Full opinion text
OPINION TSOUCALAS, Senior Judge. Plaintiff, The Timken Company (“Timken”), moves pursuant to USCIT R. 56.2 for judgment upon the agency record challenging the Department of Commerce, International Trade Administration’s (“Commerce”) final determination, entitled Final Results of 1996-1997 Antidumping Duty Administrative Review and New Shipper Review and Determination Not To Revoke Order in Part of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From the People’s Republic of China (“Final Results ”), 63 Fed.Reg. 63,842 (Nov. 17, 1998), as amended, Amended Final Results of 1996-1997 Antidumping Duty Administrative Review of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From the People’s Republic of China (“Amended Final Results ”), 63 Fed.Reg. 71,447 (Dec. 28, 1998). Specifically, Timken contends that Commerce erred in: (1) selecting, for valuing the hot-rolled steel bar used to manufacture tapered roller bearings (“TRBs”) cups and cones, export data from Japan to Indonesia, rather than the annual report data from eight Indian bearing producers or Indian import statistics or export statistics from Japan to India; (2) valuing material costs for steel inputs by using the prices paid by a People’s Republic of China (“PRC”) bearing producer and a PRC trading company to market-economy suppliers; (3) valuing scrap generated from the production of cups, cones and rollers using unadjusted Indonesian import statistics; and (4) failing to adjust overhead, selling, general and administrative expenses (“SG & A”) and profit rates to account for differences in material and labor values of other surrogate sources used in determining normal value (“NV”). BACKGROUND This case concerns the 1987 antidumping duty order on TRBs from the PRC for the period of review (“POR”) covering June 1, 1996, through May 31, 1997. See Antidumping Duty Order; Tapered Roller Bearings and Parts Thereof, Finished or Unfinished, From the People’s Republic of China (“Antidumping Duty Order”), 52 Fed.Reg. 22,667 (June 15, 1987). On July 10, 1998, Commerce published the preliminary results of the subject review. See Preliminary Results of 1996-1997 Antidumping Duty Administrative Review and New Shipper Review of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From the People’s Republic of China (“Preliminary Results ”), 63 Fed.Reg. 37,339. Commerce published the Final Results on November 17, 1998. See 63 Fed.Reg. at 63,842. JURISDICTION The Court has jurisdiction over this matter pursuant to 19 U.S.C. § 1516a(a) (1994) and 28 U.S.C. § 1581(c) (1994). STANDARD OF REVIEW In reviewing a challenge to Commerce’s final determination in an anti-dumping administrative review, the Court will uphold Commerce’s determination unless it is “unsupported by substantial evidence on the record, or otherwise not in accordance with law .... ” 19 U.S.C. § 1516a(b)(l)(B)(i) (1994). I. Substantial Evidence Test Substantial evidence is “more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Universal Camera Corp. v. NLRB (“Universal Camera”), 340 U.S. 474, 477, 71 S.Ct. 456, 95 L.Ed. 456 (1951) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938)). Substantial evidence “is something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence.” Consolo v. Federal Maritime Comm’n, 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966) (citations omitted). Moreover, “[t]he court may not substitute its judgment for that of the [agency] when the choice is ‘between two fairly conflicting views, even though the court would justifiably have made a different choice had the matter been before it de novo.’ ” American Spring Wire Corp. v. United States (“American Spring Wire ”), 8 CIT 20, 22, 590 F.Supp. 1273, 1276 (1984) (quoting Penntech Papers, Inc. v. NLRB (“Penntech Papers ”), 706 F.2d 18, 22-23 (1st Cir.1983) (quoting, in turn, Universal Camera, 340 U.S. at 488, 71 S.Ct. 456)). II. Chevron Two-Step Analysis To determine whether Commerce’s interpretation and application of the anti-dumping statute is “in accordance with law,” the Court must undertake the two-step analysis prescribed by Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc. (“Chevron ”), 467 U.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984). Under the first step, the Court reviews Commerce’s construction of a statutory provision to determine whether “Congress has directly spoken to the precise question at issue.” Id. at 842, 104 S.Ct. 2778. “To ascertain whether Congress had an intention on the precise question at issue, [the Court] employ[s] the ‘traditional tools of statutory construction.’ ” Timex V.I., Inc. v. United States, 157 F.3d 879, 882 (Fed.Cir.1998) (citing Chevron, 467 U.S. at 843 n. 9, 104 S.Ct. 2778). “The first and foremost ‘tool’ to be used is the statute’s text, giving it its plain meaning. Because a statute’s text is Congress’s final expression of its intent, if the text answers the question, that is the end of the matter.” Id. (citations omitted). Beyond the statute’s text, the tools of statutory construction “include the statute’s structure, canons of statutory construction, and legislative history.” Id. (citations omitted); but see Floral Trade Council v. United States, 23 CIT 20, 22 n. 6, 41 F.Supp.2d 319, 323 n. 6 (1999) (noting that “[n]ot all rules of statutory construction rise to the level of a canon, however”) (citation omitted). If, after employing the first prong of Chevron, the Court determines that the statute is silent or ambiguous with respect to the specific issue, the question for the Court becomes whether Commerce’s construction of the statute is permissible. See Chevron, 467 U.S. at 843, 104 S.Ct. 2778. Essentially, this is an inquiry into the reasonableness of Commerce’s interpretation. See Fujitsu Gen. Ltd. v. United States, 88 F.3d 1034, 1038 (Fed.Cir.1996). Provided Commerce has acted rationally, the Court may not substitute its judgment for the agency’s. See Koyo Seiko Co. v. United States, 36 F.3d 1565, 1570 (Fed.Cir.1994) (holding that “a court must defer to an agency’s reasonable interpretation of a statute even if the court might have preferred another”); see also IPSCO, Inc. v. United States, 965 F.2d 1056, 1061 (Fed.Cir.1992). The “[C]ourt will sustain the determination if it is reasonable and supported by the record as a whole, including whatever fairly detracts from the substan-tiality of the evidence.” Negev Phosphates, Ltd. v. United States, 12 CIT 1074, 1077, 699 F.Supp. 938, 942 (1988) (citations omitted). In determining whether Commerce’s interpretation is reasonable, the Court considers the following non-exclusive list of factors: the express terms of the provisions at issue, the objectives of those provisions and the objectives of the antidumping scheme as a whole. See Mitsubishi Heavy Indus. v. United States, 22 CIT 541, 545, 15 F.Supp.2d 807, 813 (1998). DISCUSSION I. Commerce’s Selection of Export Data From Japan to Indonesia as a Surrogate Value for Bearing Quality Steel Bar Used by PRC Producers to Manufacture TRB Cups and Cones A. Background Antidumping margins are the difference between NV and United States price of the merchandise. When the merchandise is produced in a non-market economy country (“NME”) such as the PRC, Commerce constructs NV pursuant to section 1677b(c), which provides that the valuation of the factors of production shall be based on the best available information regarding the values of such factors in a market economy country or countries considered to be appropriate by [Commerce]. 19 U.S.C. § 1677b(e)(l) (1994) (emphasis supplied). The statute does not define the phrase “best available information,” it only provides that [Commerce], in valuing factors of production ..., shall utilize, to the extent possible, the prices or costs of factors of production in one or more market economy countries that are[:] (A) at a level of economic development comparable to that of the non-market economy country, and (B) significant producers of comparable merchandise. 19 U.S.C. § 1677b(c)(4) (1994) (emphasis supplied). Thus, the statute grants to Commerce broad discretion to determine the “best available information” in a reasonable manner on a case-by-case basis. See Lasko Metal Prods., Inc. v. United States (“Lasko”), 43 F.3d 1442, 1446 (Fed.Cir.1994) (noting that the statute “simply does not say — anywhere—that the factors of production must be ascertained in a single fashion.”) Consequently, Commerce values as many factors of production (“FOPs”) as possible using information obtained from the “primary” surrogate country, that is, the country that Commerce considers to be most comparable in economic terms to the NME country being investigated, and that also produces merchandise comparable to the subject merchandise. See, e.g., Tianjin Mach. Import & Export Corp. v. United States (“Tianjin”), 16 CIT 931, 940-41, 806 F.Supp. 1008, 1018 (1992); Timken Co. v. United States, 16 CIT 142, 145-46, 788 F.Supp. 1216, 1218 (1992). Additionally, if Commerce determines that suitable values cannot be obtained from the data of the primary surrogate country, Commerce resorts to the data from the second, and sometimes the third, surrogate. See, e.g., Timken Co. v. United States (“Timken 2001 ”), 25 CIT -, -, 166 F.Supp.2d 608, 621-23 (2001); Notice of Final Determination of Sales at Less Than Fair Value: Certain Cased Pencils From the People’s Republic of China, 59 Fed.Reg. 55,625, 55,629 (Nov. 8, 1994); Final Determination of Sales at Less Than Fair Value: Certain Helical Spring Lock Washers From the People’s Republic of China, 58 Fed.Reg. 48,833, 48,835 (Sept. 20, 1993). During this review, Commerce initially chose India as the primary surrogate country to value all FOPs except steel inputs and scrap, which were valued using the data from the secondary surrogate country, Indonesia. See Preliminary Results, 63 Fed.Reg. at 37,342-43. Commerce explained that in order to value the steel inputs used by PRC producers to manufacture TRB cups and cones, Commerce “reviewed several data sources, including: U.S., Indian, and Indonesian import statistics, and [export data from Japan] ... to determine the most accurate value for steel inputs.” Final Results, 63 Fed.Reg. at 63,845. Commerce reasoned that it decided to use secondary surrogate data (that is, Indonesian import statistics) over import data from India because Commerce determined that steel values contained in the Indian import data were not reliable for two reasons: (1) Commerce was unable to isolate Indian import value for bearing quality steel used to manufacture the merchandise at issue, see Def.’s Mem. Opp. Pl.’s Mot. J. Agency R. (“Def.’s Mem.”), App. Ex. 8 at 3; and (2) “when compared with the U.S. import statistics for the HTS category which only includes bearing quality steel bars and rods, the Indian values are unreliably high.” Final Results, 63 Fed.Reg. at 63,845. Commerce, however, re-examined the matter after considering comments that questioned the use of Indonesian import statistics to value bearing quality steel bar used by Chinese manufacturers in the production of cups and cones. See id. Upon examining the Indonesian import statistics, Commerce found that Indonesian tariff category 7228.30 “included] several types of hot-rolled bars and rods of alloy steel, in addition to the bearing quality steel bars and rods used in cup and cone production.” Id. at 63,845. Although the Indonesian import statistics were consistent with the United States benchmark, Commerce was persuaded by “Timken’s arguments that the volume of steel imported into Indonesia exceeded the volume of bearing quality steel that could actually be consumed in that country.” Def.’s Mem. at 14. Commerce, therefore, decided to further examine the Indonesian import values. See Final Results, 63 Fed.Reg. at 63,845. Examining the data further, Commerce observed that the export data from Japan to Indonesia “provided] a breakdown of the broad six-digit 7228.30 category into several more narrowly defined ... categories.” Id. In particular, during the period of review, 2,974 metric tons (“MTs”) of the merchandise were exported to Indonesia under Japanese HS Code 7228.30.900 (that is, a category that most likely includes the bearing quality steel bar used to produce the merchandise at issue). See id. at 63,-846. Consequently, Commerce concluded that export data from Japan to Indonesia under category 7228.30.900 would constitute the best information available to value steel used to produce the merchandise at issue. See id. Commerce stated that [b]ecause this Japanese tariff category is the narrowest category which could contain bearing quality steel and because it is consistent with [the United States] benchmark, [Commerce] believe[s] it is the best alternative for valuing steel used in the production of cups and cones. Moreover, [Commerce] view[s] the data on [exports from Japan] to Indonesia as an Indonesian value, i.e., it is a value from a country comparable to the PRC. Although the data are from Japanese statistics, [Commerce] ha[s] used those statistics to “refine” the Indonesian data in an attempt to make the import category conform better to the input used by the PRC TRB producers. Id. Moreover, Commerce examined and rejected the annual report data of eight Indian bearing manufacturers suggested by Timken as an alternative for valuing the bearing quality steel used in the production of the subject merchandise at issue. See 63 Fed.Reg. at 63,843-44. Commerce found that the annual report data of the eight Indian bearing manufacturers were unsuitable to value the steel inputs because “only three [of these manufacturers] break out steel costs according to the type of steel used in the production of bearings.” Id. at 63,843. Commerce further pointed out that [f]or the three companies that do break out their steel costs by broad types of steel, only Asian Bearing separately identified] “steel bars,” the steel input used by the Chinese respondents to produce certain TRB components (cups, cones, & rollers). However, because Asian Bearing provides an average cost for steel bar and does not provide specific costs according to the type of bar used (i.e., hot-rolled versus cold-rolled), [Commerce] is unable to accurately value the two types of steel bar used in the production of cups and cones versus that used in the production of rollers. Furthermore, the annual report does not specify whether the steel bar is only used by Asian Bearing in the production of tapered roller bearings or whether it is used to produce other products manufactured by the company. To the extent that Asian Bearing uses hot-rolled and cold-rolled steel bars in different proportions than the PRC TRB producers, , Asian Bearing’s average cost of steel bars is not an accurate value to apply to the PRC producers’ factors. Id. Commerce also stated that it was rejecting Asian Bearing’s data because of Commerce’s “longstanding practice of relying, to the extent possible, on public statistics on surrogate countries to value any factors for which such information is available over company-specific data.” Id. at 63,844. Finally, Commerce in its brief explained the basis for its rejection of the export statistics from Japan to India as an alternative for valuing the bearing quality steel used in the production of the subject merchandise at issue. See Def.’s Mem. at 31-33. Commerce reasoned that: Because (1) Commerce found that the Indian import data were significantly higher than the U.S. benchmark; and (2) Timken supplied the [export data from Japan] to India in support of its argument that the Indian import data were reasonable, it is apparent that Commerce rejected the [export data from Japan] to India for the same reasons that it rejected the Indian import data (ie., both sources of data were unreliable when compared to the U.S. benchmark). Id. at 32. B. Contentions of the Parties 1. Timken’s Contentions Timken contends that Commerce abused its discretion when it used export data from Japan to Indonesia to value “the hot-rolled steel bar used to produce tapered roller bearing cups and cones over: (1) the annual report data from eight Indian producers; (2) Indian import statistics; or (3) [export statistics from Japan] to India.” Timken’s Mem. P. & A. Supp. Mot. J. Agency R. (“Timken’s Mem.”) at 24. With regards to the annual report data from eight Indian producers, Timken asserts that the average material costs of the eight Indian producers was a superior surrogate source to value hot-rolled steel bar used to produce TRB cups and cones' than Commerce’s use of the export-data from Japan to Indonesia. See id. at 25-32. In particular, Timken maintains that: (1) “the eight annual reports for the Indian bearing producers are publicly available average data from the primary surrogate country,” id. at 28; (2) “unlike Japanese export statistics, the average steel costs contained in the eight annual reports reflect non-export prices,” id.; (3) “the eight annual reports for the 1996-97 fiscal year are representative of a range of material prices contemporaneous with the period of review,” id.; (4) unlike “the Japanese export statistics which also cover non-bearing quality steel, seven of the eight annual reports primarily reflect material costs for bearing quality steel in India,” id. at 28-29; and (5) “unlike the Japanese export statistics, the material costs included in the annual reports also reflect domestic prices.” Id. at 29. Moreover, Timken points out that Commerce departed from its own “strong preference [to] calculate[] normal value in NME cases based on factor values from a single, primary surrogate source” by rejecting the annual report data from eight Indian producers. Timken’s Mem. at 26-27 (citing Peer Bearing Co. v. United States (“Peer Bearing 1998 ”), 22 CIT 472, 481, 12 F.Supp.2d 445, 455 (1998); Tianjin, 16 CIT at 940, 806 F.Supp. at 1017-18; Industrial Nitrocellulose From, the People’s Republic of China: Final Results of Antidumping Duty Administrative Review, 62 Fed.Reg. 65,667, 65,668 (Dec. 15, 1997); Notice of Final Determination of Sales at Less Than Fair Value: Certain Cut-to-Length Carbon Steel Plate From Ukraine, 62 Fed.Reg. 61,754, 61,762 (Nov. 19, 1997); and Final Determination of Sales at Less Than Fair Value: Certain Carbon Steel Buth-Weld Pipe Fittings From the People’s Republic of China, 57 Fed.Reg. 21,058, 21,062 (May 18, 1992)). Additionally, Timken argues that Commerce “failed to compare the merits of [Indian annual report data] with ... export statistics [from Japan] to Indonesia.” Timken’s Mem. at 30; see also Timken’s Reply Br. (“Timken’s Reply”) at 4-5. In particular, Timken asserts that: (1) the export data from Japan to Indonesia does not “separately identify material costs for hot-rolled bar for the production of cups and cones,” Timken’s Mem. at 30; (2) the export data from Japan to Indonesia “include[s] non-bearing quality steel,” id., and; (3) “Japanese exports of steel to Indonesia were not likely to have been used for the production [of the] subject merchandise.” Id. Timken also asserts that the annual reports of the eight Indian producers were publicly available and were used by Commerce to value overhead, SG & A and profit. Timken’s Mem. at 31. Finally, Timken maintains that the “fact that the average material ] costs” of the eight Indian producers were on average “higher than Japanese export prices to Indonesia ... is insufficient to support use of ... [Japanese exports to Indonesia] as the ‘best available information’ to value material costs [at issue].” Id. at 32. Timken, therefore, argues that Commerce’s decision to use export data from Japan to Indonesia to value the subject merchandise at issue is arbitrary and unsupported by substantial evidence. See Timken’s Reply at 5. As an alternative to the prior argument, Timken suggests that Commerce should have used Indian import statistics to value the steel inputs at issue. Id. In particular, Timken argues that: (1) Commerce’s use of United States import data as a benchmark for assessing the reliability of the Indian import data was unreliable and unreasonable, see Timken’s Reply at 6-7; Timken’s Mem. at 24 n. 3; (2) “import[] statistics from the primary surrogate country are superior to ... export statistics [from Japan] to the secondary surrogate,” Timken’s Mem. at 24-25 n. 3; and (3) Commerce arbitrarily selected export statistics from Japan to Indonesia as a surrogate to value the subject merchandise at issue despite the fact that Indonesia is not a “ ‘significant’ bearing producer” and “Indian import statistics were remarkably consistent with the raw material costs reported in the annual reports of eight Indian bearing[] producers.” Id. at 25 n. 3; see also, Timken’s Reply at 7. Finally, Timken alternatively argues that Commerce failed to explain Commerce’s rejection of export data from Japan to India as a surrogate value. . See Timken’s Mem. at 32-35; Timken’s Reply at 8-9. Timken asserts that “[without an articulation of reasons as to why [Commerce] considered ... export statistics [from Japan] to India inadequate, the Court cannot determine whether [Commerce’s] decision was arbitrary, capricious, or otherwise not in accordance with law.” Timken’s Mem. at 35 (citing SEC v. Chenery Corp., 332 U.S. 194, 196, 67 S.Ct. 1575, 91 L.Ed. 1995 (1947)). Moreover, Timken contends that Commerce should have used the export data from Japan to India over export data from Japan to Indonesia as a surrogate to value the subject merchandise at issue because (1) if Commerce was persuaded by the fact that the export statistics from Japan to Indonesia provide more product-specific data for bearing quality steel bar to value TRB cups and cones, then the very same fact with regards to export statistics for Japanese exports to India' should be equally considered by Commerce, see Timken’s Mem. at 33; (2) “Japanese steel exported to Indonesia was less likely to be used in the production of identical or comparable merchandise than Japanese exports to India,” id. at 34; (3) Commerce’s reliance on United States import data as a benchmark was unreasonable, see id.; and (4) “[i]f Japanese export statistics under HTS 7228.30.90 contained more product-specific information than Indian or Indonesian import statistics, then [Commerce]- should have used ... export statistics [from Japan] to India.” Id. 2. Commerce’s Contentions Commerce responds that its decision to value steel inputs used by PRC producers to manufacture TRB cups and cones by using export data from Japan to Indonesia rather than either the annual report data for eight Indian producers, or export statistics from Japan to India, or Indian import statistics was reasonable and in accord with the mandate of 19 U.S.C. § 1677b(c). See Def.’s Mem. at 23-33. Specifically, Commerce points out that, contrary to Timken’s argument, “‘[t]he court’s role is not to determine whether the information chosen by Commerce is the “best” actually available, but whether the choice is supported by substantial evidence and is in accordance with law.’ ” Id. at 25 (quoting Novachem, Inc. v. United States, 16 CIT 782, 786, 797 F.Supp. 1033, 1037 (1992)). Commerce, therefore, maintains that its selection of the export data from Japan to Indonesia as the “best available” surrogate value should be sustained because that data “represented ‘the narrowest category most likely containing bearing quality steel bar’; and ... ‘it is consistent with [the United States] benchmark.’ ” Def.’s Mem. at 25 (quoting Final Results, 63 Fed.Reg. at 63,846). Commerce argues that its decision to reject the annual report data of eight Indian bearing manufacturers as an alternative for valuing the bearing quality steel used in the production of the subject merchandise at issue was supported by substantial evidence. See Def.’s Mem. at 26-29. Commerce asserts that it examined the annual report data of the eight Indian producers and found that only three of the eight reports “identified steel costs by the type of steel used in the production of bearings.” Id. at 27. Moreover, Commerce points out that “[f]or the three companies that do break out their steel costs by broad types of steel, only Asian Bearing separately identifie[d] ‘steel bars,’ the steel input used by the Chinese respondents to produce certain TRB components (cups, cones, & rollers).” Id. (quoting Final Results, 63 Fed.Reg. at 63,843). Commerce further reasoned that it rejected the Asian Bearing annual report for three reasons: (1) “Asian Bearing provides an average cost for steel bar and does not provide specific costs according to the type of bar used (i.e., hot-rolled versus cold-rolled)”; (2) “the annual report does not specify whether the steel bar is only used by Asian Bearing in the production of tapered roller bearings or whether it is used to produce other products manufactured by the company”; and (3) “public statistics provide a more representative value for these material inputs than a single company’s information.” Def.’s Mem. at 27 (quoting Final Results, 63 Fed.Reg. at 63,843-44). Additionally, Commerce maintains that “[njeither the Indian annual reports nor the Japanese export data ... satisfied all of Commerce’s preferences.” Def.’s Mem. at 29. Commerce, therefore, selected the “policy preference (i.e., non-export value or product-specificity) [that] would lead to a more accurate dumping margin.” Id. Commerce also argues that its decision to reject Indian import statistics as an alternative for valuing the bearing quality steel used in the production of the subject merchandise at issue was supported by substantial evidence. Id. at 29-31. Commerce points out that “[i]n comparing [Indian import statistics] data to other market values, including U.S. imports from category 7228.30.20 (the only import category on the record which explicitly contains only bearing quality steel), [Commerce] found the Indian values to be unreliable because the values for these imports were significantly higher.” Id. at 30 (quoting App. Ex. 8). Additionally, Commerce was unable to isolate Indian import value for bearing quality steel used to manufacture the subject merchandise at issue. See Def.’s Mem., App. Ex. 8 at 3. Commerce also points out that the United States benchmark used by Commerce in assessing the reliability of the Indian import data was reasonable and reliable. See Def.’s Mem. at 31; see also Final Results, 63 Fed.Reg. at 63,844-45. Finally, Commerce contends that its decision to reject export data from Japan to India as an alternative for valuing the bearing quality steel used in the production of the subject merchandise at issue was supported by substantial evidence. See Def.’s Mem. at 81-33. Commerce agrees with Timken that Commerce “did not formally explain the basis for its rejection of ... export statistics [from Japan] to India as a surrogate value.” Id. at 31. Nevertheless, Commerce maintains that the Court may discern Commerce’s rejection of export data from Japan to India as a surrogate value because Commerce’s reasoning “is apparent from the administrative record.” Id. In particular, Commerce reasoned that [bjecause [:](1) Commerce found that the Indian import data were, significantly higher than the U.S. benchmark; and (2) Timken supplied the ... export data [from Japan], to India in support of its argument that the Indian import data were reasonable, it is apparent that Commerce rejected the ... export data [from Japan] to India for the same reasons that it rejected the Indian import data (i.e., both sources of dgta were unreliable when compared to the U.S. benchmark). Id. at 32. C. Analysis 1. Commerce’s Changes of Policy or Methodology Agency statements .provide guidance to regulated industries. While “ ‘an agency does not act rationally when it chooses, and implements one policy and .decides to consider the merits of a potentially inconsistent policy in the very near future,’ ” Transcom, Inc. v. United States, 24 CIT -, -, 123 F.Supp.2d 1372, 1381 (2000) (quoting ITT World Communications, Inc. v. FCC, 725 F.2d 732, 754 (D.C.Cir.1984)), Commerce, in view of the rapidly-changing world of global trade and Commerce’s limited resources, should be able to rely on its “unique expertise and policy-making prerogatives.” Southern Cal. Edison Co. v. United States, 226 F.3d 1349, 1357 (Fed.Cir.2000). “ ‘The power of an administrative agency to administer a congressionally created ... program necessarily requires the formulation of policy ....’” Chevron, 467 U.S. at 843, 104 S.Ct. 2778 (quoting Morton v. Ruiz, 415 U.S. 199, 231, 94 S.Ct. 1055, 39 L.Ed.2d 270 (1974)). An agency decision involving the meaning or reach of a statute that reconciles conflicting policies “ ‘represents a reasonable accommodation of conflicting policies that were committed to the agency’s care by the statute, [and a reviewing court] should not disturb [the agency decision] unless it appears from the statute or its legislative history that the accommodation is not one that Congress would have sanctioned.’ ” Chevron, 467 U.S. at 845, 104 S.Ct. 2778 (quoting United States v. Shimer, 367 U.S. 374, 382-83, 81 S.Ct. 1554, 6 L.Ed.2d 908 (1961)). Furthermore, an agency must be allowed to assess the wisdom of its policy on a continuing basis. Under the Chevron regime, agency discretion to reconsider policies is inalienable. See Chevron, 467 U.S. at 843, 104 S.Ct. 2778. Any assumption that Congress intended to freeze.an administrative interpretation of a statute would be- entirely contrary to the concept of Chevron which assumes and approves the ability of administrative agencies to change their interpretations. See, e.g., Maier v. United States EPA, 114 F.3d 1032, 1043 (10th Cir.1997), J.L. v. Social Sec. Admin., 971 F.2d 260, 265 (9th Cir.1992), Saco Defense Sys. Div., Maremont Corp. v. Weinberger, 606 F.Supp. 446, 450-51 (D.Me.1985). In sum, underlying agency interpretative policies “are given controlling weight unless they are arbitrary, capricious, or manifestly contrary to the statute.” Chevron, 467 U.S. at 844, 104 S.Ct. 2778. Moreover, “ ‘[a]n [agency] announcement stating a change in the method ... is not a general statement of policy.’ ” American Trucking Ass’ns, Inc. v. ICC, 659 F.2d 452, 464 n. 49 (5th Cir.1981) (quoting Brown Express, Inc. v. United States, 607 F.2d 695, 701 (5th Cir.1979) (internal quotations omitted)). While a policy “denotes ... [the] general purpose ... [of the statute] considered as directed to the welfare or prosperity of the state,” BLACK’S LAW DICTIONARY 1157 (6th ed.1990), methodology refers only to the “performing [of] several operations[] in the most convenient order,” id. at 991; accord Avoyelles Sportsmen’s League, Inc. v. Marsh, 715 F.2d 897 (5th Cir.1983); Interstate Natural Gas Ass’n of Am. v. Federal Energy Regulatory Comm’n, 716 F.2d 1 (D.C.Cir.1983); Hooker Chems. & Plastics Corp. v. Train, 537 F.2d 620 (2d Cir.1976). Consequently, the courts are even less in the position to question an agency action if the action at issue is a choice of methodology, rather than policy. See, e.g., Maier, P.E., 114 F.3d at 1043 (citing Professional Drivers Council v. Bureau of Motor Carrier Safety, 706 F.2d 1216, 1221 (D.C.Cir.1983)). Similarly, an agency decision to change its methodology, that is, to take an act of statutory implementation while pursuing the same policy, should be examined under the Chevron test and sustained if the new methodology is reasonable. See, e.g., Koyo Seiko Co., v. United States, 24 CIT -, -, 110 F.Supp.2d 934, 942 (2000) (stating that “ ‘the use of different methods [of] calculation] ... does not [mean there is a] conflict with the statute,’ ”) (quoting Torrington Co. v. United States, 44 F.3d 1572, 1578 (Fed.Cir.1995)). Therefore, Commerce’s decision to reject the annual report data of eight Indian producers and Commerce’s consequential use of alternative data as a surrogate value for bearing quality steel bar used by PRC producers to manufacture TRB cups and cones was a justifiable change of methodology as long as such change in position was reasonably supported by the record. 2. Commerce’s Decision to Use Export Data from Japan to Indonesia As a preliminary matter, the Court rejects Timken’s assertion that Commerce erred in using United States data as benchmarks to test the reliability of the Indian import data and export data from Japan to India. A comparison of surrogate data to that of market economy in order to determine the reliability of such surrogate data is within “ ‘Commerce’s statutory authority and consistent with past practice.’ ” Peer Bearing 1998, 22 CIT at 481, 12 F.Supp.2d at 455 (quoting Writing Instrument Mfrs. Ass’n v. United States (“Writing Instrument”), 21 CIT 1185, 1195, 984 F.Supp. 629, 639 (1997)) (upholding use of United States benchmark as a point of comparison for two possible surrogate values and quoting, in turn, Olympia Indus., Inc. v. United States (“Olympia 1997”), 21 CIT 364, 369, 1997 WL 181529 (1997) (approving Commerce’s use of data from other market economies to test the reliability of surrogate country data)). Commerce, therefore, acted within its statutory authority by utilizing United States data to aid in its FOPs valuation. See 19 U.S.C. §§ 1677b(c)(l) and (4); Peer Bearing 1998, 22 CIT at 481, 12 F.Supp.2d at 455. Next, with respect to Timken’s challenge to Commerce’s decision to use export data from Japan to Indonesia to value the hot-rolled steel bar used by PRC producers to manufacture TRB cups and cones, the Court finds that Commerce’s decision was unreasonable. In this case, during the review at issue, Commerce examined the Indonesian import statistics and found that: (1) Indonesian import statistics were consistent with the United States benchmark; and (2) “the volume of steel imported into Indonesia exceeded the volume of bearing quality steel that could actually be consumed in that country.” Def.’s Mem. at 14. Upon further examination of Indonesian import statistics, Commerce observed that export data from Japan to Indonesia under category 7228.30.900 would constitute the best information available to value steel used to produce the merchandise at issue. Commerce reasoned that because this Japanese tariff category is the narrowest category which could contain bearing quality steel and ... it is consistent with [the United States] benchmark. Final Results, 63 Fed.Reg. at 63,846. Commerce went on to state that [Commerce] view[s] the data on Japanese exports to Indonesia as an Indonesian value, ie., it is a value from a country comparable to the PRC. Although the data are from Japanese statistics, [Commerce] ha[s] used those statistics to “refine” the Indonesian data in an attempt to make the import category conform better to the input used by the PRC TRB producers. Id. With respect to export statistics from Japan to India, Commerce, however, admittedly failed to explain its rejection of the export statistics from Japan to India as a surrogate value. See Def.’s Mem. at 31. While Commerce maintains that the Court may discern Commerce’s reasoning for rejecting the export data from Japan to India from the record, the Court finds that Commerce’s reasoning for rejecting the export data from Japan to India as a surrogate value was not sufficiently explained. To the contrary, on the basis of the explanation supplied by Commerce one may conclude that it was illogical for Commerce to utilize export data from Japan to Indonesia in order to “refine” the Indonesian data and then to subsequently reject analogously structured export data from Japan to India. Accordingly, the Court remands this issue to Commerce with instructions to provide the Court with an explanation as to why export statistics from Japan to India are not the “best available information” for the purpose of choosing a surrogate to value hot-rolled steel bar used to produce TRB cups and cones. II. Commerce’s Use of Luoyang Bearing Factory’s and China National Machinery Import and Export Corporation’s Market Economy Import Data A. Background During the POR, Luoyang Bearing Factory (“Luoyang”), China National Machinery Import and Export Corporation (“CMC”), Zhejiang Changshan Bearing (Group) Co., Ltd. (“ZX”), and Zhejiang Machinery Import and Export Corporation (“Zhejiang”) “submitted [to Commerce] market economy input prices for steel they imported, directly or indirectly, and used in the production of’ TRBs. Def.’s Mem., App. Ex. 6 at 1. In the Preliminary Results, Commerce stated that [Luoyang and CMC] ... purchased steel from market economy suppliers and paid for the steel with market economy currencies. In these instances [Commerce] valued the steel input using the actual prices reported for imported inputs from a market economy .... Where ... [ZX and Zhejiang] purchased the steel from a PRC trading company [CMC] and paid for the steel in ... [non-market economy currency], [Commerce] did not use the market economy price to the trading company and instead used surrogate data [to value the steel input]. 63 Fed.Reg. at 37,343 (citing Def.’s Mem., App. Ex. 6). However, in the Final Results, Commerce partially departed from the conclusion reached in its Preliminary Results and “us[ed] ... [CMC’s] import steel price as surrogate data for those companies that actually used the imported steel [that is, ZX and Zhejiang].” Final Results, 63 Fed.Reg. at 63,854; accord Def.’s Mem. at 33 n. 35. For the purpose of assessing the alternative surrogate data, Commerce determined the reliability of CMC’s import prices by examining the following: “(1) the value and volume of steel imports, (2) the type and quality of the imported steel, and (3) consumption of imported steel by the NME producer.” Final Results, 63 Fed.Reg. at 63,854; see also, Olympia Indus., Inc. v. United States (“Olympia 1999 ”), 23 CIT 80, 82, 36 F.Supp.2d 414, 416 (1999). Upon examining these factors, Commerce concluded that: [t]he record evidence demonstrates that ... [CMC] purchased steel from a market-economy country, in a convertible currency. This company used a portion of the steel in its own production of TRBs but also sold a portion of the steel to an unrelated manufacturer. Based on the invoices for the imported steel, and the specifications of the steel sourced by the factories domestically, [Commerce] conclude[d] that the imported steel is of the same grade and has the same range of sizes as steel that the NME manufacturers used to produce the subject merchandise. Regarding the value of the steel imported by ... [CMC], [Commerce] found that the price paid by the trading company is within the range of prices created by the actual steel prices paid by PRC producers and [Commerce’s] surrogate value. Consequently, the price paid by ... [CMC] is not aberrational. With respect to volume and consumption of steel by the NME producer, [Commerce] note[s] that the amount of steel imported by the trading company was significant and that the NME producer in question consumed a significant amount of imported steel to produce the subject merchandise. Final Results, 63 Fed.Reg. at 63,854. B. Contentions of the Parties 1. Timken’s Contentions Timken contends that Commerce’s decision to value material costs for certain steel inputs by using the prices paid by CMC to market-economy suppliers was not supported by substantial evidence and contrary to law. See Timken’s Mem. at 36-38. In particular, Timken argues that Commerce’s reliance on CMC’s import prices as an alternative surrogate value violates “[t]he plain language of the statute and regulations [which] require, ... ‘to the extent possible,’ that [Commerce] value factors of production based on prices or costs ‘in’ another market economy country at a comparable level of development.” Id. at 36 (quoting 19 U.S.C. § 1677b(c)(4) and 19 C.F.R. § 353.52(c)(1997)); see also Timken’s Reply at 9. Relying on Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, Timken maintains that “trading company import prices are not actual prices but surrogate values subject to the requirements of 19 U.S.C. § 1677b(c)(4).” Timken’s Reply at 10; see also Timken’s Mem. at 37. Based on the foregoing, Timken further maintains that “[n]owhere in its final determination does [Commerce] explain that it was not ‘possible’ to use Indian or other surrogate values according to the expressed statutory requirements.” Timken’s Mem. at 38; see Timken’s Reply at 13. Timken, therefore, asserts that a remand is necessary so that Commerce can explain its interpretation of 19 U.S.C. § 1677b(c)(4) as it “applie[s] to the facts of this case.” Timken’s Reply at 13. Additionally, Timken argues that Commerce’s three-pronged test only examines whether trading company import prices are aberrational or insignificant and does not “determine whether [trading company import] prices reflect market forces and are more reliable than surrogate values from a comparable market economy.” Timken’s Mem. at 42^13; Timken’s Reply at 15-16. Timken contends that in order for Commerce to assess the reliability of trading company import prices pursuant to § 1677b(c)(l), Commerce should have considered: (1) “whether the trading company importer sufficiently covered its costs in reselling the imported materials;” (2) “any countertrade arrangements between the trading company and its market-economy supplier;” (3) “any commissions or other consideration paid by the purchaser or supplier to the trading company, or lack thereof;” and (4) “any affiliation between the trading company, the market-economy supplier and/or the Chinese manufacturer.” Timken’s Mem. at 43. Moreover, Timken maintains that contrary to Commerce’s assertion that Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, approved Commerce’s three-pronged test, “[t]he issue [in Olympia 1999 ] was not whether [Commerce] could rely on the test to support acceptance of trading company import prices.” Timken’s Reply at 16. Next, Timken argues that Commerce’s determination that a PRC bearing producer’s (that is, Luoyang’s) import prices constituted the “best available information” under § 1677b(c)(l) to value material costs for certain steel inputs was contrary to § 1677b(c)(l) and unsupported by substantial evidence because Commerce failed to determine whether the prices paid by the PRC bearing producer to the market-economy suppliers were “market-driven.” See Timken’s Mem. at 39-41. In particular, Timken maintains that “[i]mports from a market-economy country are not necessarily priced at market-economy rates when sold in a nonmarket economy country.” Timken’s Mem. at 40. Timken states: [i]ndeed, with the increasing number of countries applying antidumping rules, it can be expected that exports to China could be dumped with impunity or sold at price levels that are atypical of prices in the country of exportation.... Producers in highly-developed countries, concerned with unused capacity might export to China at below-market prices in order to better spread their fixed costs. Or, the domestic Chinese competition may require potential exporters to price at levels not found ‘in’ their own market economies in order to establish channels of distribution and market share. In either case, dumped import prices would not reflect prices in the exporting country, whether or not it was at a comparable level of development. Id. Moreover, relying on Final Determinations of Sales at Less Than Fair Value: Oscillating Fans and Ceiling Fans From the People’s Republic of China (“Oscillating Fans”), 56 Fed.Reg. 55,271, 55,275 (Oct. 25, 1991), Timken maintains that “as [Commerce] evaluates market-economy prices to determine whether they are reliable in a market-economy case, [Commerce] should evaluate those prices to determine whether they are rehable in [an] NME case.” Timken’s Mem. at 41. Timken also contends that Commerce “should have considered the volume and frequency of’ Luoyang’s market-economy purchases and “should have rejected all prices that were not at arm’s length, that did not reflect commercial quantities, or that otherwise did not reasonably reflect the actual cost of production in a comparable market economy.” Id. at 41^42; see Timken’s Reply at 15. 2. Commerce’s Contentions Commerce responds that its determination to value material costs for steel inputs using the prices paid by: (1) a PRC bearing producer (Luoyang) and (2) a PRC trading company (CMC) to market-economy suppliers was supported by substantial evidence and in accordance with law. See Def.’s Mem. at 33-39. First, with respect to Commerce’s decision to value material costs for certain steel inputs by using the prices paid by a PRC trading company to market-economy suppliers, Commerce, relying on Lasko argues that the Court “reject[ed][the] argument that [§ 1677b(c)(4) ] set forth a hierarchy that requires Commerce to ‘determine [NY] in a[n] NME solely on the basis of surrogate factors of production.’ ” Def.’s Mem. at 35 (quoting Lasko, 43 F.3d at 1445). Commerce further argues that since § 1677b(c)(4) does not distinguish between producers and trading companies for purposes of determining NV in a case involving an NME country, it is apparent that Commerce’s authority to use the actual market-economy prices paid for by producers also extends to actual market-economy prices paid for by trading companies. Def.’s Mem. at 35. Moreover, Commerce' contends that its three-pronged test is presumptively correct and has been approved by Olympia Indus. Inc. v. United States, 36 F.3d 414 (CIT 1999)[sic]. Id. at 38. Commerce further maintains that § 1677b(c)(l) is silent as to the methodology Commerce is to use in “determin[ing] whether to use the market prices paid by trading companies as an alternative surrogate value.” Def.’s Mem. at 38-39. Commerce, therefore, argues that since the statute is silent “ ‘the Supreme Court ... ha[s] held that our duty is not to weigh the wisdom of, or to resolve any struggle between, competing views of the public interest, but rather to respect legitimate policy choices made by the agency interpreting and applying the statute.’” Id. at 39 (quoting Lasko, 43 F.3d at 1446 and Suramerica de Aleaciones Laminadas, C.A. v. United States (“Suramerica"), 966 F.2d 660, 665 (Fed.Cir.1992), and citing Timken 1999, 23 CIT at 516, 59 F.Supp.2d at 1377). Second, with respect to Commerce’s determination to value material costs for certain steel inputs by using the prices paid by a PRC bearing producer to market-economy suppliers, Commerce argues that this practice was sustained by the CAFC in Lasko. See Def.’s Mem. at 33. In particular, Commerce points out that § 1677b(c)(l) “requires Commerce to value factors of production using the ‘best available information’ ” and that Lasko found that “ ‘the best available information oh what the supplies used by the Chinese manufactures would cost in a market economy country was the price charged by those supplies on the international market.’ ” Id. at 33-34 (quoting Lasko, 43 F.3d at 1446). Commerce also points out that contrary to Timken’s argument, the prices paid by the PRC bearing producer constituted the best available information because the PRC bearing producer had a contract priced in United States dollars between itself and a market-economy supplier and “ ‘[t]he cost for raw materials from a market economy supplier, paid in convertible currencies, provides Commerce with the closest approximation of the cost of producing the goods in a market economy country.’ ” Def.’s Mem. at 35-36 (quoting Lasko Metal, 16 CIT at 1081, 810 F.Supp. at 317). Additionally, Commerce asserts that since Timken’s argument (that is, the prices paid by the PRC bearing producer, Luoyang, might not reflect market-economy prices) is based on hypothetical assertions, Commerce’s decision to accept the PRC producer’s prices are not in conflict with legislative history. See Def.’s Mem. at 36 (citing to 1.988 U.S.C.C.A.N. 1647, 1623-24). Commerce also asserts that Timken’s argument (that is, Commerce should have considered the volume and frequency of Luoyang’s market-economy purchases) is unpersuasive because “[t]he authorities relied upon by Timken reveal that it is [Commerce’s] practice to consider the volume of market-economy purchases for purposes of determining whether to value domestically-purchased inputs based upon the value of imports from a market-economy country.” Id. at 37 (citing Final Results of Antidumping Duty Administrative Review of Certain Helical Spring Lock Washers From the People’s Republic of China (“Certain Helical Spring Lock Washers”), 62 Fed.Reg. 61,794, 61,796 (Nov. 19, 1997)). Commerce, therefore, points out that “[w]here Commerce uses the prices of a respondent’s market-economy purchases to value those purchases, it does not consider the volume or frequency of those purchases.” Id. at 38 (citing Lasko, 43 F.3d at 1446). C. Analysis The applicable statute provides that, when dealing with imports from an NME country such as the PRC, Commerce shall determine the NV of the subject merchandise based on FOPs utilized in producing the merchandise. See 19 U.S.C. § 1677b(c)(l). The statute further provides that Commerce shall value the reported FOPs based on the best available information regarding the values of FOPs in an appropriate market economy. See id. While conducting NME investigations, Commerce “shall utilize, to the extent possible, the prices or costs of [FOPs] in one or more market economy countries that are[:] (A) at a level of economic development comparable to that of the nonmarket economy country, and (B) significant producers of comparable merchandise.” See 19 U.S.C. § 1677b(c)(4). The CAFC, however, reasoned that “the purpose of the statutory provisions [that is, §§ 1677b(c)(l) and (4) ] is to determine antidumping margins ‘as accurately as possible.’ ” Shakeproof Assembly Components, Div. of Illinois Tool Works, Inc. v. United States (“Shakeproof”), 268 F.3d 1376, 1382 (Fed.Cir.2001) (quoting Lasko, 43 F.3d at 1446); see also Olympia Indus., Inc. v. United States (“Olympia 1998 ”), 22 CIT 387, 390, 7 F.Supp.2d 997, 1000-01 (1998) (noting that “accuracy is the touchstone of the antidumping statute” and citing Rhone Poulenc, Inc. v. United States (“Rhone Poulenc”), 899 F.2d 1185, 1191 (Fed.Cir.1990)). Additionally, Commerce’s “task in [an NME] investigation is to calculate what ... [the] costs or prices would be [in the NME] if such prices or costs were determined by market forces.” Tianjin, 16 CIT at 940, 806 F.Supp. at 1018. 1. Commerce’s Decision to Value Material Costs for Certain Steel Inputs by Using the Prices Paid by a PRC Trading Company The Court disagrees with Timken that Commerce is required to value FOPs pursuant to § 1677b(c)(4) prior to resorting to a PRC trading company’s import prices paid to a market-economy supplier to value material costs for certain steel inputs. Specifically, the Court disagrees with Timken’s narrow reading of Lasko, 43 F.3d 1442. The Court in Lasko Metal, 16 CIT at 1081, 810 F.Supp. at 317, reasoned that “[t]he cost for raw materials from a market economy supplier, paid in convertible currencies, provides Commerce with the closest approximation of the cost of producing the goods in a market economy country.” Additionally, the CAFC observed “[w]here we can determine that a [non-market economy] producer’s input prices are market determined, accuracy, fairness, and predictability are enhanced by using those prices. Therefore, using surrogate values when market-based values are available would, in fact, be contrary to the intent of the law.” ■ Shakeproof, 268 F.3d at 1382 (emphasis in original) (quoting Lasko, 43 F.3d at 1446); accord Oscillating Fans, 56 Fed.Reg. at 55,275; see also Olympia 1998, 22 CIT at 392, 7 F.Supp.2d at 1002 (stating that “[t]he same holds true here with respect to the trading company data”). Moreover, the relevant regulation provides: [Commerce] normally will use publicly available information to value factors. However, where a factor is purchased from a market economy supplier and paid for in a market economy currency, [Commerce] normally will use the price paid to the market economy supplier. In those instances where a portion of the factor is purchased from a market economy supplier and the remainder from a nonmarket economy supplier, [Commerce] normally will value the factor using the price paid to the market economy supplier. 19 C.F.R. § 351.408(c)(1). In the case at bar, “[t]he record evidence demonstrates that the Chinese trading company [that is, CMC,] purchased steel from a market-economy country, in a convertible currency.” Final Results, 63 Fed.Reg. at 63,854. Moreover, “[t]his company used a portion of the steel in its own production of TRBs but also sold a portion of the steel” to ZX and Zhejiang, the PRC producers that purchased the steel from the trading company and paid for the steel in nonmarket economy currency. Id.; see also Preliminary Results, 63 Fed.Reg. at 37,343; see also Def.’s Mem., App. Ex. 6. Based on the foregoing, the Court finds that Commerce’s decision to use the PRC trading company’s import steel price as surrogate data for ZX and Zhejiang is reasonable, is in accordance with law and is in accord with the purpose o'f the statutory provisions to 'determine antidumping margins as accurately as possible. Next, observing that § 1677b(c)(l) does not specify what constitutes “best available information,” thfe Court concludes that “ ‘[t]he statute [,therefore, does not] ... require Commerce to follow any single approach in evaluating data.’” Timken 1999, 23 CIT at 515, 59 F.Supp.2d at 1376 (quoting Olympia 1997, 21 CIT at 368, 1997 WL 181529, and citing Lasko, 43 F.3d at 1446); see also Shakeproof Assembly Components, Div. of Illinois Tool Works, Inc. v. United States, 23 CIT 479, 481, 59 F.Supp.2d 1354, 1357 (1999), aff'd, Shakeproof, 268 F.3d 1376 (stating that “[t]he statute requires Commerce to use the best available information, but does not define that term” and pointing out that “ ‘[t]he relevant statute does not clearly delineate how Commerce should determine what constitute the [best available information,]’ ” (quoting Olympia 1998, 22 CIT at 389, 7 F.Supp.2d at 1000)). During the POR, Commerce utilized a three-pronged test in assessing the reliability of the PRC ■ trading company’s import prices. See Final Results, 63 Fed.Reg. at 63,854. Specifically, Commerce examined: “(1) the value and volume of steel imports, (2) the type and quality of the imported steel, and (3) consumption of imported steel by the NME producer.” Id. Applying the three-pronged test to the case at bar, Commerce stated: Based on the invoices for the imported steel, and the specifications of the steel sourced by the factories domestically, [Commerce] conclude[d] that the imported steel is of the same grade and has the same range of sizes .as steel that the NME manufacturers used to produce the subject merchandise. Regarding the value of the steel imported by the trading company, [Commerce] found that the price paid by the trading company is within the range of prices created by the actual steel prices paid by [the] PRC producers and [Commerce’s] surrogate value. Consequently, the price paid by the PRC trading company is not aberrational. With respect to volume and consumption of steel by the NME producer, [Commerce] note[s] that the amount of steel imported by the trading company was significant and that the NME producer in question consumed a significant amount of imported steel to produce the subject merchandise. Id. While it is possible that Timken’s proposed factors could indeed have better assessed the reliability of trading company import prices, the Court’s “duty is not to weigh the wisdom of, or to resolve any struggle between, competing views of the public interest, but rather to respect legitimate policy choices made by the agency in interpreting and applying the statute.” Suramerica, 966 F.2d at 666. The Court, therefore, affirms Commerce’s use of its three-pronged test in assessing the reliability of trading company import prices as reasonable and in accordance with law. 2. Commerce’s Decision to Value Material Costs for Certain Steel Inputs by Using the Prices Paid by a PRC Bearing Producer The Court disagrees with Timken’s argument that since Commerce did not use the mode of examination offered by Timken on the issue, that is, whether prices paid by a PRC bearing manufacturer, Luoyang, to market-economy suppliers were market driven, Commerce’s determination to value certain steel inputs by using the prices paid by Luoyang was contrary to § 1677b(c)(l) and unsupported by substantial evidence. The Court is not persuaded by Timken’s argument that “as [Commerce] evaluates market-economy prices to determine whether they are reliable in a market-economy case, [Commerce] should [use the same mode to] evaluate those prices to determine whether they are reliable in [an] NME case.” Timken’s Mem. at 41. As Lasko Metal stated, “[t]he cost for raw materials from a market economy supplier, paid in convertible currencies, provides Commerce with the closest approximation of the cost of producing the goods in a market economy country.” 16 CIT at 1081, 810 F.Supp. at 317 (emphasis supplied); see also Shakeproof 268 F.3d at 1382, “[w]here we can determine that a [non-market economy] producer’s input prices are market determined, accuracy, fairness, and predictability are enhanced by using those prices. Therefore, using surrogate values when market-based values are available would, in fact, be contrary to the intent of the law.” (emphasis in original) (quoting Lasko, 43 F.3d at 1446); accord Oscillating Fans, 56 Fed.Reg. at 55,275. Therefore, the cost for raw materials from a market-economy supplier, paid in convertible currency, con-statutes an alternative market-driven price for the purpose of valuation. During the POR, Commerce determined that the import prices paid in hard currency by Luoyang (that is, a PRC bearing producer) to a market-economy supplier represented the “best available information” to value material costs for certain steel inputs. Commerce indicates that Luoyang’s “November 12, 1997, submission included a contract between Luoyang and a market economy supplier for the purchase of steel used in the production of bearing cages. The contract showed a price in U.S. dollars.” Def.’s Mem., App. Ex. 6 at 1; see also Def.’s Proprietary Ex. 1 (providing a copy of the November 12, 1997 contract). Based on the foregoing, the Court finds that Commerce’s determination to value certain steel inputs by using the prices paid by Luoyang to market-economy suppliers is reasonable, is in accordance with § 1677b(c)(l) and is supported by substantial evidence. See Peer Bearing 2001, 25 CIT at -, 182 F.Supp.2d at 1305 (“ ‘[i]n the absence of a statutory mandate to the contrary, Commerce’s actions must be upheld as long as they are reasonable’ ”) (quoting Timken 1999, 23 CIT at 516, 59 F.Supp.2d at 1377); see also Chevron, 467 U.S. at 844-45, 104 S.Ct. 2778. Similarly, the Court is not persuaded by Timken’s argument that Commerce was obligated to examine the volume and frequency of Luoyang’s market-economy purchases. As Commerce correctly notes, “[t]he authorities relied upon by Timken reveal [conversely,] that it is [Commerce’s] practice to consider the volume of market-economy purchases for purposes of determining whether to value domestically-purchased inputs based upon the value of imports from a market-economy country.” Def.’s Mem. at 37 (citing