Statement of reasons—Termination: Corrosion-Resistant Steel Sheet 3 (COR3 2024 IN)

Domestic industry

[11] The domestic industry is comprised of three producers, ArcelorMittal Dofasco G.P. (AMD), Material Sciences Corporation, and Stelco Inc. (Stelco). At initiation of the investigation, the CBSA sent a particular market situation (PMS) request for information (RFI) to these three producers. Responses were received from AMD and Stelco.

Trade union

[12] The United Steelworkers has been identified as representing persons employed in the production of like goods in Canada.

Importers

[13] At the time of initiation of the investigation, the CBSA identified 11 potential importers of the subject goods from CBSA import documentation. Two importers provided a response to the importer RFI.^{Footnote 1}

Exporter

[14] The exporter and producer of the subject goods, Borçelik in Türkiye, was asked to respond to the CBSA’s Dumping RFI, and provided a response. Borçelik represents 100% of the volume of subject goods during the POI. Producers and suppliers of hot-rolled or cold-rolled steel used as input in the production of subject and like goods, that are related to Borçelik, were also requested to respond to parts of the RFI. None of Borçelik’s associated producers or suppliers of such input provided a response.

Government

[15] At the initiation of the investigation, the CBSA sent a PMS RFI to the Government of Türkiye (GOT), to which the GOT responded.

Definition

[16] For the purposes of this investigation, subject goods are defined as:

Additional product information^{Footnote 2}

[17] The product definition includes COR where the substrate is coated with a corrosion-resistant material such as zinc, aluminum, and other alloys. The coating may be applied by a variety of processes including hot-dip galvanizing or electro-galvanizing.

[18] The product definition includes galvannealed steel. Galvannealed steel is produced by passing the steel through an annealing furnace after it completes the hot-dip galvanizing process and while the zinc is still liquid. This causes the iron and zinc layers to diffuse into each other, creating a zinc-alloy layer at the surface.

[19] Passivation refers to a material becoming “passive”, that is, less affected or corroded by the environment of future use. Passivation involves creation of an outer layer of shield material that is applied as a micro-coating, created by chemical reaction with the base material, or allowed to build from spontaneous oxidation in the air. As a technique, passivation is the use of a light coat of a protective material, to create a shell against corrosion.

[20] Corrosion-resistant steel with anti-fingerprint coatings (whether as part of a passivation treatment or separate) is also included within the product definition.

[21] COR is usually produced from cold-rolled carbon steel sheet (“CRS”) and sometimes from hot-rolled carbon steel sheet (“HRS”). However, additions of certain elements, such as titanium, vanadium, niobium or boron, during the steel-making process enable the steel to be classified as alloy steel. Therefore, COR produced from either carbon steel or alloy steel is included in the definition of the subject goods.

[22] The subject goods (and like goods produced by the domestic industry) are manufactured to meet certain American Society for Testing and Materials (ASTM), Society of Automotive Engineering (SAE) or equivalent specifications, including, but not limited to:

• ASTM A653/653M
• ASTM A792/A792M
• SAE J403
• SAE J1392
• SAE J2329
• SAE J1562

[23] The product definition includes “seconds”. Seconds are goods that do not meet some aspect of the original specification. This could include dimensions, grade, or coating. It could also include a coil that has been damaged. Seconds are sold at a discount. Seconds may meet ASTM, SAE or other specifications or may be re-certified to meet a standard. For example, a coil that is damaged along the edge may be a “second”. However, if the damaged edge is slit and the damage is removed the coil could be classified as a primary coil produced to the new width. Seconds are graded and sold on a scale of five.

[24] For greater clarity, the product definition does not cover:

• Corrosion-resistant steel for use in automobiles and automobile parts, hereafter referred to as “Automotive”. Automotive end users include Original Equipment Manufacturers (“OEMs”) and auto part producers. Such excluded goods may fall under Customs Tariff item 9959.00.00
• Pre-painted steel and steel permanently coated in plastic. Pre-painted steel is steel on which paint has been applied by coil coating at the manufacturing facility. The paint may be applied to one or both sides. The paint may be applied as a liquid, paste, powder, varnish or lacquer. Paints may include, but are not limited to, primers, finishing coats, polyesters polymers, plastisol paints, polyurethanes, polyvinylidene fluorides, and epoxy. Steel permanently coated in plastic is steel to which plastics, including films or laminates, are permanently attached

Manufacturing process^{Footnote 3}

[25] The subject goods are usually produced from CRS and sometimes from HRS sheet. The steel sheet to be coated is commonly referred to as steel substrate. Hot-dip galvanizing and electro-galvanizing are the two processes that can be used to coat the substrate steel sheet with zinc, aluminum, or other alloys. AMD uses hot-dip galvanizing.

[26] In the hot-dip galvanizing process, the first step is to clean the surfaces to improve the adhesion of the coating. After cleaning, the substrate enters a continuous annealing furnace. The furnace heats the substrate to the temperature necessary to develop the desired metallurgical properties of the final product. The substrate is then placed in a molten coating bath and, as it emerges from the bath, an air, nitrogen or steam wipe is used to control the thickness of the coating. The galvanized steel sheet is then cooled in a cooling tower.

[27] In the electro-galvanizing process, charged steel passes through a plating bath and opposite electrical charges cause the zinc solution to coat the steel. Cold-rolled steel coils are batch annealed in multi-stack furnaces or in off-line continuous annealing process, often skin passing on a temper mill, before being electro-galvanized with a thin coating of zinc on a continuous processing line.

Product use^{Footnote 4}

[28] Common applications for COR falling within the product definition include, but are not limited to, production of farm buildings, grain bins, culverts, garden sheds, roofing material, siding, floor decks, roof decks, wall studs, drywall corner beads, doors, door frames, ducting (and other heating and cooling applications), flashing, hardware products and appliance components.

Classification of imports

[29] Beginning January 1, 2022, under the revised customs tariff schedule, subject goods are normally classified under the following tariff classification numbers:

1. 7210.30.00.00
2. 7210.49.00.40
3. 7210.49.00.50
4. 7210.49.00.60
5. 7210.49.00.70
6. 7210.61.00.10
7. 7210.61.00.20
8. 7210.69.00.10
9. 7210.69.00.20
10. 7212.20.00.10
11. 7212.20.00.20
12. 7212.20.00.30
13. 7212.20.00.40
14. 7212.30.00.10
15. 7212.30.00.20
16. 7212.30.00.30
17. 7212.30.00.40
18. 7212.50.00.30
19. 7212.50.00.40
20. 7212.50.00.50
21. 7212.50.00.60
22. 7225.91.00.10
23. 7225.91.00.20
24. 7225.91.00.30
25. 7225.91.00.40
26. 7225.92.00.10
27. 7225.92.00.20
28. 7225.92.00.30
29. 7225.92.00.40
30. 7226.99.00.11
31. 7226.99.00.12
32. 7226.99.00.13
33. 7226.99.00.19

[30] These tariff classification numbers may also include non-subject goods, and subject goods may also fall under additional tariff classification numbers.

Particular market situation

[49] The CBSA investigated whether a PMS existed in Türkiye for Borçelik, which would not permit a proper comparison of Borçelik’s domestic sales of like goods with their sales of subject goods to the importers in Canada.

[50] Pursuant to paragraph 16(2)(c) of the SIMA, the President of the CBSA may form the opinion that a PMS exists, which affects the sales of like goods for use in the country of export, such that a proper comparison with export sales is not permitted. According to subsection 16(2.1) of SIMA, a PMS may be found to exist in respect of any goods of a particular exporter or of a particular country, as appropriate in the circumstances.

[51] In accordance with paragraph 16(2)(c) of SIMA, the CBSA will not consider any sales of like goods for use in the country of export in determining the normal values of goods under section 15, if, in the opinion of the President of the CBSA, a PMS exists which does not permit a proper comparison with the sales of the goods to the importer in Canada.

[52] Although the SIMA does not define PMS, the President of the CBSA may form the opinion that a PMS exists, which does not permit a proper comparison with the sales of the goods to the importers in Canada. For example, certain factors (such as government regulations, significant volatility in economic conditions in the home market of the exporter and distorted input costs) have had a significant impact on the domestic sales of like goods in the country of export, such that the PMS does not permit a proper comparison between these sales and export sales to Canada.

[53] If the President is of the opinion that the domestic sales of like goods in the country of export do not permit a proper comparison with the sales of the goods to the importers in Canada because of a PMS, the normal values of those goods will be determined under section 19 of SIMA, where possible, or section 29 of SIMA.

[54] Additionally, if the President forms the opinion that a PMS exists which does not permit a proper comparison of the sales of like goods with the sales of the goods to the importer in Canada, such that the acquisition cost of an input used in the production of the subject good does not reasonably reflect the actual cost of that input, the cost of the input shall be substituted in accordance with subsection 11.2(2) of the SIMR, in the first of the amounts prescribed in paragraphs (a) to (e) that reasonably reflects the actual cost of the input so as to permit a proper comparison.

[55] This investigation is specific to one exporter. As such, the market being assessed is the market for Borçelik's domestic sales of COR meeting the product definition; and the relevant point of inquiry is whether there was, during the POI, a PMS that precluded a proper comparison of Borçelik’s domestic sales of like goods with their export sales of subject goods to Canada.

[56] In order to form an opinion, pursuant to paragraph 16(2)(c) of the SIMA, that a PMS existed in Türkiye for Borçelik, which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their sales of subject goods to the importers in Canada, sufficient information on the record would have been required to demonstrate that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

[57] At the initiation of the investigation, the CBSA sent PMS RFIs^{Footnote 11} to the GOT and Canadian domestic producers. The Dumping RFI^{Footnote 12} sent to Borçelik also included questions relating to PMS. During the investigation, the CBSA further sent SRFIs to the GOT, Canadian domestic producers and Borçelik to collect additional information relating to PMS. Responses^{Footnote 13} to the RFIs and SRFIs were received by the CBSA. Additional information^{Footnote 14} was also submitted by Canadian domestic producers. In the final phase of the investigation, an on-site verification^{Footnote 15} was held at Borçelik’s premises in Türkiye. The CBSA also included on the record a variety of available information^{Footnote 16} gathered by the CBSA, such as media articles, academic papers, industry information, pricing data, analysis, etc.

[58] The GOT submitted their comments^{Footnote 17} regarding the preliminary determination before the date of closing of the record. On the date of closing of the record, Borçelik and Canadian domestic industry submitted additional attachments.^{Footnote 18}

[59] The CBSA published its precursory PMS analysis^{Footnote 19} on the record and invited comments from interested parties^{Footnote 20}. Representations^{Footnote 21} on the CBSA’s precursory PMS analysis were received from the GOT, Canadian domestic producers and Borçelik. Further, Borçelik and Canadian domestic industry also filed case briefs^{Footnote 22} and reply submissions^{Footnote 23} for this investigation.

[60] The information on the record was used to evaluate whether a PMS existed in Türkiye for Borçelik, which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their sales of subject goods to the importers in Canada; and whether the application of subsection 11.2(2) of the SIMR is warranted.

[61] The CBSA has concluded that the information on the record was insufficient for the CBSA to form the opinion, pursuant to paragraph 16(2)(c) of SIMA, that a PMS existed in Türkiye for Borçelik due to the distorted input costs (caused by the significant volumes of HRC imports from China, Russia, Japan and India), which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their sales of subject goods to the importers in Canada.

[62] The CBSA considered the arguments submitted by Canadian domestic producers, as well as the evidence on the record. The information on the record was insufficient for the CBSA to form the opinion, pursuant to paragraph 16(2)(c) of SIMA, that a PMS existed in Türkiye for Borçelik due to the PMS factors alleged by the Canadian domestic producers, so as not to permit a proper comparison of Borçelik’s domestic sales of like goods with their sales of subject goods to the importers in Canada. These alleged PMS factors were, inter alia, volatile economic conditions, distorted inputs, presence of dumped COR in the Turkish market, Government support programs, and Turkish inward processing Regime (IPR).

1. Investigated Possible PMS Factor: Distorted input costs caused by significant volumes of HRC imports from China, Russia, Japan and India

[63] Given the evidence available to the CBSA at the initiation of the investigation that hot rolled coil (HRC) imports from China, Russia, Japan and India were dumped and caused material injury to the Turkish domestic industry, the CBSA chose to further investigate whether unfairly traded or low-priced HRC imports from China, Russia, Japan and India did in fact cause a price distortion that led to a PMS in the Turkish COR market.

[64] Through the investigation, the CBSA did not form the opinion, based on the information on the record, that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and Russia
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

1.1 Inputs (HRC and CRC) for COR

[65] HRCs and cold rolled coils (CRCs) are both major inputs for the production of COR. Generally, HRC accounts for the majority of the cost of CRC. As such, COR can be considered to be produced from HRC directly or indirectly.^{Footnote 24} HRC, CRC and COR are considered as mature products in the steel industry and have standardized manufacturing processes. They are produced and sold according to well-established standards that specify their chemical composition, mechanical properties, dimensional tolerances, surface finish, etc.^{Footnote 25}

[66] Price sensitivity among HRC, CRC and COR purchasers plays a crucial role in shaping market trends and influencing the production strategies of their respective manufacturers. By their nature, HRC, CRC and COR are commodity products. HRC, CRC and COR offered by one supplier is easily substitutable by another supplier and domestic supply can be easily substituted by imports. In light of this characteristic, purchasers of HRC, CRC and COR are price sensitive when selecting their supply source.^{Footnote 26}

1.2 Turkish HRC Market

[67] According to the GOT, the primary and most important raw material for the production of all flat-rolled steel products (including CRC and COR) are HRCs; and the HRC market in Türkiye was an open market and was closer to a perfect competition market.^{Footnote 27}

[68] Based on an analysis^{Footnote 28} of the information submitted by the GOT for the Turkish HRC market, for the period of January 2023 to September 2024, the CBSA concluded that the Turkish HRC market was open and fairly competitive; considered price as a major factor for competition; did not have indications of market dominance or strength by the four largest participants; and had significant imports from China, Russia, Japan and India.

[69] Given these conditions in the Turkish HRC market, an influx of unfairly traded or low-priced HRC imports from China, Russia, Japan and India may have lowered both domestic HRC prices in Türkiye and HRC import prices from other countries.

1.3 Turkish CRC market

[70] According to the GOT, the CRC market in Türkiye was also an open market and was closer to a perfect competition market.^{Footnote 29}

[71] Based on an analysis^{Footnote 30} of the information submitted by the GOT for the Turkish CRC market, for the period of January 2023 to September 2024, the CBSA concluded that the Turkish CRC market was open and fairly competitive; considered price as a major factor for competition; and did not have indications of market dominance or strength by the four largest participants. The CBSA reached the same conclusion when the information submitted by the GOT for the Turkish CRC market was updated with production information submitted by Borçelik.

[72] As discussed in the subsection 1.2 and as HRC is the major input for CRC, given the aforementioned market conditions of the Turkish CRC market (e.g. open, fairly competitive, price as a major factor for competition and no indications of market dominance or strength by the four largest participants), the Turkish domestic CRC prices and Turkish CRC import prices may have been subsequently lowered as well in order to remain competitive.

1.4 Turkish COR market

[73] According to the GOT, the COR market in Türkiye was an open market and was closer to a perfect competition market.^{Footnote 31}

[74] Based on an analysis^{Footnote 32} of the information submitted by the GOT for the Turkish COR market, for the period of January 2023 to September 2024, the CBSA concluded that the Turkish COR market was open and fairly competitive; considered price as a major factor for competition; and did not have indications of market dominance or strength by the four largest participants.

[75] As discussed in the subsection 1.2 and as HRC is the major input for CRC and COR, given the aforementioned market conditions of the Turkish CRC and COR markets (open, fairly competitive, price as a major factor for competition and no indications of market dominance or strength by the four largest participants), the COR prices in Türkiye may have been lowered as well.

1.5 Significant volumes of unfairly-traded or low-priced HRC imports into Türkiye from China, Russia, Japan and India

[76] Based on an analysis^{Footnote 33} of the information submitted by the GOT for HRC imports into the Turkish market, for the period of January 2023 to September 2024, the CBSA concluded that there were significant volumes of HRC imports from China, Russia, Japan and India; as determined by the GOT, HRC imports from China, Russia, Japan and India during the period of January 2023 to June 2023 were dumped and caused material injury to Turkish domestic industry; and HRC imports from China, Russia, Japan and India during the period of July 2023 to September 2024 were low-priced.

[77] In order to evaluate whether the increased volumes of unfairly-traded or low-priced HRC imports from China were exerting downward pressure on the Turkish domestic COR prices, the CBSA assessed the pricing relationship between Chinese HRC export prices and the Turkish domestic COR prices using a correlation coefficient. A high correlation coefficient indicates a strong relationship between the prices. Based on an analysis^{Footnote 34} of the correlation coefficients between Chinese HRC export prices, the Turkish HRC/CRC prices and the Turkish domestic COR prices, the CBSA concluded that the Turkish COR prices are perfectly correlated with Turkish HRC/CRC prices, which are perfectly correlated with Chinese HRC export prices. However, the CBSA was unable to conclude that changes in Turkish COR prices were caused by Chinese HRC export prices. In order to demonstrate a causal relationship, other known possible causes of the observed correlations would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish HRC and COR markets were impacted by the factors such as the earthquake that happened in February 2023, local demand, scrap prices, and export volumes.^{Footnote 35} These factors were considered as possible causes of observed correlations. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to conclude that these factors did not cause the observed correlations and that there was a causal link between changes in COR prices in the Turkish market and the importation of Chinese HRC.

[78] In their representation^{Footnote 36} regarding PMS, Borçelik calculated correlation coefficientsusing the Turkish domestic HRC prices as published by Fastmarkets, and HRC imports data from the Turkish Statistical Institute (“TUIK”). The CBSA considered that this proposed approach should not be adopted due to the following reasons:

• When calculating the cross-correlation between steel price time series from two markets, the pricing information for both markets should be produced consistently and representatively during the analysis period, in order to appropriately discern if there is a strong correlation relationship between the prices
• Both the Chinese HRC export prices and the Turkish domestic HRC prices used by the CBSA are published by the same leading commodity price reporting agency, Fastmarkets, which adopts the price-discovery process to produce consistent and representative indicators of value for specific markets over defined trading periods^{Footnote 37}
• Information^{Footnote 38} on the record indicates that HRC product characteristics impact their prices. In this situation, it is more appropriate to use the pricing information for representative product group(s) to reflect real pricing trend/level in the market, as the average unit price of all different types of purchased/imported HRC may not be able to reflect real pricing trend/level in the market due to significant impact from the composition of the different types of purchased/imported HRC

[79] In its representation^{Footnote 39} regarding PMS, Borçelik also calculated correlation coefficients by using the Turkish domestic COR prices as published by Fastmarkets, and the alleged HRC imports data from the TUIK. The CBSA considered that this proposed approach should not be adopted due to the same reasons as described in the paragraph above.

[80] In addition to imports from China, it should also be noted that a considerable volume of HRC was imported from Russia during the period of January 2023 to September 2024. As a response to Russia’s invasion of Ukraine on February 24, 2022, several major steel-consuming countries imposed sanctions on Russia, including restrictions on trade and the revocation of Russia’s Most-Favoured-Nation (MFN) status. The export of Russian steel products including HRC, was particularly affected by the revocation of Russia’s MFN status by several countries including EU member states, the United Kingdom, the USA, Canada and Japan.

[81] However, Türkiye did not impose these sanctions on Russia. The revocation of Russia’s MFN status resulted in a major trade barrier for Russian products, including HRC. Further, any increase in domestic consumption to make up for losses of export markets was quite unlikely for Russia considering that economic sanctions were also creating a range of economic challenges in the country’s steel consuming industries. These conditions suggest that a large volume of Russian excess HRC supply was available to be sold to the markets that were still willing to take them at significantly-discounted prices, such as Türkiye who had not imposed sanctions on Russia.

[82] Given the relationships between HRC, CRC and COR products, the features and relationships of the Turkish HRC, CRC and COR markets, and the correlations between these markets, the significant volumes of unfairly traded or low-priced HRC imports from China, Russia, Japan and India may have subsequently lowered prices in the Turkish COR market, due to the competitive nature of theses markets where price was a major factor for competition.

1.6 Methodology applied to evaluate price distortions (selection of benchmarks)

[83] In order to evaluate if a situation has caused price distortions to a market under investigation, there are different methodologies the CBSA may employ.

[84] Under the first methodology, absolute values are selected or established as benchmark values. These benchmark values represent what the prices should be if a situation under investigation becomes present in the market but price distortions to the market have not been caused by this situation. Actual prices in the market are measured and then compared to these benchmark values to evaluate the difference. Price distortions are found to exist if the difference is considered significant. For example, if market A and market B have comparable economic factors, comparable industry structures, comparable costing levels and comparable market conditions for the product, the prices of the product in market A would be comparable to the prices of the product in the market B. When a new situation becomes present in market A, the prices of the product in market B during the same period can be utilized (with necessary adjustments) as the benchmark values to evaluate if price distortions have been caused by this situation to the prices of the product in market A. If a significant difference is found between the actual prices of product in market A and the benchmark values (i.e. the prices of the product in market B with necessary adjustments), then it can be concluded that price distortions have been caused by this situation to the prices of the product in market A, if all other market factors are substantially unchanged.^{Footnote 40} For this case, the CBSA was unable to apply this methodology as sufficient adjustment information was not available to the CBSA.^{Footnote 41}

[85] In this case, the CBSA used a methodology wherein the relationship between prices in two comparable markets (such as A and B) is used as the benchmark relationship. Specifically, for the period before a situation becomes present in market A, and is not present in market B, the relationship between the absolute prices of the product in market A and B is analyzed and used as the benchmark relationship. When the situation under investigation becomes present in market A, but does not appear in market B, the absolute prices of the product in market A and B are measured again and the relationship between the absolute prices of the product in market A and B (“relationship under investigation”) is summarized and then compared to the benchmark relationship. If a significant difference is found between the relationship under investigation and the benchmark relationship, then it can be concluded that price distortions have been caused by this situation to the prices of the product in market A, if all other market factors are substantially unchanged.^{Footnote 42}

[86] Based on the CBSA’s analysis^{Footnote 43} of the information on the record, the CBSA concluded that the Italian HRC market and the Southern European CRC/COR markets are the most appropriate markets to be used to evaluate if price distortions happened in the Turkish markets. This is due to their geographical proximity; their close relationship; their free trade agreements; the stable economic conditions in the EU; and the EU’s trade defence measures. Further, the period of February 2019 to December 2019 was selected as the appropriate period as this is prior to the POI of the GOT’s injury finding on HRC imports from China, Russia, Japan and India; the EU imposed definitive safeguard measures on imports of certain steel products since February 1, 2019; and there were not any other apparent distortions in the markets at that time.

1.7 Insufficient information to evaluate Borçelik’s specific purchases of HRC and to conclude a casual link

[87] Information on the record was insufficient for the CBSA to evaluate Borçelik’s specific purchases of HRC (i.e., from China, Russia, Japan, India for the period of July 2023 to September 2024, and from other countries and the Turkish domestic producers) and to conclude that the prices of Borçelik’s for those HRC purchases had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market.

[88] A comparison of the relationship between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices for the period of February 2019 to December 2019 and for the period of January 2023 to September 2024 was used to evaluate if Turkish HRC prices (domestic and import) were distorted during the period of January 2023 to September 2024. Turkish HRC prices (domestic and import) and Italian domestic HRC prices were gathered from Fastmarkets.

[89] The CBSA analyzed^{Footnote 44} the correlation coefficients between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices, based on the pricing information from Fastmarkets:

• For the period of February 2019 to December 2019, the period of January 2023 to September 2024 and the POI of this investigation, the correlation coefficients indicate perfect or very strong associations between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices, which supports the CBSA’s selection of Italian domestic HRC prices in the evaluation of price distortions
• The correlation coefficients between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices decreased from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the POI of this investigation. This demonstrates that the association between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices weakened, especially considering the perfect correlation during the period of February 2019 to December 2019

[90] In their representation^{Footnote 45} regarding PMS, Borçelik questioned the CBSA’s use of monthly prices (instead of weekly prices) to calculate correlation coefficients between the Turkish domestic HRC prices and the Italian domestic HRC prices. The CBSA considered that it is more appropriate to use monthly prices, due to a consideration of the price transmission time required between these two closely intertwined and integrated markets.

[91] Further, the CBSA assessed^{Footnote 46} the statistical distributions of differences between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices for those different periods: there are significant changes in the statistical distributions (such as, mean, median, standard deviation, sample variance, minimum, maximum, range, etc.) of differences between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the CBSA’s POI, which further supports that significant changes happened to the association between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices. Especially, there are significant increases in the means of the statistical distributions of the differences between the Turkish HRC prices (domestic and import) and the Italian domestic HRC prices from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the CBSA’s POI. This indicates that the Turkish HRC prices (domestic and import) for the period of January 2023 to September 2024 and the CBSA’s POI moved away significantly from the Italian domestic HRC prices and the differences between the Turkish HRC prices and the Italian domestic HRC prices increased significantly.

[92] However, the CBSA was unable to conclude that the changes in price correlations and/or increased pricing difference between the Turkish HRC prices and the Italian domestic HRC prices were caused by the significant volumes of low-priced HRC imports from China, Russia, Japan and India for the whole period of July 2023 to September 2024. In order to demonstrate a causal relationship, other known possible causes of the observed correlations would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish HRC market was impacted by the factors such as the earthquake that happened in February 2023, local demand, scrap prices, and export volumes.^{Footnote 47} These factors were considered as possible causes of observed correlations. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the changes in price correlations and/or increased pricing difference between the Turkish HRC prices and the Italian domestic HRC prices were caused by the significant volumes of low-priced HRC imports from China, Russia, Japan and India for the whole period of July 2023 to September 2024. Consequently, the CBSA was unable to conclude that Turkish HRC prices had been lowered or otherwise affected by the significant volumes of low-priced HRC imports from China, Russia, Japan and India for the whole period of July 2023 to September 2024.

[93] This is an exporter-specific investigation. Without an evaluation of Borçelik’s specific commercial practices, the CBSA was not able to conclude that all Borçelik’s HRC input costs would have been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market. This conclusion could be reached only after Borçelik’s specific commercial practices (i.e. purchases of HRC) are specifically evaluated. Further details are discussed in the following three paragraphs.

[94] Information on the record indicates that HRC prices depend on HRC product characteristics and sales terms. For example, Borçelik reported^{Footnote 48} that prices of HRC vary depending on specification, grade, size, thickness, width, form and chemistry and the variations in price can be significant; information^{Footnote 49} from AMD and information^{Footnote 50} from Borçelik also indicate that several factors impacted HRC prices. As reported ^{Footnote 51}by Borçelik, Borçelik purchased many different types of HRC products.

[95] During the investigation, the CBSA collected benchmark prices information through RFIs and SRFIs, as well as the CBSA’s own research. The record includes the benchmark prices information from several publications, such as Fastmarkets, CRU and MEPS. However, the benchmark prices from those publications can not be used to evaluate Borçelik’s specific purchases of HRC (i.e., from China, Russia, Japan, India for the period of July 2023 to September 2024, and from other countries and the Turkish domestic producers, if any), due to the following reasons:

• The product characteristic information for the products associated with published benchmark prices is not detailed enough and does not allow the CBSA to make a proper comparison between the same or the substantially same products
• No information is available to adjust the published benchmark prices to permit a proper comparison with Borçelik’s purchase prices

[96] As described previously, in order to demonstrate a causal relationship, other known possible causes would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish HRC market was impacted by the factors such as the earthquake that happened in February 2023, local demand, scrap prices, and export volumes^{Footnote 52}. These factors were considered as possible causes of changes in Borçelik’s purchases prices of HRC. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was not able to evaluate those factors in order to conclude that the prices of Borçelik’s HRC purchases (i.e., from China, Russia, Japan, India for the period of July 2023 to September 2024, and from other countries and the Turkish domestic producers) had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market, even if the lowering down or changes of Borçelik’s purchasing prices of those HRC are observed.

[97] In summary:

• While the CBSA observed changes in price correlations and/or increased pricing difference between the Turkish HRC prices and the Italian domestic HRC prices, the CBSA was unable to conclude that these were caused by the significant volumes of low-priced HRC imports from China, Russia, Japan and India for the whole period of July 2023 to September 2024, or whether these were caused by other factors
• As a result, the CBSA was unable to conclude that Turkish HRC prices were impacted by the significant volumes of low-priced HRC imports from China, Russia, Japan and India for the whole period of July 2023 to September 2024
• In addition, the CBSA was unable to obtain sufficient evidence to conclude that the prices of Borçelik’s purchases of HRC (i.e., from China, Russia, Japan, India for the period of July 2023 to September 2024, and from other countries and the Turkish domestic producers) had been impacted by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India

1.8 Insufficient Information to Evaluate Borçelik’s Specific Purchases of CRC and to Conclude a Casual Link

[98] Information on the record was insufficient for the CBSA to evaluate Borçelik’s specific purchases of CRC and to conclude that the prices of Borçelik’s CRC purchases had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market.

[99] A comparison of the relationship between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices for the period of February 2019 to December 2019 and for the period of January 2023 to September 2024 was used to evaluate if the Turkish CRC prices (domestic and import) were distorted during the period of January 2023 to September 2024. The Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices were gathered from Fastmarkets.

[100] The CBSA analyzed^{Footnote 53} the correlation coefficients between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices, based on the pricing information from Fastmarkets:

• For the period of February 2019 to December 2019, the period of January 2023 to September 2024 and the POI of this investigation, the correlation coefficients indicate very strong or strong associations between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices, which supports the CBSA’s selection of Southern European domestic CRC prices in the evaluation of price distortions
• The correlation coefficients between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices declined from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the POI of this investigation. This demonstrates that the association between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices weakened, especially in comparison to the perfect or very strong correlation during the period of February 2019 to December 2019

[101] Further, the CBSA assessed^{Footnote 54} the statistical distributions of differences between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices for those different periods: there are significant changes in the statistical distributions (such as mean, median, standard deviation, sample variance, minimum, maximum, range, etc.) of differences between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the CBSA’s POI, which further supports that significant changes happened to the association between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices. Especially, there are significant increases in the means of the statistical distributions of the differences between the Turkish CRC prices (domestic and import) and the Southern European domestic CRC prices from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the CBSA’s POI. This indicates that the Turkish CRC prices (domestic and import) for the period of January 2023 to September 2024 and the CBSA’s POI moved away significantly from the Southern European domestic CRC prices and the differences between the Turkish CRC prices and the Southern European domestic CRC prices increased significantly.

[102] However, the CBSA was unable to conclude that the changes in price correlations and/or increased pricing difference between the Turkish CRC prices and the Southern European domestic CRC prices were caused by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India. In order to demonstrate a causal relationship, other known possible causes of the observed correlations would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish HRC market was impacted by the factors such as the earthquake that happened in February 2023, local demand, scrap prices, and export volumes^{Footnote 55}. Due to close relationships between HRC and CRC, these factors were considered as possible causes of observed correlations between the Turkish CRC prices and the Southern European domestic CRC prices. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the changes in price correlations and/or increased pricing difference between the Turkish CRC prices and the Southern European domestic CRC prices were caused by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India. Consequently, the CBSA was unable to conclude that Turkish CRC prices had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India.

[103] This is an exporter-specific investigation. Without an evaluation on Borçelik’s specific commercial practices, the CBSA was not able to conclude that Borçelik’s CRC input costs would have been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market. This conclusion could be reached only after Borçelik’s specific commercial practices (i.e. purchases of CRC) are specifically evaluated. Further details are discussed in the following three paragraphs.

[104] Information on the record indicates that CRC prices depend on CRC product characteristics and sales terms. For example, Borçelik reported in their response^{Footnote 56} to the SRFI#1 that prices of Full Hard vary depending on specification, grade, size, thickness, width, form and chemistry and the variations in price can be significant; information^{Footnote 57} from AMD and information^{Footnote 58} from Borçelik also indicate that several factors impacted CRC prices. As reported in Appendix 5^{Footnote 59} submitted by Borçelik, Borçelik purchased many different types of CRC products.

[105] During the investigation, the CBSA collected benchmark prices information through RFIs and SRFIs, as well as the CBSA’s own research. The record includes the benchmark prices information from several publications, such as Fastmarkets, CRU and MEPS. However, the benchmark prices from those publications can not be used to evaluate Borçelik’s specific purchases of CRC, due to the following reasons:

• The product characteristic information for the products associated with published benchmark prices is not detailed enough and does not allow the CBSA to make a proper comparison between the same or the substantially same products
• No adjustment information is available to adjust those published benchmark prices to permit a proper comparison with Borçelik’s purchase prices

[106] As discussed previously, in order to demonstrate a causal relationship, other known possible causes would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish HRC market was impacted by the factors such as the earthquake that happened in February 2023, local demand, scrap prices, and export volumes.^{Footnote 60} Due to close relationships between HRC and CRC, these factors were considered as possible causes of changes in Borçelik’s purchases prices of CRC. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the prices of Borçelik’s CRC purchases had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market, even if the lowering down or changes of Borçelik’s purchasing prices of CRC were observed.

[107] In summary:

• While the CBSA observed changes in price correlations and/or increased pricing difference between the Turkish CRC prices and the Southern European domestic CRC prices, the CBSA was unable to conclude that these were caused by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India, or whether these were caused by other factors
• As a result, the CBSA was unable to conclude that Turkish CRC prices were impacted by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India
• In addition, the CBSA was unable to obtain sufficient evidence to conclude that the prices of Borçelik’s purchases of CRC had been impacted by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India

1.9 Insufficient Information to Evaluate Borçelik’s Domestic Sales of COR and to Conclude a Casual Link

[108] Information on the record was insufficient for the CBSA to evaluate Borçelik’s specific domestic sales of COR and to conclude that the prices of Borçelik’s domestic sales of COR had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market.

[109] A comparison of the relationship between the Turkish domestic COR prices and the Southern European domestic COR prices for the period of February 2019 to December 2019 and for the period of January 2023 to September 2024 was used to evaluate if the Turkish domestic COR prices were distorted during the period of January 2023 to September 2024. The Turkish domestic COR prices and the Southern European domestic COR prices information were gathered from Fastmarkets.

[110] The CBSA analyzed^{Footnote 61} the correlation coefficients between the Turkish domestic COR prices and the Southern European domestic COR prices, based on the pricing information from Fastmarkets:

• For the period of February 2019 to December 2019, the period of January 2023 to September 2024 and the POI of this investigation, the correlation coefficients indicate perfect or very strong associations between the Turkish domestic COR prices and the Southern European domestic COR prices, which supports the CBSA’s selection of the Southern European domestic COR prices in the evaluation of price distortions
• The correlation coefficients between the Turkish domestic COR prices and the Southern European domestic COR prices decreased from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the POI of this investigation. This demonstrates that the association between the Turkish domestic COR prices and the Southern European domestic COR prices weakened, especially in comparison to the perfect correlation during the period of February 2019 to December 2019

[111] In their representation^{Footnote 62} regarding PMS, Borçelik questioned the CBSA’s use of monthly prices (instead of weekly prices) to calculate correlation coefficients between the Turkish domestic COR prices and the Southern European domestic COR prices. The CBSA considered that it is more appropriate to use monthly prices due to a consideration of price transmission time required between these two closely intertwined and integrated markets.

[112] Further, the CBSA assessed^{Footnote 63} the statistical distributions of differences between the Turkish domestic COR prices and the Southern European domestic COR prices for those different periods: there are significant changes in the statistical distributions (such as mean, median, minimum, maximum, etc.) of differences between the Turkish domestic COR prices and the Southern European domestic COR prices from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the CBSA’s POI, which further supports that significant changes happened to the association between the Turkish domestic COR prices and the Southern European domestic COR prices. Especially, there are significant decreases in the means of the statistical distributions of the differences between the Turkish domestic COR prices and the Southern European domestic COR prices from the period of February 2019 to December 2019 to the period of January 2023 to September 2024 and the CBSA’s POI. This indicates that the Turkish domestic COR prices moved closer significantly to Southern European domestic COR prices for the period of January 2023 to September 2024 and the CBSA’s POI and the differences between the Turkish domestic COR prices and the Southern European domestic COR prices decreased significantly. It should be noted that the COR products associated with Fastmarkets’ published Turkish domestic COR prices were thinner and sold at smaller order quantity (consequently more expensive) than the COR products associated with Fastmarkets’ published Southern European domestic COR prices.

[113] The CBSA further observed that the Turkish domestic COR prices and the Southern Europe domestic COR prices follow an almost perfect trajectory for the period of February 2019 to December 2019, while the COR prices no longer follow an almost perfect trajectory for the period of July 2023 to September 2024.^{Footnote 64}

[114] However, the CBSA was unable to conclude that the changes in price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices were caused by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India. As discussed previously, in order to demonstrate a causal relationship, other known possible causes of the observed correlations would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish COR market was impacted by the factors such as the earthquake that happened in February 2023, local demand, and export volumes^{Footnote 65}. These factors were considered as possible causes of observed correlations. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the changes in price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices were caused by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India. Consequently, the CBSA was unable to conclude that Turkish domestic COR prices had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India.

[115] This is an exporter-specific investigation. Without an evaluation of Borçelik’s specific commercial practices, the CBSA was not able to conclude that Borçelik’s domestic COR prices would have been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market. This conclusion could be reached only after Borçelik’s specific commercial practices (i.e. domestic sales of COR) are specifically evaluated. Further details are discussed in the following three paragraphs.

[116] Information on the record indicates that COR prices depend on COR product characteristics and sales terms. For example, information^{Footnote 66} from AMD and information^{Footnote 67} from Borçelik indicate that several factors impacted COR prices. As reported in Appendix 3A^{Footnote 68} submitted by Borçelik, Borçelik sold many different types of COR products domestically.

[117] During the investigation, the CBSA collected benchmark prices information through RFIs and SRFIs, as well as the CBSA’s own research. The record includes the benchmark prices information from several publications, such as Fastmarkets, CRU and MEPS. However, the benchmark prices from those publications cannot be used to evaluate Borçelik’s specific domestic sales of COR, due to the following reasons:

• The product characteristic information for the products associated with published benchmark prices is not detailed enough and does not allow the CBSA to make a comparison between the same or the substantially same products
• No information is available to adjust the published benchmark prices to permit a proper comparison with Borçelik’s domestic sales prices

[118] As discussed previously, in order to demonstrate a causal relationship, other known possible causes would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish COR market was impacted by the factors such as the earthquake that happened in February 2023, local demand, and export volumes.^{Footnote 69} These factors were considered as possible causes of changes in Borçelik’s domestic sales prices of COR. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the prices of Borçelik’s domestic sales of COR had been lowered or otherwise affected by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India into the Turkish market, even if the lowering down or changes of the prices of Borçelik’s domestic sales of COR are observed.

[119] In summary:

• While the CBSA observed changes in price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic CRC prices, the CBSA was unable to conclude that these were caused by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India, or whether these were caused by other factors
• As a result, the CBSA was unable to conclude that Turkish domestic COR prices were impacted by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India
• In addition, the CBSA was unable to obtain sufficient evidence to conclude that the prices of Borçelik’s domestic sales of COR had been impacted by the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia, Japan and India

2. Other Investigated Possible PMS Factors

[120] The CBSA also reviewed all other PMS factors that the Canadian domestic producers (AMD and Stelco) alleged to contribute to a PMS in Türkiye for Borçelik, which does not permit a proper comparison of Borçelik’s domestic sales with their export sales of subject goods to Canada.

[121] AMD and Stelco alleged that the following PMS factors, individually and/or cumulatively, contributed to a PMS in Türkiye for Borçelik, which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their export sales of subject goods to Canada:

• Volatile economic conditions
• Distorted inputs
• Lack of inflation accounting adjustments
• Presence of dumped COR in the Turkish market
• Government support programs
• Turkish Inward Processing Regime (IPR)

[122] Through the investigation, the CBSA did not form the opinion, based on the information on the record, that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the alleged PMS factors
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

2.1 Volatile Economic Conditions

[123] In the response^{Footnote 70} to the PMS RFI, Stelco submitted that Türkiye’s economic instability and volatility, together with the GOT’s policies, created a PMS that distorted prices of COR in the Turkish market and the input costs of COR incurred by Turkish producers; when inflation occurred at a rapid rate, this directly distorted the domestic selling prices of COR and inputs in Türkiye, as the value of the domestic sale relative to the export sale may be fundamentally different during the period (the value of the domestic sale may decline relative to the sale to the importer in Canada between the date of sale and the date of payment), which made a proper comparison between domestic and export selling prices impossible. In the response^{Footnote 71} to the PMS RFI, Stelco submitted that, as a result of rapid currency depreciation, the selling prices and cost data for Turkish COR were unreliable. In the response^{Footnote 72} to the PMS RFI, Stelco submitted that the unconventional interventions by the Turkish Central Bank further exacerbated the PMS existing in the Turkish market.

[124] AMD submitted similar information to the CBSA in their responses^{Footnote 73} to the PMS RFI.

[125] In the response^{Footnote 74} to the SRFI#1, AMD submitted that Türkiye has a very high degree of macro-economic volatility. Stelco provided a same response in their response^{Footnote 75} to the SRFI#1.

[126] In their case brief,^{Footnote 76} AMD and Stelco submitted that economic conditions in Türkiye remained volatile as hyperinflation, severe currency depreciation, and heavy-handed policies from the Turkish government had contributed to the distorted costing and pricing for Turkish COR. AMD and Stelco further submitted^{Footnote 77} that:

• Türkiye’s economy was in a state of hyperinflation. When inflation occurred at such a rapid rate, the selling prices and cost data during the 60-day period prescribed by section 15(d) of SIMA were unreliable, as the value of the domestic sale relative to the export sale may be fundamentally different from the beginning to the end of that period. The value of the domestic sale may decline relative to the sale to the importer in Canada between the date of sale and the date of payment. A proper comparison becomes impossible under these conditions
• Türkiye’s economic situation was further compounded by a depreciating currency. Like hyperinflation, rapid currency depreciation renders the selling prices and cost data during the 60-day period prescribed by section 15(d) of SIMA unreliable
• The GOT’s intervention in monetary policy further contributed to market distortions, particularly by disrupting price signals

[127] In their reply submission, Borçelik submitted that mismatching of revenues and expenses is not a concern in Borçelik’s case since costs and expenses were both denominated and settled in USD, typically within short settlement cycles; Borçelik’s auditors have confirmed that IAS 29 (Financial Reporting in Hyperinflationary Economies) was not applicable to the company and, as such, delays in the adoption of hyperinflationary accounting policies are not relevant; there was no disassociation between cost of goods sold and sales revenues since both were measured in a stable currency environment (USD); the GOT’s monetary policies requiring the conversion of foreign currency revenues to TRY did not impact Borçelik: the steel industry was largely exempted from these requirements and, in any event, there was no prohibition on immediate reconversion to USD;^{Footnote 78} and Borçelik’s entire commercial ecosystem was constructed around foreign currencies, particularly the USD and EUR.^{Footnote 79}

[128] In their representation regarding PMS, the GOT submitted^{Footnote 80} that it has not been demonstrated how the economic challenges have created a PMS within the steel market.

[129] Information^{Footnote 81} on the record indicates that volatile economic conditions existed in Türkiye.

[130] Having considered the information on the record and the representations made by the parties, the CBSA did not form the opinion that a PMS existed in Türkiye for Borçelik which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their export sales of subject goods to Canada, due to volatile economic conditions in Türkiye:

• The record includes the benchmark pricing information from several publications, such as Fastmarkets, CRU and MEPS. The CBSA was able to use the methodology as described in the subsection 1.6 to perform a pricing correlation analysis similar to the analysis as described in the subsection 1.9. However, the CBSA was unable to conclude that the changes in the price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices were caused by volatile economic conditions in Türkiye. In order to demonstrate a causal relationship, other known possible causes of the observed correlations would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish COR market was impacted by other factors, such as the earthquake that occurred in February 2023, local demands, and export volumes.^{Footnote 82} These factors were considered as possible causes of observed correlations. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the changes in the observed correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices were caused by volatile economic conditions in Türkiye. Consequently, the CBSA was unable to conclude that Turkish domestic COR prices had been affected by volatile economic conditions in Türkiye
• This is an exporter-specific investigation. Without an evaluation on Borçelik’s specific commercial practices, the CBSA was unable to conclude that Borçelik’s domestic COR prices would have been affected by volatile economic conditions in Türkiye. This conclusion could be reached only after Borçelik’s specific commercial practices (i.e. domestic sales of COR) are specifically evaluated. As discussed in the subsection 1.9, Borçelik sold many different types of COR products domestically and the information on the record was not able to be used to evaluate Borçelik’s specific domestic sales of COR. As such, the information on the record was insufficient for the CBSA to evaluate Borçelik’s specific domestic sales of COR and to conclude that the prices of Borçelik’s domestic sales of COR had been affected by volatile economic conditions in Türkiye. In order to demonstrate a causal relationship, other known possible causes would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish COR market was impacted by the factors such as the earthquake that happened in February 2023, local demand, and export volumes.^{Footnote 83} These factors were considered as possible causes of changes in Borçelik’s domestic sale prices of COR. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the prices of Borçelik’s domestic sales of COR had been affected by volatile economic conditions in Türkiye, even if the changes of the prices of Borçelik’s domestic sales of COR are observed

[131] In summary:

• While the CBSA observed changes in price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices, the CBSA was unable to conclude that these were caused by volatile economic conditions in Türkiye, or whether these were caused by other factors
• As a result, the CBSA was unable to conclude that Turkish domestic COR prices were impacted by volatile economic conditions in Türkiye
• In addition, the CBSA was unable to obtain sufficient evidence to conclude that the prices of Borçelik’s domestic sales of COR had been impacted by volatile economic conditions in Türkiye

[132] In conclusion, the CBSA did not form the opinion, based on the information on the record, that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to volatile economic conditions in Türkiye
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

2.2 Distorted Inputs

[133] In the response to the PMS RFI, Stelco submitted that the principal effect of the PMS in Türkiye, both in respect of COR and its primary input (HRC and/or CRC), was to cause Turkish input and COR pricing to be lower than other markets.^{Footnote 84}

[134] In the response to the PMS RFI, AMD submitted that Turkish steel producers such as Borçelik were incentivized to seek out low-cost inputs, and to source major inputs such as HRC from other countries at very low prices; large volumes of dumped HRC were imported into the Turkish market during the POI at prices that undercut Turkish domestic prices; and the availability of low-priced Russian HRC in Türkiye further distorted the pricing at which HRC was sold in Türkiye.^{Footnote 85}

[135] In the response^{Footnote 86} to the SRFI#1, AMD submitted that the Turkish market was significantly impacted by trade with the major input used in the production of COR from countries that were non-market economies, as well as countries subject to economic sanctions from most other countries in the world. Stelco provided a same response in the response^{Footnote 87} to the SRFI#1.

[136] In their case brief,^{Footnote 88} AMD and Stelco submitted that there is sufficient evidence on the record to support a determination that a PMS existed in the Turkish COR market over the POI; this existing PMS had been exacerbated by the dumping of HRC from China and Russia in the Turkish steel market, which had in turn distorted significant input costs in Türkiye for downstream products such as cold-rolled steel and COR, and in particular for the exported subject goods, which benefited significantly from the IPR established by the GOT; there have been market distortions for significant input materials caused by large volumes of dumped Chinese HRC available in the Turkish market at heavily discounted prices with the effect of depressing and supressing Turkish COR prices generally; and the PMS in the Turkish COR sector renders Turkish domestic sales and exporter costs inappropriate for the purposes of calculating normal values.

[137] In their case brief,^{Footnote 89} AMD and Stelco submitted that:

• There was the influx of dumped HRC in the Turkish market. The trade measures have not remedied the effects of Chinese and Russian HRC on the Turkish steel market
• Following the outbreak of the Russia-Ukraine War, Türkiye continued to import huge volumes of Russian steel, including slab and other flat-rolled products. Turkish buyers had reportedly taken advantage of the diminished market for Russian steel by demanding steep discounts from Russian producers. The surge in Russian slab imports had not only granted Turkish COR producers a large supply of inexpensive inputs, but also dragged down the price of slab imports from other countries. The price of Russian slab imports to Türkiye had steadily declined since 2021. The availability of low-priced Russian slab imports created the distorting effect on input costs in Türkiye. This in turn distorted Turkish flat steel prices. The use of Russian slab in the production of COR in Türkiye was not only distorting the costs of Turkish COR producers who used Russian inputs but also the costs of Turkish COR producers that did not use Russian inputs, due to the price-suppressing effect of Russian imports in the Turkish market

[138] In their case brief, Borçelik submitted that it cannot be inferred that HRC imports from China, Russia, Japan and India continued to be dumped and cause injury after the GOT’s period of investigation.^{Footnote 90} In their representation regarding PMS, the GOT provided a similar comment to the CBSA.^{Footnote 91}

[139] In their reply submission, Borçelik submitted that there was a lack of connection to any evidence that Rus was actually used in any COR production in Türkiye and there was no evidence on the record that Russian slab imports distorted COR inputs.^{Footnote 92}

[140] As described previously in the section 1 based on the information on the record, the CBSA did not form the opinion that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the significant volumes of unfairly-traded or low-priced HRC imports from China, Russia. Japan and Russia;
• The PMS had an impact on the domestic sales of Borçelik; and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

[141] With regard to the alleged low-priced Russian slab imports, having considered the information on the record and the representations made by the parties, due to a lack of sufficient information for the Turkish slab market and due to the reasons similar to those as described in the subsections 1.7 to 1.9, the CBSA did not form the opinion that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the alleged low-priced Russian slab imports;
• The PMS had an impact on the domestic sales of Borçelik; and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

2.3 Lack of Inflation Accounting Adjustments

[142] In their case brief, AMD and Stelco submitted that producer costs, financial statements, and accounting records were distorted and unreliable due to the lack of inflation accounting adjustments.^{Footnote 93}

[143] In their reply submission, Borçelik submitted that mismatching of revenues and expenses is not a concern in Borçelik’s case since costs and expenses were both denominated and settled in USD, typically within short settlement cycles; Borçelik’s auditors have confirmed that IAS 29 (Financial Reporting in Hyperinflationary Economies) is not applicable to the company and, as such, delays in the adoption of hyperinflationary accounting policies are not relevant; there was no disassociation between cost of goods sold and sales revenues since both were measured in a stable currency environment (USD); the GOT’s monetary policies requiring the conversion of foreign currency revenues to TRY did not impact Borçelik: the steel industry was largely exempted from these requirements and, in any event, there was no prohibition on immediate reconversion to USD;^{Footnote 94} and Borçelik’s entire commercial ecosystem was constructed around foreign currencies, particularly the USD and EUR.^{Footnote 95}

[144] This is an exporter-specific investigation. During the investigation, the CBSA verified the information submitted by Borçelik and did not find that Borçelik’s costs, financial statements and accounting records are distorted and unreliable due to the lack of inflation accounting.

2.4 Presence of Dumped COR in the Turkish Market

[145] In their case brief,^{Footnote 96} AMD and Stelco submitted that, on December 25, 2024, the Turkish government launched an investigation into the dumping of cold-rolled steel and galvanized and painted coil from China and South Korea; and while the outcome of this investigation is yet to be determined, this trade action indicates a high likelihood that there was an oversupply of dumped imported COR in the Turkish market.

[146] In their reply submission, Borçelik submitted that the initiation of the GOT’s investigation into dumped coated steel products from China and South Korea provided no legal or factual support for the PMS allegation.^{Footnote 97}

[147] As already noted by AMD and Stelco, the outcome of the GOT’s investigation is yet to be determined. There was no finding at this time that COR imports from South Korea and China were dumped and caused material injury to the Turkish domestic COR industry.

2.5 Government Support Programs

[148] In their case brief,^{Footnote 98} AMD and Stelco submitted that GOT’s support programs were available to the Turkish COR producers/exporters:

• There were subsidies and support mechanisms for Türkiye’s steel industry and exporters
  • There were Government support programs relating to steel industry
  • There were Government support programs previously identified by the CBSA
  • United States also identified the GOT’s support measures
  • There were also other GOT’s subsidies and support programs
• The GOT was involved in the means of production of COR. Beyond the direct subsidies and support programs, Türkiye also provides support for key inputs to produce COR
• The GOT was involved through industry associations in exporting COR. The GOT provides additional state support for the steel industry, including COR production, through its steel producing and exporting associations

[149] The GOT submitted their export support and promotion measures for Turkish exporters.^{Footnote 99}

[150] Borçelik reported that they had indeed benefitted from export support programs and a 5% corporate income tax reduction on earnings exclusively derived from export activities.^{Footnote 100}

[151] In their reply submission, Borçelik submitted that, to the extent that Borçelik may have received minor subsidies, those subsidies would carry through to domestic and export sales equally.^{Footnote 101}

[152] The Turkish government promotes export growth through various initiatives and policies, such as export promotion programs, financial supports, market research and information services, export training and capacity building, and taxation preferences.^{Footnote 102}

[153] Having considered the information on the record and the representations made by the parties, due to the reasons similar to those as described through the paragraphs 130 and 131 the CBSA did not form the opinion that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the GOT’s support programs
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

2.6 Turkish Inward Processing Regime (IPR)

[154] In the response^{Footnote 103} to the PMS RFI, AMD submitted that the Turkish IPR caused distortions in the costs and prices of COR.

[155] In their comments, AMD and Stelco submitted^{Footnote 104} the information about the operation of Turkish IPR and submitted^{Footnote 105} that the program incentivized COR exports using dumped HRC; the existence of macro-economic conditions which contributed to PMS conditions in Türkiye, combined with the facilitation of the use of dumped HRC inputs for processing into COR for export, enabled Borçelik to dump COR into the Canadian market at non-competitive prices; Borçelik’s COR sales which had derived a benefit from the IPR do not permit a proper comparison with its domestic sales for the purposes of calculating a normal value; this program clearly distorted pricing within the Turkish market, creating a PMS within the meaning of subsection 16(2)(c); and more information was required to trace IPR inputs for COR production.

[156] In their case brief,^{Footnote 106} AMD and Stelco submitted that IPR counteracts benefits from Turkish anti-dumping measure on Chinese HRC; the IPR permitted businesses to be exempt from import duties under both a duty suspension system and a duty drawback system and issued corresponding types of IPR Certificates; the effects of a duty suspension system differed from those of a duty drawback system; under a duty suspension system, the duty exemption applied to all imports of raw material (inputs) regardless of whether the actual input was sold domestically or exported, so long as a corresponding finished product was exported within the D1 certificate’s time limit; and the duty suspension system of the IPR allowed both domestic and export sales to benefit from lower input costs through the continued use of dumped inputs.

[157] In their reply submission, Borçelik submitted that there is no evidence on the record of Borçelik using D1 certificates to avoid antidumping duties on inputs used in the production of either domestic or export sales; and the POI in this investigation ended prior to the imposition of measures on HRC in Türkiye and, as a factual matter, there is no evidence of D1 certificates being used after those measures were imposed.^{Footnote 107}

[158] Both the GOT and Borçelik provided the information about IPR.

[159] In response to SRFI#1, the GOT provided the following information regarding IPR:^{Footnote 108}

• IPR is a system allowing Turkish manufacturers/exporters to obtain raw materials, intermediate unfinished goods that are used in the production of the exported goods without paying customs duty including VAT and without being subject to commercial policy measures
• Türkiye has a system in place to confirm which inputs, and in what amounts are consumed in production of the exported products under IPR and
• If companies utilized the IPR, they were exempt from paying duties, including trade remedy measures, otherwise, they were required to pay all applicable duties and taxes

[160] In the response to SRFI#1, Borçelik provided the following information regarding the IPR:^{Footnote 109}

• Borçelik has an Inward Processing Authorization Certificate / Permission (“IPC”) and imported HRCs under Türkiye’s IPR during the POI
• Exports to Canada were used to satisfy the conditions under which Borçelik imported certain duty exempted HRCs
• Companies are not required to declare whether imported inputs will be used to produce goods for domestic consumption or for export. Once the goods are imported under the IPR, no taxes or duties are payable and the remaining commitment is to demonstrate that a certain volume of corresponding exports have been made and
• Pursuant to Article 5 of the IPR legislation, domestically sourced inputs can be used in the production of a finished product and the importation of the inputs can be realized afterwards

[161] During the investigation, the costing information (including costing information for inputs) submitted by Borçelik had been verified by the CBSA through SRFIs and on-site verification.

[162] Having considered the information on the record and the representations made by the parties, due to the reasons similar to those as described through the paragraphs 130 and 131 the CBSA did not form the opinion that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the Turkish IPR
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

2.7 The Cumulative Effects of All Alleged Factors

[163] In the response^{Footnote 110} to the PMS RFI, Stelco submitted that several PMS factors (such as Government support programs, significant volatility in economic conditions in the home market, distorted input costs, the GOT’s regulations on HRC and COR, the GOT’s taxation policies, and state-owned or state-controlled suppliers and purchasers) individually and cumulatively demonstrate the existence of a PMS in the Turkish COR market. In the response^{Footnote 111} to the PMS RFI, Stelco submitted that the impact of PMS on domestic selling prices is different from the impact on prices for export to Canada due to variations in market dynamics, trade policies and demand conditions.

[164] In the response^{Footnote 112} to the PMS RFI, AMD submitted that several PMS factors (such as the significant volatility in the economic conditions in Türkiye, distorted input costs caused by the remission of duties on dumped inputs, the availability of Russian inputs at pricing distorted by sanctions in other markets) are particularly relevant in this investigation. In the response^{Footnote 113} to the PMS RFI, AMD submitted that PMS factors (such as high inflation, significant currency volatility, the lack of sanctions on Russian goods, the remission of antidumping duties on HRC used to produce exported COR) had impacted the prices of COR sold in the Turkish domestic market that do not permit a proper comparison between domestic sale prices and export prices.

[165] In the response^{Footnote 114} to the SRFI#1, AMD submitted that an assessment of whether a PMS exists must be undertaken by considering the cumulative impact of all factors (such as the significant volatility in the economic conditions in Türkiye; distorted input costs). Stelco provided a same response in the response^{Footnote 115} to the SRFI#1.

[166] In their case brief,^{Footnote 116} AMD and Stelco submitted that Borçelik’s operational environment necessarily impacted its business; and the PMS in Türkiye necessarily affected Borçelik’s COR pricing in domestic and export sales, as well as its input costs. Further, AMD and Stelco argued that several factors contribute to a PMS in Türkiye and these factors include volatile economic conditions,^{Footnote 117} distorted inputs,^{Footnote 118} a lack of inflation accounting adjustments,^{Footnote 119} presence of dumped COR in the Turkish market,^{Footnote 120} Government support programs,^{Footnote 121} and IPR.^{Footnote 122}

[167] In their reply submission,^{Footnote 123} AMD and Stelco also provided comments on HRC price depression analysis, conditions of competition in Türkiye, use of pricing correlations, and effects of distorted HRC prices on CRC and COR markets.

[168] In their reply submission,^{Footnote 124} Borçelik submitted that Stelco and AMD’s alleged distortions must be quantified and shown to be significant, otherwise, there is no statutory or WTO-consistent foundation for rejecting Borçelik’s domestic sales on the basis that they do not permit a proper comparison with its export sales; and absent such quantification, any finding that Borçelik’s sales “do not permit a proper comparison” is purely speculative and contrary to the plain wording of article 2.2 of the WTO Antidumping Agreement and paragraph 16(2)(c) of SIMA.

[169] The CBSA reviewed all the PMS factors alleged by the Canadian domestic producers and evaluated the cumulative effects of all the alleged PMS factors.

[170] Having considered the information on the record and the representations made by the parties,, the CBSA did not form the opinion that a PMS existed in Türkiye for Borçelik which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their export sales of subject goods to Canada, due to the alleged PMS factors:

• The record includes the benchmark pricing information from several publications, such as Fastmarkets, CRU and MEPS. The CBSA was able to use the methodology as described in the subsection 1.6 to perform a pricing correlation analysis similar to the analysis as described in the subsection 1.9. However, the CBSA was unable to conclude that the changes in the price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices were caused by the alleged PMS factors. In order to demonstrate a causal relationship, other known possible causes of the observed correlations would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish COR market was impacted by the factors such as the earthquake that happened in February 2023, local demand, and export volumes.^{Footnote 125} These factors were considered as possible causes of observed correlations. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the changes in the price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices were caused by the alleged PMS factors. Consequently, the CBSA was unable to conclude that Turkish domestic COR prices had been actually affected by the alleged PMS factors
• This is an exporter-specific investigation. Without an evaluation on Borçelik’s specific commercial practices, the CBSA was not able to conclude that Borçelik’s domestic COR prices had been actually affected by the alleged PMS factors. This conclusion could be reached only after Borçelik’s specific commercial practices (i.e. domestic sales of COR) are specifically evaluated. As discussed in the subsection 1.9, Borçelik sold many different types of COR products domestically and the information on the record can not be used to evaluate Borçelik’s specific domestic sales of COR. As such, the information on the record was insufficient for the CBSA to evaluate Borçelik’s specific domestic sales of COR and to conclude that the prices of Borçelik’s domestic sales of COR had been actually affected by the alleged PMS factors. In order to demonstrate a causal relationship, other known possible causes would be required to be evaluated. In their case brief, Borçelik raised the issue that the Turkish COR market was impacted by the factors such as the earthquake that happened in February 2023, local demand, and export volumes.^{Footnote 126} These factors were considered as possible causes of changes in Borçelik’s domestic sales prices of COR. However, the issue was raised too late for the CBSA to seek out the information that would be required to address it. As such, the CBSA was unable to evaluate those factors in order to conclude that the prices of Borçelik’s domestic sales of COR had been actually affected by the alleged PMS factors, even if the changes of the prices of Borçelik’s domestic sales of COR are observed

[171] In summary:

• While the CBSA observed changes in price correlations and/or decreased pricing difference between the Turkish domestic COR prices and the Southern European domestic COR prices, the CBSA was unable to conclude that these were caused by the alleged PMS factors, or whether these were caused by other factors
• As a result, the CBSA was unable to conclude that Turkish domestic COR prices were impacted by the alleged PMS factors
• In addition, the CBSA was unable to obtain sufficient evidence to conclude that the prices of Borçelik’s domestic sales of COR had been impacted by the alleged PMS factors

[172] Having considered the information on the record and the representations made by the parties, the CBSA did not form the opinion that:

• A PMS existed in respect of COR originating in or exported from Türkiye by Borçelik, due to the alleged PMS factors
• The PMS had an impact on the domestic sales of Borçelik and
• As a result of the PMS, a proper comparison cannot be made between Borçelik’s domestic sales and Borçelik’s export sales to Canada

3. Conclusion on PMS

[173] With a consideration of all the information on the record, for the final decision, the information on the record was insufficient for the CBSA to form the opinion that a PMS existed in Türkiye for Borçelik, which did not permit a proper comparison of Borçelik’s domestic sales of like goods with their export sales of subject goods to the importers in Canada.

Borçelik

[174] Borçelik is the producer and exporter and is responsible for shipping the subject goods to Canada. Borçelik produces hot-dip galvanized steel, cold-rolled steel, and pickled & oiled hot-rolled steel. The administration, production, sale and distribution activities of the company are undertaken at Borçelik’s facility in Gemlik, Bursa.

[175] Borçelik represents 100% of the volume of subject goods exported to Canada and 13.9% of COR imports from all countries during the POI. Borçelik provided a complete response to the Dumping RFI and subsequent SRFIs. An on-site verification was also conducted at Borçelik’s premises.

[176] As per the CBSA’s review and verification of Borçelik’s information, all of the issues raised during the course of the investigation were addressed, with the exception that the costing information requested from associated suppliers and producers of HRS and CRS input used in the production of some of the subject and like goods. Borçelik’s submission was considered to be substantially complete and reliable for purposes of the final decision, with the exception of the lack of information from the associated suppliers and producers of these input.

[177] Pursuant to subsection 11.2(1) of the SIMR, if an input used in the production of the goods is acquired by the exporter or producer from an associated person and is a significant factor in the production of the goods, the cost of that input in the country of export is considered to be the greater of (a) the price paid in respect of that input by the exporter or producer to the associated person; (b) the cost incurred by the associated person in the production of that input, including the administrative, selling and all other costs with respect to that input; and (c) the price in the country of export of the same or substantially the same inputs, if sufficient information is available to enable the price to be determined on the basis of either (i) the selling prices of those inputs in the country of export, in the same or substantially the same quantities, between parties who are not associated persons, or (ii) the published prices of those inputs in the country of export.

[178] Where sufficient information was not available to determine the cost incurred by an associated person in the production of an input used in the production of subject goods, and is a significant factor in the production of the goods, the normal values of the goods produced from such input were determined under a Ministerial Specification pursuant to Section 29 of the SIMA, based on the export price, plus an amount equal to the highest instance by which a normal value exceeded an export price on an individual transaction for that exporter for the final decision, excluding any anomalies, expressed as a percentage of the export price, multiplied by the export price.

[179] Where insufficient information was provided to determine the costs incurred by an associated person in the production of an input used in the production of domestically sold like goods, the domestic sales of like goods produced from such input were excluded from consideration under paragraph 16(2)(b) of the SIMA, pursuant to a Ministerial Specification. The provisions of paragraph 16(2)(b) provide for the exclusions of certain sales at a loss from being included in the population of domestic sales used for the purposes of determining normal values and a reasonable amount for profits. Pursuant to a Ministerial Specification, the domestic sales of like goods produced from such input were thus excluded from the profitability testing under paragraph 16(2)(b), and as such, excluded from the population of domestic sales used for the purposes of determining normal values and a reasonable amount for profits.

[180] Borçelik had domestic sales of like goods during the PAP. Where applicable, normal values were either determined in accordance with the methodology of section 15 of the SIMA, based on domestic selling prices of like goods or in accordance with the methodology of paragraph 19(b) of the SIMA, based on the aggregate of cost of production, a reasonable amount for administrative, selling and all other costs, and a reasonable amount for profits.

[181] For the purposes of paragraph 19(b) of SIMA amount for profits was determined in accordance with subparagraph 11(1)(b)(ii) of the SIMR by using Borçelik’s profitable domestic sales of goods that were of the same general category as the subject goods exported to Canada during the POI (i.e. all COR).

[182] During the POI, all of the subject goods exported to Canada by Borçelik were sold to unrelated importers. Export prices were determined pursuant to section 24 of the SIMA, based on the lesser of the exporter’s selling price and the importer’s purchase price, adjusted by deducting the costs, charges and expenses incurred in preparing the goods for shipment to Canada and resulting from the exportation and shipment of the goods.

[183] For purposes of the final decision, the total normal value compared to the total export price results in a margin of dumping of 0% for Borçelik, expressed as a percentage of the export price.

Summary of final results

[184] A summary of the final results of the dumping investigation respecting all subject goods released into Canada during the POI are as follows:

[185] Under paragraph 41(1)(a) of SIMA, the CBSA is required to terminate an investigation in respect of any goods of an exporter if it is satisfied that the goods have not been dumped or the margin of dumping of the goods of that exporter is insignificant, meaning a margin of dumping that is less than 2% of the export price of the goods.

[186] The CBSA determined that the subject goods have not been dumped. Therefore, the CBSA is required to terminate the dumping investigation in respect of certain COR exported to Canada from Türkiye by Borçelik.