Manchester Tank & Equipment Co. v. United States, 483 F.Supp.3d 1309

Commerce investigated antidumping duties on steel propane cylinders from Thailand for Apr. 1, 2017–Mar. 31, 2018; Sahamitr Pressure Container (SMPC) was the sole mandatory respondent.
Commerce’s initial model-match instruction asked respondents to report cylinders as coated or uncoated; Sahamitr reported three coating codes: uncoated, coated-normal, and coated-special (zinc).
Commerce used Sahamitr’s dataset that distinguished zinc-coated cylinders in both the Preliminary and Final Determinations, finding zinc coating to be a commercially significant characteristic and assigning Sahamitr a 10.77% dumping margin.
Petitioners (Manchester Tank & Worthington) challenged Commerce’s inclusion of a zinc-coating CONNUM distinction and contested the reliability of Sahamitr’s CONNUM-specific cost data, seeking total adverse facts available (AFA).
Commerce verified Sahamitr’s books, concluded costs were recorded on a product-specific basis, rejected total AFA, and sustained the zinc distinction; the Court of International Trade sustained Commerce’s Final Determination.

Issue	Plaintiffs' Argument	Defendant's Argument	Held
Whether Commerce permissibly added a zinc-coating distinction to the model-match/CONNUM criteria	Commerce departed from its initial model-match instructions and lacked substantial evidence that zinc coating is commercially significant	Zinc coating is customer-requested, requires distinct processing, raises costs and prices, and Commerce may adopt criteria developed during the investigation	Court: Commerce reasonably developed (not revised) the model-match criteria during the investigation; substantial evidence supports treating zinc coating as commercially significant
Whether Commerce properly found Sahamitr’s CONNUM-specific cost data reliable and declined to apply total AFA	Plaintiffs identified CONNUM pairings with unexplained cost differences and argued SMPC withheld or misreported costs, warranting total AFA	Commerce verified SMPC’s accounting, explained cost variances (e.g., collars/foot rings, zinc coating effects) as minor or explained, so data are reliable and total AFA is unwarranted	Court: Substantial evidence supports Commerce’s finding that SMPC’s cost data were reliable and that total AFA was unnecessary

SKF USA, Inc. v. United States, 537 F.3d 1373 (Fed. Cir. 2008) (Commerce has broad discretion to define foreign like product and develop model-match criteria)
Pesquera Mares Australes Ltda. v. United States, 266 F.3d 1372 (Fed. Cir. 2001) (explains model-match methodology for identical and similar merchandise)
Bohler Bleche GmbH & Co. KG v. United States, 324 F. Supp. 3d 1344 (Ct. Int’l Trade 2018) (review standard for reasonableness of Commerce’s chosen methodology in investigations)
Atl. Sugar, Ltd. v. United States, 744 F.2d 1556 (Fed. Cir. 1984) (substantial evidence is not a de novo review; court defers if record supports agency conclusion)
U.S. Steel Corp. v. United States, 856 F. Supp. 2d 1318 (Ct. Int’l Trade 2012) (Commerce need not address every piece of evidence, only significant undermining evidence)
Downhole Pipe & Equip., L.P. v. United States, 776 F.3d 1369 (Fed. Cir. 2015) (courts do not reweigh evidence in administrative review)
NMB Singapore Ltd. v. United States, 557 F.3d 1316 (Fed. Cir. 2009) (agency must provide a discernible path of reasoning supported by record evidence)