this investigation, the administrative record closed on October 2, 2024.

Parties contending that continued or resumed dumping is likely

GLC

[46] GLC made representations in its case brief,^{Footnote 16} and its response to the ERQ,^{Footnote 17} in support of the position that the continuation or resumption of dumping of the subject goods from the named countries would be likely to continue or resume should the orders be rescinded. Consequently, GLC argues against rescinding the orders.

[47] The main factors identified by GLC can be summarized as follows:

• Commodity nature of copper tube
• Global and domestic market conditions
• Foreign producers and economic outlook in the named countries
• Decrease in volume of imports from the named countries
• Increase in imports of copper tube from non-named countries and
• Imposition of measures in other jurisdictions

Commodity nature of copper tube

[48] GLC states that copper tubes are interchangeable commodity-type products regardless of where they are made, whether in Canada or abroad. They reference CITT’s original injury determination where it is noted that the subject goods and the domestic products “…compete head-to-head in what largely seems to be a commodity market.” Consequently, price becomes the determining purchasing factor for interchangeable commodity-like goods and entices purchasers to switch to low-priced sources from non-named countries, as observed by the CITT.^{Footnote 18}

[49] GLC adds that the price sensitive nature of copper tube has not changed, and that it continues to compete in the Canadian market largely on the basis of price in a highly competitive environment. Next Plumbing & Hydronics Supply Inc. seconds this statement and describes its sales as dependant on the aggressive nature of market pricing.^{Footnote 19}

Global and domestic market conditions

[50] GLC mentions that demand for copper tube is driven by global economic conditions generally and more particularly by construction activity. In its July 2024 World Economic Outlook update, the International Monetary Fund (IMF) projected a timid global GDP growth of 3.2% and 3.3% in 2024 and 2025 respectively. China’s GDP growth is projected to slow to 4.5% in 2025 as for Latin America, which includes Brazil and Mexico, GDP growth was revised downward in 2024 with a slight improvement for Brazil in 2025, according to the IMF’s forecast.^{Footnote 20}

[51] The price of copper tube in Canada and worldwide fluctuates with the changes in the COMEX and Shanghai exchanges. The increased production of electric vehicles, advancements in artificial intelligence, automation and renewable energy are drivers of higher copper prices in the future. Whereas, the demand for copper products used in buildings and HVACR (subject products) is expected to decline.^{Footnote 21}

[52] On the domestic front, GLC has noticed a softening in the residential and non-residential construction activities, as a result of high inflation and interest rates, which is expected to remain until early 2025. However, GLC hopes that the expected interest rate cuts will result in a rebound in construction activities by mid 2025. GLC cites Build Force Canada and RBC Economics which forecast a modest growth for residential construction in 2025, and a return to normal growth for non-residential construction in 2026.^{Footnote 22}

[53] GLC notices new developing trends in the Canadian market for copper tube driving additional demand for the product. These trends include the increase in the build out of data center cooling infrastructure, medical gas distribution for new hospital builds, and large groceries shifting to CO2 based cooling.^{Footnote 23}

[54] Canadian-produced copper tubes are marketed through plumbing, heating and ACR wholesalers in addition to retailers. Through market intelligence gathering, GLC has learned that some foreign exporters are bypassing the wholesale channel to market and sell directly to contractors. Their action has negatively impacted GLC’s volumes and the proportion sold through the various channels of distribution.^{Footnote 24} GLC adds that it itself receives unsolicited email offers for copper tube from foreign suppliers.^{Footnote 25}

Foreign producers and economic outlook in the named countries

[55] GLC provides a summary of publicly available information regarding some of the main exporters in the named countries, in addition to information on copper tube demand perspectives in their respective domestic markets.

Brazil: Paranapanema and Termomecanica^{Footnote 26}

[56] Paranapanema is one of Brazil’s largest copper tube producers; it opened a new production facility in 2016, with an annual capacity of 36,000 tonnes.

[57] In 2022, Paranapanema filed for bankruptcy protection. Paranapanema engaged in a “temporary suspension” of certain activities, including copper sales. A recovery plan was approved by creditors in 2023 and a reorganization plan was approved by the courts in November 2023. The plan included the resumption of operations and the company’s most recent Earnings Release (Q2 2024) reported a partial resumption of activities that had previously been suspended, including “the return of copper sales”. While the company’s overall sales have plummeted this year, sales in the segment including the subject goods as a percentage of total sales increased significantly in Q1 2024, suggesting that this is an important segment as the company moves forward with its restructuring plans. Revenues from exports to Europe declined by more than 99% in Q1 2024, further suggesting, in GLC’s opinion, that Paranapanema will be looking to expand its presence in other markets, including Canada.

[58] Termomecanica is one of Brazil’s largest private industrial companies and a leader in the production of copper products, including copper tube. Termomecanica reports that it “has the largest and the most complete set of equipment and machines for rolling and drawing in Latin America, with the capacity to draw up to 200 tons.”

[59] The company’s 2022 Sustainability Report states its vision includes increasing participation in global markets.

[60] At the macro level, Brazil’s economy expanded modestly in 2024, however, central bankers forecast the local economy cooling for the balance of the year and into 2025. GLC references Trading Economics, which stated that GDP from construction contracted in 2024 and is forecasted to show only modest growth in 2025.

China: Golden Dragon, Zhejaing Hailiang, others^{Footnote 27}

[61] There are several large copper tube producers in China, including Golden Dragon and Zhejiang Hailiang Co., Ltd. (Hailiang). Numerous Chinese producers of copper tube, including Golden Dragon and Hailiang, each individually possess production capacity that exceeds the size of the entire Canadian copper tube market.

[62] According to Shanghai Metals Market, China’s copper tube producers have a combined capacity of 1.78 million tonnes (nearly 4 billion pounds). In July 2024, China was operating at 72.66%, resulting in unused capacity in excess of 485,000 tonnes (over 1 billion pounds).

[63] Hailiang has opened plants in Vietnam (Hailiang Vietnam Copper Mfg Co., Ltd) and Thailand (Loyal Hailiang Copper (Thailand) Co., Ltd.). GLC’s market intelligence shows that Hailiang’s copper tube from Vietnam and Thailand is being imported into Canada at very low prices through their trading company, Hong Kong Hailiang Metal Trading Limited.

[64] Chinese production of copper (raw material) continues to increase to record levels. Shanghai Metals Market reported in May 2024 that China’s imports of copper tubes may decline but “exports are expected to remain strong due to robust overseas demand.”

[65] Overall economic forecasts for China vary but there is general consensus that China’s construction sector is in crisis. GLC cites Oxford Economics which forecasts that residential construction in 2024 will decline by 2.5% and non-residential construction by 21.6%. Another GLC source, Trading Economics, adopts a slightly more positive outlook, forecasting modest growth in 2025.

[66] In their submission, GLC references an article from The New York Times, which reported that China has nearly 4 million apartments that no one wants to buy and over 10 million homes that developers have sold but have not finished building.

[67] According to The New York Times, dozens of large developers have “gone bust” with many others on the brink of default. Despite Chinese government plans to shore up the property market, GLC refers to economists at banks including UBS Group AG, JPMorgan Chase & Co. and Bank of America who predict that China will not meet its growth targets this year. Bloomberg Economics, an additional GLC source, reported that China has “the equivalent of 60 million unsold apartments, which will take more than four years to sell without government aid.”

[68] Against this backdrop, GLC submits that Chinese copper tube producers will be more incentivized to seek export market opportunities than ever before.

Greece: Halcor^{Footnote 28}

[69] Halcor is the leading producer of copper tube in Greece; it is the largest producer in Europe, the Middle East and Africa and over 95% of its products (by value) are exported. Halcor describes itself as “export oriented” and a company that “actively seeks to expand into new markets”. It has recently been working “to upgrade production and bolster production capacity” in its plants and “is implementing an investment plan the key pillars of which [include] increasing production”.

[70] Halcor has an annual production capacity of 80,000 tonnes, which is equivalent to 176 million pounds.

[71] Halcor’s sales declined by 7.9% in 2023. The stated core of Halcor’s strategy is “to continuously expand the Group’s presence beyond Greek boundaries” and, to this end, it specifically identifies “the United States and Canada” as targets for expansion. Recent construction forecasts for Greece do not point to any significant domestic growth that would impede Halcor’s ability to export copper tube to Canada. In particular, construction output in Greece has declined steadily and sharply since Q4 2022.

[72] More recently, Greece has trimmed its own forecast for 2024 economic growth. Greece’s fiscal council has reduced its forecast twice this year citing a wider EU economic slowdown.

Mexico: Nacobre, Golden Dragon, IUSA^{Footnote 29}

[73] Nacional De Cobre, S.A. DE C.V. (Nacobre) is the metals division of Elementia, S.A.B. de C.V. (“Elementia”), a publicly traded company. Nacobre “serves the U.S. and Canadian market” through its Nacrobe USA division and has three production facilities. Elementia has additionally invested $90 million USD to “allow for an increase in production capacity for [its] plants.”

[74] Golden Dragon Precise Copper Tube Group Inc. (Golden Dragon) is a multinational corporation with production facilities in Mexico. Golden Dragon is the world’s largest producer of copper tube. The Mexican facility, with an annual capacity of 120,000 tonnes (260 million pounds) was built for the purpose of expanding Golden Dragon’s presence in North America.

[75] Industrias Unidas S.A. de C.V. (IUSA) is the fourth largest copper supplier in the world. IUSA has a “modern, state-of-art copper refinery and tube mill in Pasteje Mexico.” It exports to 35 countries and has over 3,000 distributors worldwide. Around 60% of IUSA’s revenues come from products manufactured in Mexico and the company allocates over 40% of its capital expenditures to copper tubing (its largest expenditure). IUSA’s revenues “consist mainly of sales of copper-based products (tubing, wire, cable and alloys) and electrical products.”

[76] In their submission, GLC refers to Trading Economics, which stated that construction output in Mexico has declined steadily since August 2023. According to the same source a contraction in GDP from construction is expected in Q1 2025 followed by only modest growth in Q2 2025.

[77] GLC cites similar observations made by BBVA in its recent economic outlook for Mexico, noting that in Q1 2024 the construction sector fell by 0.7% quarter over quarter, 7% below the average recorded during the first three quarters of 2023. Looking ahead, BBVA forecasts the construction sector’s momentum recorded in 2023 will gradually dissipate due to reductions in public and private investment and a continuing high interest rate environment.

[78] GLC also mentions Bloomberg Economics which reported that political uncertainly and lower public spending in the second half of 2024 will weigh on growth, and referenced observations to the effect that weak activity data add to the evidence that Mexico’s economy is struggling for momentum.

[79] Against a backdrop of muted growth forecasts, particularly for the construction sector, GLC argues that Mexican producers with significant copper tube production capacities will be motivated to search for other markets, including Canada.

South Korea: Nungwon^{Footnote 30}

[80] Nungwon Metal Industries Co. Ltd. (Nungwon) is the largest copper tube manufacturer in South Korea. Nungwon is export oriented, selling its products in over 30 countries. Nungwon has an annual production capacity of 40,000 tonnes (88 million pounds).

[81] GLC refers to the Korean Development Institute (KDI) which observed that the South Korean economy is expected to register lower growth in 2024 than previously forecast. KDI also projects an overall contraction in construction investment. According to Trading Economics, a different reference source, construction output in South Korea has decreased since the beginning of 2024 and will only see modest growth in 2025.

[82] Oxford Economics, on the other hand, has a more pessimistic outlook, calling for an 5.8% decline in overall construction in 2025 and, more particularly, a 14% reduction in non-residential work.

[83] South Korea’s copper pipe exports accounted up to $47.2 million in July 2024 alone and total exports increased by 78.9% between July 2023 and July 2024, with the US as the primary destination. In GLC’s point of view, there is little doubt that export markets are important to South Korean producers; with declining demand in their domestic market in the near term, export markets, including Canada, will become increasingly important to their overall operations.

Decrease in volume of imports from the named countries

[84] Imports from the named countries were negligible, volume wise, in the Canadian market during the POR, as shown in the above CBSA’s enforcement data in Table 3; SIMA duties were assessed on over 95% of them as a percentage of the total value for duty. Since the Tribunal original finding, imports from Brazil, Greece and South Korea have disappeared.^{Footnote 31} GLC adds that in response to the Tribunal finding, Hailiang began exporting copper tube from its related companies in Vietnam and Thailand at very low prices, instead from its much larger production facilities in China.^{Footnote 32}

[85] In GLC’s opinion, these low imports figures, less than 1% of total imports by volume, indicate that exporters in the named countries are unable to compete in the Canadian market at non-dumped prices. To put this in perspective, GLC refers to the CBSA estimates in 2012 where subject goods accounted for as much as 56% of total imports by volume, prior to the CITT’s finding.^{Footnote 33}

[86] GLC contends that while exporters in the named countries have abandoned the Canadian market, they can re-enter it with ease if allowed to compete, absent normal value disciplines. GLC refers to the UN Comtrade Data to show that exports in kg from the named countries to the rest of the world, under HS code 7411.10, remained relatively stable with moderate fluctuation over the POR.^{Footnote 34}

Increase in imports of copper tube from non-named countries

[87] GLC refers to the CBSA’s enforcement data which show that volume of imports from non-named countries has almost doubled during the POR, from 2.6 million kg in 2021 to 5.1 million kg in 2023, with continued strong volume growth for the first 6 months of 2024.

[88] GLC’s market intelligence, demonstrates that there is an influx of low-price imports namely from Vietnam, Thailand and India.^{Footnote 35}

[89] To support its claim, GLC pulls imports data, for the named and non-named countries, out of Statistics Canada database for the Canadian market;^{Footnote 36} the data feature in particular imports from Vietnam, Thailand and India in addition to other countries for HS codes 7411.10.00.10 and 7411.10.00.20. The data confirm what GLC observed and show a net increase in imports from the specific above named countries, and a decrease in imports into Canada from the rest of the world during the POR.

[90] These low-priced imports have created somewhat a new benchmark for new low prices, against which imports from the named countries will re-enter the Canadian market if orders were to expire.^{Footnote 37} GLC submits several exchanged emails, proving that Canadian importers have offered low-priced imports to its customers, more competitive than its own set prices. As a result, GLC was forced to lower its prices or lose sales.^{Footnote 38}

[91] GLC goes on saying that Canada will remain an attractive market for copper tube. GLC references Build Force Canada which forecasts a modest growth for residential construction in 2025 and a return to growth in 2026 for non-residential building construction. The aforementioned forecasts are roughly in line with those of RBC Economics.

Imposition of measures in other jurisdictions

[92] GLC indicates that copper tube from China and Mexico has been subject to antidumping since 2010 in the United States. Additionally, in five-year (sunset) reviews in 2016 and 2022 the U.S. International Trade Commission concluded that the revocation of anti-dumping duties would likely result in the continuation or recurrence of dumping, and cause material injury to the above mentioned industry. Hence, the Commission commanded the continuation of the orders that established the anti-dumping duties.^{Footnote 39}

[93] GLC also refers to the WTO Committee on Anti-Dumping Practices Semi-Annual Reports of Anti-Dumping Actions for 2024, which show multiple measures against the named countries. Whilst the measures pertain to a broad range of industrial and consumer products, they show the propensity of the exporters in the named countries to export at dumped prices in several markets.^{Footnote 40}

Likelihood of continuation or resumption of dumping of the subject goods

[94] Copper tube is a commodity product, therefore price becomes the defining factor in purchasing choices. GLC states that the presence of the subject products from the named countries has significantly decreased in the Canadian market, proving that the related exporters cannot compete under normal value disciplines.

[95] GLC asserts that if the orders are rescinded, the subject goods will re-enter the Canadian market in significant volumes at new low prices. Exporters in the named countries have high production capacities and some of them, singly, possess production output that exceeds the size of the entire Canadian copper tube market.

[96] Additionally, the tepid market conditions and slow economic recovery, especially in the residential and non-residential construction sectors, in the named countries render exporters with excess production. The Canadian market for copper tube looks promising, which incentivizes exporters to target it to reduce their excess inventory.

[97] As a matter of fact, there has been an increase in imports involving a shift towards subject goods from non-named countries; this demonstrates that Canada remains an attractive market for copper tube.

Parties contending that continued or resumed dumping is unlikely

[98] No other parties contended that the continuation or resumption of dumping of the subject goods from the named countries is unlikely should the orders expire.

Commodity nature of copper tube

[101] In its findings in inquiry NQ-2013-004, the CITT noted and stated the following:

[102] As noted by the CITT in its orders and reasons issued in expiry review RR-2018-005:

[103] GLC submits, in its Expiry Review response and case brief, enough information detailing the price sensitivity nature of copper tube, in addition to several situations where a price reduction was warranted at the risk of losing a sale. Next Plumbing and Hydronics Supply Inc. also talks about the aggressive nature of market pricing, in its importer ERQ response, that it is competing with, which affects the company’s sales.^{Footnote 45}

[104] In reviewing the importer ERQ responses, Next Plumbing and Hydronics Supply Inc. states that quality, price and availability are the major factors which influence the purchasing decision to source certain copper tube.^{Footnote 46} Oceanex Inc. names price, product range and lead time as the major factors influencing the purchasing decision, which are in line with those of Next Plumbing and Hydronics Supply Inc.^{Footnote 47}

[105] In sum, all evidence indicates that the copper tube market is very price sensitive and that the product itself is a commodity. The lower the price of copper tube, the more enticing for foreign exporters and producers to dump their excess production into the Canadian market.

Global and domestic market conditions

[106] Demand for copper tube is generally driven by global economic activities and more particularly by residential and non-residential investments. The International Monetary Fund (IMF), in its World Economic Outlook update in July 2024, projects a global growth of 3.2% in 2024 and 3.3% in 2025 which remains stable when compared to a 3.5% growth in 2022 and 3.3% in 2023.^{Footnote 48}

[107] According to the IMF, global disinflation is already under way but at a slower momentum in certain sectors, such as in services. This will entice central banks, depending on local market conditions, to ease their monetary policies as inflation converges toward target levels. Prolonged periods of high interest rates tighten credit markets and have devastating effects on investment activities, especially on the commercial and residential real estate sectors, and vise versa.

[108] On the other hand, debt levels have increased to new highs during the pandemic, which encourage governments to impose different fiscal discipline measures and consequently curb spending and hinder growth.^{Footnote 49}

[109] The IMF projects a real GDP growth of 2.1% for Brazil in 2024 followed by a slight increase to 2.4% in 2025. As for China, the expected growth is 5.0% in 2024 and anticipated to fall to 4.5% in 2025. Greece follows a similar declining forecast pattern, where GDP is expected to reach 2.0% in 2024 and slightly lower in 2025 to hit the 1.9% mark. For Mexico and South Korea, real GDP growth is projected to attain 1.6% and 2.2% in 2025 down from the forecast figures of 2.2% and 2.5% respectively in 2024.

[110] In Canada, the gradual unwinding of the tight monetary policy stance by the Bank of Canada is yet to be felt, as inflation is slowly approaching the mid-range target of 2% by early 2025 as anticipated.

[111] The IMF observes that when a country undergoes a demographic transition, with declining fertility rates and an aging population, the share of its working-age population starts to shrink.^{Footnote 50} Canada is experiencing this phenomenon along with several large economies, resulting in a noticeable decline in labour’s contribution to growth. To counter this imbalance and mitigate the increasing demographic pressures on labour supply, immigration and migrant workers become important for advanced economies, especially Canada.

[112] The IMF projects for Canada a real GDP growth of 1.3% in 2024, faring better in 2025 at 2.4%.

[113] In sum, disinflation is not uniform across sectors and economies which might delay foreign central banks in adopting a relaxed monetary policy in their respective markets. This, coupled with high debt levels accumulated during the pandemic, would likely result in international economies growing at different pace. To fill the labour gaps in certain advanced economies, a massive influx of immigrants and migrant workers might occur to support economic growth. Markets with sluggish, or rosy, economic outlooks, will see their exporters and producers target foreign markets to sell their unsold, or excess, production of copper tube.

Economic outlook in the named countries and canada

[114] There was no participation from the known exporters and foreign producers in this expiry review. Consequently, the CBSA will not submit any further information on top of what the Canadian producer has already submitted as regards companies information and their respective production capacity. In its consideration and analysis, the CBSA will rely on its own, limited, research and put the emphasis on the construction industry, where information is available, and more specifically the real estate market, since copper tube demand is closely tied to them.

Brazil

[115] Economic stability, government policies, market trends, and the legal framework affect the real estate market in Brazil. The economy has experienced significant ups and downs; growth periods boost the market, while downturns lead to stagnation.

[116] Brazil’s main economic partner, China, is expected to experience weaker growth in the years ahead, which could reduce exports and consequently the economic activities. However, faster disinflation could favour lower policy rates and bolster economic activities, acting as counterbalance.^{Footnote 51}

[117] Public debts remain high compared to other emerging market economies. The new reformed fiscal policy could better control spending and focus on the long-term when it comes to infrastructure investment, like improved transportation, and potentially increase related spending. A better coordination among different government levels (federal and subnational) could strengthen public sector investments, and favour better sharing of technical capacities to carry infrastructure projects to completion.^{Footnote 52}

[118] Government future policies may see changes in taxation, housing subsidies, and infrastructure investments, impacting the real estate market.

[119] Recent economic recovery shows positive signs for real estate, despite challenges like high unemployment and political uncertainty. Government initiatives, such as the “Minha Casa Minha Vida” (My House My Life) and “Casa Verde e Amarela” (Green and Yellow House) programs, aim to tackle housing shortages, particularly in urban areas, vary in effectiveness by region.^{Footnote 53}

[120] Brazil's real estate market is influenced by its diverse economic landscape, which affects regions differently. In major cities like São Paulo and Rio de Janeiro, high demand for well-located properties creates competitive markets, fueled by the influx of foreign capital. Conversely, smaller cities and rural areas might have a balanced or surplus property supply.

[121] Aging populations and urbanization are reshaping Brazil's real estate market. Young professionals and small families tend to favour studio flats and smaller apartments, more accessible homes, driving more people to cities for jobs and education, increasing demand for urban housing. This trend is shifting residential developments toward smaller, more affordable units.

[122] In suburban areas, demand shifts to single-family homes, preferred by families and older tenants who value space, privacy, and access to schools.

[123] According to figures released by Fundação Instituto de Pesquisas Econômicas (FIPE), Brazil’s FIPEZAP house price index rose by 5.54% in Q1 2024, from a year earlier. When adjusted for inflation, nationwide house prices rose by a meager 0.99% over the same period. House prices increased nominally the most in urban cities such as São Paulo, Rio de Janeiro and Brasilia; in certain areas inflation adjusted house prices rises were moderate even fell in Q1 2024.^{Footnote 54}

[124] Inflation is expected to ease through 2024 to reach 4.1% and 3.0% in 2025.^{Footnote 55} This triggered the Banco Central do Brasil’s Monetary Policy Committee to cut the Selic rate, the reference interest rate for the Brazilian economy, to 10.75% in March 2024. As a consequence thereof, the stimulation of housing demand in the medium term.^{Footnote 56}

[125] Despite the reduction in interest rates, the real estate credit market continues to slow. According to the Brazilian Mortgage Association (ABECIP), the total amount of loans for the construction of properties dropped 17.6% y-o-y to USD 773.6 million in the first two months of 2024; the total loan value for the purchase of real estate fell by 8.5% y-o-y to USD 3.23 billion for the same period.^{Footnote 57}

[126] The economy continues to grow modestly, amidst tight labour market conditions. In its April world economic outlook, the IMF projects nationwide unemployment rates at 8.0% and 7.9% in 2024 and 2025 respectively.

[127] As for the real estate market outlook in Brazil, it is expected to reach a value of USD 8.73/tn in 2024, of which the residential real estate holds over 80% of the market share. It is anticipated that the market will grow at an annual rate of 1.23% until 2029 from 2024, according to Statista.^{Footnote 58}

[128] In sum, interest rates remain restrictive but are set to fall; they hinge upon inflation and its convergence towards a tolerance level. Growth is expected to be moderate in light of the still-tight monetary policy, keeping interest rates somewhat high. There are positive signs in the real estate market, however the economic and fiscal headwinds will keep it hesitant in the next couple of years. The copper tube industry depends heavily on the real estate market and will likely be affected by the uncertainty that surrounds it, thus enticing Brazilian exporters and producers to seek alternate markets for their excess production.

China

[129] China's real estate sector, a key contributor to nearly a third of the nation's GDP, is experiencing a severe crisis. Traditionally, the Chinese prefer property investment due to its tangible nature, potential appreciation and, moreover, it is a symbol of wealth, status in addition to being essential for building families.

[130] The collapse of major companies like Evergrande and Country Garden threatens China's economic stability. The turmoil in China’s housing market is driven by: pessimism among potential homebuyers regarding job security and future earnings; instability among real estate developers who are defaulting on project deliveries, eroding consumer confidence; and demographic challenges, particularly an ageing population, leading to a reduced demand for new housing.

[131] Consequently, new home prices saw a 3.9% decline y-o-y in May 2024; Beijing prices fell 10-30% from their peak by December 2023, residential home sales dropped 31% and property developer cash reserves decreased by 26% by March 2024. Additionally, new property sales for China's top 100 developers fell 47% y-o-y in the first 4 months of 2024.^{Footnote 59}

[132] Furthermore, the scale of surplus housing is unclear with estimates suggesting that vacant homes could house up to a billion people or maybe more.

[133] Commercial real estate faces uncertainties too arising from the slow recovery of the leasing market, but fares better than residential real estate. Commercial Real Estate Services (CBRE), in its China real estate market outlook, projects a moderate recovery of office leasing demand, an equitable balance between supply and demand for logistics warehouse, in addition to a stable retail sector conditional upon improving consumer confidence in 2024.^{Footnote 60}

[134] This prompted the GOC to introduce a series of measures to stabilize the struggling property sector, which include reducing down payment requirements, lowering mortgage rates, easing purchase requirements, and encouraging local governments to buy unsold properties for social housing.

[135] The IMF reports that China’s overall monetary policy stance was moderately accommodative in 2023 and is expected to remain so in 2024. Nevertheless, the effectiveness of policy rate transmission to the real economy through the housing market has been limited. Previously, the housing market was sensitivity to short-term interest rate movements, but since the mid-2021 property sector downturn, nonmonetary factors like developer distress and large unfinished homes inventories have lessened the cause and effect relationship between house prices and borrowing costs.^{Footnote 61}

[136] Inflationary pressures remain subdued as a result of lower domestic food prices and pass-through effects on underlying core inflation. The IMF projects consumer prices to increase 1.0% in 2024 from 0.2% in 2023, and to reach 2.0% in 2025.^{Footnote 62}

[137] Unemployment is expected to remain stable at 5.1% in 2024 and 2025, according to the IMF. However, China is experiencing a demographic drag on labour supply due to ageing population and gender disparities in labour force participation. This could potentially reduce the contribution of labour supply to GDP growth in the years to come.^{Footnote 63}

[138] Statista expects the real estate market in China to reach a value of USD 130.70tn in 2024. Worthy of note is that the residential real estate holds over 85% of the market share in the same year. It is expected that the market will grow at an annual rate of 1.96% from 2024 to 2029, according to the same source.

[139] In sum, despite the accommodative monetary policy stance in China, its effect on housing prices has yet to be felt. Unsold and unfinished properties in addition to the downfall of big developers weaken the monetary policy intended effect. The population is ageing which further exacerbate the demand for new housing and negatively impact the property market. In the absence of a comprehensive restructuring policy package for the troubled property sector, house prices could further decline. This could falter China’s future growth and, consequently, create a negative spillover effect on the neighbouring countries and the world. Since copper tube is closely tied the property market, it is logical to conclude that Chinese exporters and producers will be incentivized to find alternative foreign markets to sell their excess goods.

Greece

[140] Greek house prices are surging, driven by strong demand from foreign homebuyers, increased residential construction, and continued economic growth. In urban areas, house prices rose by 10.76% y-o-y in Q1 2024, and when adjusted for inflation, the increase was 7.31% y-o-y. Quarterly growth in Q1 2024 was 2.4% (2.76% in real terms).^{Footnote 64}

[141] This surge is largely due to the Golden Visa Program, launched in 2013 to revive the housing market, which offers residency to non-EU investors purchasing property over €250,000. The property market in Greece is a significant component of foreign direct investment (FDI), contributing about 20% to 35% annually. Additionally, in 2023 foreign buyers' real estate purchases constituted 80-85% of all purchases, an all-time high. Also worthy of mention is the lower house prices in Greece, than those in most of the European countries, are attracting foreign investors.^{Footnote 65}

[142] The Government of Greece has introduced several measures among others, the suspension of VAT payments, the tax relief for real estate and the reduction of the single property tax (ENFIA), which buoyed the housing market. It is important to note that Greece emerged from an economic crisis in 2017 that dramatically impacted residential property prices between 2007 and 2017. During the Greek crisis in 2012, unsold houses attained a record 350K units, which now have been resorbed. House prices have appreciated ever since by circa 50% between Q3 2017, their lowest point, and Q1 2023. Nevertheless, house prices remain lower from their all-time high in Q3 2008.^{Footnote 66}

[143] This ensued in rapid urbanization, which has created a stark contrast between urban and rural areas. Over 35% of housing stock is vacant in rural areas, often in need of major renovation. Urban areas, however, face crowded living conditions and high transaction costs.

[144] Mortgage interest rates in Greece have been rising due to successive rate hikes by the European Central Bank (ECB) over the past two years to combat inflation. Consequently, the mortgage market in Greece is shrinking and is expected to drop further below 12% of GDP in 2024, on top of the contraction of 12.7% of GDP in 2023.^{Footnote 67}

[145] The Bank of Greece reports a contraction in housing loans since 2021 which continue to moderately decelerate in 2024, at the expense of consumer loans which have been increasing since mid-2022. This contraction is attributed to the high level of interest rates and household’s relying on cash-based transactions (savings) in addition to other bank loans and external financing.^{Footnote 68}

[146] Residential construction has been rising continuously over the past years, after nearly a decade of declining activity, except in 2022 where building permits fell by 2.2% y-o-y. In 2024, as of May y-t-d, building permits have increased by 22.0%, suggesting a strong rise in building activities.^{Footnote 69}

[147] The Bank of Greece expects inflation, based on the Harmonised Index of Consumer Prices (HICP), to reach 3.0% in 2024 and to decelerate to 2.3% in 2025. Inflation has been on decline over the past two years, and can be mainly ascribed to lower food prices, non-energy industrial goods and services.^{Footnote 70}

[148] The unemployment rate is projected to attain 10.5% in 2024 and to improve to 9.6% in 2025. The high demand for labour in the tourist, construction, agriculture and health sectors is the main factor behind such improvement. This will eventually lead to an increase in the rate of compensation, as the labour market tightens, putting upward pressure on costs.^{Footnote 71}

[149] Greece is gradually relaxing its monetary policy after tightening it in the previous years to counter inflation. The upgrade of Greece sovereign credit rating in 2023 to investment grade coupled with a prudent fiscal policy and a converging inflation toward ECB target, will help boost growth.

[150] Statista projects the real estate market in Greece to reach a value of USD 1.53tn in 2024, with the residential real estate value accounting for over 83% of the total market. Furthermore, Statista expects the real estate market to grow annually at a rate of 3.53% until 2029.

[151] In sum, the real estate market in Greece has recovered from a deep slump that lasted 10 years. The surplus of housing units supply has been, or close to being, resorbed, and there is every reason to believe that the sector is geared towards an uptick. House prices remain lower than prices in other European markets, which give the Greek housing market a competitive advantage over their European counterparts. Moreover, the government is adopting responsible monetary and fiscal policies, thus improving the economy and fueling future growth. Since the real estate and copper tube markets are closely intertwined, the latter is poised to thrive. The strength of the real estate post-crisis rebound remains to be seen, as unexpected events may enter into play such as high energy prices, inflation stubbornness, international conflicts, etc. In this eventuality, Greek exporters and producers might look for external markets to sell their excess products.

Mexico

[152] Mexico's housing market is growing, driven by strong domestic demand and the return of foreign homebuyers. In Q1 2024, the nationwide house price index increased by 9.64% y-o-y; the increase amounted to 5% when adjusted for inflation. New houses saw an average price growth of 10.36%, and existing houses of 9.07% for the same period.^{Footnote 72}

[153] Mexico's housing market is fueled by a robust domestic market, particularly a growing middle class. The middle class makes up almost half of the total households, estimated at about 16 million, and is expected to grow by 3.8 million more households by 2030.^{Footnote 73}

[154] The residential construction investment has grown, but remains weaker than non-residential construction. Additionally, about 25% of dwellings exhibit poor quality and are constructed with subpar materials, are overcrowded, or lack essential facilities.^{Footnote 74}

[155] Foreign demand is also strong. As economic activity returns to pre-pandemic levels, American and Canadian buyers are returning, buying coastal properties and pushing home values up. Foreign Direct Investment (FDI) increased by 27% in 2023, with the U.S. contributing the most.^{Footnote 75}

[156] Fiscal policies are prudent and ensure debt sustainability. However, they do not provide the necessary support to smooth out economic downturns, as they are more geared towards reducing spending to attain fiscal targets. The fiscal stance is expected to be expansionary in 2024 with more social spending and public investment increasing, which could support short to medium-term growth at the expense of a rising inflation. In contrast, the monetary policy stance is expected to remain tight in 2025 to counter inflationary pressure in certain sectors such as processed food and services, reducing growth potential.^{Footnote 76}

[157] Banco de México has successively hiked the interest rate in response to increasing inflationary pressures. In May 2024, the interest rate stood at 11.0%, following a rate cut in March 2024, dragging mortgage rates up. As of April 2024, mortgage rates averaged 13.89%, which are considerably high. The interest rate is expected to decline but it depends upon how close inflation is contained within the Bank’s target rate of 3%.^{Footnote 77} The IMF projects a subdued inflation rate, as measured by the CPI, of 4.0% in 2024 edging down to 3.3% in 2025.^{Footnote 78}

[158] The labour market is anticipated to remain strong and tight, with increasing participation for women. However, the level of informality, i.e. not regulated or protected jobs, is affecting 55% of Mexican workers and therefore jobs stability. When informality prevails among workers, tapping into credit markets becomes a challenge for low to middle-income households. Recent government policies are more focused on regularising informal work and aiding low-income households.^{Footnote 79} The IMF expects the unemployment rate to stand at 2.8% in 2024 and slightly edge up to 3.2% in 2025.

[159] Statista anticipates the real estate market in Mexico to reach a value of USD 5.44tn in 2024, with the residential sector accounting for more than 75% of the total value. Going forward, Statista projects an annual growth rate of 5.02% from 2024 to 2029.

[160] In sum, Mexico faces some tailwinds and headwinds affecting the real estate sector. The middle class is growing increasing demand for housing, and foreign investors are back driving house prices up. The labour market remains tight suggesting more disposable income at hand and the capability to engage in long-term investments, such as buying houses. Conversely, the level of informality remains high among workers, which limits their accessibility to mortgages. Additionally, inflation pressures, although tamed, show stubbornness in certain sectors. This triggers the adoption of a restrictive monetary policy, keeping interest rates sufficiently high thus restraining access to credit markets products. The real estate sector is expected to be caught between these opposing directions and to adjust accordingly, which could affect its speed of growth rate or the lack of it. As for exporters and producers of copper tube, nothing prevents them from seeking other markets to clear excess production, when needs arise.

South Korea

[161] Over the past years, a successive interest rate hikes to combat inflationary pressures in South Korea has severely impacted the real estate sector. High interest rates led housing prices to a nominal decline of about 9% in June 2023 from their post-pandemic peak. Consequently housing transactions spiraled down and inventories of unsold properties surged, slowing mortgage lending.^{Footnote 80}

[162] This has resulted in an elevated servicing burden and household holding back consumption. The weak housing market has also reverberated on project financing in the construction sector; high interest rates devalued the real estate collateral in asset-backed securities, increased the debt servicing delinquency rates, and forced certain construction companies to default on their debts or to reach an agreement with their creditors.

[163] South Korean authorities intervened to ward off severe declines in housing prices by easing macro prudential regulations such as reducing housing taxes, relaxing laws pertaining to zoning and reconstruction, introducing new lending programme depending on family status (young, newlyweds, family with new-born kids, etc.).^{Footnote 81} These regulations seem to have stabilised the falling housing prices however, housing market sentiment is expected to remain hesitant, due to high household debt levels, in the year ahead before it starts gaining confidence.^{Footnote 82}

[164] Commercial real estate is anticipated to pick up as the market sentiment improves, with the office sector to remain buoyant due to demand supply imbalance. The retail sector is also expected to rebound, as foreign tourists come back and households improve their purchasing power due to abating inflation and debt levels. Vacancy rate is projected to remain high in logistics, which will eventually be absorbed as economic activities increase. All in all, investment in the commercial sector will remain timid in the short-run and will gradually pick up, pending interest rate cuts, with the office sector leading the way.^{Footnote 83}

[165] The Bank of Korea has tightened its monetary policy repeatedly by increasing its base rate, starting in August 2021, which stood at 3.50% since early 2023. This restrictive policy was in response to CPI inflation rate that reached a 6.3% high (y-o-y) in July 2022. Consequently, household debt servicing burden increased, disposable income decreased, and insolvency grew exerting drag on consumption and housing prices. Nevertheless, The monetary stance is expected to loosen in late 2024 combined with a responsible fiscal policy, which should help relieve pressure on consumption, mortgage rates, and construction investment.^{Footnote 84}

[166] Inflationary pressure is easing and trending down from its peak in July 2022 towards the 2% target, despite showing stubbornness in the food and energy sectors. The IMF projects inflation, as measured by the consumer prices, to post 2.5% rate in 2024 and to display a downward trend in 2025 to attain 2.0%.^{Footnote 85}

[167] The labour market remains resilient with an unemployment rate expected to reach 3.0% in 2024 and to slightly edge up to 3.1% in 2025, according to the IMF; this resiliency can be attributed to participation driven by women and elderly people. It is important to note that the Korean fertility rate is among the lowest in the world and the population is set to halve in the next 60 years. This will result in increasing old-age dependency ratio, decreasing labour supply thus exerting pressure on government fiscal policies, economic growth and consequently the real estate market. Additionally, the labour market duality, regular versus non-regular workers, shows a big gap in pay, job quality and security, productivity and social protection, restricting access of non-regular workers to credit markets.^{Footnote 86}

[168] According to Statista, the real estate market is expected to reach a value of USD 12.25tn, with the residential real estate accounting for over 67% of the market volume in 2024. Statista anticipates the real estate market to grow by 1.10% on a annual basis, for the 5-year period ending in 2029.^{Footnote 87}

[169] In sum, high interest rates resulting in elevated debt servicing levels coupled with inflationary pressures and falling housing prices will remain a drag on consumption. The housing real estate sector is expected to remain stagnant in the near future, and the commercial real estate to fare slightly better. The expected interest rates cuts will not have an immediate effect on market sentiment, as there is a delayed response to the intended monetary policy goals. The labour market stayed resilient and prevented a contraction of domestic demand, however it is ageing as fertility rate is decreasing. If the fertility rate is not reversed along with tapping into underutilized labour resources and immigration, there will be a shortage in labour supply and consequently higher construction costs. Regulating the labour market duality will also give access to credit markets to a large portion of workers. In the face of a hesitant real estate market, Korean exporters and producers of copper tube have no choice but to go after opportunities abroad to liquidate their excess inventories.

Canada

[170] Interest rates increases from early 2022 aimed to combat inflationary pressures, led to an economic slowdown that affected the housing market. Higher mortgage rates reduced homeownership demand and house price growth, limiting consumers spending. Additionally, builders and developers struggled to get financing, slowing construction of smaller buildings like single-detached homes. Consequently, the CMHC anticipates housing starts to decline in 2024 before they pick up in 2025-2026.^{Footnote 88}

[171] Moreover, affordability challenges emerged, and will likely persist, especially in the rental sector due to higher costs of homeownership and reduced construction of rental buildings. Vacancy rate is decreasing bearing the brunt of the continued pressure from the labour market, which remained resilient throughout 2023. Adding to the problem the record population growth emanating from immigration, which created a big demand supply gap in the housing market. All factors considered, the CMHC judges rental demand to rise along with rents and vacancy rate to fall. ^{Footnote 89}

[172] The CMHC observes that the number of senior households is bound to increase in the future. However, the elderly tend to cling to their properties and only list them for sale as they advance in age. In other words, the impact on the nation housing shortage from the added elderly supply remains limited for now.^{Footnote 90}

[173] Speaking of housing shortages, the CMHC projects that 3.5 million additional units, housing supply gap based on its baseline economic and demographic scenario, are needed by 2030 in order to reach an adequate level of affordability. This projection may differ from baseline, then between 3.1 and 4 million units will be needed depending on a low-economic-growth or a high-population-growth scenario. The CMHC estimates that 18.2 million housing units will be built by 2030.^{Footnote 91}

[174] To help solve the housing crisis, the Government of Canada has introduced a series of initiatives geared towards increasing housing supply and improving affordability. To name a few, the housing accelerator fund aims to streamline approval processes and to create new opportunities to redevelop properties; the removal of GST from new rental apartment projects unlocks cheaper financing for lenders and reduces costs for builders; the apartment construction loan program helps create affordable rental housing by providing low-cost repayable loans to builders and developers.^{Footnote 92}

[175] The Bank of Canada has initiated a series of interest rates hikes in early 2022 to tame inflationary pressures that was built up during the pandemic. Accordingly, house prices fell from their peak in 2022 and property sales slowed; at its peak, the interest rate stood at 5.0%. Now that inflationary pressures are receding, the monetary policy stance started to ease in mid 2024, and will likely continue through 2025 depending on how well inflation is contained.^{Footnote 93}

[176] Canada is faced with a shortage of labour in the skilled trades and rising costs, lengthening construction time. Additionally, labour supply stemming from immigration growth cannot be timely trained and absorbed by Canadian companies. Consequently, the IMF projects unemployment rate to rise to 6.3% in 2024, from the 5.4% level in 2023, then to remain stable in 2025.^{Footnote 94}

[177] Inflationary pressures are abating from the 3.9% mark in 2023, which should ease lending and, consequently, the mortgage market. The IMF anticipates inflation to reach 2.6% in 2024 and to continue to decline to 1.9% in 2025.^{Footnote 95}

[178] Statista anticipates the Canadian real estate market to attain a value of USD 8.47tn in 2024, of which the residential real estate accounts for over 77% of the market share. Until 2029, Statista projects an annual rate of growth of 3.71% from 2024.^{Footnote 96}

[179] In sum, inflationary pressures are subsiding, interest rates are decreasing, and fiscal policies are geared towards alleviating the housing market crisis. This should ease affordability and induce households to resume spending. The housing supply gap remains enormous as demand emanating from high immigration levels will take time to adjust. The labour market is resilient and will see high-skilled workers forming in sectors where there are shortages. The demand for constructing new housing units is real, in order to reach an adequate level of affordability for Canadians. As for house prices, they will fluctuate according to supply and demand and the speed at which the gap is closed. There will be some headwinds but all the right conditions are in place for housing construction to start and for the real estate sector to boom in the years to come. Since copper tube is an integrant part of real estate, Canada will become a very attractive market for foreign exporters and producers who will be incentivized to tap into it to liquidate their excess production.

Decrease in volume of imports from the named countries

[180] The CBSA has noticed that imports from the named countries have significantly decreased during the POR. The aforementioned Table 3 shows the downward export trend of subject goods to Canada during the current expiry review.

[181] To put the issue into perspective, the CBSA has produced a comparative Table 4 depicting the volume and value of imports from the 2018 expiry review next to the current one. Total imports volume during the 2018 expiry review into Canada amounted to 38,652 kg versus 934 kg in the 2024 expiry review, representing a whopping of 98% decrease. Value of imports for duty attained $409,933 in 2018 compared to $23,913 in 2024.

[182] This information is highly suggestive of the inability of exporters and producers in the named countries to maintain their presence and compete in the Canadian market at non-dumped prices.

Increase in imports of copper tube from non-named countries

[183] The CBSA has noticed that imports from all other countries have vastly increased during the POR. The aforementioned Table 2 shows the aggregate volume and value of exports from all other countries of subject goods during the current expiry review.

[184] To put the issue into perspective, the CBSA has produced a comparative Table 5 depicting the volume and value of imports from the 2018 expiry review next to the current one. Total volume of imports into Canada increased by 31% during the 2024 expiry review, amounting to 15,459,123 kg when compared to 11,767,780 kg in the 2018 expiry review. As for the value of imports during the current POR, it has more than doubled reaching $236,493,309 versus $116,405,597 in the 2018 POR.

[185] It is strongly evident that the imposition of trade remedies saw an exit from the Canadian market by the named countries and created a change in trade pattern, substituting those imports by other countries. GLC observes the rising exports namely from Vietnam and India; the CBSA concurs with this observation and confirms this rising trend from internal data.

[186] As a matter of fact, internal records show that Vietnam and India hold the second and third position respectively in terms of volume, as exporters of subject goods during the POR.

[187] This information is proving the continued attractiveness of the Canadian market.

Imposition of measures in other jurisdictions

[188] In its effort to find the anti-dumping measures in force applicable to the named countries, the CBSA relied on information gathered from the WTO online database. The following Table 6 summarizes the measures in force in effect per reporting members applicable to exporting members from the named countries.

[189] The data show that China is the exporting member with the most measures in force applicable to (318), followed by South Korea (70), Brazil (20), Mexico (11) and Greece (4).

[190] Combining the figures from Canada and the U.S. demonstrates that 30% of the goods in the base metals sector were sold at dumped prices in North America. The CBSA noticed that there have been measures in force in effect in the base metals sector since 1986, suggesting that without anti-dumping duties the named countries will likely sell at dumped prices.

[191] By refining the search in the U.S. for copper tube which is referred to as “seamless refined copper pipe and tube” the CBSA noticed that imports from China and Mexico have been subjected to anti-dumping duties since 2010. Furthermore, there is a new measure in force applicable to Vietnam for imports into the U.S., which has been in effect since 2021. This shows the continued attractiveness of the North American markets, as a destination of choice for subject goods.

[192] It seems that Mexico and Greece are the least countries with measures in force applicable to. It is needless to say that these two countries are among the biggest producers of copper tube in the world, with production capacities that far outweigh what their respective local markets can absorb.

Dumping: Determination

[193] The CBSA has conducted its analysis by relying on its own research, which concurs with the Canadian producer assessment.

[194] Based on the available information concerning various factors:

• Copper tube is a commodity product primarily sold on the basis of price
• Exporters from the named countries have either stopped or significantly decreased their exports to Canada since the findings were issued
• There has been a shift in copper tube imports into Canada from countries not covered by the CITT’s findings
• Uncertain domestic demand outlooks in certain named countries
• Measures in force involving the named countries in other jurisdictions
• Significant production capacity of producers in the named countries

Therefore, the CBSA determined that the expiry of the orders in respect of copper tube originating in or exported from Brazil, China, Greece, Mexico, and South Korea is likely to result in the continuation or resumption of dumping of the goods.

Parties contending that continued or resumed subsidizing is likely

GLC

[195] GLC made representations in its case brief,^{Footnote 100} in support of the position that the continuation or resumption of subsidizing of the subject goods from China would be likely to continue or resume should the orders be rescinded. Consequently, GLC argues against rescinding the orders.

[196] GLC highlights that the Government of China and Chinese exporters have neither responded to the CBSA's questionnaire nor cooperated.

[197] GLC adds that during the original investigation, the CBSA found that Chinese exporters who cooperated were benefiting from 178 countervailable programs, with 100% of the goods exported from China being subsidized. GLC goes on to say that the CBSA, since the CITT's finding on copper tube, has conducted eight additional subsidy investigations involving China, resulting in 19 countervailing measures on Chinese goods sold to Canada. These investigations revealed various subsidy programs, including preferential tax policies and grants, which may also be available to copper tube producers.

[198] GLC refers to China's recent notification to the WTO Committee, which confirms that the Chinese Government continues to provide countervailable subsidies that may be available to copper tube producers. GLC cites the last expiry review of Copper Pipe Fittings, where the CBSA found that Chinese producers were likely to keep receiving these subsidies.

Parties contending that continued or resumed subsidizing is unlikely

[199] No other parties contended that the continuation or resumption of subsidizing of the subject goods from China is unlikely should the orders expire.

Subsidy: Determination

[212] Based on the available information concerning various factors:

• Continued availability of subsidy programs for exporters in China
• Uncertain domestic demand outlooks in China
• Countervailing measures in force applicable to China in other jurisdictions
• Significant production capacity of Chinese producers
• Continued attractiveness of North American markets
• Lack of transparency and cooperation from the GOC

Therefore, the CBSA determined that the expiry of the orders in respect of copper tube originating in or exported from China is likely to result in the continuation or resumption of subsidizing of the goods.