Packing costs are usually not controversial. The Commerce Department includes the costs of packing materials and labour devoted to the packing. Sometimes the Commerce Department includes an amount for overhead, but the amount is typically so small that the Commerce Department often disregards overhead. For cost of production, the Commerce Department uses the cost of packing for the foreign market. For constructed value, the Commerce Department uses the cost of packing for the United States market, In either case, the foreign company usually takes the packing cost data presented in the price response and simply uses that same data for the cost response. The Commerce Department almost always accepts this use of data from the price response.

Source: Business Guide to Trade Remedies in the United States: Anti-dumping, countervailing and safeguards legislation practices and procedures