Coalition of American Manufacturers of Mobile Access Equipment v. United States

Slip Op. 25-150
UNITED STATES
COURT OF INTERNATIONAL TRADE
Court No. 22-00152
COALITION OF AMERICAN MANUFACTURERS
OF MOBILE ACCESS EQUIPMENT,
Plaintiff,
v.
UNITED STATES,
Defendant,
and
ZHEJIANG DINGLI MACHINERY CO., LTD.,
Defendant-Intervenor.
Before: M. Miller Baker, Judge
OPINION
[Sustaining Commerce’s remand redetermination.]
Dated: December 11, 2025
Ned H. Marshak, Dharmendra N. Choudhary, and
Jordan C. Kahn, Grunfeld, Desiderio, Lebowitz, Sil-
verman & Klestadt LLP, New York, NY, on the com-
ments for Defendant-Intervenor.
Tara K. Hogan, Assistant Director, and Kristin E. Ol-
son, Trial Attorney, Commercial Litigation Branch,
Civil Division, U.S. Department of Justice, Washing-
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Ct. No. 22-00152 	Page 2
ton, DC, on the comments for Defendant. Of counsel
for Defendant was Ruslan Klafehn, Attorney, Office of
the Chief Counsel for Trade Enforcement & Compli-
ance, U.S. Department of Commerce, Washington, DC.
Timothy C. Brightbill, Laura El-Sabaawi, and Theo-
dore P. Brackemyre, Wiley Rein LLP, Washington, DC,
on the comments for Plaintiff.
Baker, Judge: This dumping case involving self-pro-
pelled lifting machines from China returns after a re-
mand on two issues. See Slip Op. 24-66, 2024 WL
2796654 (CIT 2024).
The first involved the surrogate value for ocean
freight charges. As relevant here, the court instructed
the Department of Commerce to explain why it was
permissible for Zhejiang Dingli Machinery Co. (Dingli)
to designate its shipping routes as business proprie-
tary 	information. 	Slip 	Op. 	24-66, 	at 	7, 	2024 	WL
2796654, at **2–3. If the agency found it impermissi-
ble, it was to allow the company to redesignate the in-
formation as public and then give the Coalition of
American Manufacturers of Mobile Access Equipment
the corresponding opportunity to resubmit its pro-
posed surrogate value data as public. Id. at 7–8, 2024
WL 2796654, at *3. Relatedly, the court instructed the
Department to reconsider its finding that the shipping
routes 	reflected 	in 	the 	Descartes, 	Freightos, 	and
Drewry 	information 	are 	more 	specific 	to 	Dingli’s
routes than the Maersk data and to “reconcile” its find-
ing that the latter set of pricing information is not pub-
licly available with contrary past pronouncements. Id.
at 10–13, 2024 WL 2796654, at **4–5.
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For the second issue, Commerce was to reconsider
internal inconsistencies in its valuation of certain of
Dingli’s inputs, “minor fabricated steel components.”
Id. at 16–20, 2024 WL 2796654, at **6–7.
I
A
On remand, the agency found that Dingli’s designa-
tion of its shipping routes as business proprietary in-
formation “may have been an impermissible charac-
terization.” 	Appx22052 	(citing 	19 	C.F.R.
§ 351.105(c)(3), (5), and (6)). The company redesig-
nated the information as public. Appx22052–22053.
The Coalition did the same with the Maersk data.
Appx22053.
The Department found that the Maersk figures
were publicly available ocean freight prices and, based
on past decisions, a reliable source of information. Id.
It therefore compared them to Descartes, Drewry, and
Freightos 	to 	determine 	the 	“best 	available 	infor-
mation” for valuing ocean shipping.
Commerce noted that Dingli reported using two
routes to ship its goods during the period of investiga-
tion—Shanghai to New York and Shanghai to Oak-
land, with the latter employed for most of the com-
pany’s relevant sales. Appx22053–22054. Maersk in-
cluded pricing for Shanghai–Oakland. But Descartes
was limited to Shanghai–New York; Drewry included
that 	route 	along 	with 	Shanghai–Los 	Angeles 	and
Shanghai–Houston; and Freightos included Shang-
hai–Long Beach and Ningbo–New York. Appx22054.
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Ct. No. 22-00152 	Page 4
Stating that its practice is to use ocean freight surro-
gate values that are “specific to the port combinations
a respondent uses for its shipments of merchandise
under consideration,” the agency found Maersk supe-
rior because it was the only source with pricing for the
same route Dingli used for most of its shipments.
Appx22054–22055.
Commerce also found that Maersk included “all in-
cidental ocean freight charges” and that the figures
covered “export service fees, terminal handling service
fees (origin), documentation fees, bunker adjustment
factor fees, low sulfur surcharge, and terminal han-
dling service fees (destination)” as part of the rates.
Appx22055. The other three datasets, in contrast, “of-
fer[ed] no accompanying rate details (or accompanying
information explaining the methodology for price data
collection and reporting),” such that it could not “be
determined whether the ocean freight rates in the Des-
cartes, Freightos, and Drewry information include all,
or any, ocean freight incidental charges.” Id.
In response to Dingli’s objection that the Maersk
data were unreliable because they were based on price
quotes, rather than actual transactions, the Depart-
ment pointed to instances when it gave preference to
price quotes over other sources’ actual transactions
when data-quality considerations weighed more heav-
ily. Appx22061–22063. It “determined that route spec-
ificity should be accorded more weight . . . because only
one data subset proffered on the record is actually spe-
cific to Dingli’s shipping routes.” Appx22063.
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That conclusion segued directly into the agency’s
answer to the company’s objection to route specificity.
While Dingli did not dispute that the Maersk routes
were more specific than the ones it proffered, it raised
other objections. The company claimed that its alter-
native 	routes 	were 	of 	similar 	distances 	such 	that
“freight charges should be nearly equal,” that Shang-
hai–Los 	Angeles 	and 	Shanghai–Long 	Beach 	are
“nearly as route specific as the Maersk data,” and that
any difference between charges for shipment to the
East and West Coasts is “insignificant.” Id. (emphasis
in original). Commerce rejected those arguments, em-
phasizing that its practice is to prefer ocean freight fig-
ures “that are specific to the port combinations a re-
spondent uses for its shipments of merchandise under
consideration.” Id. So it did not analyze Dingli’s asser-
tions about whether other routes “should be nearly
equal.” Id. (emphasis removed).
The agency also disagreed with Dingli’s contention
that the Maersk data were distortive because they
double-counted certain costs already accounted for on
the record by the World Bank’s Doing Business 2020
(Brazil) report. It explained that this source “likely”
did not include the charges reflected in the Maersk in-
formation. Appx22065.
Finally, Commerce disagreed with Dingli that con-
tainer weight is vital. It found that the Maersk data
“are for a specified quantity of goods as opposed to a
theoretical ‘container load’ of merchandise” and that
the 18,000-kilogram weight Maersk used was both
“within range for a 20-foot container capacity” and
“very close” to the lowest 40-foot container capacity,
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Ct. No. 22-00152 	Page 6
based on figures in the record. Appx22067. The agency
also observed that because the record showed that a
40-foot container might carry a payload as low as
20,000 kg, the 18,000 kg figure was “not so anomalous
as to be unreliable.” Appx22068. And it noted that
Dingli cited no evidence that Commerce had ever de-
clined to use Maersk figures because of low container
weights. Id.
B
Dingli now challenges Commerce’s decision to use
the Maersk price quotes instead of the other sources’
transaction-based pricing. ECF 92, at 4–13. The com-
pany contends that “this distinction” was “a sufficient
standalone reason to reject” the former data. Id. at 8.
That might well be, but the Department—not the
court—is the entity authorized to make that discre-
tionary determination. It explained that a source’s use
of price quotes “is not dispositive as to [its] reliability.”
Appx22061–22062. On this record, it found that route
specificity 	was 	the 	more 	important 	consideration.
Appx22063.
The agency’s conclusion was both lawful and sup-
ported by substantial evidence. While this court has
remanded the use of price quotes when the agency
failed to explain why it favored them, it has also held
that 	using 	them 	can 	be 	reasonable. 	See 	Jiangsu
Zhongji 	Lamination 	Materials 	Co. 	(HK) 	v. 	United
States, Slip Op. 23-84, at 28–29, 2023 WL 3863201,
at *10 (CIT 2023) (citing Changzhou Trina Solar En-
ergy Co. v. United States, 492 F. Supp. 3d 1322, 1330
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Ct. No. 22-00152 	Page 7
(CIT 2021), and Changzhou Trina Solar Energy Co. v.
United States, 532 F. Supp. 3d 1333, 1336–37 (CIT
2021)).
Dingli contends that Jiangsu Zhongji is “distin-
guishable based on its facts” because there, the non-
Maersk datasets included Chinese figures that could
reflect subsidies. ECF 92, at 10–11. But that misses
the point—weighing the evidence is a task for Com-
merce, not this court. See Slip Op. 23-84, at 29, 2023
WL 3863201, at *10. 1 To the extent there are compet-
ing agency preferences—one for actual transactions,
the other for route specificity—the Department may
choose between them as long as it explains its reason-
ing. See Catfish Farmers of Am. v. United States, Slip
1 In the Changzhou Trina cases, in turn, the court did not
remand because the use of price quotes was impermissible,
but rather because the agency did not explain why it
deemed it reasonable to use them. See 492 F. Supp. 3d
at 1330 (remanding the use of Maersk on that basis); 532
F. Supp. 3d at 1337 (sustaining the remand results after
Commerce found Xeneta “more specific to the shipping
routes used by” the respondent). Similarly, while Dingli
disparages the agency’s citation of Jinko Solar Import and
Export Co. v. United States, 701 F. Supp. 3d 1367 (CIT
2024), and argues that because Commerce used both Des-
cartes and Maersk data there it cannot reject Descartes
here, see ECF 92, at 12–13, the Jinko court made two im-
portant observations. First, “[a]lthough the Maersk data
[do] not reflect actual transactions, it is reasonably appar-
ent that Commerce viewed the data as reliable.” 701
F. Supp. 3d at 1385. The same is true here. Second, the
agency relied on both datasets for route-specificity reasons.
Id. at 1385–86. If anything, its emphasis on route specific-
ity in those cases suggests that its heavily weighting that
factor here is consistent with past practice.
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Ct. No. 22-00152 	Page 8
Op. 25-24, at 13, 2025 WL 748133, at *5 (CIT 2025)
(“Such weighing of preferences is the agency’s prerog-
ative.”). That is what it did here.
Dingli also objects to Commerce’s route-specificity
finding. It argues that the other datasets “are nearly
as 	route-specific 	as 	Maersk’s 	Shanghai–Oakland
route.” ECF 92, at 14 (emphasis added). The company
complains 	that 	Commerce 	“summarily 	dismisse[d]
this argument” because Maersk included the actual
route the company used. Id. at 14–15. But the agency
did no such thing. It reasonably explained that its
practice is to “use ocean freight surrogate value data
that are specific to the port combinations a respondent
uses for its shipments of merchandise under consider-
ation.” Appx22054. The Department’s finding as to
route specificity is thus supported by substantial evi-
dence.
Turning to brokerage and handling expenses, the
company essentially contends that in previous pro-
ceedings, Commerce excluded various parts of Maersk
data to avoid double-counting amounts reported else-
where. Dingli complains that the Department failed to
“distinguish” the World Bank Doing Business (2017)
Thailand report used in the 2018 Solar Cells from
China proceeding, 83 Fed. Reg. 35,616, “from the cor-
responding data reported in the Doing Business 2020
(Brazil) report” on the record here. ECF 92, at 22.
But the agency addressed that issue, observing that
while the Thailand report may have allowed it to de-
termine that the brokerage and handling value in-
cluded the incidental freight fees, the Brazil report on
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Ct. No. 22-00152 	Page 9
the record lacked information needed for such a find-
ing. 	Appx22066–22067. 	While 	the 	company 	insists
that “both reports provide substantially the same cost
elements,” ECF 92, at 22, Commerce explained why it
disagreed, see Appx22066–22067. That factual finding
is supported by substantial evidence, even if the court
were to agree with Dingli’s reading of the record.
Finally, the company argues that Commerce over-
looked “a critical deficiency underlying the Maersk
price quotes” because they all assumed a load of 18,000
kg in 40-foot dry containers. It asserts, “[T]his payload
is unrealistically low as compared to the prescribed in-
dustry standard payload of 28,000 kg for a 40-foot con-
tainer, published by Maersk itself.” ECF 92, at 24 (cit-
ing Appx6621–6622). It also argues that in past pro-
ceedings, “for Maersk price data, Commerce used an
even 	higher 	container 	weight—28,870 	kg 	(for 	40
foot)—to 	value 	ocean 	freight.” 	Id. 	at 	25 	(citing
Appx18593, Appx18596). “These facts render the ane-
mic 	18,000 	kg 	data 	printed 	on 	the 	Maersk 	ocean
freight quotes as anomalous and unreliable.” Id.
The 	government 	responds 	that 	Dingli 	conflates
payload with container capacity and assumes, without
evidence, that it is possible to load every container to
its maximum capacity. 2 It argues that the company’s
only support for its claimed industry standard payload
for a 40-foot container is “a citation to the Coalition’s
2 The government offers the useful example of one cubic
foot of feathers versus one cubic foot of lead. They both take
up the same amount of space in the container, but the lead
weighs considerably more. ECF 94, at 26 n.3.
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Ct. No. 22-00152 	Page 10
administrative case brief which provided a survey of
various container capacities.” ECF 94, at 27–28 (em-
phasis in original) (citing ECF 92, at 24). The Coalition
agrees, 	noting 	that 	Commerce 	was 	clear 	that 	the
Maersk data were for a specific quantity of goods, ra-
ther than some theoretical volume, and asserts that “it
is not inconsistent or anomalous for actual container
loads to have lower weights than the theoretical max-
imum of container freight data.” ECF 93, at 11–12. Ty-
ing both points together, the government emphasizes
that the agency must base its decision on the record
and not on “theoretical assumptions about the pay-
load.” ECF 94, at 28.
As discussed above, the Department found that the
18,000 kg figure was used to establish “a specified
quantity of goods,” rather than speculating on what “a
theoretical ‘container load’ of merchandise might be,”
and it noted that a 40-foot container might carry a pay-
load as low as 20,000 kg. Appx22067–22068. It said
that Dingli provided no evidence in the original pro-
ceeding to show that Maersk’s container weights were
unreliable and cited nothing on remand to merit a dif-
ferent result. Appx22068 (citing Appx1048).
The agency’s explanation is reasonable. Despite the
company’s characterization of the Maersk data as “un-
reliable, anomalous, potentially distortive, and quali-
tatively inferior,” ECF 92, at 27, the Department ex-
plained why it rejected each of Dingli’s arguments and
selected that dataset as the best available information
on the record. The court sustains the use of Maersk as
a surrogate value for ocean freight costs.
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Ct. No. 22-00152 	Page 11
II
A
The other issue is the valuation of minor fabricated
components. The court remanded because the agency’s
analysis was internally inconsistent. Commerce first
said the Coalition offered no evidence to show that
Dingli’s suppliers fabricated steel plate into various
components. See Appx1072. But it then said that while
sometimes the suppliers do minimal work, “in some
cases, they may do more in-depth fabrication or pro-
cessing.” Id. The court directed the Department to re-
solve the contradiction. Slip Op. 24-66, at 19–20; 2024
WL 2796654, at *7.
On remand, the agency conceded the inconsistency
and framed the issue as “whether 16 inputs [it] valued
using raw steel categories under [Harmonized Tariff
Schedule (HTS)] chapters 7208, 7211, and 7214 were
products purchased by Dingli as minor fabricated steel
parts 	or 	raw 	steel, 	i.e., 	plate, 	sheet, 	bar, 	rod.”
Appx22056–22057. It found that the record showed
the suppliers “fabricated” the inputs to varying de-
grees, based on the company’s specifications, for later
incorporation into finished machines. As a result, the
components were no longer raw steel. Appx22057. The
company’s submissions confirmed that, but it disa-
greed that the suppliers’ processing and fabrication
work had any significance. Id. Commerce found it es-
sential that “Dingli relied on evidence summarizing
‘the degree of fabrication or processing’ for all sourced
material inputs of production.” Id. “Once a set of fab-
rication processes dedicated to a specific outcome is
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Ct. No. 22-00152 	Page 12
performed on the purchased primary steel, [it] is no
longer usable to customers other than Dingli and is
only usable for incorporation into” the company’s lift
machines. Id.
The Department therefore concluded that the use
of HTS subheadings “that reflect base steel material,”
as Dingli advocated, was improper because fabrication
transforms the raw steel into something else, resulting
in 	“further 	value 	added.” 	Appx22057–22058. 	The
agency selected subheading 8341.20.90, “Parts suita-
ble for use solely or principally with machinery of
heading 8427, other than Fork lift trucks.” Id.
The company objected and argued that Commerce
had followed a strict Customs classification analysis,
rather than selecting a subheading that would yield a
more accurate value. Appx22069. The Department
again disagreed, emphasizing that because the inputs
were no longer raw steel, it was inappropriate to value
them 	using 	HTS 	chapters 	covering 	that 	material.
Appx22069–22070. It rejected the company’s reliance
on two Federal Circuit cases, 3 finding they simply hold
that the agency may employ Customs classifications as
part 	of 	its 	analysis 	but 	is 	not 	required 	to 	do 	so.
Appx22071. Commerce found that any code that did
not cover minor fabricated steel components would be
inappropriate, 	including 	those 	covering 	raw 	steel
(which the inputs no longer were). Appx22073. It also
3 Downhole Pipe & Equip., L.P. v. United States, 776 F.3d
1369, 1378–79 (Fed. Cir. 2015), and SolarWorld Americas,
Inc. v. United States, 910 F.3d 1216, 1223–25 (Fed. Cir.
2018).
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Ct. No. 22-00152 	Page 13
observed that, in the pre-remand administrative brief-
ing, Dingli had cited 8431.20.90 as the appropriate
classification for “parts (i.e., not base materials) used
in the production of subject merchandise” because the
fact that the parts were dedicated for a particular pur-
pose was “more important” than their composition. Id.
(quoting Appx6675).
Finally, Commerce rejected Dingli’s argument that
8431.20.90 “is somehow discredited” because the aver-
age unit value under that heading is higher than the
averages for the same inputs in the final determina-
tion. Appx22074. It observed that the company placed
market-economy 	prices 	for 	fabricated 	components
used in its machinery on the record “to corroborate the
recommended [HTS] numbers and the corresponding
[average unit values] for various fabricated component
inputs.” Appx22075. The Department found that the
average unit value was corroborated with market-
economy 	prices 	for 	similar 	fabricated 	components,
which it said was another reason to use 8431.20.90. Id.
B
Dingli begins its argument with a chart showing
the differences in valuation between the final determi-
nation and the remand results for the 16 inputs in
question. All of them increased between 461–680 per-
cent. ECF 92, at 28. The company objects that the De-
partment’s revised analysis is “unsupported by sub-
stantial record evidence and controlling judicial prec-
edent.” Id. It argues that the agency elevated adher-
ence to classification principles over “normal practice
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Ct. No. 22-00152 	Page 14
that favors [an] HTS subheading yielding a more reli-
able, representative, and accurate value.” Id. at 30.
Dingli’s theme is that 8431.20.90 might be appro-
priate for inputs that underwent major fabrication,
but it results in significant overvaluation for those
subject to minor changes like cutting and bending. Id.
at 33–34. The company asserts that “simple machining
operations” do not result in the “outsize value addi-
tion” assigned by 8431.20.90 and that headings for raw
steel plate, sheet, bar, and rod more “reasonably ap-
proximate” the inputs’ actual value. Id. at 34–35. It
also argues, again, that Downhole Pipe and Solar-
World Americas require the agency to follow some ap-
proach other than “conducting a rigid classification
analysis.” Id. at 30–32.
The government responds that Dingli ignores that
the components are no longer usable as raw steel. It
emphasizes Commerce’s finding that the reason for
the fabrication work is to render the inputs fit “for a
specific purpose,” such that they “have ceased to be-
come 	‘primary 	steel.’୻” 	ECF 	94, 	at 	50 	(citing
Appx22057–22058). “Dingli points to no flaws with
HTS 8431.20.90 other than its unsupported belief that
the value is too high.” Id. at 49.
The Coalition notes the Department originally used
HTS numbers for primary or raw steel because it
found the group had not supported its claim that
Dingli 	was 	purchasing 	anything 	other 	than 	raw
steel—the finding the court remanded as inconsistent.
ECF 93, at 15 (citing Appx22056). And it points out
that, on remand, the agency cited the company’s own
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Ct. No. 22-00152 	Page 15
acknowledgment that the inputs underwent fabrica-
tion or processing. Id. at 16–17 (citing Appx22057).
The Coalition emphasizes that Dingli has not chal-
lenged Commerce’s finding, observing that if there
were “any evidence on the record that these compo-
nents were actually raw steel—and thus should be val-
ued as such—then, presumably, [the company] would
have made that argument.” Id. at 18.
The points made by the government and the Coali-
tion are persuasive. Commerce reasonably explained
that fabrication of a component adds value, so it is no
longer a raw input and should not properly be valued
as one. Appx22058. Dingli does not really dispute that
point, instead quibbling with the amount of value
added. Thus, it has tacitly admitted that the raw steel
headings result in undervaluation. 4 But rather than
suggesting an alternative, it simply says the underval-
uation was the “most accurate” surrogate value. ECF
92, at 35. Essentially, Dingli asks the court to substi-
tute its judgment for the agency’s. The court declines.
Downhole Pipe and SolarWorld Americas do not
dictate otherwise. The former emphasizes the agency’s
“discretion to determine what constitutes the best
available information, as this term is not defined by
statute.” 776 F.3d at 1375. While Dingli is correct that
4 Dingli’s emphasis on the average unit values tied to the
candidate headings fails for a similar reason. As the Coali-
tion observes, the company’s argument ignores the Depart-
ment’s finding “that a fabricated component is necessarily
going to have a higher value than its underlying raw ma-
terial.” ECF 93, at 20 (citing Appx22074).
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Ct. No. 22-00152 	Page 16
Downhole Pipe states that the Department need not
follow 	the 	classification 	principles 	Customs 	and
Border Protection uses, see id. at 1379, the flip side is
also true. Nothing in that opinion prohibits Commerce
from using such principles if it concludes they would
yield the most accurate result. The point is that the
agency 	must 	explain 	its 	rationale 	such 	that 	“a
reasonable mind could conclude that [it] chose the best
available information.” Id. (quoting Zhejiang DunAn
Hetian Metal Co. v. United States, 652 F.3d 1333, 1341
(Fed. Cir. 2011)). And SolarWorld Americas confirms
that a subheading may be the best available even if it
is not a perfect match. See 910 F.3d at 1223 (citing
Home Meridian Int’l Inc. v. United States, 772 F.3d
1289, 	1296 	(Fed. 	Cir. 	2014) 	(“The 	data 	on 	which
Commerce relies to value inputs must be the ‘best
available information,’ but there is no requirement
that the data be perfect.”)).
Finally, the Department observed that Dingli’s ad-
ministrative briefing argued that 8431.20.90 is appro-
priate for valuing factors of production “that are parts
(i.e., not base materials) used in the production of sub-
ject 	merchandise.” 	Appx22073 	(quoting 	Appx6675).
The company responds that its argument was based
on valuing “major customized fabricated subassem-
blies.” ECF 92, at 34 (emphasis added).
But its argument actually swept more broadly. 5 It
recognized that 8431.20 “trumps a basket heading
5 It is true that the cited discussion appeared in a section
of 	the 	company’s 	case 	brief 	titled 	“Fabricated 	Steel
(footnote continues on next page)
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Ct. No. 22-00152 	Page 17
based on component material, since ‘the fact that the
parts were dedicated for use in the subject merchan-
dise is more important than the fact [they] are com-
posed of certain materials.’୻” Appx6675 (ellipses and
brackets 	omitted) 	(quoting 	Vertical 	Shaft 	Engines
from China I&D Memo at 39 (Mar. 5, 2021), accompa-
nying 86 Fed. Reg. 14,077). 6 The Department, in turn,
followed that principle in finding that “once a set of
fabrication processes . . . dedicated to a specific out-
come is performed on the purchased primary steel, [it]
is no longer usable to customers other than Dingli and
is only usable for incorporation into” the company’s lift
machines. Appx22074. Dingli has not explained why
that rule should apply to “major” components but not
“minor” ones.
In sum, while the company contends—as did the
Downhole Pipe appellants, see 776 F.3d at 1380—that
the value Commerce selected is too high, its solution is
to insist that the Department use subheadings the
agency found inappropriate. But because Commerce
gave 	a 	reasonable 	explanation 	of 	why 	those
Components,” see Appx6668, and that a separate section
addressed 	“Minor 	Fabricated 	Steel 	Components,” 	see
Appx6686. The latter advocated for treating the minor
components as raw steel. Appx6687.
6 Vertical Shaft Engines made the point even more strongly
than Dingli suggested. It said that “in cases similarly in-
volving machinery made from numerous parts and materi-
als, Commerce has determined that the fact that the parts
were dedicated for use in the subject merchandise was
more important than the fact that the parts were composed
of certain materials.” Vertical Shaft Engines I&D Memo
at 38–39.
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Ct. No. 22-00152 	Page 18
subheadings were unsatisfactory, the court must sus-
tain its decision as supported by substantial evidence.
The agency reasonably found it important not to value
components as something they are not (raw steel).
That decision was its to make.
* 	* 	*
The court sustains Commerce’s redetermination. A
separate judgment will issue. See USCIT R. 58(a).
Dated: 	December 11, 2025 	/s/ M. Miller Baker
New York, NY 	Judge
Case 1:22-cv-00152-MMB Document 100 Filed 12/11/25 Page 18 of 18