Full opinion text
OPINION TSOUCALAS, Senior Judge. This consolidated action concerns the claims raised by plaintiff and defendant-intervenor, Luoyang Bearing Factory (“Luoyang”), and defendant-intervenor and plaintiff, The Timken Company (“Timken”), who move 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 1997-1998 Anti-dumping Duty Administrative Review and Final Results of New Shipper Review of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From the People’s Republic of China {“Final Results”), 64 Fed.Reg. 61,837 (Nov. 15, 1999). Specifically, Luoyang contends that Commerce erred in selecting, for valuing the bearing quality steel bar used to manufacture tapered roller bearings (“TRBs”) cups and cones, export data from Japan to India, rather than reviewing and using People’s Republic of China (“PRC”) trading company import data. Timken contends that Commerce erred in: (1) including “consumption of traded goods” in Indian bearing producers’ direct input costs when calculating the overhead, selling, general and administrative expenses (“SG & A”), and profit rates; (2) selecting, for valuing PRC labor costs, the wage rates in Chapter 5 of the International Labor Office’s (“ILO”) 1998 Yearbook of Labor Statistics (“1998 Yearbook”) rather than the labor costs reported in Chapter 6A of the ILO’s 1998 Yearbook; (3) valuing certain steel inputs by using the price paid by a PRC bearing producer to a market-economy supplier; and (4) excluding the annual report data of the National Engineering Company (“NEI”) in Commerce’s determination of overhead, SG & A and profit rates. BACKGROUND This case concerns the antidumping duty order on TRBs and parts thereof, finished and unfinished, from the PRC for the period of review (“POR”) covering June 1, 1997, through May 31, 1998. See Final Results, 64 Fed.Reg. at 61,837. On July 8, 1999, Commerce published the preliminary results of the subject review. See Preliminary Results of 1997-1998 Antidumping Duty Administrative Review and Partial Recission of Antidumping Duty Administrative Review of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From the People’s Republic of China {“Preliminary Results”), 64 Fed.Reg. 36,853. Commerce published the Final Results on November 15, 1999. See Final Results, 64 Fed.Reg. 61,837. JURISDICTION The Court has jurisdiction over this matter pursuant to 19 U.S.C. § 1516a(a) (2000) and 28 U.S.C. § 1581(c) (2000). STANDARD OF REVIEW In reviewing a challenge to Commerce’s final determination in an antidumping 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, 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, 8 CIT 20, 22, 590 F.Supp. 1273, 1276 (1984) (quoting Penntech Papers, Inc. v. NLRB, 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., 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’ 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 India as a Surrogate Value for Bearing Quality Steel Bar Used by a PRC Producer to Manufacture TRB Cups and Cones A. Background 1. Statutory Background An antidumping margin is the difference between normal value (“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(e), 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(c)(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, 16 CIT 931, 940—41, 806 F.Supp. 1008, 1018 (1992); Timken Co. v. United States, 16 CIT 142, 143-44, 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). 2. Factual Background During this review, Commerce initially chose secondary surrogate data (that is, export data from Japan to Indonesia) over data from the primary surrogate country (that is, India) to value bearing quality steel bar used by Luoyang, a PRC producer, in the manufacturing of TRB cups and cones. See Preliminary Results, 64 Fed.Reg. at 36,856; see also Def.’s Mem. Opp’n Luoyang’s Mot. J. Agency R. (“Def.’s Mem. Opp’n Luoyang”), App. Ex. 4. In the Preliminary Results, Commerce also determined that it would use export data from Japan to Indonesia to value the steel bar purchased by Luoyang from a PRC trading company rather than that “trading company[’s] prices.” Preliminary Results, 64 Fed.Reg. at 36,856. Commerce explained that in order to value the steel bar used by Luoyang to manufacture TRB cups and cones, Commerce compared several data sources (including: (1) Indian import statistics; (2) export data from Japan to India; (3) Indonesian import statistics; and (4) export data from Japan to Indonesia) to the United States import statistics for the Harmonized Tariff Schedule (“HTS”) category which “isolates bearing quality steel used in the production of cups and cones and has been used for comparison purposes in past reviews.” Def.’s Mem. Opp’n Luoy-ang, App. Ex. 4 at 4 (citing Final Results of1996-1997 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 (“10th Annual Review”), 63 Fed.Reg. 63,842, 63,-845 (Nov. 17, 1998)). Commerce reasoned that it decided to use export data from Japan to Indonesia to value steel bar used in the production of TRB cups and cones 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; and (2) when compared with the United States import statistics “the[ ] Indian values [were] too high to be considered a reliable indicator of the value of bearing quality steel used for the production of cups and cones.” Def.’s Mem. Opp’n Luoyang, App. Ex. 4 at 4. Similarly, Commerce determined that: (1) export data from Japan to India was unreliable because “the prices [were] too high, when compared to the U.S. benchmark,” id.; and (2) “[although ... Indonesian [import statistics] [were] closer to the U.S. benchmark in terms of price than the Indian values, like the Indian data, the Indonesian import statistics d[id] not provide a further breakdown of the aforementioned Indonesian basket category.” Id. at 4-5. Commerce, however, re-examined the matter after considering comments made by Timken, namely, that Commerce can use a “range of [United States import] prices contained in HTS category 7228.30.20 ... to gauge the reliability of Indian import values.” Final Results, 64 Fed.Reg. at 61,839. Upon examining the United States import data from HTS category 7228.30.20, Commerce determined that during the POR, “the range of prices from the countries with the most significant volumes of sales [was] approximately $642 [per metric ton (“MT”) ] to $834 [per MT].” Id. In the Final Results, Commerce compared Indian import data to the range of United States prices and found that: (1) as “in the past, [Commerce] [was] unable to isolate bearing quality steel in Indian import category 7228.30 because none of the eight-digit sub-categories within 7228.30 specifically include bearing quality steel bar,” id. at 61,839^40; and (2) although the “ ‘Others’ category, 7228.3019, could contain the type of steel [at issue,] ... the Indian values continue to be unreliable because the values for these imports remain significantly higher than any price in the U.S. import range.” Id. at 61,840. Since the Indian import data was unreliable, Commerce then proceeded to examine export data from Japan to India. Id. Commerce observed that the export data from Japan to India “f[e]ll within the range of the values in the U.S. [benchmark] category,” 7228.30.20, that is, the value of steel imported into the United States during the POR which ranged from $642 per MT to $834 per MT. Id. Consequently, Commerce concluded that export data from Japan to India would constitute the best available information 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 values contained in ... [the United States] benchmark category, [Commerce] believe[s] that these data are the best alternative for valuing steel used in the production of cups and cones. It is [Commerce’s] stated preference to use information from its primary surrogate to the extent possible.... Because these data relate to [Commerce’s] primary surrogate and are within the price range of the U.S. benchmark category, [Commerce] ha[s] not analyzed data from [Commerce’s] secondary surrogate, Indonesia, to find a value for steel used to produce cups and cones. Final Results, 64 Fed.Reg. at 61,840. Commerce refused to use Luoyang’s PRC trading company import prices to value the bearing quality steel bar used in the production of the subject merchandise at issue. See id. at 61,845. Commerce pointed out: [Commerce] recognize[s] that in [Olympia Indus., Inc. v. United States (“Olympia 1999”), 23 CIT 80, 36 F.Supp.2d 414 (1999) ], the Court, in dicta, stated that Commerce must test the reliability of the trading company value in order to determine whether it comprises the best available information for purposes of the FOP calculation. However, Commerce respectfully disagrees with the Court’s interpretation of the statute. As [Commerce] stated in [Commerce’s] ... Final Results of Re-determination Pursuant to Court Remand of Olympia Indus., Inc. v. United States [ (“Olympia 1998”), 22 CIT 387, 7 F.Supp.2d 997 (1998) ] ..., nothing in the Lasko, [43 F.3d 1442,] decision alters the statutory mechanism for selection of surrogate values. In Lasko, the Court [of Appeals for the Federal Circuit (“CAFC”) ] merely recognized that, where the actual cost to the producer was a market economy price (and paid in a market economy currency), the actual cost to the producer was better information than a surrogate value. See Lasko, 43 F.3d at 1446. The selection of surrogate values is governed by section [1677b(c)(4) ] ..., which, as discussed above, establishes a preference for values from a comparable market economy that is a significant producer of comparable merchandise. Had Congress intended a preference for using import prices into the NME as surrogate values, it could easily have stated this preference. Id. (emphasis in original). B. Contentions of the Parties 1. Luoyang’s Contentions Luoyang contends that Commerce’s decision to value bearing quality steel bar by using export data from Japan to India was not supported by substantial evidence and was contrary to law. See Pl.’s Mem. P. & A. Supp. Rule 56.2 Mot. J. Agency R. (“Luoyang’s Mem.”) at 10-15, 17-81; Luoyang’s Reply Br. (“Luoyang’s Reply”) at 2-15. In particular, Luoyang argues that Commerce’s refusal to review PRC trading company import prices “and to determine whether that data constituted the best available information for purposes of the FOP analysis,” Luoyang’s Mem. at 17, was (1) an “[un]reasonable interpretation of [19 U.S.C. § 1677b(c)(1) ],” id. at 21 (citing Olympia 1998, 22 CIT at 392, 7 F.Supp.2d at 1002); (2) an “utter disregard” of Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, Luoyang’s Mem. at 17; and (3) inconsistent with Commerce’s prior administrative determination in the 10th Annual Review, 63 Fed.Reg. at 63,853-54. See Luoyang’s Mem. at 24-27. Luoyang maintains that the PRC trading company import data constitutes the “best available information” because “ ‘[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,’ ” Luoyang’s Mem. at 23 (quoting Lasko Metal Prods., Inc. v. United States (“Lasko Metal”), 16 CIT 1079, 1081, 810 F.Supp. 314, 317 (1992), aff'd, Lasko, 43 F.3d 1442), and “ ‘[t]he same holds true ... with respect to the trading company data.’ ” Luoyang’s Mem. at 23 (quoting Olympia 1998, 22 CIT at 392, 7 F.Supp.2d at 1002). Responding to Commerce’s argument that Commerce’s “policy [i]s to evaluate inputs sourced from market-economy suppliers only when those inputs are actually purchased by the NME [producer], and not when purchased by NME trading companies,” Luoyang’s Mem. at 19, Luoyang asserts that: (1) 19 C.F.R. § 351.408(c)(1) (1998) does not “limit the use of NME import prices from market economy countries to those paid by the producer,” Luoyang’s Reply at 4; (2) both Olympia 1999, 23 CIT at 83, 36 F.Supp.2d at 417, and Olympia 1998, 22 CIT at 390, 7 F.Supp.2d at 1001, require Commerce, pursuant to 19 U.S.C. § 1677b(c)(1), to review PRC trading company import prices and to determine whether that data constitutes the best available information for the FOP analysis, see Luoyang’s Mem. at 20; (3) “Commerce used trading company prices to value factors of production” in the 10th Annual Review, 63 Fed.Reg. at 63,854, Luoyang’s Reply at 4; (4) although the language in “the commentary accompanying the promulgation of [19 C.F.R. § 351.408(c)(1) ] noted that the NME buyer should be the ‘producer,’ ” id., “Commerce’s use of the phrase ‘normally’ ” means that Commerce did not choose to limit its evaluation of inputs sourced from market-economy suppliers solely to those inputs actually purchased by an NME producer, id. at 5; and (5) 19 U.S.C. §§ 1677b(c)(1) and (c)(4), the legislative history of these provisions and Lasko, 43 F.3d 1442, do not prohibit the use of trading company import prices to value steel bar used in the production of TRB cups and cones. See Luoyang’s Reply at 5-7. Luoyang, therefore, argues that a remand is necessary so that Commerce, by applying the three-pronged test approved in Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, would review and assess the reliability of the PRC trading company import prices as a surrogate to value all the bearing quality steel bar used by Luoyang to manufacture TRB cups and cones and, if Commerce “finds that the data is not ‘aberrational’ and ... me[ets] the requirements of the Olympia [1999] reliability test,” to use the PRC trading company data to value all of the subject merchandise at issue. Luoyang’s Mem. at 31. In the alternative, Luoyang asserts that the PRC trading company data should be used as a surrogate to value “the steel Luoyang purchased through the trading company and actually used in the manufacture of those subject cups and cones.” Id. Next, Luoyang argues that Commerce erred in selecting export data from Japan to India under HTS category 7228.30.900 to value the subject merchandise at issue because that data is not an appropriate surrogate. See id. at 27-29; accord Luoy-ang’s Reply at 8-12. In particular, Luoy-ang maintains that: (1) “the surrogate values based on ... [export data from Japan] to India represent values for steel in category 7228.30.900 which could include the type of steel used to produce the cups and cones, but which in fact also may not include the type of steel used,” Luoyang’s Mem. at 27 (emphasis in original) (citing Final Results, 64 Fed.Reg. at 61, 840); and (2) the export data from Japan to India fell outside the United States benchmark range of $642 per MT to $834 per MT. See Luoyang’s Reply at 8-9. Responding to Commerce’s statement that “Commerce’s regulations give preference to the use of one surrogate country” to value all factors of production, Luoyang argues that there is no such restriction. Id. at 9; see also Luoyang’s Reply at 10-11 (citing 10th Annual Review, 63 Fed.Reg. at 63,846; Final Results of Antidumping Administrative Review of Tapered Roller Bearings and Parts Thereof, Finished and Unfinished, From the People’s Republic of China, 62 Fed.Reg. 61,276, 61,282 (Nov. 17, 1997); and Timken Co. v. United States, 69 F.Supp.2d 1371 (CIT 1999)[sic]. ) Luoyang, therefore, asserts that if PRC trading company import prices are not used as a surrogate, Commerce should use export data from Japan to Indonesia over export data from Japan to India as a surrogate to value the subject merchandise at issue. See Luoyang’s Mem. at 32. Alternatively, Luoyang contends that if the Court sustains Commerce’s use of export data from Japan to India as a surrogate to value the subject merchandise at issue, the values for January 1998 and March 1998 should be excluded because they are aberrational. See id. 2. Commerce’s Contentions Commerce responds that its decision to use export data from Japan to India to value bearing quality steel bar used by Luoyang to manufacture TRB cups and cones is supported by substantial evidence and otherwise in accordance with law. See Def.’s Mem. Opp’n Luoyang at 15-28. Specifically, Commerce maintains that its selection of the export data from Japan to India as the “best available” surrogate value should be sustained because that data represents “ ‘a category which would include the type of bearing quality steel bar [used in the production of the subject merchandise]’; and ... ‘these Japanese export prices to India fall within the range of the values in the [United States benchmark].’ ” Def.’s Mem. Opp’n Luoyang at 18 (quoting Final Results, 64 Fed.Reg. at 61,840). Responding to Luoyang’s argument that “Commerce’s selection of [export data from Japan to India] is erroneous because it ‘only theoretically includes bearing steel prices,’” Commerce maintains that Luoyang’s argument is merely a crafty restatement of “Commerce’s own statement” aiming to distort the gist of Commerce’s conclusion. Def.’s Mem. Opp’n Luoyang at 18. With respect to Luoyang’s argument that the export data from Japan to India is not a reliable surrogate, Commerce points out that “ ‘[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 19 (quoting Novachem, Inc. v. United States, 16 CIT 782, 786, 797 F.Supp. 1033, 1037 (1992)). Additionally, Commerce argues that its decision to reject the PRC trading company data as an alternative for valuing the bearing quality steel bar used in the production of the subject merchandise at issue was in accordance with law. See Def.’s Mem. Opp’n Luoyang at 20-28. Relying on Lasko, 43 F.3d 1442, and 19 C.F.R. § 351.408(c)(1), Commerce asserts that the transaction involving the PRC trading company’s purchase of the steel bar at issue from a market-economy country does not “qualiffy] as a market economy purchase.” Id. at 22. In particular, Commerce maintains that: (1) “the commentary accompanying the promulgation of [19 C.F.R. § 351.408(c)(1)] makes clear that Commerce intended to use a market economy price to value a factor of production only when the PRC producer itself made the purchase,” id. (citing Final Rule, 62 Fed.Reg. at 27,366); and (2) “the use of the price paid by Luoyang to the trading company in question would be contrary to congressional intent because that [NME] transaction is not reliable.” Def.’s Mem. Opp’n Luoyang at 24 (citing S.Rep. No. 93-1298 (1974), reprinted in 1974 U.S.C.C.A.N. 7186, 7311). Contrary to Luoyang’s argument that both Olympia 1999, 23 CIT at 83, 36 F.Supp.2d at 417, and Olympia 1998, 22 CIT 387, 7 F.Supp.2d 997, require Commerce to review PRC trading company import prices and to determine whether that data constitutes the best available information for the FOP analysis pursuant to 19 U.S.C. § 1677b(c)(1), Commerce maintains that it disagrees with those decisions and that Lasko, 43 F.3d at 1446, “ ‘merely recognized that, where the actual cost to the producer was a market economy price (and paid in a market economy currency), the actual cost to the producer was better information than a surrogate value.’ ” Def.’s Mem. Opp’n Luoyang at 25 (quoting Final Results, 64 Fed.Reg. at 61,845, emphasis in original). Commerce further maintains that it properly rejected PRC trading company import prices from its FOP analysis because “[t]his ‘actual cost’ does not exist in the trading company situation because the price paid by the trading company to the market economy supplier does not reflect the price paid by the PRC producer to the trading company.” Def.’s Mem. Opp’n Luoyang at 25. Commerce concedes that during its pri- or determination (that is, 10th Annual Review, 63 Fed.Reg. at 63,854), it adhered to Olympia 1999, 23 CIT at 83, 36 F.Supp.2d at 417, and Olympia 1998, 22 CIT 387, 7 F.Supp.2d 997, by reviewing PRC trading company import prices and determining whether that data constituted the best available information for purposes of the FOP analysis, see id. at 27. However, Commerce maintains that [h]aving reconsidered the meaning of Lasko, [43 F.3d 1442,] and the statute’s NME provisions, Commerce now views Lasko, [43 F.3d 1442] as limited to the situation involving the actual cost to the producer (not the price paid by the trading company). Commerce further views the statute itself as expressing a preference for the use of values from a comparable market economy that is a significant producer of comparable merchandise. Moreover, in [10th Annual Review, 63 Fed.Reg. 63,842], Commerce conducted its review applying its prior regulations.... The current regulations do not permit the result advocated by Luoyang. Id. at 27-28. 3. Timken’s Contentions Timken generally agrees with Commerce and maintains that Commerce’s decision to use export data from Japan to India to value the bearing quality steel bar used by Luoyang in the production of TRB cups and cones over PRC trading company import prices was supported by substantial evidence and was in accordance with law. See Timken’s Resp. Opp’n Pl.’s Mot. J. Agency R. (“Timken’s Resp.”) at 8-33. In particular, Timken argues that by selecting export data from Japan to India to value the subject merchandise at issue, Commerce “followed the statutory scheme [under 19 U.S.C. § 1677b(c)(4) and 19 C.F.R. § 351.408(c)(1) ], since [Commerce] clearly used, ‘to the extent possible,’ the ‘best available information’ as judged by the surrogate selection.” Timken’s Resp. at 9. Moreover, Timken asserts that the Court should sustain Commerce’s selection of export data from Japan to India as the “best available information” to value the subject merchandise at issue because: (1) unlike export data from Japan to India which meets the statutory preference of 19 U.S.C. § 1677b(c)(4) since it constitutes a “surrogate value[ ] from a comparable market economy that is a significant producer of comparable merchandise[,] ... there is no statutory preference, mandatory or otherwise, for the use of PRC trading company import prices,” id. at 10; (2) export data from Japan to India is “consistent with the objectives of § 1677b(c)(4) which favor the use of publicly available sources of information to value factors of production,” id. at 11, whereas “Luoyang’s PRC trading company import prices are not broad, publicly-available information from a comparably reliable, verifiable, and reusable source,” id. at 12; (8) Luoyang has failed to assert that it purchased the subject merchandise at issue from the PRC trading company in a convertible currency, see id.; and (4) Commerce’s selection of export data from Japan to India to value the bearing quality steel bar used by Luoyang to manufacture TRB cups and cones was consistent with “[t]he purpose of the antidumping statute[s] [that is, 19 U.S.C. §§ 1677b(c)(1) and (4) ] ... to calculate dumping margins as accurately as possible.” Id. (citing Lasko, 43 F.3d at 1446). Additionally, Timken maintains that Luoyang’s reliance on Lasko, 43 F.3d 1442, Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, Olympia 1998, 22 CIT 387, 7 F.Supp.2d 997, and Olympia Indus., Inc. v. United States (“Olympia 1997”), 1997 WL 181529, 21 CIT 364 (1997), is misplaced. See Timken’s Resp. at 14-26. First, referring to Lasko, 43 F.3d at 1446, and Olympia 1998, 22 CIT at 390-91, 7 F.Supp.2d at 1001, Timken asserts that the PRC trading company import prices are not actual prices but are merely surrogate values. See Timken’s Resp. at 14 n. 5. Second, Timken argues that the CAFC in Lasko, 43 F.3d at 1446, addressed “ ‘whether or not ... [Commerce was] permitted] to determine the factors of production using both surrogate country values and actual cost values,’ ” id. at 14-15 (quoting Lasko, 43 F.3d at 1445), and did not address the issue of the proper interpretation of 19 U.S.C. § 1677b(c)(4) or the use of Chinese trading company purchases as surrogates. See id. at 15. Third, Timken contends that the Olympia cases (that is, Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, Olympia 1998, 22 CIT 387, 7 F.Supp.2d 997, and Olympia 1997, 1997 WL 181529, 21 CIT 364) were “decided on [the] facts [of those cases] and did not address the proper interpretation of 19 U.S.C. § 1677b(c)(4).” Id. at 15-20. Fourth, Timken maintains that since the Court in Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, took an “additional step of disapproving [Commerce’s] interpretation of 19 U.S.C. § 1677b(c)(4)” by stating that Commerce must test the reliability of the trading company value in order to determine whether it comprises the best available information for purposes of the FOP calculation, this additional step was merely dicta and “this Court remains free to sustain” Commerce. Id. at 19-20. Finally, Timken asserts that Commerce is not required to apply the three-pronged test approved in Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, to review and assess the reliability of the PRC trading company import prices because: (1) “[t]here is no three-part ... test in the statute or regulations compelling a specific methodology to be used in selecting surrogate values,” id. at 23 (citing Lasko, 43 F.3d at 1446); and (2) Commerce, despite Commerce’s application of the three-pronged test in the 10th Annual Review, 63 Fed.Reg. 63,842, “provided a reasonable explanation ... for rejecting PRC trading company import prices.” Timken’s Resp. at 24. In the alternative, Timken argues that, if the Court remands to Commerce to review and assess the reliability of the PRC trading company import prices, Commerce should consider whether there was: (1) “a significant difference between the resale price and the PRC trading company import prices and whether that difference was sufficient to cover the trading company’s costs”; (2) “any countertrade or other 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.” Id. at 25. Moreover, Timken maintains that “[i]f the Court requires use of Luoyang’s PRC trading company import prices, those prices should not be extended to value other purchases of steel.” Id. at 26. Next, contrary to Luoyang’s argument that certain values of export data from Japan to India should be excluded because they are aberrational (that is, values for January 1998 and March 1998), Timken asserts that: (1) “the mere fact that some months were high is not a basis for exclusion,” id. at 31; (2) “in any average, some values exceed the norm, while other values are below,” id. at 32; and (3) “Luoyang cannot ‘pick and choose’ and conveniently eliminate only high values.” Id. 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, P.E. 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 refusal to review and use PRC trading company import data and Commerce’s consequential use of export data from Japan to India as a surrogate value for bearing quality steel bar used by Luoyang 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 Determination at Bar The CAFC has reasoned that “the purpose of the statutory provisions [that is, 19 U.S.C. §§ 1677b(c)(1) and (4) ] is to determine antidumping margins ‘as accurately as possible.’ ” Shakeproof Assembly Components, Div. of Illinois Tool Works, Inc. v. United States, 268 F.3d 1376, 1382 (Fed.Cir.2001) (quoting Lasko, 43 F.3d at 1446); see also Olympia 1998, 22 CIT at 390, 7 F.Supp.2d at 1000-01 (noting that “accuracy is the touchstone of the antidumping statute” and citing Rhone Poulenc, Inc. v. United States, 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. a. Commerce’s Refusal to Review and Use PRC Trading Company Import Prices The Court finds that Commerce’s refusal to review PRC trading company import prices and to determine whether that data constituted the best available information for purposes of the FOP analysis was unreasonable. Specifically, the Court disagrees with Commerce’s and Timken’s narrow reading of Lasko, 43 F.3d 1442, and 19 C.F.R. § 351.408(c)(1). 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 [it] can [be] determine[d] 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 the “same holds true here with respect to the trading company data”); Timken Co. v. United States, 26 CIT -, -, 201 F.Supp.2d 1316, 1335 (2002) (finding that “Commerce’s decision to use [a] PRC trading company’s import steel price as surrogate data for [certain PRC producers] is reasonable, is in accordance with law and is in accord with the purpose of the statutory provisions [that is, §§ 1677b(c)(1) and (c)(4) ] to determine antidumping margins as accurately as possible”). Next, observing that 19 U.S.C. § 1677b(c)(l) does not specify what constitutes “best available information,” the 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, 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 the “statute requires Commerce to use the best available information, but does not define that term” and quoting Olympia 1998, 22 CIT at 389, 7 F.Supp.2d at 1000, that “ ‘[t]he relevant statute does not clearly delineate how Commerce should determine what constitutes’ ” the best available information). While the Court finds that Commerce is not required to apply the three-pronged test approved in Olympia 1999, 23 CIT 80, 36 F.Supp.2d 414, to review and assess the reliability of the PRC trading company import prices, the Court remands this issue to Commerce with instructions to examine whether or not the PRC trading company import prices constitute the “best available information” to value either all of the subject merchandise at issue or a portion of the subject merchandise purchased by Luoy-ang through the trading company and used by Luoyang in the manufacture of TRB cups and cones and, if Commerce concludes that the PRC trading company import prices present the “best available information” for the purpose of such surrogate evaluation, to recalculate Commerce’s determination' not inconsistent with this opinion. b. Commerce’s Decision to Value Bearing Quality Steel Bar by Using Export Data from Japan to India The Court disagrees with Commerce and Timken that Luoyang is assailing not the reasoning but rather the correctness of Commerce’s result, which is outside the Court’s standard of review. See Writing Instrument Mfrs. Ass’n, Pencil Section v. United States, 21 CIT 1185, 1195, 984 F.Supp. 629, 639 (1997). During the review at issue, Commerce observed: In comparing [export data from Japan to India] to the range of values contained in the [United States] benchmark [that is, the value of steel imported into the United States during the POR under HTS category 7228.30.20 which ranged from $642 per MT to $834 per MT], [Commerce] found that these Japanese export prices to India fall within the range of the values in the [United States] category. Final Results, 64 Fed.Reg. at 61,840. Nevertheless, as Luoyang points out: The range of values for [export data from Japan] to India in HTS category 7228.30.900 was $561 per metric ton to $1,414 per metric ton and the average value was $871 per metric ton.... The average value of $871 per metric ton is not between [the United States benchmark range of] $642 per metric ton and $834 per metric ton. Luoyang’s Reply at 8-9 (emphasis in original) (citing Def.’s Mem. Opp’n Luoyang at 9). However, the Court disagrees with Luoyang that the Court should order that Commerce exclude the values for January 1998 and March 1998 from the export data from Japan to India. Luoyang may not usurp Commerce’s role as fact-finder and substitute Luoyang’s analysis for the result reached by Commerce. Next, with respect to Luoyang’s argument that Commerce should have used export data from Japan to Indonesia over export data from Japan to India as a surrogate to value the subject merchandise at issue, the Court notes that Commerce admittedly failed to review export data from Japan to Indonesia as a surrogate value. See Final Results, 64 Fed.Reg. at 61,840 (Commerce “ha[s] not analyzed data from [Commerce’s] secondary surrogate, Indonesia, to find a value for steel used to produce cups and cones”). The Court finds that Commerce’s reasoning for refusing to review the export data from Japan to Indonesia as a surrogate value was not sufficiently explained. To the contrary, it was illogical for Commerce to utilize export data from Japan to India and then to subsequently fail to review analogously structured export data from Japan to Indonesia. Based on the foregoing, the Court remands this issue to Commerce to examine if, and only if, Commerce finds that the PRC trading company import prices do not constitute the “best available information,” whether or not Indonesian data (that is, Indonesian import statistics and export data from Japan to Indonesia) constitute the “best available information” over export data from Japan to India to value the bearing quality steel bar used in the production of TRB cups and cones, and to explain, (if Commerce finds that export data from Japan to India is the “best available information,”) how the entire export data from Japan to India falls within the range of values in the United States category benchmark range. II. Commerce’s Inclusion of “Consumption of Traded Goods” in Indian Bearings Producers’ Direct Input Costs A. Background In the Final Results, Commerce designated the line item “consumption of traded goods” in certain Indian bearings producers’ 1997-98 annual reports as material costs to be included in direct input costs that were used as the denominator of the overhead, SG & A, and profit rate calculations. See 64 Fed.Reg. at 61,844; see also Def.’s Mem. Partial Opp’n Timken’s Mot. J. Agency R. (“Def.’s Mem. Partial Opp’n Timken”), App. Ex. 5 at 3-4. Specifically, Commerce explained that [Commerce] disagree^] that [Commerce] should exclude “Consumption of Traded Goods” from the direct input costs calculated for the Indian bearings producers. Although the CIT did instruct [Commerce] to exclude the purchases of traded goods from the cost of manufacture with respect to the 1994-95 administrative review of TRBs in Timken v. U.S., [23 CIT 509, 59 F.Supp.2d 1371], that ruling is not yet final. Thus, [Commerce is] not compelled to apply the court-directed methodology in these reviews. [Commerce] further note[s] that [Commerce] excluded “Consumption of Traded Goods” from [Commerce’s] direct input costs calculation in the preliminary results of the new shipper review. Again, because Timken v. U.S., [23 CIT 509, 59 F.Supp.2d 1371] is not yet final, [Commerce] ha[s] revised [Commerce’s] preliminary calculations to include the traded goods amount in direct input costs. Final Results, 64 Fed.Reg. at 61,844. B. Contentions of the Parties Timken asserts that the “consumption of traded goods” should be excluded from the direct input costs denominator used in the overhead, SG & A and profit rate calculations. See Mem. P & A Supp. Timken’s Mot. J. Agency R. (“Timken’s Mem.”) at 2, 22-23. Relying on Timken 1999, 23 CIT at 518-19, 59 F.Supp.2d at 1378-79, Timken maintains that this Court: (1) “rejected [Commerce’s] inclusion of the line item for ‘traded goods’ in material costs used to calculate overhead, SG & A and profit ratios in its review of the 1994-95 period,” id. at 22; and (2) “agreed that [Commerce] had failed to demonstrate how these already manufactured goods constitute a material cost incurred in manufacturing the subject merchandise.” Id. (internal quotations omitted). Moreover, contrary to Commerce’s argument that this Court’s decision in Timken 1999, 23 CIT 509, 59 F.Supp.2d 1371, is not yet final, Timken points out that “this Court’s decision in Timken [1999], did become final and was not appealed.” Id. (citing Timken Co. v. United States, Slip. Op. 00-13, 2000 WL 174972, *1 (Feb. 8, 2000)). Timken, therefore, argues that this case should be remanded to Commerce with instructions that Commerce exclude “consumption of traded goods from the cost of materials used in the denominator of the overhead, SG & A, and profit ratios” and recalculate the dumping margins accordingly. Timken’s Mem. at 23. Commerce agrees that a remand is necessary to exclude the “consumption of traded goods” from Commerce’s overhead, SG & A and profit rate calculations since “consumption of traded goods utilized by Commerce in the Final Results, [64 Fed.Reg. at 61,844,] are similar in nature to the ‘purchases of traded goods’ reviewed by the Court in Timken [1999].” Def.’s Mem. Partial Opp’n Timken at 21. C. Analysis In Timken 1999, 28 CIT 509, 59 F.Supp.2d 1371, this Court determined that “Commerce failed to demonstrate how these already manufactured goods [that is, purchases of traded goods] constitute a material cost incurred in manufacturing the subject merchandise.” Id., 23 CIT at 519, 59 F.Supp.2d at 1379. Because Commerce’s inclusion of the “consumption of traded goods” in Commerce’s overhead, SG & A and profit rate calculations, and the parties’ arguments are practically identical to those presented in Timken 1999, 23 CIT 509, 59 F.Supp.2d 1371, the Court adheres to its reasoning in Timken 1999, and remands this issue with instructions that Commerce exclude “consumption of traded goods” from Commerce’s overhead, SG & A and profit rate calculations and to recalculate the dumping margins accordingly. III. Commerce’s Use of Wage Rates from Chapter 5 of the International Labor Office’s 1998 Yearbook of Labor Statistics to Value Labor A. Background During the POR, Commerce, pursuant to 19 C.F.R. § 351.408(c)(3) (1998), used a regression-based wage rate to value labor costs. See Preliminary Results, 64 Fed.Reg. at 36,856. Commerce explained that [b]ecause of the variability of wage rates in countries with similar levels of per capita Gross Domestic Product (GDP), section 351.408(c)(3) of [Commerce’s] regulations (19 CFR Part 351, April 1998) requires the use of a regression-based wage rate. Therefore, to value the labor input, [Commerce] used the PRC regression-based wage rate published by Import Administration on its website, which was last revised on May 1999. The source of the wage rate data on the Import Administration’s website is the 1998 Yearbook of Labour Statistics, published by the International Lab-our Office (ILO) ... Chapter 5: Wages in Manufacturing. Def.’s Mem. Partial Opp’n Timken, App. Ex. 3 at 4. In the Final Results, Commerce valued the PRC labor costs by utilizing the wage rates reported in Chapter 5 of the 1998 Yearbook instead of the labor costs reported in Chapter 6A of the 1998 Yearbook as proposed by Timken. Commerce determined that [Commerce’s] regulations at section 351.408(c)(3) state that “[Commerce] will use regression-based wage rates reflective of the observed relationship between wages and national income in market economy countries.” Therefore, to value the labor inputs[,] ... [Commerce] applied the PRC regression-based wage rate published by the Import Administration on its website, which was last revised in May 1999. With respect to [Timken’s] argument, [Commerce] disagree^]. The [1998 Yearbook] states that the wage rates, used to calculate the regression analysis are comprehensive wage rates which also includes overtime, bonuses, holiday pay, incentive pay, pay for piecework, and cost-of-living allowances. See Magnesium from the People’s Republic of China, Final Results of Antidumping Duty New Shipper Administrative Review, 68 Fed.Reg. 3085, 3091 (Jan. 21, 1998). Thus, for purposes of these final results, [Commerce] ha[s] not adjusted the regression-based wage rate used in the preliminary results. Final Results, 64 Fed.Reg. at 61,842. B. Contentions of the Parties Timken contends that Commerce’s decision to value PRC labor costs by using the wage rates in Chapter 5 of the 1998 Yearbook rather than the labor costs in Chapter 6A of the 1998 Yearbook was not supported by substantial evidence and was contrary to law. See Timken’s Mem. at 23-25. In particular, Timken argues that: (1) Commerce’s use of Chapter 5 wage rates was a departure from Commerce’s consistent practice of “interpret[ing] [19 U.S.C. §§ 1677b(c)(l) and (3) ] ... as calling for the use of fully-loaded costs, including all the costs and benefits in addition to basic wage, of employing labor,” Timken’s Mem. at 23 (citing I0Th Annual Review, 63 Fed.Reg. at 63,848, and Final Results and Partial Recission of Antidumping Duty Administrative Review of Maganese Metal From the People’s Republic of China, 63 Fed.Reg. 12,440, 12,446 (March 13, 1998)); see also, Reply Br. Timken Co. (“Timken Reply”) at 2-4; (2) “the record is devoid of evidence that Chapter 5 wage rates [of the 1998 Yearbook] are comprehensive,” Timken’s Mem. at 24, because “[f]or example, the wage rates in Chapter 5 did not include additional costs for employers’ social security expenditures or welfare services ... [and these] costs [are not] captured anywhere else in [Commerce’s] calculation,” Timken’s Reply at 6-7; and (3) “[a] broad reading of ‘wage rates’ in § 351.408(c)(3), which calls for use of fully-loaded labor costs when available, would save the regulation from running afoul of the statutory scheme.” Timken’s Reply at 9 (emphasis omitted). Timken, therefore, asserts that a remand is necessary so that Commerce can value PRC labor costs using Chapter 6A of the 1998 Yearbook or, in the alternative, “explain why [Commerce’s] departure from established practice was lawful in the face of the statute and statutory scheme.” Timken’s Reply at 8; see also Timken’s Mem. at 25. In the alternative, Timken argues that, if the Court sustains Commerce’s use of Chapter 5 wage rates, the Court should “require [Commerce] to account for all labor costs not included in Chapter 5 wage rates elsewhere in [Commerce’s] calculation.” Timken’s Reply at 9. Additionally, Timken maintains that Commerce’s “labor cost methodology should be the same for calculating constructed value and factors of production.” Id. at 5; see also id. at 9 (stating that “the statutory scheme calls for costs included in constructed value and factors of production to be the same”). Responding to Commerce’s argument that 19 U.S.C. § 1677b(c)(1), 19 U.S.C. § 1677b(c)(3), and 19 C.F.R. § 351.408(c)(3) do not require Commerce to use comprehensive costs in valuing labor, Timken maintains that this argument “must be rejected as a post hoc rationalization because [Commerce] did not take this position” in Final Results, 64 Fed.Reg. at 61,842. Id. at 7. In response, Commerce asserts that its decision to use Chapter 5 wage rates to value PRC labor costs is supported by substantial evidence and is in accordance with law. See Def.’s Mem. Partial Opp’n Timken at 21-26. Commerce argues that 19 U.S.C. § 1677b(c)(3) does not require Commerce “to utilize comprehensive costs for purposes of valuing labor [but][r]ather, the statute merely directs [Commerce] to value the ‘hours of labor required’ as part of the [FOP] utilized in producing the merchandise.” Id. at 25. Commerce further argues that Commerce complied with 19 C.F.R. § 351.408(c)(3) in using Chapter 5 wage rates rather than Chapter 6A labor costs to value PRC labor costs because: (1) 19 C.F.R. § 351.408(c)(3) “does not provide that Commerce must utilize comprehensive labor costs [but][i]nstead, that ... ‘[Commerce shall] use regression-based wage rates,’ ” id. (quoting 19 C.F.R. § 351.408(c)(3)) (emphasis omitted); (2) 19 C.F.R. § 351.408(c)(3) is silent as to the particular source Commerce is to use to value wages, see Def.’s Mem. Partial Opp’n Timken at 26; and (3) Commerce’s preference to use Chapter 5 wage rates over Timken’s preference to use Chapter 6A labor costs to value PRC labor costs should be sustained because “the Court should defer to Commerce’s interpretation of [the] regulation, not Timken’s interpretation.” Id. C. Analysis As a preliminary matter, the Court finds that Commerce’s decision to use the wage rates of Chapter 5 of the 1998 Yearbook over the labor costs of Chapter 6A of the 1998 Yearbook to value the PRC labor costs was a justifiable change of methodology as long as such change in position was reasonably supported by the record. See supra Discussion Part I, Cl (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 and that Commerce shall value the reported FOPs based on the best available information regarding the values of FOPs in an appropriate market economy. See 19 U.S.C. § 1677b(c)(1). According to section 1677b(c)(3), the FOPs to be utilized in valuing merchandise from an NME include, but are not limited to: “(A) hours of labor required, (B) quantities of raw- materials employed, (C) amounts of energy and other utilities consumed, and (D) representative capital cost, including depreciation.” The statute further provides that 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). Moreover, the relevant regulation provides: [f]or labor, [Commerce] will use regression-based wage rates reflective of the observed relationship between wages and national income in market economy countries. [Commerce] will calculate the wage rate to be applied in nonmark-et economy proceedings each year. The calculation will be based on current data, and will be made available to the public. 19 C.F.R. § 351.408(c)(3). In the case at bar, Commerce used the wage rates reported in Chapter 5 of the 1998 Yearbook, which were “made available to the public by means of Import Administration’s website,” to value the PRC labor costs. Def.’s Mem. Partial Opp’n Timken at 24. “The [1998 Yearbook] states that the wage rates [that is, the wage rates of Chapter 5], used to calculate the regression analysis are comprehensive wage rates which also includes overtime, bonuses, holiday pay, incentive pay, pay for piecework, and cost-of-living allowances.” Final Results, 64 Fed.Reg. at 61,842. Based on the foregoing, the Court finds that Commerce’s decision to value PRC labor costs by using wage rates reported in Chapter 5 of the 1998 Yearbook over the labor costs reported in Chapter 6A of the 1998 Yearbook was reasonable, in accordance with law (that is, Sections 1677b(c)(1), (c)(3), (c)(4) and 19 C.F.R. § 351.408(c)(3)), supported by substantial evidence, and in accord with the purpose of the statutory scheme of determining antidumping margins as accurately as possible. See Peer Bearing Co. v. United States, 25 CIT -, -, 182 F.Supp.2d 1285, 1305 (2001) (pointing out that “ ‘[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, Skidmore v. Swift & Co., 323 U.S. 134, 139-40, 65 S.Ct. 161, 89 L.Ed. 124 (1944). IY. Commerce’s Use of a PRC Producer’s Market Economy Import Data A. Background In the Preliminary Results, Commerce stated that a PRC producer purchased part of its steel sheet directly from a market-economy supplier and paid for such steel w