Carbon Activated Tianjin Co., Ltd., Carbon Activated Corporation v. United States, Calgon Carbon Corporation, Norit Americas, Inc.

N OTE: This disposition is nonprecedential.
United States Court of Appeals
for the Federal Circuit
______________________
CARBON ACTIVATED TIANJIN CO., LTD.,
CARBON ACTIVATED CORPORATION,
Plaintiffs-Appellants
DATONG JUQIANG ACTIVATED CARBON CO.,
LTD., DATONG JUQIANG ACTIVATED CARBON
USA, LLC, NINGXIA GUANGHUA CHERISHMET
ACTIVATED CARBON CO., LTD., DATONG
MUNICIPAL YUNGUANG ACTIVATED CARBON
CO., LTD.,
Plaintiffs
v.
UNITED STATES, CALGON CARBON
CORPORATION, NORIT AMERICAS, INC.,
Defendants-Appellees
______________________
2023-2413
______________________
Appeal from the United States Court of International
Trade in Nos. 1:22-cv-00017-MAB, 1:22-cv-00025-MAB,
1:22-cv-00026-MAB, Chief Judge Mark A. Barnett.
______________________
Decided: May 9, 2025
______________________
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 2
STEPHANIE HARTMANN, Wilmer Cutler Pickering Hale
and Dorr LLP, Washington, DC, argued for plaintiffs-ap-
pellants. Also represented by P ATRICK K LEIN, J OHN M.
P ETERSON, Neville Peterson LLP, New York, NY; RICHARD
F. O'N EILL , Seattle, WA.
J OSHUA E. K URLAND, Commercial Litigation Branch,
Civil Division, United States Department of Justice, Wash-
ington, DC, argued for defendant-appellee United States.
Also represented by BRIAN M. B OYNTON, CLAUDIA B URKE,
P ATRICIA M. M CC ARTHY , ANTONIA R AMOS SOARES ;
ASHLANDE G ELIN, Office of the Chief Counsel for Trade En-
forcement and Compliance, United States Department of
Commerce, Washington, DC.
MELISSA M. BREWER , Kelley Drye & Warren, LLP,
Washington, DC, argued for defendants-appellees Calgon
Carbon Corporation, Norit Americas, Inc. Also represented
by J OHN M. HERRMANN, ROBERT ALAN L UBERDA .
______________________
Before T ARANTO, SCHALL , and CHEN, Circuit Judges.
SCHALL , Circuit Judge.
Carbon Activated Tianjin Co., Ltd. and Carbon Acti-
vated Corporation (collectively, “Carbon Activated”) are
companies that export activated carbon to the United
States from the People’s Republic of China (“China”).1 Ac-
tivated carbon is a solid carbon adsorbent material that is
used to remove pollutants in gas and liquids.
Carbon Activated now appeals the decision of the
United States Court of International Trade (“Trade Court”)
1 Specifically, Carbon Activated Tianjin Co., Ltd. ex-
ports activated carbon from China to the United States,
where it is resold by Carbon Activated Corporation.
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 3
in Carbon Activated Tianjin Co., Ltd. v. United States, 650
F. Supp. 3d 1354 (Ct. Int’l Trade 2023) (“Carbon Acti-
vated”). In that decision, the Trade Court sustained the
final results of the Department of Commerce (“Commerce”)
in the thirteenth administrative review (“AR13”) of the an-
tidumping duty order on certain activated carbon from
China for the period April 1, 2019, through March 31, 2020.
See Certain Activated Carbon from the People’s Republic of
China: Final Results of Antidumping Duty Administrative
Review; and Final Determination of No Shipments; 2019–
2020, 86 Fed. Reg. 73,731 (Dep’t Commerce Dec. 28, 2021)
(“Final Results”), App. 7967–70.2 We have jurisdiction pur-
suant to 28 U.S.C. § 1295(a)(5). For the reasons set forth
below, we affirm.
I
The Tariff Act of 1930, as amended, directs Commerce
to impose an antidumping duty on foreign merchandise if
the “merchandise is being, or is likely to be, sold in the
United States at less than its fair value.” 19 U.S.C.
§ 1673(1). The antidumping duty reflects the amount by
which the normal value (the price a producer charges in its
home market) exceeds the export price (the price of the
product in the United States). Id. § 1673; see U.S. Steel
Corp. v. United States, 621 F.3d 1351, 1353 (Fed. Cir. 2010)
(citation omitted). However, in an antidumping duty pro-
ceeding involving a non-market economy country, such as
China, Commerce calculates normal value “on the basis of
the value of the factors of production utilized in producing
the merchandise.” 19 U.S.C. § 1677b(c)(1). The statute di-
rects Commerce to value the factors of production “based
on the best available information regarding the values of
such factors in a market economy country or countries con-
sidered to be appropriate by” Commerce. Id. The factors
2 Our citation to “App.” refers to the Appendix filed
by the parties, ECF Nos. 42, 43.
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 4
of production that Commerce must value include, but are
not limited to, “hours of labor required,” “quantities of raw
materials employed,” “amounts of energy and other utili-
ties consumed,” and “representative capital cost, including
depreciation.” Id. § 1677b(c)(3). The resulting values are
commonly referred to as “surrogate values,” and the mar-
ket economy country from which the surrogate values are
derived is commonly referred to as the “surrogate country.”
See Risen Energy Co., Ltd. v. United States, 122 F.4th 1348,
1352 (Fed. Cir. 2024) (“By identifying a surrogate country
and surrogate values for the factors of production, Com-
merce approximates what a non-market economy manufac-
turer might pay in a market economy setting.” (internal
quotation marks and citation omitted)). The statute pro-
vides that, in valuing factors of production under
§ 1677b(c)(1), Commerce “shall utilize, to the extent possi-
ble, the prices or costs of factors of production in one or
more market economy countries that are . . . at a level of
economic development comparable to that of the nonmar-
ket economy country, and . . . significant producers of com-
parable merchandise.” 19 U.S.C. § 1677b(c)(4). It is
Commerce’s preference to use a “primary” surrogate coun-
try as the reference point when there are several countries
that are at a level of economic development comparable to
the nonmarket economy country and that are significant
producers of comparable merchandise. Jiaxing Bro. Fas-
tener Co., Ltd. v. United States, 822 F.3d 1289, 1294 (Fed.
Cir. 2016) (citing 19 C.F.R. § 351.408(c)(2)).
To select a primary surrogate country, Commerce has
adopted a four-step approach. See Import Admin., U.S.
Dep’t of Commerce, Non-Market Economy Surrogate Coun-
try Selection Process, Policy Bulletin 04.1 (2004), http://en-
forcement.trade.gov/policy/bull04-1.html (“Policy Bulletin”
or “Bulletin”). Relevant to this case, the Policy Bulletin
provides that when there is not “adequate data available
from major producing countries, . . . ‘significant producer’
could mean a country that is a net exporter, even though
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 5
the selected surrogate country may not be one of the
world’s top producers.” Id. The Policy Bulletin defines “net
exporter” as “a country whose exports exceed its imports.”
Id. at n.1.
This case presents the issues of whether, in AR13,
Commerce properly determined (1) surrogate financial ra-
tios; (2) surrogate values for certain factors of production;
and (3) the surrogate value of ocean freight expenses.
II
Since, as noted, China is a non-market economy coun-
try, in AR13 Commerce was required to select surrogate
values from a surrogate country. In accordance with the
Policy Bulletin, Commerce’s Office of Policy (“OP”) com-
piled a list of potential surrogate countries that were at a
comparable level of economic development to China. OP
identified six potential surrogate countries: Brazil, Malay-
sia, Mexico, Romania, Russia, and Turkey. Carbon Acti-
vated, 650 F. Supp. 3d at 1360. In the Final Results,
Commerce selected Malaysia as the primary surrogate
country. Id. It did so after determining that Malaysia was
the only country on the OP list that was a significant pro-
ducer of comparable merchandise because it was the only
“net exporter” of such merchandise. Id. at 1362.
Having selected Malaysia as the surrogate country,
Commerce turned to the matter of surrogate financial
rates. The relevance of this item is that, once Commerce
identifies surrogate values for factors of production, “an
amount for general expenses and profit plus the cost of con-
tainers, coverings, and other expenses” is added to calcu-
late normal value. 19 U.S.C. § 1677b(c)(1)(B); see also
Dorbest Ltd. v. United States, 604 F.3d 1363, 1368 (Fed.
Cir. 2010). Commerce values expenses “by using financial
ratios derived from financial statements of producers of
comparable merchandise in the surrogate country.” Ad
Hoc Shrimp Trade Action Comm. v. United States, 618 F.3d
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 6
1316, 1319–20 (Fed. Cir. 2010) (citing Dorbest, 604 F.3d at
1368).
Commerce had before it the financial statements of
four companies. Two financial statements were from Ma-
laysian producers of activated carbon, Century Chemical
Works Sdn. Bhd. (“Century”) and Bravo Green Sdn. Bhd.
(“Bravo Green”). Carbon Activated, 650 F. Supp. 3d at
1362. The record also contained financial statements from
S.C. Romcarbon S.A. (“Romcarbon”), a Romanian producer
of polyethylene, polypropylene, polyvinyl chloride, polysty-
rene processing, filters, and protective materials, and fi-
nancial statements from Joint Stock Company Sorbent
(“JSC Sorbent”), a Russian producer of respiratory protec-
tion products and activated carbon. Id.
In the Final Results, Commerce determined that the
Century and Bravo Green financial statements were the
best available information for the purpose of calculating
surrogate financial ratios. First, Commerce determined
that, while Century and Bravo Green’s principal business
activity was the manufacture and sale of activated carbon,
Romcarbon’s financial statements indicated that its princi-
pal business activity was unrelated to the manufacture or
sale of activated carbon, while it was difficult to ascertain
what portion of JSC Sorbent’s portfolio related to the pro-
duction of activated carbon and what portion related to
other business activities. Carbon Activated, 650 F. Supp.
3d at 1362. Finally, Commerce explained that, having
found Malaysia to be the primary surrogate country, Cen-
tury and Bravo Green’s financial statements were prefera-
ble because of Commerce’s preference for valuing all factors
of production in one surrogate country, and Malaysia was
the only country that provided multiple usable financial
statements. Id.
Next, Commerce valued four factors of production used
by Carbon Activated in producing activated carbon: coal-
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 7
based carbonized material; coal tar; hydrochloric acid; and
steam.
For the Final Results, Commerce valued coal-based
carbonized material using Malaysian data under Harmo-
nized Tariff Schedule (“HTS”) 4402.90.1000, which covers
“coconut shell charcoal.” Carbon Activated, 650 F. Supp. 3d
at 1365. To value coal tar, Commerce used Malaysian data
under HTS subheading 2706.00, which covers “Mineral
Tars, Including Reconstituted Tars.” Id. at 1367. To arrive
at a value for hydrochloric acid, Commerce turned to Ma-
laysian data for HTS 2806.10, which covers “hydrogen chlo-
ride (hydrochloric acid).” Id. at 1369. Finally, Commerce
valued steam using Malaysian data for HTS 2711.11,
which covers liquified natural gas. Id. at 1371.
The final matter relevant to this appeal is valuation of
the expense of ocean freight. The administrative record
contained two sets of data, one from the Danish shipping
company Maersk and the other from Descartes Systems
Group Inc. (“Descartes”). In the Final Results, Commerce
selected the Maersk data. Carbon Activated, 650 F. Supp.
3d at 1372. As noted, the Trade Court sustained the Final
Results, and this appeal followed.
III
We review decisions of the Trade Court concerning
Commerce’s antidumping determinations by applying the
same standard of review used by the Trade Court. Yang-
zhou Bestpak Gifts & Crafts Co., Ltd. v. United States, 716
F.3d 1370, 1377 (Fed. Cir. 2013). “Commerce’s determina-
tion will be sustained unless it is ‘unsupported by substan-
tial evidence on the record, or otherwise not in accordance
with law.’” Id. (quoting 19 U.S.C. § 1516a(b)(1)(B)(i)). Sub-
stantial evidence is “such relevant evidence as a reasonable
mind might accept as adequate to support a conclusion.”
Consol. Edison Co. v. N.L.R.B., 305 U.S. 197, 229 (1938).
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 8
IV
On appeal Carbon Activated challenges each of the de-
terminations noted above. We address its contentions in
turn.
A. Surrogate Financial Ratios
Carbon Activated begins by challenging Commerce’s
selection of Malaysia as the primary surrogate country. It
argues that Commerce erred because, in selecting Malay-
sia, it relied solely on the “net exporter” criterion in the Pol-
icy Bulletin. According to Carbon Activated, by following
this erroneous approach, Commerce “shielded itself from
having to consider the on-record (and superior) financial
statements of Romanian producer Romcarbon.” Appel-
lants’ Br. 13–14. Carbon Activated urges that Commerce
thus ran afoul of the requirement of both the Policy Bulle-
tin and 19 U.S.C. § 1677b(c)(1)(B) that the selection of a
surrogate country be based upon the “best available infor-
mation.” Id. at 14–15. Carbon Activated thus argues that
Commerce erred in not considering Romcarbon’s financial
statements when it made its surrogate country selection of
Malaysia over Romania. Appellants’ Br. 15–16.
We do not agree. We have recognized Commerce’s re-
liance on the Policy Bulletin, Jiaxing, 822 F.3d at 1294 n.3,
and Carbon Activated does not challenge that reliance. In
accordance with the Policy Bulletin, Commerce determined
that Malaysia was a net exporter of activated carbon be-
cause it exported more of the product than it imported.
App. 7919–20 & nn. 217, 221. That determination is sup-
ported by substantial evidence. In addition, Commerce’s
significant-producer determination was supported by the
financial statements on the record. Commerce found that
only the Malaysian financial statements provided evidence
of significant production of activated carbon in terms of
both quantity and value. App. 7920 & n.222 (citing App.
3708–90). We see no error in Commerce’s reliance on the
net exporter criterion of the Policy Bulletin.
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 9
Carbon Activated also challenges Commerce’s reliance
on the financial statements of Century and Bravo Green.
Carbon Activated argues that the Century and Bravo
Green financial statements, which did not disaggregate the
costs of labor, raw materials, and energy, were less reliable
than those of Romcarbon and JSC Sorbent. Appellants’ Br.
26–31. Commerce acknowledged that the Century and
Bravo Green financial statements were “not as detailed” as
it preferred. App. 7921. It explained, however, that the
financial statements still “provide[d] sufficient information
to calculate surrogate ratios for factory overhead costs,
[selling, general, and administrative] expenses, and profit.”
Id. Moreover, as noted above, Commerce analyzed the con-
tents of both Romcarbon’s and JSC Sorbent’s statements
and found that the principal activities of both companies
were dissimilar to the production of activated carbon, un-
like the Malaysian producers. App. 7920. “Commerce has
broad discretion to determine what constitutes the best
available information, as this term is not defined by stat-
ute.” Qingdao Sea-Line Trading Co., Ltd. v. United States,
766 F.3d 1378, 1386 (Fed. Cir. 2014). The test “is not
whether the information Commerce used was the best
available, but rather whether a reasonable mind could con-
clude that Commerce chose the best available information.”
Jiaxing, 822 F.3d at 1300–01; see also Downhole Pipe &
Equip., L.P. v. United States, 776 F.3d 1369, 1379 (Fed. Cir.
2015). Under this standard, based upon the evidence it had
before it, we see no error in Commerce’s selection of the fi-
nancial statements of Century and Bravo Green over those
of Romcarbon and JSC Sorbent. Thus, the Trade Court did
not err in sustaining Commerce’s selection of surrogate fi-
nancial ratios. We consider next Carbon Activated’s argu-
ments with respect to the four factors of production noted
above.
B. Valuation of Carbonized Material
Carbon Activated argues that Commerce’s decision to
value carbonized material using Malaysian import data for
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 10
coconut shell charcoal classified under HTS subheading
4402.90.1000 was not supported by substantial evidence.
Specifically, it claims that the data that Commerce selected
was not contemporaneous with the period of review and
that it was not an appropriate basis for valuing the coal-
based carbonized material that Carbon Activated asserts it
actually used. Appellants’ Br. 34–43.
Relevant to the first point, in valuing carbonized mate-
rial, Commerce used data from the immediately preceding
twelfth administrative review, that it adjusted for infla-
tion, to determine the value that it used in AR13. App.
7927; App. 6914. Carbon Activated argues that this ap-
proach was contrary to the Policy Bulletin, which states, in
relevant part, that “it is the Department’s stated practice
to use . . . prices that are contemporaneous with the period
of . . . review.” We see no error in this case, however, in
Commerce’s use of adjusted data from the twelfth admin-
istrative review. Whether surrogate values are contempo-
raneous with the period of review is one of the factors that
Commerce considers when selecting the best available in-
formation, but it is not a dispositive factor and, thus, Com-
merce has discretion to select non-contemporaneous data.
See Qingdao, 766 F.3d at 1386. Commerce properly exer-
cised that discretion here. Commerce explained that, while
the data it selected was non-contemporaneous with the pe-
riod of review in AR13, it “favor[ed] specificity over contem-
poraneity” in the review based on its finding that HTS
4402.90.1000 was the most appropriate proxy to value the
carbonized material used by Carbon Activated. App. 7927;
see also Carbon Activated, 650 F. Supp. 3d at 1366.
Carbon Activated’s second argument with respect to
the valuation of carbonized material is that the surrogate
value for carbonized material upon which Commerce relied
is deficient because coconut shell charcoal is distinct from
Carbon Activated’s coal-based carbonized material and is
dissimilar to surrogate information concerning wood-based
charcoal used by Commerce in prior reviews. Appellants’
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 11
Br. 36–43. We agree with the Trade Court’s rejection of
Carbon Activated’s argument on this point. The court de-
termined that Commerce provided “a reasoned explanation
as to why coconut shell charcoal was a more appropriate
proxy for the coal-based carbonized material used by [Car-
bon Activated] than wood charcoal.” Carbon Activated, 650
F. Supp. 3d at 1366 (citing App. 7925–26). As the court
explained:
First, the record indicates that “both coconut shell-
and coal-based carbonized material are steam acti-
vated[,] whereas wood-based carbonized material
is generally chemically activated,” impacting “the
ultimate physical structure of the carbonized ma-
terial.” Second, the record showed that coconut
shell- and coal-based carbonized materials had a
different level of filtration than wood-based acti-
vated carbon.
Id. (internal citations omitted) (quoting App. 7925).
C. Valuation of Coal Tar
As noted, in the Final Results, Commerce valued coal
tar using Malaysian HTS subheading 2706.00 import data.
This subheading covers “Mineral Tars, Including Reconsti-
tuted Tars.” Carbon Activated, 650 F. Supp. 3d at 1367; see
App. 7913. Carbon Activated makes two main arguments
as to why Commerce’s determination is not supported by
substantial evidence. It first argues that the surrogate in-
formation relied on by Commerce is distorted because the
Malaysian values for merchandise classified under HTS
subheading 2706.00 are higher than those classified under
HTS subheading 2708.10 for “pitch,” a downstream prod-
uct that should therefore reflect higher values than coal
tar. Appellants’ Br. 44–45. The Trade Court rejected this
argument because Carbon Activated “did not provide evi-
dence to support [its] inference that the higher value-added
product necessarily should be priced higher on the same
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 12
per weight basis.” 650 F. Supp. 3d at 1368. We see no error
in this ruling.
Carbon Activated’s second main argument on this
point is that Malaysian coal tar import data is unreliable
due to the “[s]tark disparities . . . between the domestic
market and Malaysian import prices for both Malaysia and
Spain.” Appellants’ Br. 45; see also id. at 44–46. The Trade
Court rejected this argument on the ground that Carbon
Activated “failed to provide evidentiary support for [its] as-
sertion that the Spanish data [was] aberrant.” Carbon Ac-
tivated, 650 F. Supp. 3d at 1368. Again, we see no error in
this ruling.
D. Valuation of Hydrochloric Acid
Commerce valued hydrochloric acid under Malaysian
import data for HTS 2806.10, which covers “hydrogen chlo-
ride (hydrochloric acid).” Carbon Activated, 650 F. Supp.
3d at 1369. This is a basket category that covers both an-
hydrous hydrogen chloride (without added water) and
aqueous hydrochloric acid (with added water). Id.
Carbon Activated argues that, because the subheading
2806.10 covers both forms of hydrochloric acid, the Malay-
sian import data Commerce used to value hydrochloric acid
is not specific to the diluted aqueous hydrochloric acid it
uses. Appellants’ Br. 48–50. Instead, Carbon Activated as-
serts, Commerce should have relied on Brazilian import
data for merchandise classified under HTS subheading
2806.10.20 for aqueous hydrochloric acid. Id. at 50–52.
We are not persuaded by either argument. Before the
Trade Court, Commerce argued, and the court agreed, that
Carbon Activated failed to demonstrate with substantial
evidence the aqueous nature of all of its hydrochloric acid
inputs. Carbon Activated, 650 F. Supp. 3d at 1370–71. We
see no reason to disturb that finding and thus see no merit
in Carbon Activated’s arguments that Commerce should
have used a more specific subheading or more specific data.
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 13
E. Valuation of Steam
Carbon Activated next argues that Commerce improp-
erly valued steam by relying on the Malaysian import
value for liquified natural gas, classified under HTS sub-
heading 2711.11, because it “is not specific to steam.” Ap-
pellants’ Br. 52–53. It argues that, instead, Commerce
should have relied on the value of merchandise classified
under HTS subheading 2711.21, the provision that covers
natural gas in a gaseous state. Id. at 55.
Before the Trade Court, Commerce argued that Malay-
sian import data for liquified natural gas was the best
available information in the record to value steam because
this data was publicly available and from the primary sur-
rogate country. Carbon Activated responded to this argu-
ment by contending that Commerce failed to explain how
the use of liquified natural gas explained the costs incurred
by Carbon Activated when Carbon Activated did not use a
liquid to produce steam, but rather natural gas in a gase-
ous state. Carbon Activated, 650 F. Supp. 3d at 1371–72.
Carbon Activated also contended that domestic gaseous
natural gas prices in Malaysia during the period of review
were significantly lower than the import data used to value
its steam. Id.
In sustaining Commerce’s decision, the Trade Court
noted that, in the twelfth administrative review, it had re-
jected the argument that Commerce may not select liqui-
fied natural gas as a surrogate because it is not specific to
steam, noting that “the energy source input need not be in
the same phase (solid, liquid, gaseous) as the steam the en-
ergy creates.” Id. at 1372 (quoting Carbon Activated Tian-
jin Co. v. United States, 586 F. Supp. 3d 1360, 1377 (Ct.
Int’l Trade 2022)). In addition, the court noted that Com-
merce had explained that the domestic natural gas prices
identified by Carbon Activated were unreliable and did not
represent the best available information. Id. On appeal,
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 14
Carbon Activated has failed to demonstrate any error in
the Trade Court’s reasoning on this point.
F. Valuation of Ocean Freight
The final issue before us is Commerce’s valuation of
ocean freight. As noted, Commerce valued ocean freight on
the basis of Maersk freight data rather than Descartes
data. Carbon Activated, 650 F. Supp. 3d at 1372. Com-
merce determined that the data from Maersk represented
the best available information to value freight expenses be-
cause that data represented freight tariffs covering the en-
tire period of review and various routings. App. 7929. The
Trade Court sustained Commerce’s determination. It con-
cluded that Commerce’s decision was supported by sub-
stantial evidence. First, it found that Carbon Activated
had not provided any evidence undermining Commerce’s
determination that the Maersk data represented actual
tariff rates and not approximations. Carbon Activated, 650
F. Supp. 3d at 1373. And second, it concluded that, even if
the flaws in the Maersk data alleged by Carbon Activated
existed, Carbon Activated had failed to show that the Des-
cartes data was the best available information with which
to value ocean freight. Significantly, the court stated that
Carbon Activated had not provided “any evidence to sup-
port its contention that the Descartes data represents ac-
tual transactions.” Id. We have considered all of the
arguments made by Carbon Activated on this point. None
of them has convinced us that the Trade Court erred in con-
cluding that Commerce’s decision with respect to freight
charges was supported by substantial evidence and was
free of legal error.
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CARBON ACTIVATED TIANJIN CO., LTD. v. US 15
CONCLUSION
For the foregoing reasons, we affirm the decision of the
Trade Court sustaining Commerce’s Final Results in
AR13.3
AFFIRMED
3 We have considered the additional arguments
raised by Carbon Activated with respect to each issue dis-
cussed above and have found them to be unpersuasive.
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