Pursuant to subsection 31(1) of the Special Import Measures Act, the President of the Canada Border Services Agency initiated investigations on June 13, 2014, respecting the alleged injurious dumping and subsidizing of hot-rolled deformed steel concrete reinforcing bar in straight lengths or coils, commonly identified as rebar, in various diameters up to and including 56.4 millimeters, in various finishes, excluding plain round bar and fabricated rebar products, originating in or exported from the People’s Republic of China, the Republic of Korea and the Republic of Turkey.
 On April 24, 2014, the Canada Border Services Agency (CBSA) received a written complaint from ArcelorMittal LCNA (Arcelor), located in Contrecoeur, Quebec, Gerdau Longsteel North America (Gerdau), located in Whitby, Ontario and Alta Steel Inc. (Alta), located in Edmonton, Alberta, (hereafter ‘the Complainants’), alleging that imports into Canada of certain concrete reinforcing bar originating in or exported from the People’s Republic of China (China), the Republic of Korea and the Republic of Turkey (Turkey) are being dumped and subsidized. The Complainants allege that the dumping and subsidizing have caused injury and are threatening to cause injury to the Canadian industry producing like goods.
 The Complainants provided evidence to support the allegations that certain concrete reinforcing bar from China, the Republic of Korea and Turkey have been dumped and subsidized. The evidence also discloses a reasonable indication that the dumping and subsidizing have caused injury and are threatening to cause injury to the Canadian industry producing like goods.
 On May 15, 2014, pursuant to paragraph 32(1)(a) of the Special Import Measures Act (SIMA), the CBSA informed the Complainants that the complaint was properly documented. The CBSA also notified the governments of China (GOC), the Republic of Korea (GOK) and Turkey (GOT) that a properly documented complaint had been received and provided each of them with the relevant non-confidential version of the subsidy complaint. The GOC, GOK, and GOT were invited for consultations prior to the initiation of the investigations, pursuant to Article 13.1 of the Agreement on Subsidies and Countervailing Measures (ASCM).
 On June 5, 2014 the government of Canada received written representations from the GOK with respect to its views on the adequacy of the evidence presented in the non-confidential version of the subsidy portion of the complaint. On June 11, 2014, consultations pursuant to Article 13.1 of the ASCM were held between the government of Canada and the GOK. During these consultations, the GOK reiterated the written representations with respect to its views on the adequacy of the evidence presented in the non-confidential version of the subsidy complaint. The CBSA considered these written representations in its analysis of whether there was sufficient evidence of subsidization to warrant the initiation of a subsidy investigation.
 On June 11, 2014, consultations pursuant Article 13.1 of the ASCM were held between the government of Canada and the GOT. On the same day, the government of Canada received written representations from the GOT with respect to its views on the accuracy and adequacy of the evidence presented in the non-confidential version of the subsidy complaint. The CBSA considered these written representations in its analysis of whether there was sufficient evidence of subsidization to warrant the initiation of a subsidy investigation.
 The Complainants are the only Canadian producers of like goods in Canada.
 The company now known as Alta was founded in 1955. It has undergone various ownership changes and is now owned by Arrium Limited (previously known as OneSteel Limited).
 Alta is a scrap-based mini-mill with melting and casting manufacturing facilities in Edmonton, Alberta. The company employs over 370 people. Alta makes a variety of round, flat, and square bar shapes for use by downstream manufacturers in the mining, oil and gas, automotive, construction, agriculture and OEM industries.
 Arcelor is a subsidiary of ArcelorMittal and has eleven steel manufacturing facilities in Canada and the US. Arcelor produces over 5 million metric tons (MT) per year and has 3,400 employees. It produces a range of products including rebar, billets, flats, and wire rod. These facilities produce billets and slabs as primary products. For value added products, the company’s Montreal facility produces rebar, wire rod and downstream wire products, flat bar and round bar, and other products.
 Arcelor has three rebar manufacturing facilities in Quebec, the Contrecoeur East facility produces rebar in coil form while the Contrecoeur West and the Longueuil facilities produce cut-to-length rebar.
 The parent company of Gerdau is Gerdau S.A of Brazil. Gerdau entered the North American market in 1989 with the acquisition of Courtice Steel in Cambridge, Ontario. In 1995, Gerdau acquired MRM Steel in Selkirk Manitoba. In 2002, Gerdau merged its North American operations with Co-Steel of Whitby, Ontario, and the combined entity became Gerdau Ameristeel Corporation. Gerdau acquired 100% ownership of Gerdau Ameristeel in 2010. Gerdau now operates these three Canadian plants, as well as six American plants producing rebar, as Gerdau Longsteel North America, a division of Gerdau Ameristeel.
 Gerdau has manufacturing facilities in Whitby and Cambridge, Ontario and in Selkirk, Manitoba. Gerdau’s three Canadian rebar-producing operations are capable of producing the full range of sizes and grades of rebar. The Whitby plant has produced straight rebar since 1964, as well as other bars and structural shapes. The Cambridge plant has produced rebar since 1986. It also produces rounds, squares, channels and angles. Gerdau MRM in Selkirk has produced rebar for over 75 years.
 The CBSA has identified 32 potential importers of the subject goods from CBSA import documentation and from information submitted in the complaint.
 The CBSA has identified 137 potential exporters (90 located in China, 13 in the Republic of Korea and 34 in Turkey) of the subject goods from CBSA import documentation and from information submitted in the complaint.
 For the purpose of these investigations, "GOC”, "GOK” or "GOT” each refers to all levels of government, i.e., federal, central, provincial/state, regional, municipal, city, township, village, local, legislative, administrative or judicial, singular, collective, elected or appointed. It also includes any person, agency, enterprise, or institution acting for, on behalf of, or under the authority of, or under the authority of any law passed by, the government of that country or that provincial, state or municipal or other local or regional government.
Hot-rolled deformed steel concrete reinforcing bar in straight lengths or coils, commonly identified as rebar, in various diameters up to and including 56.4 millimeters, in various finishes, excluding plain round bar and fabricated rebar products, originating in or exported from the People’s Republic of China, the Republic of Korea and the Republic of Turkey.
 Hot-rolled deformed steel concrete reinforcing bar in straight lengths or coils, commonly identified as rebar, in various diameters up to and including 56.4 millimeters, in various finishes, excluding plain round bar and fabricated rebar products, will hereafter be referred to as Rebar.
 The following are the most common bar designation numbers for the Subject goods in Canada, with the corresponding diameter in millimetres in brackets: 10 (11.3), 15 (16.0), 20 (19.5), 25(25.2), 30(29.9), 35 (35.7). Rebar sizes are commonly referred to as the bar designation number combined with the letter "M”. Thus, 10M Rebar has a designation number of 10 and a diameter of 11.3 millimetres. Other diameters may also be demanded, and other measurement systems employed. For example, Imperial measure #7 bar (approximately 22 mm) is a common designation used in the mine roofing industry.
 Subsection 2(1) of SIMA defines "like goods” in relation to any other goods, as goods that are identical in all respects to the other goods, or in the absence of identical goods, goods the uses and other characteristics of which closely resemble those of the other goods.
 Rebar produced by the domestic industry competes directly with, has the same end uses as, and can be substituted for, the subject goods. Also, both are made from the same input material and are produced in the same general manner. Therefore, the CBSA has concluded that the Rebar produced by the Canadian industry constitutes like goods to the subject goods.
 The Complainants represent all production of like goods in Canada.
 Since the Complainants are the only producers of Rebar in Canada, the CBSA is satisfied that the standing requirements pursuant to subsection 31(2) of SIMA have been met.
 According to the Complainants, subject goods and domestic like goods are distributed through the same channels and the conditions of competition apply to all Rebar whether produced in the subject countries or by the domestic industry, or from any other import source.
 The domestic industry markets its Rebar to customers across Canada. Rebar may be sold directly to Rebar fabricators, or steel service centres/distributors. Rebar fabricators are the major link in the supply chain. They quote jobs to the construction sector, buy the steel, cut and bend to order and deliver to job sites.
 The Complainants estimate that approximately 90% of market sales go directly to Rebar fabricators. Service centres/distributors purchase Rebar in a range of grades and sizes and stock the product for re-sale, primarily to smaller Rebar fabricators. Canadian distributors and Rebar fabricators may purchase domestically from the Canadian mills, from imports or from other distributors located in Canada or abroad. Service centres/distributors and Rebar fabricators may also import directly from mills in the named countries.
 The Complainants estimated the market based on their domestic sales, publicly available information and import data obtained from Statistics Canada for 2011 to February 2014. The Department of Foreign Affairs, Trade and Development (DFATD) import permit data was used to estimate March 2014 figures.
 The CBSA conducted its own analysis of imports of Rebar based on actual import data.
 The CBSA’s import data demonstrated similar trends and volumes as the information provided by the Complainants.
 The Complainants alleged that subject goods from China, the Republic of Korea and Turkey have been injuriously dumped into Canada. Dumping occurs when the normal value of the goods exceeds the export price to importers in Canada.
 The Complainants provided information to support the allegation that the concrete reinforcing bar industry, which is part of the long products steel sector in China may not be operating under competitive market conditions and as such, normal values should be determined under section 20 of SIMA.
 The CBSA’s analysis of the alleged dumping is based on a comparison of the Complainants’ estimated normal values with estimated export prices based on the actual declared value for duty during the period examined, that is, between January 1, 2013 and March 31, 2014. The export price information was obtained from customs entry documentation. The CBSA found that a three month lead time was reasonable for purposes of comparing available market pricing with imports into Canada and so used this approach as well when analyzing the data.
 Estimates of normal value and export price by both the Complainants and the CBSA are explained as follows.
 The Complainants had limited information on the actual selling prices of the like goods to unrelated purchasers in each of the named countries. The Complainants have calculated normal values and dumping margins in accordance with section 15 of SIMA where possible, based on the domestic selling price of like goods in the country of export.
 For purposes of these section 15 estimates, the Complainants conducted a survey of available information pertaining to home market pricing in the Republic of Korea and Turkey. They were able to obtain home market pricing for the Republic of Korea from Metal Bulletin and for Turkey from Steel Business Briefing (SBB). The dumping calculations compare the offer/selling price in Canada from Statistics Canada import data which reflects the value for duty to the home market price reported in Metal Bulletin and SBB.
 The CBSA found the Complainants’ overall section 15 normal value estimates to be reasonable and representative. For increased accuracy, the CBSA re-calculated the weighted average normal values on an entry-by-entry basis as opposed to the monthly average used by the Complainants. This approach proved to be slightly more conservative than the straight average used by the Complainants.
 The Complainants also estimated normal values for the subject goods using the methodology set out in paragraph 19(b) of SIMA. Under this methodology, normal values are determined as the aggregate of the cost of production of the goods, a reasonable amount for administrative, selling and all other costs, and a reasonable amount for profits.
 Using their own costs of production as a starting point the Complainants made certain adjustments to take into account differences in labour costs and substituted a reasonable amount for profit suitable for those markets based on publicly available information.
 Due to the significant number of products within the subject goods definition, the Complainants selected representative high-volume models to act as benchmarks. Normal values were constructed for these benchmark models.
 The Complainants provided information supporting the initiation of a section 20 inquiry respecting the allegedly dumped goods from China and are of the opinion that domestic selling prices in China are substantially influenced by government policies and should not be used in the calculation of normal values since the prices are not reflective of competitive market conditions. The Complainants argued that normal values in China should be determined based on information from producers in a surrogate country, and went on to identify both Turkey and the Republic of Korea as suitable surrogates.
 For China, the Complainants estimated an amount for profit at 11.0% of costs based on 2013 results of SMIC, a large Chinese manufacturing company operating a semiconductor foundry traded on the New York Stock Exchange. The Complainants submit that this amount for profit is appropriate as it reflects recent, publicly available information of a large Chinese industrial concern that is not subject to the same degree of Chinese government control of operations. The Complainants submit that this profit amount is being used only for the alternative section 19 estimate of Chinese normal values since they maintain that section 20 ought to be applied for China.
 For the Republic of Korea, the amount for profit was estimated based upon the publicly reported 7.5% profit amount as a percentage of costs, sourced from a large Korean steel producer POSCO for 2013. POSCO produces subject goods.
 For Turkey, the amount for profit was estimated based upon the publicly reported 14.6% as a percentage of costs of the large steel producing company named Erdemir group from Turkey for 2013. Erdemir is a large integrated steel manufacturer from Turkey that produces a range of steel products including subject goods.
 The CBSA considers the amounts for profit to be reasonable for purposes of initiation and accepts the amounts of profit estimated by the Complainants.
 The CBSA found the Complainants’ overall section 19 normal value estimates to be reasonable and representative. In terms of adjustments to the section 19 normal values, the CBSA concluded that using an average of the three benchmark models in Attachment 19 of the complaint was more appropriate as opposed to the way the Complainants separated the normal values based on the three benchmark models since the export price that these normal values will ultimately be compared to in order to calculate margins of dumping will also be an average.
 The Complainants estimated export prices based on Statistics Canada import data for HS classification numbers 7213.10 and 7214.20 for 2013 and January-February 2014 data as well as the DFATD import permit data for Rebar for March 2014, the most recent period available.
 The CBSA estimated export prices based on actual import data for the period January 1, 2013 to March 31, 2014. Customs documentation for the selected entries not yet received will be reviewed in respect of subjectivity and products for the purposes of the preliminary determination. Since this analysis was based on actual import data, the CBSA considers its estimates to be more comprehensive and accurate than those provided by the Complainants.
 For purposes of initiation, the CBSA used its more conservative section 15 estimates of margins of dumping for both Turkey and the Republic of Korea.
 It should be noted that section 16 of SIMA requires that sales used for the purpose of normal value determination under section 15 be profitable. The Complainants allege that goods in the named countries are benefiting from significant countervailable subsidies. They allege that selling prices in the country of export are lower than could be the case in the absence of the subsidies and may not be profitable. Estimates of normal values based on market pricing may therefore be understated.
 For purposes of initiation, the CBSA estimated margins of dumping for China using an average of domestic pricing in Turkey and the Republic of Korea as surrogate countries pursuant to the methodology of section 20 of SIMA.
 Based on the preliminary analysis, it is estimated that the subject goods from China, the Republic of Korea and Turkey were dumped. The margins of dumping estimated for each subject country are shown in the following table.
 On the basis of the estimated margins of dumping and the estimated volumes of dumped imports for the period of January 1, 2013 to March 31, 2014, summarized in the following table, the estimated margins of dumping and the estimated volumes of dumped goods are greater than the thresholds outlined above.
 The Complainants allege that the conditions described in section 20 prevail in the concrete reinforcing bar industry, which is part of the long products steel sector, in China. That is, the Complainants allege that this industry in China does not operate under competitive market conditions and consequently, prices established in the Chinese domestic market for Rebar are not reliable for determining normal values.
 The CBSA recognizes that governments can both directly and indirectly determine domestic prices through a variety of mechanisms. These can include influencing the supply or price of the inputs used in the production of subject goods or manipulating the supply or price of the goods themselves. In this regard, the Complainants presented evidence that the GOC strongly influences the supply and price of steel billet, the major input of the subject goods.
 The Complainants provided a variety of evidence supporting its claim that the GOC substantially determines domestic prices of Rebar, such as evidence of state-ownership. The Complainants also cited specific GOC policies such as the 12th Five-Year Plan: Iron and Steel (Development Plan for the Steel Industry).
 The information currently available to the CBSA indicates that there are numerous GOC industrial policies and measures including import and export restrictions and subsidization that have been implemented which influence the long products steel sector, which includes the Rebar industry, in China.
 With respect to the long products steel sector, the CBSA has information which demonstrates that the prices of steel may be significantly affected by the GOC’s policies and that prices of Rebar in China may not be substantially the same as they would be if they were determined in a competitive market.
 Consequently, on June 13, 2014, the CBSA initiated a section 20 inquiry based on the information available in order to determine whether the conditions set forth in paragraph 20(1)(a) of SIMA prevail in the concrete reinforcing bar industry, which is part of the long products steel sector, in China. A section 20 inquiry refers to the process whereby the CBSA collects information from various sources so that the President may, on the basis of this information, form an opinion regarding the presence of the conditions described under section 20 of SIMA, in the sector under investigation.
 As part of this section 20 inquiry, the CBSA sent section 20 questionnaires to all potential Rebar producers and exporters in China, as well as to the GOC requesting detailed information related to the concrete reinforcing bar industry, which is part of the long products steel sector, in China. To enable the determination of normal values should paragraph 20(1)(a) be applicable, the CBSA requested domestic pricing and costing information from 23 producers of Rebar in the Kingdom of Thailand (Thailand) and Chinese Taipei. These countries were selected as their growing economies and well-developed steel industries are comparable to the situation in China.
 Information from these parties was requested on a courtesy basis as there was no requirement for compliance. The CBSA also requested information from Canadian importers of Rebar regarding their sales from other countries.
 In the event that the President forms the opinion that domestic prices of Rebar in China are substantially determined by the GOC and there is sufficient reason to believe that the domestic prices are not substantially the same as they would be if they were determined in a competitive market, the normal values of the goods under investigation from China will be determined, pursuant to paragraph 20(1)(c), where such information is available, on the basis of the domestic selling price or full cost plus a reasonable amount for profits of the like goods sold by producers in any country designated by the President and adjusted for price comparability; or on the basis of the selling price in Canada of like goods imported from any country designated by the President and adjusted for price comparability, pursuant to paragraph 20(1)(d).
 A state-owned enterprise (SOE) may be considered to constitute "government” for the purposes of subsection 2(1.6) of SIMA if it possesses, exercises, or is vested with, governmental authority. Without limiting the generality of the foregoing, the CBSA may consider the following factors as indicative of whether the SOE meets this standard: 1) the SOE is granted or vested with authority by statute; 2) the SOE is performing a government function; 3) the SOE is meaningfully controlled by the government; or some combination thereof.
 If a subsidy is found to exist, it may be subject to countervailing measures if it is specific. A subsidy is considered to be specific when it is limited, in law or in fact, to a particular enterprise or is a prohibited subsidy. An "enterprise” is defined under SIMA as also including a "group of enterprises, an industry and a group of industries”. Any subsidy which is contingent, in whole or in part, on export performance or on the use of goods that are produced or that originate in the country of export is considered to be a prohibited subsidy and is, therefore, specific according to subsection 2(7.2) of SIMA for the purposes of a subsidy investigation.
 For purposes of a subsidy investigation, the CBSA refers to a subsidy that has been found to be specific as an "actionable subsidy”, meaning that it is countervailable.
 The Complainants alleged that the exporters of the subject goods originating in China, the Republic of Korea and Turkey have benefited from actionable subsidies provided by various levels of government, which may include the governments of the respective provinces in which the exporters are located, and the governments of the respective municipalities in which the exporters are located.
 The Complainants identified 224 subsidy programs and allege that all of these programs have conferred benefits to the Chinese producers of subject goods, which in turn have resulted in the countervailable subsidizing of Chinese exports of subject goods to Canada.
 Information from the CBSA’s previous subsidy investigations involving steel products in China as well as the material included in the complaint provide support for many of the Complainants’ allegations that the subject goods have been subsidized.
 The CBSA removed certain subsidy programs that were identified as duplicates, expired or those that were specific to a certain geographical location in which none of the potential manufacturers and/or exporters of the subject goods are located. The CBSA relied on its address list, which contains all potential manufacturers and/or exporters identified by the Complainants, as well as CBSA internal sources of information when performing this exercise.
 It should also be noted that the Complainants allege that large Chinese integrated steel mills producing Rebar fall directly within the scope of several previous CBSA subsidy investigations in respect of steel products. The Complainants are of the opinion the CBSA’s determination of subsidies in these other steel cases are directly applicable to producers of subject goods in these proceedings.
 As the GOC did not provide complete responses to the CBSA during recent subsidy investigations to permit a proper analysis, these programs require further investigation by the CBSA to confirm whether they are actionable and countervailable. Since other integrated steel mills have received benefit from these programs the CBSA has reason to believe that Rebar producers in China may have also benefited from these same programs.
 For those programs where incentives are provided to enterprises operating in SEZs or Other Designated Areas, the CBSA considers that these may constitute actionable subsidies for the reason that eligibility is limited to enterprises operating in such regions or is limited to certain enterprises operating within those regions.
 The CBSA will investigate whether exporters of subject goods received benefits under these 179 programs and whether such programs constitute actionable subsidies.
 The Complainants identified 30 subsidy programs and allege that all of these programs have conferred benefits to producers of subject goods in Korea, which in turn have resulted in the countervailable subsidizing of exports of subject goods from Korea to Canada.
 The Complainants relied on United States Department of Commerce (USDOC) subsidy rulings on several products from the Republic of Korea as their primary reference source. The USDOC has found 14 of the 30 alleged subsidy programs to be countervailable. The Complainants also relied on other publically available information such as public articles, as well as various Korean bank and government websites. A general description of the alleged subsidy programs was provided, and the documents that formed the basis for these allegations were included in the complaint.
 The CBSA analysis did not benefit from having access to a similar body of evidence that exists for the other two named countries, and in particular China. The CBSA analysed reference documents submitted by the Complainants that supported their allegations of countervailable subsidies, source documents supporting the Complainants’ calculations of estimated amounts of subsidy, subsidy investigations against the Republic of Korea in other countries and other publicly available information.
 At least some of the programs in all of the listed categories except for the National Excellence in Steel Products Strategy category, were determined to be countervailable subsidies by the USDOC in past subsidy proceedings.
 The Complainants identified potential subsidy programs in the National Excellence in Steel Products Strategy category because the programs were announced by the Korean Ministry of Knowledge Economy (now the Ministry of Trade, Industry Energy) in June 2011.
 The Complainants’ provided positive evidence pertaining to potential producers of subject goods having received benefits from three of the above programs. Given that these benefits are likely attributable to the subject goods, and due to the evidence provided by the complainants of the existence of the other programs, the CBSA will investigate whether exporters of subject goods received benefits under each of these 30 programs and whether such programs constitute actionable subsidies.
 Sufficient evidence is available to support the allegation that the subsidy programs outlined in Appendix 1 are available to exporters and producers of the subject goods in the Republic of Korea. In investigating these programs, the CBSA has requested information from the GOK, producers and exporters to determine whether exporters of subject goods received benefits under these programs and whether these programs are actionable subsidies and, therefore, countervailable under SIMA.
 The Complainants identified 57 subsidy programs and allege that all of these programs have conferred benefits to the producers of subject goods in Turkey, which in turn have resulted in the countervailable subsidizing of exports of subject goods from Turkey to Canada.
 The Complainants relied on information from previous and current USDOC subsidy investigations, Turkey’s 2012 World Trade Organization (WTO) subsidy notification, and other publicly available information, including the 2013 annual report of a large steel products producer in Turkey. A general description of the alleged subsidy programs was provided, and the documents that formed the basis for these allegations were included in the complaint.
 The CBSA removed certain subsidy programs where there was not sufficient evidence to suggest that Rebar producers would have access to them. If information is found during the course of the investigation that supports the existence of these programs and their use by Rebar producers or exporters in Turkey, the CBSA will request information from the exporters and the GOT as appropriate.
 Of the 57 alleged subsidy programs identified by the Complainants, 40 will be investigated by the CBSA, together with an additional three programs identified by the CBSA.
 Turkey’s 2012 WTO subsidy notification identifies six different forms of benefits available: exemption from customs duties, value-added tax exemptions, interest support measures, social security premium support, corporate or income tax reductions and land allocation. Evidence available to the CBSA indicates that Rebar producers in Turkey may be eligible to receive some of these benefits under the IEP category.
 At least some of the programs in each of the five remaining categories were identified as countervailable, or potentially countervailable subsidies by the USDOC in past and/or ongoing subsidy proceedings.
 Further, the Turk Eximbank is a state-owned bank acting as the GOT’s major export incentive instrument in Turkey’s sustainable export strategy. Turk Eximbank is mandated to support foreign trade and contractors/investors from Turkey operating overseas.
 The 17 programs identified by the Complainants that are not being investigated by the CBSA all fall under Turk Eximbank Programs and Other Programs.
 The CBSA will investigate whether exporters of subject goods received benefits under each of these 43 programs and whether such programs constitute actionable subsidies.
 Sufficient evidence is available to support the allegation that the subsidy programs outlined in Appendix 1 are available to exporters and producers of the subject goods in Turkey. In investigating these programs, the CBSA has requested information from the GOT, producers and exporters to determine whether exporters of subject goods received benefits under these programs and whether these programs are actionable subsidies and, therefore, countervailable under SIMA.
 The Complainants stated that they do not have access to publicly available information upon which to base an estimate of the amount of subsidy that may be conferred as a result of the various subsidy programs.
 For purposes of this initiation, the CBSA estimated the amount of subsidy conferred to exporters of the subject goods in the named countries by calculating the difference between their average 2013 cost of production, as estimated by the CBSA, and the selling prices reported in customs entry documents of subject goods sold to importers in Canada.
 In this regard, it is assumed that these costs of production reflect what the costs in the named countries would be if not distorted by government subsidies. It is further assumed that the export price of the subject goods to Canada is at least equal to the subsidized costs of the exporter. The difference between the export price of the goods, being the estimated subsidized cost of a given exporter and the average cost of production as estimated by the CBSA reflects the amount of subsidy embedded in the cost of the subject goods.
 The CBSA’s analysis of the information indicates that subject goods imported into Canada during the period of January 1, 2013 to March 31, 2014, were subsidized and the average amounts of subsidy applicable to subject goods are estimated to be 4.3% for China, 14.6% for the Republic of Korea and 18.7% for Turkey, expressed as a percentage of the export prices of the subject goods.
 SIMA does not define or provide any guidance regarding the determination of a "developing country” for purposes of Article 27.10 of the WTO Agreement on Subsidies and Countervailing Measures. As an administrative alternative, the CBSA refers to the Development Assistance Committee List of Official Development Assistance Recipients (DAC List of ODA Recipients) for guidance. As China and Turkey are both included in the listing, the CBSA extends developing country status to China and Turkey for purposes of this investigation.
 On the basis of the estimated amounts of subsidy and the estimated volumes of subsidized imports for the period of January 1, 2013 to March 31, 2014, summarized in the above table, the estimated amounts of subsidy and the estimated volumes of subsidized goods are greater than the thresholds outlined above.
 The Complainants alleged that the subject goods have been dumped and subsidized and that such dumping and subsidizing have caused or are threatening to cause material injury to the Rebar industry in Canada.
 SIMA refers to material injury caused to the domestic producers of like goods in Canada. The CBSA has accepted that Rebar produced by the Complainants are like goods to those imported from the named countries.
 In support of its allegations, the Complainants provided evidence related to: price undercutting, erosion and suppression; lost sales and market share; financial results; production, overcapacity and employment; and the impact on capital investments.
 The Complainants allege that dumped imports of subject goods have captured market share at the expense of the Canadian industry by aggressively undercutting their prices. Even with the expense of shipping Rebar long distances, Rebar from the named countries is still priced below the prices offered by the Canadian producers.
 The Complainants submitted evidence showing that the average selling prices from the named countries are substantially lower than those of the Complainants, and they are also substantially lower than those of other non-named countries. The subject goods are the price leaders in the Canadian market and undercut comparable domestic producer prices. Of note is the fact that the price gap has increased from 2011 through the first quarter of 2014.
 Not only do the average price figures show significantly lower prices for subject goods, but the customer specific evidence gathered by the Complainants also reflects substantial price undercutting by subject goods. The confidential import reports included in the complaint demonstrate, on a product-by-product basis, that subject goods are the price leaders in the Canadian market and substantially undercut comparable domestic producer pricing.
 The Complainants documented numerous specific instances where the prices of subject goods undercut its selling prices of like goods. The Complainants pointed out that this is of particular importance because Rebar is a commodity product and purchasing decisions are made primarily on the basis of price.
 The CBSA agrees that allegedly dumped and subsidized imports from named countries have forced the Complainants to not only keep their prices from rising as costs rose, but reduce their pricing during a time of increased cost pressures, all of which have caused the Complainants material injury.
 Based on the evidence, the CBSA finds that the Complainants’ claims of price undercutting, erosion and price suppression are well supported and sufficiently linked to imports of the allegedly dumped and subsidized goods.
 The Complainants explained that the recession that started at the end of 2008 had a significant impact on sales in 2009. Canadian demand began to improve in 2010, but while the Canadian market has grown since 2010, the domestic industry’s sales of Rebar from Canadian production have struggled to keep pace. As demonstrated by the confidential apparent Canadian market table, sales from domestic production from 2011 to 2013 increased by only 6% while imports from the named countries rose by 46%.
 In 2013, the domestic industry’s market share increased to 48.1%, while the named countries’ share decreased slightly to 14.6%. The Complainants state that the domestic industry’s gain in market share in 2013 was mainly done by capturing market share that was previously held by US and other non-subject imports which are priced relatively similar to that of Canadian producers.
 The Complainants documented numerous specific instances where sales were lost to subject goods in the confidential import activity reports.
 While the CBSA does agree that the named countries have increased their market share and that the rate of the increase has been faster than that of the domestic industry, it does not appear that the Complainants have lost market share in absolute terms. As a result the CBSA does not agree that this evidence sufficiently supports the Complainants injury arguments with respect to lost market share. The CBSA does agree, however, that the Complainants’ claims of lost sales are well supported and sufficiently linked to the imports of the alleged dumped and subsidized goods.
 The Complainants relied on confidential Attachment 9 of the complaint containing their consolidated income statement for much of the evidence presented in this section.
 The domestic industry as a whole has suffered poor financial performance since 2011 and has posted combined net losses during each of the last three years. Although their financial performance improved in 2012, it has worsened significantly in 2013. Indeed, the majority of the losses in 2013 occurred in the second half of 2013.
 The CBSA agrees that the domestic industry as a whole has had poor financial performance and that this is at least partly attributable to the injurious dumping and subsidizing of the subject goods. It should be noted, however, that when looking at the three different complainant’s financial statements independently, it appears that the impact is not the same for each of the three producers.
 Nevertheless, the Complainants’ aggregate financial performance is in decline and is likely due to lost sales, price undercutting, price erosion and price suppression resulting from allegedly dumped and subsidized goods form the named countries.
 The Complainants relied on confidential Attachment 10 of the complaint containing their consolidated capacity, capacity utilization, employment, hours worked and wages data for much of the evidence presented in this section. This attachment also shows the data separately for each of the three producers.
 The Complainants’ combined Rebar production increased in 2012, but decreased in 2013.
 The Complainants’ utilization rate for Rebar specifically hovered at a mostly steady ratio of total capacity from 2011 to 2013. The Complainants’ total utilization rate (i.e., Rebar and other products produced on the same equipment as rebar) decreased slightly from 2011 to 2013. The Complainants still have significant unused capacity.
 The Complainants stated that they have lost employees since 2010 as a result of the poor performance caused by competition with subject goods. Direct employment for the three Complainants combined dropped over 6% from 2011 to 2013.
 In analyzing this information, the CBSA also looked at the data for each complainant individually. For falling production levels and capacity utilization, evidence of injury does exist, for one of the Complainants. The CBSA finds that this evidence can be reasonably linked to the increased volume of the allegedly dumped and subsidized imports. Looking at the company specific direct employment levels, two of the three Complainants saw reductions in employment while the other’s most recent data is trending downward. In summary, evidence of injury is sufficient for this factor.
 The Complainants submitted that in order for them to be successful, they must have the ability to support the investment that they require to sustain and improve their operations. Arcelor has plans to invest in new Rebar equipment in 2014.
 The Complainants submitted that unfairly traded imports in the Canadian market, and in particular the massive volume of low-priced subject goods imports which are entering the Canadian market at an increasing rate, pose a significant threat to the Complainants’ ability to continue to make the necessary investments.
 The CBSA does agree that this example poses a threat of injury, but the Complainants have not provided any evidence that suggests this injury factor has already occurred. This will therefore be considered in the appropriate threat of injury section below.
 While certain injury factors outlined above are not as well supported as others in the complaint, there is evidence that material injury has occurred to the domestic Rebar industry. The nature of the injury incurred by the Complainants is well-documented in terms of price undercutting, erosion and suppression and lost sales, which are the backbone of this injury analysis. Employment levels also went down marginally and evidence of injury is sufficient for this factor.
 The complaint contains reasonable evidence regarding the threat of injury due to increasing import volumes of subject goods from the named countries. The increasing volumes of imports of subject goods, at prices that substantially undercut domestic producer pricing will continue to depress and/or suppress domestic prices and threatens to take market share from the Canadian producers and impact capital investments. The Complainants allege that the adverse volume and price effects of increasing dumped imports threatens to cause domestic producers to suffer further declines in production, capacity utilization, employment, market share, prices, operating income, return on investment and other indicators of material injury.
 The Complainants indicated that the increase in the volume of allegedly dumped and subsidized imports from January 1, 2011 to March 31, 2014 at prices that undercut domestically produced like goods, poses a threat of further injury to the Canadian industry. The Complainants believe that this increase in imports indicates that their producers have an aggressive exporting agenda for Canada and that this trend is likely to continue to increase in the near future.
 Current evidence available to the CBSA supports the fact that import volumes from the named countries are continuing to increase recently at an accelerated pace which, in all likelihood, will continue into the near future. It is noteworthy that imports of subject goods from China appear to be increasing at the fastest rate. Imports from China were somewhat negligible in 2011, but they have since increased significantly, specifically during the latter part of 2013 and the first quarter of 2014.
 The Complainants demonstrated that subject imports were offered in the Canadian market at prices that forced the Complainants to lower its prices or lose sales. Several of these allegations pertain to sales during the latter part of 2013 and early part of 2014.
 The Complainants estimated that the excess capacity in the named countries will, in all likelihood, cause injury to the Canadian production of like goods. The CBSA acknowledges that exporters from the named countries have excess capacities and should they seek export markets, such as Canada, to increase their capacity utilization, this would lead to further injury to the Canadian industry. Producers in these countries will, in all likelihood, be seeking export markets to absorb their excess capacity.
 The CBSA finds that the Complainants have provided sufficient evidence that there is a reasonable indication that they have suffered injury due to the alleged dumping and subsidizing of subject goods imported into Canada. The information provided indicates an increase in the volume of imports of allegedly dumped and subsidized goods, as described above, posing a threat to the Canadian industry. There is a reasonable indication that the injury the Complainants have suffered in terms of price undercutting, erosion and suppression; lost sales; negative financial results and reduced production, capacity utilization and employment levels is related to the price advantage the alleged dumping and subsidizing has produced between the imported subject goods and the Canadian produced goods.
 Based on information provided in the complaint, other available information, and the CBSA’s internal import documentation, the President is of the opinion that there is evidence that Rebar originating in or exported from China, the Republic of Korea and Turkey has been dumped and subsidized, and there is a reasonable indication that such dumping and subsidizing has caused and is threatening to cause injury to the Canadian industry. As a result, based on the CBSA’s examination of the evidence and its own analysis, dumping and subsidy investigations were initiated on June 13, 2014.
 The CBSA requested information from all potential exporters and importers to determine whether or not subject goods imported into Canada, during the period of investigation of January 1, 2013 to March 31, 2014, were dumped. The information requested will be used to determine the normal values, export prices and margins of dumping, if any.
 The CBSA requested information from producers of Rebar in China, as well as the GOC, to determine whether the conditions of section 20 exist in the concrete reinforcing bar industry, which is part of the long products steel sector. The CBSA also requested costing and sales information from producers of Rebar in the Kingdom of Thailand and Chinese Taipei. Where sufficiently available, this information may be used to determine normal values of the goods in China in the event that the President of the CBSA forms an opinion that the evidence in this investigation demonstrates that section 20 conditions apply in the concrete reinforcing bar industry, which is part of the long products steel sector in China.
 The CBSA also requested information from the GOC, the GOK and the GOT and all potential exporters in the named countries to determine whether or not subject goods imported into Canada, during the period of investigation of January 1, 2013 to March 31, 2014, were subsidized. The information requested will be used to determine the amounts of subsidy.
 If the Tribunal finds that the evidence discloses a reasonable indication of injury to the Canadian industry and the CBSA investigations preliminarily reveal that the goods have been dumped and/or subsidized, the CBSA will make a preliminary determination of dumping and/or a preliminary determination of subsidizing within 90 days after the date of the initiation of the investigations, by September 11, 2014. Where circumstances warrant, this period may be extended to 135 days from the date of the initiation of the investigations.
 If, in respect of subject goods of any country, the CBSA investigation(s) reveal that imports of the subject goods have not been dumped and/or subsidized, that the margin of dumping and/or amount of subsidy is insignificant or that the actual and potential volume of dumped or subsidized goods is negligible, the investigation(s) will be terminated.
 In respect of importations of subsidized goods that have caused injury this provision is only applicable where the CBSA has determined that the whole or any part of the subsidy on the goods is a prohibited subsidy, as explained in the previous "Evidence of Subsidizing” section. In such a case, the amount of countervailing duty applied on a retroactive basis will be equal to the amount of subsidy on the goods that is a prohibited subsidy.
 Interested parties may provide comments regarding the acceptability of undertakings within nine days of the receipt of an undertaking by the CBSA. The CBSA will maintain a list of parties who wish to be notified should an undertaking proposal be received. Those who are interested in being notified should provide their name, telephone and fax numbers, mailing address and e-mail address to one of the officers identified in the "Information” section of this document.
 To be given consideration in this phase of these investigations, all information should be received by the CBSA by July 21, 2014.
 Any information submitted to the CBSA by interested parties concerning these investigations is considered to be public information unless clearly marked "confidential”. Where the submission by an interested party is confidential, a non-confidential version of the submission must be provided at the same time. This non-confidential version will be made available to other interested parties upon request.
Evidence provided by the Complainants suggests that the governments of the named countries may have provided support to manufacturers of subject goods in the following manner. For purposes of this investigation, the GOC, GOK, and GOT refers to all levels of government, i.e., federal, central, provincial/state, regional, municipal, city, township, village, local, legislative, administrative or judicial. Benefits provided by state-owned enterprises, which possess, exercise or have been vested with governmental authority may also be considered to be provided by the GOC, GOK and GOT for purposes of this investigation.
Grants and Grant-equivalents and Equity Programs may constitute a financial contribution pursuant to paragraph2(1.6)(a) of SIMA in that they involve the direct transfer of funds or liabilities or the contingent transfer of funds or liabilities; and pursuant to paragraph 2(1.6)(b) of SIMA as amounts owing and due to the government that are forgiven or not collected.
Available information indicates that the programs identified above may constitute a financial contribution pursuant to subsection 2(1.6) of SIMA. The available information indicates that financial contributions may exist due to: the direct transfer of funds or liabilities or the contingent transfer of funds or liabilities from the GOK; amounts that would otherwise be owing and due to the GOK are reduced or exempted, and would confer a benefit to the recipient equal to the amount of the reduction/exemption; and the GOK may provide goods or services, other than general governmental infrastructure.
Available information indicates that the programs identified above may constitute a financial contribution pursuant to subsection 2(1.6) of SIMA. The available information indicates that financial contributions may exist due to: the direct transfer of funds or liabilities or the contingent transfer of funds or liabilities from the GOT; amounts that would otherwise be owing and due to the GOT are reduced or exempted, and would confer a benefit to the recipient equal to the amount of the reduction/exemption; and the GOT may provide goods or services, other than general governmental infrastructure.
 Refer to the definition of like goods in the Like Goods section below.
 Refer to the definition of subject goods in the Product Information section below.
 Assumption that order would have been made three months prior to importation, therefore the Metal Bulletin and SBB pricing for the month which is three months prior to importation was used.
 Complaint (NC) - Attachment 14: SMIC, "2013 Annual Report, pg. 103".
 Complaint (NC) - Attachment 15: POSCO, "Separate Financial Statements December 31, 2013 and 2012", pg. 5.
 Complaint (NC) - Attachment 16: Erdemir, "2013 Annual Report”, pg. 30.
 Erdemir’s subsidiary İskenderun Demir ve Çelik A.Ş. ("Isdemir”) produces Rebar. Complaint (NC) " Attachment 17: Erdemir, "İskenderun Demir ve Çelik A.Ş.”, and Attachment 16: Erdemir 2013 Annual Report, pg. 24 confirming Isdemir is a subsidiary of Erdemir.
 Certain Carbon Steel Welded Pipe Originating in or Exported from the Republic of India, the Sultanate of Oman and the United Arab Emirates; Certain Steel Grating Originating in or Exported from the People’s Republic of China; Certain Pup Joints originating in or Exported from the People's Republic of China; and Certain Steel Piling Pipe Originating in or Exported from the People's Republic of China.
 As described above in the "Injury Factors” section.
 The combined excess capacity in the subject countries is 60 million MT.