When making a price-to-price comparison, the Commerce Department compares adjusted net export prices to adjusted net home market prices.

Companies should note a number of important points about the Commerce Department's method of calculating dumping margins.

As explained above, the Commerce Department can only use those prices that are above cost in determining normal value.

As it prepares its response, the foreign company collects the various items of information and begins to prepare the computer database.

At the end of 2005, the Commerce Department considered the following 12 countries to be NMEs.

If the targeted country cannot escape being labelled an NME, the next best thing is for the targeted industry to demonstrate that it is a 'market-oriented industry'.

The principal consequence of the Commerce Department identifying the targeted country as an NME and refusing to recognize the target industry as a market-oriented industry is that the Commerce Department presumes that all companies in an NME country are subject to the NME country's control and, consequently, that these companies' prices and costs cannot be used in the Commerce Department's AD margin calculations.

On 5 April 2005, the Commerce Department issued a new 'separate rate' application process that will be used to determine whether NME companies not selected as mandatory respondents qualify for separate rate status in NME anti-dumping investigations.