The Southern Shrimp Alliance submitted comments to the Department of Commerce on the means by which the agency can best capture the cost of labor in antidumping proceedings involving non-market (“NME”) economy countries, such as China and Vietnam.
SSA supports Commerce’s preference to employ labor wage rate data from multiple countries rather than allowing parties to cherry-pick labor wage information from individual producers in a surrogate country. Allowing parties to cherry-pick information from individual producers led to absurd results designed to mask the level of dumping in the U.S. market. For example, in a prior proceeding, Commerce found that Indian seafood workers were being paid $0.05 an hour and attributed this wage rate to Chinese seafood workers.
If the true total cost of employing a seafood processing worker in India and China was five cents an hour, such costs would be lower than the likely costs required to maintain slave or prison labor. The cherry-picking of data allowed foreign exporters to claim absurdly low labor wage rates in the course of administrative litigation to mask dumping, while U.S.distributors of imported shrimp — outside of litigation — assured retailers and consumers that this shrimp had been produced in a manner that did not abuse foreign workers.
SSA supports Commerce’s interim wage rate methodology and further agrees that this methodology can be improved by employing alternative data sources for valuing labor.