Comment-wages - DOC inEnglish

Free TranslationMINISTRY OF TRADETHESOCIALIST REPUBLIC OFVIETNAMAugust 1, 2005The Honorable Carols M. GutierrezSecretary of CommerceU.S. Department of CommerceWashington, D.c. 20230Attn: Mr. Joseph SpetriniActing Assistant Secretary for Import AdministrationU.S. Department of CommerceCentral Records Unit, Room 1870Pennsylvania Avenue and 14th Street, NWWashington, D.c. 20230Re: Comments on the Department's Calculation of Wages in NMEAntidumping ProceedingsDear Secretary Guiterrez,The Government of Vietnam appreciates the Department's consideration of interestedparties' views on its administration of antidumping cases against products from countriesconsidered by the Department to be nonmarket economies or "NMEs".W e hope that thesecomments provide the Department with the information necessary to implement policies thatwill make the administration of its NME antidumping proceedings as accurate and predictableas possible.We believe that the Department's methodology of valuing labor in NME antidumpingproceedings does not conform to the general principles of its surrogate value methodology.The Government of Vietnam believes that the Department should revise its regulations andeliminate the requirement of a regression-based analysis to determine the per-hour surrogatevalue for labor. Instead, the Department should use publicly available information from thesurrogate countries to value labor as it does with the other factors of production.We ...