Jilin Forest Industry Jinqiao Flooring Group Co., Ltd. v. United States

United States Court of Appeals
for the Federal Circuit
______________________
JILIN FOREST INDUSTRY JINQIAO FLOORING
GROUP CO., LTD.,
Plaintiff-Appellee
v.
UNITED STATES,
Defendant-Appellant
______________________
2023-2245
______________________
Appeal from the United States Court of International
Trade in No. 1:18-cv-00191-RKE, Senior Judge Richard K.
Eaton.
______________________
Decided: July 28, 2025
______________________
BRITTNEY RENEE POWELL, Fox Rothschild LLP, Wash-
ington, DC, argued for plaintiff-appellee. Also represented
by LIZBETH ROBIN LEVINSON.
BRENDAN DAVID JORDAN, Commercial Litigation
Branch, Civil Division, United States Department of Jus-
tice, Washington, DC, argued for defendant-appellant.
Also represented by BRIAN M. BOYNTON, TARA K. HOGAN,
PATRICIA M. MCCARTHY; RACHEL BOGDAN, Office of the
Chief Counsel, United States Department of Commerce,
Washington, DC.
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 2
______________________
Before HUGHES, BRYSON, and STARK, Circuit Judges.
BRYSON, Circuit Judge.
The government appeals the decision of the Court of
International Trade (“CIT”), which held that it was unlaw-
ful for the Department of Commerce (“Commerce”) to as-
sign a non-market economy (“NME”) country-wide
antidumping duty rate to Jilin Forest Industry Jinqiao
Flooring Group Co. (“Jilin”). We reverse.
I
Jilin is an exporter of multilayered wood flooring in the
People’s Republic of China (“China” or “PRC”). In Novem-
ber 2010, Commerce initiated an antidumping investiga-
tion into the sale of multilayered wood flooring from China.
For purposes of the investigation, Commerce treated China
as an NME country. Multilayered Wood Flooring From the
People’s Republic of China: Final Determination of Sales at
Less Than Fair Value, 76 Fed. Reg. 64,318 at 64,321 (Oct.
18, 2011) (“Final Determination”).
The Tariff Act defines an NME country as “any foreign
country that the administering authority determines does
not operate on market principles of cost or pricing struc-
tures, so that sales of merchandise in such country do not
reflect the fair value of the merchandise.” 19 U.S.C.
§ 1677(18)(A). The Act further lists five nonexclusive fac-
tors for Commerce to consider in determining whether a
country is an NME country. Id. § 1677(18)(B). Two of
those factors are: “the extent of government ownership or
control of the means of production” and “the extent of gov-
ernment control over the allocation of resources and over
the price and output decisions of enterprises.” Id.
§ 1677(18)(B)(iv), (v). No party to the investigation chal-
lenged China’s designation as an NME country. Final De-
termination at 64,321.
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 3
Given China’s NME status, Commerce applied a
longstanding practice that it described as follows:
In proceedings involving NME countries, the De-
partment holds a rebuttable presumption that all
companies within the country are subject to govern-
ment control and, thus, should be assessed a single
antidumping duty rate. It is the Department’s policy
to assign all exporters of the subject merchandise in
an NME country this single rate unless an exporter
can demonstrate that it is sufficiently independent
so as to be entitled to a separate rate.
Id. In its Initiation Notice, Commerce notified the parties
of the application process by which exporters may obtain
separate rates in NME investigations. Multilayered Wood
Flooring From the People’s Republic of China: Preliminary
Determination of Sales at Less Than Fair Value, 76 Fed.
Reg. 30,656 at 30,658 (May 26, 2011).
In determining the antidumping duty rate for the PRC-
wide entity, Commerce drew an adverse inference based on
a finding that not all exporters responded to Commerce’s
requests for information and thus “the PRC-wide entity
has failed to cooperate to the best of its ability.” Final De-
termination at 64,322. The final rate that Commerce cal-
culated for the PRC-wide entity was 25.62 percent. See
Baroque Timber Indus. (Zhongshan) Co. v. United States,
971 F. Supp. 2d 1333, 1339 (Ct. Int’l Trade 2014).
That PRC-wide rate was not assigned to the seventy-
four exporters that timely filed separate rate applications.
Commerce found that each of them demonstrated “both de
jure and de facto absence of government control with re-
spect to each company’s respective exports of the merchan-
dise under investigation” and thus qualified for a separate
rate instead of the PRC-wide rate. Final Determination at
64,322. Jilin was among the seventy-four exporters that
received a separate rate (3.31 percent). Id. at 64,323.
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 4
In February 2017, Commerce initiated the fifth admin-
istrative review of the antidumping duty order. Due to the
large number of exporters involved, Commerce selected the
two largest PRC exporters by volume as mandatory re-
spondents for individual examination, one of which was Ji-
lin. See App. 83–84. Commerce once again explained the
application process by which exporters could obtain sepa-
rate rates. Initiation of Antidumping and Countervailing
Duty Administrative Reviews, 82 Fed. Reg. 10,457 at
10,458 (Feb. 13, 2017).
Jilin cooperated with the review and asserted that it
was not under the control of the Chinese government and
should therefore receive a separate rate, as it had in prior
reviews. However, this time Commerce found that Jilin
failed to rebut the presumption of government control and
was therefore regarded as a part of the PRC-wide entity.
See App. 138–40.1 Accordingly, Commerce assigned Jilin
the PRC-wide antidumping duty rate of 25.62 percent, the
rate calculated in the initial investigation.2 Multilayered
Wood Flooring From the People’s Republic of China: Final
Results of Antidumping Duty Administrative Review, Fi-
nal Determination of No Shipments, and Partial Rescis-
sion; 2015–2016, 83 Fed. Reg. 35,461 at 35,464 (July 26,
2018).
Jilin challenged the results of the fifth administrative
review at the CIT. In Jilin I, the court ordered a remand,
1 “App.” citations herein refer to the appendix filed
by the government.
2 The PRC-wide rate was not subject to change, be-
cause no party requested a review of the entity. See Multi-
layered Wood Flooring From the People’s Republic of
China: Preliminary Results of the Antidumping Duty Ad-
ministrative Review, Preliminary Determination of No
Shipments, and Rescission of Review, in Part; 2015–2016,
83 Fed. Reg. 2,137 at 2,138 (Jan. 16, 2018).
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 5
questioning the lawfulness of “applying a rebuttable pre-
sumption that all companies within a nonmarket economy
country are controlled by the government of that country,
i.e., the ‘NME Policy.’” App. 20. The court ordered Com-
merce to calculate an individual antidumping duty rate for
Jilin “or provide a reasonable explanation for why it need
not.” App. 33.
On remand, Commerce identified two separate compo-
nents to its practice: a presumption of government control
over exporters in an NME country and the use of a single
antidumping duty rate for the NME-wide entity. Com-
merce explained that both components were “consistent
with a general statutory recognition of a ‘close correlation
between a nonmarket economy and government control of
prices, output decisions, and the allocation of resources.’”
App. 174 (quoting Sigma Corp. v. United States, 117 F.3d
1401, 1405–06 (Fed. Cir. 1997)). Commerce also cited 19
C.F.R. § 351.107(d) as supporting the use of a single rate
for all exporters in an NME country that are unable to
demonstrate independence from the government. App.
173.
In Jilin II, the CIT found “substantial evidence to sup-
port Commerce’s conclusion that Jilin has not rebutted the
presumption of state control.” App. 45. Nevertheless, the
court held that “Commerce has not shown that its NME
Policy . . . is in accordance with law with respect to Jilin”
and remanded the case again to Commerce to calculate an
individual weighted average rate for Jilin. App. 37
(cleaned up). On the second remand, Commerce deter-
mined, under protest, an individual weighted average rate
of zero percent for Jilin. The CIT entered that rate in its
final judgment. App. 222.
The government timely filed this appeal.
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 6
II
The Tariff Act requires Commerce to “determine the
estimated weighted average dumping margin for each ex-
porter and producer individually investigated” once it
makes a final determination that the subject merchandise
is being, or is likely to be, sold in the United States at less
than its fair value. 19 U.S.C. § 1673d(c)(1)(B)(i)(I). But
“[i]f it is not practicable to make individual weighted aver-
age dumping margin determinations under [section
1673d(c)] because of the large number of exporters or pro-
ducers involved in the investigation or review,” the Tariff
Act authorizes Commerce to “determine the weighted av-
erage dumping margins for a reasonable number of export-
ers or producers,” known as mandatory respondents. Id.
§ 1677f-1(c)(2).
At the time of the fifth administrative review in this
case, there was no statutory provision or regulation that
expressly codified the presumption of government control
over exporters in an NME country (“the NME presump-
tion”), or the assignment of a single NME-wide rate on fail-
ing to rebut the presumption (“the NME policy”).3
However, the version of 19 C.F.R. § 351.107(d) that was in
effect at the time provided that “[i]n an antidumping pro-
ceeding involving imports from a nonmarket economy
country, ‘rates’ may consist of a single dumping margin ap-
plicable to all exporters and producers.”
At issue in this case is whether Commerce lawfully as-
signed the PRC-wide antidumping duty rate to Jilin, a co-
operative mandatory respondent that failed to rebut the
NME presumption. Jilin does not appeal the CIT’s finding
3 Commerce has since promulgated a regulation, ef-
fective January 15, 2025, which sets out the substance of
the NME presumption and the NME policy. See 19 C.F.R.
§ 351.108(a), (b); 89 Fed. Reg. 101,694.
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 7
that Jilin failed to rebut the presumption of government
control. As such, reversal is required so long as the NME
policy, with the NME presumption at its core, is lawful.
The government argues that binding precedents since
Sigma Corp. v. United States, 117 F.3d 1401 (Fed. Cir.
1997) require reversal. Specifically, the government as-
serts that this court has “repeatedly upheld Commerce’s
NME policy” and recently confirmed that “Commerce may
apply the NME-wide rate to a cooperative mandatory re-
spondent who fails to rebut the presumption of government
control even when the NME-rate was based on adverse
facts available.” Appellant’s Br. at 17. According to the
government, “Commerce’s decision here is no different”
from China Manufacturers Alliance, LLC v. United States,
1 F.4th 1028 (Fed. Cir. 2021) (“CMA”), and “the same re-
sult—affirmance of Commerce’s decision—is required.”
Appellant’s Br. at 22.
In Sigma, we held that Commerce “has broad authority
to interpret the antidumping statute and devise procedures
to carry out the statutory mandate,” and that “it was
within Commerce’s authority to employ a presumption of
state control for exporters in a nonmarket economy, and to
place the burden on the exporters to demonstrate an ab-
sence of central government control.” 117 F.3d at 1405. We
explained that the antidumping statute “recognizes a close
correlation between a nonmarket economy and government
control of prices, output decisions, and the allocation of re-
sources,” citing 19 U.S.C. § 1677(18)(B)(iv) and (v). Id. at
1405–06. We further explained that “because exporters
have the best access to information pertinent to the ‘state
control’ issue, Commerce is justified in placing on them the
burden of showing a lack of state control.” Id. at 1406.
Since Sigma, we have consistently approved of Com-
merce’s practice of applying the NME presumption and as-
signing the NME-wide rate to exporters that fail to rebut
the presumption. See, e.g., Transcom, Inc. v. United States,
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 8
294 F.3d 1371, 1373 (Fed. Cir. 2002); Changzhou Wujin
Fine Chem. Factory Co. v. United States, 701 F.3d 1367,
1370 (Fed. Cir. 2012); Michaels Stores, Inc. v. United
States, 766 F.3d 1388, 1390 (Fed. Cir. 2014); Dongtai Peak
Honey Indus. Co. v. United States, 777 F.3d 1343, 1349–50
(Fed. Cir. 2015); Albemarle Corp. & Subsidiaries v. United
States, 821 F.3d 1345, 1348 (Fed. Cir. 2016); Changzhou
Hawd Flooring Co. v. United States, 848 F.3d 1006, 1009
(Fed. Cir. 2017); Diamond Sawblades Mfrs. Coal. v. United
States, 866 F.3d 1304, 1311 (Fed. Cir. 2017); Zhejiang
Mach. Imp. & Exp. Corp. v. United States, 65 F.4th 1364,
1372 (Fed. Cir. 2023); Pirelli Tyre Co. v. United States, 128
F.4th 1265, 1268 (Fed. Cir. 2025).
In CMA, we sustained Commerce’s assignment of the
PRC-wide rate to Double Coin, a cooperative mandatory re-
spondent that failed to rebut the NME presumption in an
administrative review. We held that “where a respondent
in an NME country cooperates with an investigation or re-
view but fails to rebut the presumption of government con-
trol, Commerce may permissibly apply the country-wide
NME entity rate,” including a rate that was based in whole
or in part on adverse facts available and carried forward
from the initial investigation.4 1 F.4th at 1039–40. We
further held that “[t]his conclusion applies whether or not
other members of the NME-wide entity are identified by
name and subject to the administrative review at issue.”
Id. at 1040.
Jilin, however, argues that “[t]here is simply no prece-
dent regarding the precise legal question raised in this ap-
peal that binds the Court’s hands.” Appellee’s Br. at 19.
4 See also Diamond Sawblades, 866 F.3d at 1312
(“The fact that a country-wide rate may have been calcu-
lated using [adverse facts available] does not change its ap-
plicability to a NME entity that cooperated, but ultimately
failed to qualify for a separate rate.”).
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 9
According to Jilin, the question in this case is “whether
Commerce’s application of the NME Policy is lawful in the
absence of a statute or regulation.” Id. at 15. Jilin asserts
that “[n]one of this Court’s prior decisions have addressed
why an uncodified policy should be given more deference
than the statutory provision requiring Commerce to deter-
mine the ‘individual weighted average dumping margin for
each known exporter and producer of the subject merchan-
dise.’” Id. at 18–19 (quoting 19 U.S.C. § 1677f-1(c)(1)).
Specifically, Jilin argues that this court’s decision in
CMA “rel[ied] on strict and unchallenged deference to Com-
merce, and it is that deference to an uncodified policy, with
no statutory or regulatory basis, that is being challenged in
this proceeding.” Id. at 17. Jilin contends that CMA “relied
on Sigma to conclude (and arguably ‘bootstrap’ without fur-
ther analysis) that Commerce has ‘broad authority to in-
terpret the antidumping statute and devise procedures to
carry out the statutory mandate.’” Id. at 16–17 (quoting
CMA, 1 F.4th at 1038).
Jilin’s characterization of CMA reads out the court’s
analysis of the statutory and regulatory support for the
NME policy to avoid its clear import in this case. In CMA,
respondent Double Coin “recognize[d] that binding cases
(too numerous to list in their entirety) have uniformly sus-
tained Commerce’s recognition of an NME-wide entity as a
single exporter for purposes of assigning an antidumping
rate to the individual members of the entity.” 1 F.4th at
1036. Nevertheless, Double Coin “question[ed] . . . the au-
thority for Commerce to so recognize such an NME-wide
entity,” as Jilin does in this case. Id. at 1037.
The CMA court squarely addressed that question of
Commerce’s authority by first holding that 19 C.F.R.
§ 351.107 provides “clear authority . . . for Commerce to
fashion a single rate for all exporters and producers that
qualify for the single rate.” Id. In light of that regulation,
we found it “clear that Commerce may, where the facts
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 10
warrant, recognize a single NME-wide entity to include all
exporters that fail to rebut the presumption of government
control.” Id.
We further held that the “country-wide NME entity
rate may be an ‘individually investigated’ rate within the
meaning of 19 U.S.C. § 1673d(c)(1)(B)(i)(I),” so that “Com-
merce may permissibly assign such a rate to the unitary
group of exporters in an NME country that have failed to
rebut the presumption of government control.” Id. at 1039.
We reasoned that the “PRC-wide entity rate resulting from
Commerce’s initial investigation constitute[d] an ‘individ-
ually investigated’ weighted average dumping margin . . .
because Commerce treat[ed] the companies comprising the
China-wide entity as a single entity and investigated them
as such in the original investigation.” Id. at 1037 (cleaned
up); see also Guizhou Tyre Co., Ltd. v. United States, 557 F.
Supp. 3d 1302, 1323 (Ct. Int’l Trade 2022) (“[B]ased on the
holding in China Mfrs. Alliance, the court concludes that
the PRC-wide rate must be deemed to have been assigned
to a known, ‘individually-investigated’ exporter and pro-
ducer consisting of the PRC-wide entity.”).5
The CMA court’s reliance on the holding in Sigma that
Commerce “has broad authority to interpret the antidump-
ing statute and devise procedures to carry out the statutory
5 Section 1677f-1(c)(1) of the Tariff Act cross refer-
ences section 1673d(c) as follows: “In determining weighted
average dumping margins under section 1673b(d),
1673d(c), or 1675(a) of this title, the administering author-
ity shall determine the individual weighted average dump-
ing margin for each known exporter and producer of the
subject merchandise.” 19 U.S.C. § 1677f-1(c)(1). The
court’s analysis of the “individually investigated” rate re-
quirement under section 1673d(c)(1)(B)(i)(I) applies
equally to the “individual weighted average” rate require-
ment under section 1677f-1(c)(1).
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 11
mandate” was directed to a narrow issue. We cited that
holding when discussing whether Commerce permissibly
exercised discretion to take the simple average of two rates
to determine the “proper PRC-wide entity rate.” 1 F.4th at
1038 (quoting Sigma, 117 F.3d at 1405, and holding that
“Double Coin points to no precedent that precludes the dis-
cretion Commerce exercised in averaging the two rates in
this case”). As explained above, we found statutory and
regulatory support for the fundamental aspects of the NME
policy at issue in CMA.
Accordingly, CMA and the long line of cases CMA relied
on are binding precedent that Jilin may not avoid unless or
until the court sits en banc. See Preminger v. Sec’y of Vet-
erans Affs., 517 F.3d 1299, 1309 (Fed. Cir. 2008) (“A prior
precedential decision on a point of law by a panel of this
court is binding precedent and cannot be overruled or
avoided unless or until the court sits en banc.”). Our hold-
ing in CMA that Commerce may lawfully assign an NME-
wide antidumping duty rate to a cooperative mandatory re-
spondent that has failed to rebut the presumption of gov-
ernment control requires reversing the CIT in this case.
III
Even if CMA and the long line of cases sustaining the
NME policy did not exist, Jilin’s argument that Commerce
could not apply the NME policy absent notice-and-com-
ment rulemaking would fail.
To be clear, the version of 19 C.F.R. § 351.107(d) appli-
cable to this case expressly contemplated a single anti-
dumping duty rate applicable to all exporters in an NME
country. See 19 C.F.R. § 351.107(d) (“In an antidumping
proceeding involving imports from a nonmarket economy
country, ‘rates’ may consist of a single dumping margin ap-
plicable to all exporters and producers.”). If anything, the
language of the regulation was broader than the NME pol-
icy in that it did not provide for the possibility of a separate
rate upon rebutting the presumption of government
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 12
control. To the extent that section 351.107(d) did not spell
out the NME presumption, that silence does not render the
NME presumption invalid.
The NME presumption is an evidentiary presumption,
i.e., a factual inference that arises from a finding that an
exporting country has a non-market economy. From a find-
ing that a country does not operate on market principles,
Commerce infers that the country’s government exercises
control over its exporters, unless proved otherwise in the
case of individual exporters. “Presumptions normally arise
when proof of one fact renders the existence of another fact
‘so probable that it is sensible and timesaving to assume
the truth of [the inferred] fact . . . until the adversary dis-
proves it.’” NLRB v. Curtin Matheson Sci., Inc., 494 U.S.
775, 788–89 (1990) (alteration in original) (quoting E.
Cleary, McCormick on Evidence § 343, p. 969 (3d ed.
1984)).
By its terms, the Administrative Procedure Act (“APA”)
does not always require an agency to comply with the no-
tice-and-comment procedure outlined in 5 U.S.C. § 553(b).
The APA exempts “interpretive rules, general statements
of policy, or rules of agency organization, procedure, or
practice” from notice-and-comment requirements. Id.
§ 553(b)(A). Only “legislative rules” are subject to notice-
and-comment requirements. See Perez v. Mortg. Bankers
Ass’n, 575 U.S. 92, 101 (2015); Lincoln v. Vigil, 508 U.S.
182, 196 (1993).
Jilin argues that “[i]t is a fundamental principle of ad-
ministrative law that an agency’s authority to promulgate
legislative rules (i.e. rules made pursuant to congression-
ally-delegated authority) is governed by the informal rule-
making procedures outlined in the [APA].” Appellee’s Br.
at 13. But Jilin merely assumes that the NME presump-
tion is a legislative rule. Jilin provides no authority or ex-
planation as to why an evidentiary presumption, a
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JILIN FOREST INDUSTRY JINQIAO FLOORING GROUP CO. v. US 13
shorthand for adopting a factual inference, qualifies as a
legislative rule.
The validity of an evidentiary presumption turns on its
rationality. See Republic Aviation Corp. v. NLRB, 324 U.S.
793, 804–05 (1945) (“Like a statutory presumption or one
established by regulation, the validity [of the Board’s pre-
sumption], perhaps in a varying degree, depends upon the
rationality between what is proved and what is inferred.”);
NLRB v. Baptist Hosp., 442 U.S. 773, 787 (1979) (“It is, of
course, settled law that a presumption adopted and applied
by the Board must rest on a sound factual connection be-
tween the proved and inferred facts.”); Nat’l Min. Ass’n v.
Babbitt, 172 F.3d 906, 912 (D.C. Cir. 1999) (“[A]n eviden-
tiary presumption is only permissible if there is a sound
and rational connection between the proved and inferred
facts . . . .” (cleaned up)).
There is a sound and rational connection between a
finding that a country is an NME country and the inference
that exporters in that country are subject to government
control. As noted, two of the factors that Commerce con-
siders in determining whether a country is an NME coun-
try are “the extent of government ownership or control of
the means of production” and “the extent of government
control over the allocation of resources and over the price
and output decisions of enterprises.” 19 U.S.C.
§ 1677(18)(B)(iv), (v). Logically, greater government con-
trol over the means of production or the allocation of re-
sources would lead to the conclusion that a country’s
economy does not operate on market principles. Thus, once
a country has been found to be an NME country, there is
nothing unreasonable about presuming that exporters in
that country are subject to government control, unless
proved otherwise in each individual case.
Accordingly, the NME presumption is a valid eviden-
tiary presumption that Commerce was permitted to use.
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IV
For the foregoing reasons, the judgment of the Court
of International Trade is reversed.
REVERSED
COSTS
No costs.
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