Full opinion text
Opinion and Order EATON, Judge. This case is before the court following remand to the United States International Trade Commission (“ITC”). In Nippon Steel Corp. v. United States, 26 CIT -, 2002 WL 31873457 (Dec. 24, 2002) (“Nippon III”), this court remanded the ITC’s sunset review determination in Grain-Oriented Silicon Electrical Steel From Italy and Japan, USITC Pub. 3396, Invs. Nos. 701-TA-355 and 731-TA-659-660 (Feb. 2001), List 1, Doc. 75 (“Final Determination”), made pursuant to 19 U.S.C. §§ 1675(c), 1675a(a) (2000). The court instructed the ITC to: (1) determine, in accordance with the court’s finding as to the meaning of “likely” within the context of ... [19 U.S.C. §§] 1675(c) and 1675a(a) [i.e., that likely means probable], whether revocation of the Subject Orders would be likely to lead to continuation or recurrence of material injury, upon consideration of the likely volume, price effect, and impact of imports of the subject merchandise on the industry; and (2) demonstrate, in conformity with this opinion, (a) that it performed the requisite analysis by considering each of the four factors outlined in 19 U.S.C. § 1675a(a)(2)(A)-(D); and (b) that it considered whether, were the Subject Orders revoked, the likely volume of imports of the subject merchandise would be significant either in absolute terms or relative to production or consumption in the United States, pursuant to 19 U.S.C. § 1675a(a)(2). Nippon III, 26 CIT at -, 2002 WL 31873457, *7. In light of its findings with respect to the ITC’s application of the likely standard and the legal sufficiency of the ITC’s analysis of likely volume, pursuant to 19 U.S.C. § 1675a(a)(2), the court did not address the parties’ substantial evidence arguments, finding that to do so at that time would have been premature. Id. at *7. In its remand determination, the ITC stated that it applied “likely” to mean “probable.” See Grain-Oriented Silicon Electrical Steel From Italy and Japan, USITC Pub. 3585, Invs. Nos. 701-TA-355 and 731-TA-659-660 (Mar.2003), List 1, Doc. 79R (“Remand Determination”) at 2 n. 6 (“For purposes of the Commission’s determinations on remand in these reviews, we apply the term ‘likely’ consistent with the Court’s instruction and with other recent decisions of the Court of International Trade which address the meaning of the term ‘likely’ as it is to be applied in five-year reviews.”) (citing Usinor Industeel, S.A. v. United States, 26 CIT -, -, 2002 WL 818240, *11 (2002); Usinor v. United States, 26 CIT -, -, 2002 WL 1998315, *22 (2002); Usinor Industeel, S.A v. United States, 26 CIT -, 215 F.Supp.2d 1356 (2002); Usinor Industeel, S.A. v. United States, 26 CIT -, 2002 WL 31864771 (Dec. 20, 2002)). With respect to its likely volume analysis, the ITC stated that it considered each of the statutory factors in 19 U.S.C. § 1675a(a)(2)(A)-(D), and found that “[b]e-cause of the nature of the GOES industry and market, ... all four factors were [not] dispositive in [its] analysis.” Id. at 3. The ITC concluded that “the likely volume of subject imports would be significant in terms of U.S. production and U.S. apparent consumption if the countervailing and antidumping duty orders were revoked.” Id. at 10-11. In addition, the ITC adopted the views expressed in the Final Determination with respect to the domestic like product, domestic industry, conditions of competition, and cumulation determinations. Id. at 2. By its Remand Determination, the ITC affirmed its original conclusion that revocation of the Subject Orders would be likely to lead to continuation or recurrence of material injury to an industry in the United States within a reasonably foreseeable time. Id. at 17. Plaintiffs Nippon Steel Corporation (“Nippon”), Kawasaki Steel Corporation (“Kawasaki”) (collectively, the “Japanese producers”), and ThyssenKrupp Acciai Speciali Terni S.p.A. (“AST” or the “Italian producer”) and Acciai Speciali Terni (USA), Inc. (collectively, “Plaintiffs”) challenge, as unsupported by substantial evidence on the record, several of the ITC’s determinations, including those relating to cumulation, likely volume, likely price .effects, and likely impact on the domestic industry. The court has jurisdiction pursuant to 28 U.S.C. § 1581(c) (2000) and 19 U.S.C. § 1516a(a)(2)(A)(i)(I). For the reasons set forth below, the court remands this matter to the ITC for further action in conformity with this opinion. Standard op Review The court will hold unlawful “any determination, finding, or conclusion found ... to be unsupported by substantial evidence on the record, or otherwise not in accordance with law....” 19 U.S.C. § 1516a(b)(1)(B)(i). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consol. Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938) (citations omitted). In conducting its review, the court’s function is not to reweigh the evidence but rather to ascertain whether the ITC’s determinations are supported by substantial evidence on the record. Matsushita Elec. Indus. Co. v. United States, 750 F.2d 927, 936 (Fed.Cir.1984). The possibility of drawing two inconsistent conclusions from the record evidence does not, in itself, prevent the ITC’s determinations from being supported by substantial evidence. Consolo v. Fed. Mar. Comm’n, 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966) (citations omitted). Discussion I. CUMULATION In a sunset review, before making its “likelihood of continuation or recurrence of material injury” determination, the ITC may, in its discretion, cumulatively assess the volume and effect of imports of subject merchandise from different countries “if such imports would be likely to compete with each other and with domestic like products in the United States market.” 19 U.S.C. § 1675a(a)(7); see also Usinor Industeel, S.A., 26 CIT at -, 2002 WL 31864771, *51 (quoting 19 U.S.C. § 1675a(a)(7)). Cumulation is prohibited where the ITC “determines that such imports are likely to have no discernible adverse impact on the domestic industry.” 19 U.S.C. § 1675a(a)(7). That is, “[t]he Commission shall not cumulate imports from any country if those imports are likely to have no discernible adverse impact on the domestic industry.” Statement of Administrative Action, accompanying H.R. Rep. No. 103-826(I), at 887, reprinted in 1994 U.S.C.C.A.N. 4040, 4212 (“SAA”) (emphasis added); see also Usinor Industeel, S.A., 26 CIT at -, 2002 WL 31864771, *5 (noting “there is no statutory provision enumerating the factors to be considered in determining whether subject imports from a particular country are likely to have no discernible impact.”). In the Final Determination, the ITC stated, (1) “that subject imports from each country would enter the U.S. market in sufficient quantities and at sufficiently low prices such that they would have a discernible adverse impact on the domestic industry,” Final Determination at 9; (2) that “there likely would be a reasonable overlap of competition ... between the subject imports themselves, if the orders are revoked,” id. at 10, and (3) that “there likely would be a reasonable overlap of competition between the subject imports [from Japan and Italy] and the domestic like product, ... if the orders are revoked,” id., and therefore exercised its discretion to cumulate the subject imports. Plaintiffs dispute the first and second of these findings. A. No Discernible Adverse Impact In determining whether imports are likely to have no discernible adverse impact on the domestic industry, the ITC, as this Court has explained, engages in a dual inquiry: [A]n affirmative finding of discernible impact is only part of the answer to the question of whether cumulation is precluded. In other words, the first question is whether the imports [from a particular country] are likely to have any [discernible] impact. If not, the ITC is precluded from cumulating. If yes, then the question remains whether that impact is also adverse. Neenah Foundry Co., 25 CIT at -, 155 F.Supp.2d at 775; Chefline Corp. v. United States, 25 CIT -, -, 170 F.Supp.2d 1320, 1331 (2001) (quoting Neenah Foundry, 25 CIT at -, 155 F.Supp.2d at 775). The likely “discernible impact” determination is not limited to an analysis of volume, as evidenced by Congress’s use, of the word “impact” in the statute, which, “in the context of U.S. unfair trade law, by any definition, encompasses more than volume of imports.” Neenah Foundry Co., 25 CIT at -, 155 F.Supp.2d at 776. That the discernible impact also must be adverse requires that the imports cause some harm. For cumulation to be warranted, however, this harm need not rise to the level of “material injury.” The ITC stated its discernible adverse impact determination as follows: Because of the conditions of competition and the current condition of the domestic industry, exports from Italy and Japan likely would have a discernible adverse impact on the domestic industry. Subject imports from Italy and Japan have remained in the U.S. market in the years since the orders were imposed, albeit at substantially reduced levels. The continuing presence of these subject imports in the domestic market indicates that subject foreign producers continue to have contacts and channels of distribution necessary to compete in the U.S. market. Industry capacity in Japan has remained large (greater than annual U.S. consumption) and industry capacity in Italy has grown since the original investigations. The GOES industries in both Italy and Japan devote considerable resources to export markets. In 1999, the share of total shipments of GOES exported from Italy was [[ ]] percent while the share of total shipments of GOES exported from Japan was [[ ]] percent. For the reasons discussed below, we believe that subject imports from each country would enter the U.S. market in sufficient quantities and at sufficiently low prices such that they would have a discernible adverse impact on the domestic industry. Final Determination at 9 (footnotes omitted) (emphasis added). Plaintiffs take issue with the ITC’s findings as to the Japanese and Italian imports’ “continuing presence” in the U.S. market, the size of GOES industry capacity in Japan and Italy, and the Japanese and Italian GOES industries’ export orientation. They argue that “[none] of these findings ... is sufficient to show that GOES imports from Italy and Japan likely would have any discernible impact — let alone a discernible adverse impact — upon the domestic industry.” Pis.’ Mem. Supp. Mot. J. Agency R. (“Pis.’ Mem.”) at 15 (emphasis in original). First, Plaintiffs argue that “record evidence does not, in fact, show that the subject producers have had such a ‘continuing presence’ [in the U.S. market] that they ‘continue to have contacts and channels of distribution necessary to compete in the U.S. market.’ ” Pls.’ Mem. at 15 (quoting Final Determination at 9). With respect to Japan, Plaintiffs argue that the record shows that Nippon and Kawasaki exported little or no GOES to the United States between 1997. and 2000 (the “Review Period”). Id. With respect to Italy, Plaintiffs contend that the record shows that “Italian producer AST had very few sales in the U.S. over the period of investigation,” i.e., “less than 85 tons of Italian imports over a 45-month period, with no sales during the first nine months of 2000.” Id. (citing Staff Report, tbl. 1-4). Second, Plaintiffs argue that the ITC’s findings that Japanese GOES industry capacity is “large” and that Italian GOES industry capacity “has grown,” without more, do not support the finding that Japanese and Italian subject imports would likely cause a discernible adverse impact. Id. at 16. According to Plaintiffs, the evidence shows that the Japanese and Italian producers “are operating at or near full capacity and will be for the foreseeable future.... ” Id. at 17. Third, Plaintiffs contend that the ITC’s finding that the Japanese and Italian GOES industries are export-oriented “is not predictive of what the size, make-up or impact of their U.S. exports likely would be if the orders were revoked.” Id. (emphasis in original). The ITC responds to each of these arguments in turn. First, the ITC contends that, with respect to “continuing presence,” “[i]t is not the amount of sales but the continuation of sales that’is of relevance.” Def.’s Mem. Opp’n Pls.’ Mot. Summ. J. Agency R. (“Def.’s Mem.”) at 18. The ITC explains: The continued sales indicate subject producers did not altogether abandon the U.S. market but continued- to- maintain ties with U.S. customers after the orders were imposed. As such,-subject producers had maintained the commercial links which would allow- them to increase imports to the U.S. market 'with relative ease if the orders were lifted. Id. at 18-19. Second, the ITC contends that the size of GOES industry capacity in Japan and Italy must be viewed against the backdrop of the prevailing conditions of competition in the industry. The ITC highlights that “GOES, steel production is relatively capital intensive” and requires manufacturers to “sustain relatively high capacity utilization rates to stay profitable.” Id. at 19. Therefore, the ITC posits, “increases of the volume of subject imports from each country would be likely.” Id. Third, the ITC argues that the Japanese and Italian GOES industries’ export orientation must also be evaluated in the context of the conditions of competition. The ITC claims that where an industry such as the GOES industry is reliant on exports to maintain its capacity utilization rates, there exists “economic incentive for subject producers to increase levels of subject imports to the higher-priced U.S. market upon revocation.” Id. at 19-20. The ITC argues that its finding “that subject imports from Japan and Italy would likely increase and be sold at price depressing levels resulting in a discernible adverse impact ... are both reasonable and supported by substantial evidence.” Id. at 21. The court does not agree that substantial evidence supports the ITC’s finding that GOES imports from Japan and GOES imports from Italy would likely have a discernible adverse impact on the domestic industry upon revocation of the Subject Orders. The court shall examine the record evidence with respect to Japan and Italy separately, to determine whether it supports the ITC’s determinations-i.e., whether “a reasonable mind might accept [the evidence] as adequate to support [the ITC’s] eonclusion[s].” Consol. Edison Co., 305 U.S. at 229, 59 S.Ct. 206. In conducting its review, however, the court “cannot evaluate the substantiality of evidence supporting an ITC determination ‘merely on the basis of evidence which in and of itself justified it, without taking into account contradictory evidence or evidence from which conflicting inferences could be drawn.’ ” Suramerica de Aleaciones Laminadas, C.A. v. United States, 44 F.3d 978, 985 (Fed.Cir.1994) (quoting Universal Camera Corp. v. NLRB, 340 U.S. 474, 487, 71 S.Ct. 456, 95 L.Ed. 456 (1951)). Rather, to determine the substantiality of the evidence, the court must also take into account “whatever in the record fairly detracts from its weight.” Universal Camera, 340 U.S. at 488, 71 S.Ct. 456; Suramerica, 44 F.3d at 985 (citing Atl. Sugar, Ltd. v. United States, 744 F.2d 1556, 1562 (Fed.Cir.1984)). With respect to the Japanese GOES imports’ “continuing presence” in the U.S. market, the evidence reveals that Japanese GOES was, in fact, sold in the United States during the Review Period, “albeit at substantially reduced levels.” Final Determination at 9. Indeed, the evidence cited by Plaintiffs shows the reduced levels of Japanese imports after imposition of the Subject Orders. See supra n. 19. This evidence supports the ITC’s finding that Japanese producers have maintained commercial contacts with U.S. customers such that the subject imports have a “continuing presence” in the U.S. market. Second, with respect to the size of GOES industry capacity in Japan, the record reasonably supports the finding that industry capacity was “large,” compared to annual U.S. consumption, during the Review Period. Compare Staff Report, tbl. I-1 (annual U.S. consumption figures) with tbl. TV-6 (annual Japanese production capacity). Third, the record supports the ITC’s finding that the Japanese producers are export-oriented. See id. at 11-22 (“The two Japanese producers’ exports of GOES to third-country markets, as a share of ... their total GOES shipments, averaged [[ ]] by quantity during [the Review] [P]eriod....”). There is, however, evidence that fairly detracts from the ITC’s finding that the Japanese GOES imports would likely have a discernible adverse impact on the domestic industry, and this evidence must be accounted for on remand. First, the most recent data with respect to capacity utilization suggests that, because the Japanese producers are operating at high capacity utilization rates, increases in volume are not at all likely. Staff Report at 11-21 (stating “the currently high level of capacity utilization suggests no ability of the Japanese producers to increase GOES exports to the United States in response to an increase in demand.” (emphasis added)); see also Usinor, 2002 WL 1998315, **12-13 (finding, inter alia, ITC’s failure to address most recent capacity utilization data rendered decision to cumulate German imports unsupported by substantial evidence). Second, according to the Staff Report, [[ ]], i.e., their European, Asian, Mexican and Canadian customers, reduce the likelihood that these producers would be able to significantly increase their imports to the United States in a reasonably foreseeable time. Staff Report at II-22. Specifically, the ITC staff concluded that the existence of such contracts indicated that exports “may not be readily available in the short run to increase GOES shipments to the United States in response to an increase in GOES demand.” Id. at II-23. Third, the ability to expand capacity was found to be limited, and the ITC itself concluded on remand that “subject producers indicate[d] that they have no plans to increase capacity within the foreseeable future.” Remand Determination at 9. With respect to Italy, the record supports the ITC’s finding that the Italian imports have maintained a continuing, although minimal, presence in the U.S. market. Staff Report at 11-19 (indicating that exports of GOES from Italy, to the United States during the Review Period accounted for [[ ]] by quantity of: total Italian shipments). The record also supports the ITC’s finding that industry capacity in Italy has grown since the original investigation. Id., tbl. IV-2. Further, the court agrees that the record substantially supports the finding that AST is export-oriented. The evidence indicates that during the Review Period, “[ejxports of GOES to third-country markets as a share of total shipment quantities averaged [[ ]].....” Id. at II-19-II-20 & tbl. IV-2. The share of the total quantity of shipments shipped in the home market during the Review Period was [[ ]]. See id., tbl. IV-2. Other record evidence; however, fairly detracts from the ITC’s finding that Italian GOES would-likely-have a'discernible adverse impact on the domestic industry. First, AST’s capacity utilization rate during the most recent period remained high, and according to the Staff Report, this “suggests that there is little ability of AST to increase exports to the United States in response to an increase in -demand.” Staff Report at II-19 (emphasis added). Second, evidence on the record suggests that the Italian producer would not likely increase its GOES production capacity due to the high costs and length of time required to do so. Id. Indeed, as with Japan, the ITC found on remand that the Italian producer “indicate[d] that [it has] no plans to increase capacity within the foreseeable future.... ” Remand Determination at 9. While substantial evidence is “something less than the weight of the evidence,” the court is not convinced that the ITC has ' sufficiently supported its discernible adverse impact findings and thus must remand the matter. Consolo, 383 U.S. at 620, 86 S.Ct. 1018; Nippon Steel Corp. v. United States Int’l Trade Comm’n, 345 F.3d 1379, 1381 (Fed.Cir.2003). The court is mindful that “the possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence”; however, the ITC must explain its findings and support them with substantial evidence in the first instance. Consolo, 383 U.S. at 620, 86 S.Ct. 1018. Here, the evidence must support a conclusion of “likely” consistent with the court’s earlier ruling on this issue, i.e., that likely means probable. In light of the evidence of record that detracts from the ITC’s findings with respect to the likely discernible adverse impact of Japanese GOES imports and the likely discernible adverse impact of Italian GOES imports, the court cannot find that substantial evidence supports these determinátions. Universal Camera, 340 U.S. at 488, 71 S.Ct. 456; Suramerica, 44 F.3d at 985. Accordingly, the court remands this matter for further consideration by the ITC. On remand, the ITC shall clearly address the following evidence and explain its effect on the ITC’s discernible adverse impact determination: (1) with respect to Japan: (a) interim 2000 capacity utilization data, indicating that it is unlikely that the Japanese producers will increase exports to the United States, see supra n. 22, (b) [[ ]], and (c) the evidence with respect to the Japanese producers’ inability to increase production capacity; and (2) with respect to Italy: interim 2000 capacity utilization data, indicating that it is unlikely that the Italian producer will increase exports to the United States, see supra n. 24, and the evidence with respect to AST’s inability to increase production capacity. In addition, as discussed supra in footnote 18, the ITC shall state with specificity which of its findings with respect to likely volume, price effects, and impact it took into consideration in arriving at its discernible adverse impact determination, including specific citation to any documents taken into consideration, and explain clearly its reasons for relying on such docmnent and its analysis in arriving at its findings. B. Likely Reasonable Overlap of Competition Between Imports from Japan and Imports ñ~om Italy Cumulative assessment of imports, pursuant to 19 U.S.C. § 1675a(a)(7), involves not only a determination of whether GOES imports from Japan and GOES imports from Italy would each likely have a discernible adverse impact on the domestic industry, but also an examination of whether “such imports would be likely to compete with each other and with domestic like products in the United States market.” 19 U.S.C. § 1675a(a)(7). The question the ITC is required to ask, when deciding whether to cumulate imports from different countries in the context of a sunset review, is whether a reasonable overlap in competition between the subject imports, and between subject imports and the domestic like product, likely would exist if the orders under review were revoked. See Wieland Werke, AG v. United States, 13 CIT 561, 563, 718 F.Supp. 50, 52 (1989); Indorama Chems. (Thail.) v. United States Int’l Trade Comm’n, 26 CIT -, -, slip op. 02-105 at 17 (Sept. 4, 2002). In making this determination, the ITC has generally considered (1) the degree of fungibility between imports from different countries and between those imports and the domestic like product, (2) the presence of sales or offers to sell imports from different countries and the domestic like product in the same geographical markets, (3) the existence of common or similar channels of distribution for imports from different countries and the domestic like product, and (4) simultaneous presence in the market. See Final Determination at 8 n. 34 (citing Wieland Werke, 13 CIT at 563, 718 F.Supp. at 52). “These factors are neither exclusive nor determinative.” Indorama Chems. (Thail.), 26 CIT at -, slip op. 02-105 at 17. As the decision to cumulatively assess the volume and effect of imports from different countries is made prospectively, in the context of a sunset review determination, the ITC also considers “other significant conditions of competition that are likely to prevail if the orders under review are revoked.” Final Determination at 8; see also Usinor Industeel, S.A., 26 CIT at -, 2002 WL 31864771, *-, slip op. 02-152 at 11. Here, Plaintiffs challenge the ITC’s finding that “there likely would be a reasonable overlap of competition ... between the subject imports [from Japan and Italy] ... if the orders are revoked.” Final Determination at 10. In its review, the ITC examined the four factors set forth in Wieland Werke. First, the ITC considered the degree of fungibility between imports from Japan and imports from Italy. The ITC recalled its findings in the original investigation leading to its conclusion that a reasonable overlap of competition between imports did not exist. The ITC originally found that “all imported Italian GOES was conventional, and all but a very small percentage was M-6 grade. By contrast, ... most Japanese GOES was high-permeability steel, with some conventional, primarily M-3 grade, GOES.” Id. at 9. This finding was important to the ITC’s finding of a lack of competition between the imports in its original investigation “because purchasers often substituted only one grade up or one grade down, and ... very few purchasers bought both the Italian and Japanese product.” Id. Second, with respect to channels of distribution, the ITC noted that it had originally found that “Japanese GOES was sold directly to transformer manufacturers, whereas Italian GOES was sold to stampers who laminated the product and then sold it to makers of small transformers or appliances.” Id. Noting that the “differences in product type and channels of distribution between recent subject imports have not changed since the original determination,” for purposes of the sunset review, the ITC nonetheless “[did] not find them significant enough to prevent [it] from concluding that there [was] likely to be a reasonable overlap of competition” between Japanese and Italian imports of GOES. Final Determination at 9-10. The ITC explained: In a five-year review, the proper focus is on the likely post-revocation behavior, and the composition of current imports, affected by the discipline of an anti-dumping or countervailing duty order, is not necessarily indicative of likely post-revocation competition. While current imports may be specialized or limited to a particular grade, subject producers in both Italy and Japan can and do produce a broad range of GOES products. Over [[ ]] of its shipments to both Canada and Mexico were of conventional GOES in 2000. For example, while Japan sells primarily high permeability GOES to the U.S. market, it also sells significant amounts of conventional GOES grades to other markets. Similarly, while Japanese producers currently sell directly primarily to end-users in the United States, this pattern of sales is likely to change with an alteration in the product mix shipped to the United States. Indeed, Japanese subject producers sell to laminators/slitters for subsequent sale of the GOES in Mexico and presumably could do so in the United States. Id. at 10 (emphasis added) (citations omitted). Thus, the ITC reversed its position from the original investigation, and concluded that a likely overlap of competition would exist between imports from Japan and Italy if the Subject Orders were revoked. 1. Fungibility Plaintiffs argue that it is unlikely that the Japanese and Italian producers will sell similar products in the U.S. market. Specifically, Plaintiffs argue that the Japanese producers do not make the type of conventional GOES used in the United States-a thin gauge GOES for use in wound core transformers-and that the record indicates that the Japanese producers do not intend to start exporting conventional GOES to the United States. Pls.’ Mem. at 11-12. Rather, Plaintiffs contend that the Japanese producers “only sought to have the subject orders removed'so as to better serve their existing customers for high-end, high-permeability GOES. ” Id. at 12 (emphasis in original) (citing ITC Hearing Tr. (Jan. 11, 2001) (“Tr.”), List 1, Doc. 56 at 159 (testimony of Mr. Mitsuru Tsukakoshi)). In addition, Plaintiffs contend that “the record. provides no basis to believe that [AST] would change its U.S. product mix.” Pis.’ Mem. at 10. Plaintiffs contend that at all times, GOES imported from Italy was conventional, and while AST is capable of producing high permeability GOES, the record suggests that it would not export high permeability GOES to the United States. Id. at 10-11 (citing, inter alia, AST’s Posthearing Br., List 1, Doc. 60, List 2, Doc. 29 at A-1 (“AST has not shipped high-permeability GOES to Mexico or Canada, even though it had the ability to do so.... AST has not sold high-permeability GOES outside of Europe.”). Plaintiffs assert that merely because “AST theoretically may be capable of changing its product mix and competing against Nippon Steel and Kawasaki for high-permeability sales in the United States (or vice-versa), [this,] without more, is an insufficient basis upon which to deem such competition likely.” Id. at 14 (citing Chefline Corp., 26 CIT at -, 170 F.Supp.2d at 1333). In sum, Plaintiffs argue that, the fact that both Japanese and Italian GOES producers “can and do produce a broad range of GOES products,” Final Determination at 10, “says very little ... about what these producers either intend to do or actually could do with respect to sales in the U.S. market if the orders were lifted.” Pls.’ Mem. at 10 (emphasis in original). The ITC contends that its fungibility finding is supported by substantial evidence, arguing that “subject producers would likely produce similar types of GOES for sale in the U.S. market,” Def.’s Mem. at 23, and that the conditions of competition make it likely that “Italian and Japanese producers will ... ship both high-permeability and conventional GOES to satisfy U.S. demand.” Id. at 24. The ITC further argues that competition between conventional and high permeability GOES will grow. According to the ITC, GOES purchasers will increase their “use of lower, less efficient, and less costly grades of GOES in transformer manufacture” as a result of the deregulation of the electric utilities in the United States. Final Determination at 14. In addition, “[r]elative decreases in prices of higher-grade GOES would likely result in a purchaser switching to a better grade in order to produce a low-efficiency transformer, as core performance could be significantly enhanced, thus heightening competition between high-permeability and conventional GOES.” Def.’s Mem. at 24. In evaluating the substantiality of the record evidence, the court looks at the record as a whole, taking into account any evidence that fairly detracts from its weight. Universal Camera, 340 U.S. at 488, 71 S.Ct. 456; Suramerica, 44 F.3d at 985 (citing Atl. Sugar, Ltd., 744 F.2d at 1562). The court recognizes, as this Court and the Court of Appeals for the Federal Circuit have recognized, the unique circumstances present in a sunset review that bear on the type of evidence produced at the administrative level: In no case will the Commission ever be able to rely on concrete evidence establishing that, in the future, certain events will occur upon revocation of an anti-dumping order. Rather, the Commission must assess, based on currently available evidence and on logical assumptions and extrapolations flowing from that evidence, the likely effect of revocation of the antidumping order on the behavior of the importers. Ugine-Savoie Imphy v. United States, 26 CIT -, -, 248 F.Supp.2d 1208, 1222 (2002) (quoting Matsushita, 750 F.2d at 933). The court nonetheless finds that it cannot sustain the ITC’s fungibility finding. While it is undisputed that the Japanese and Italian subject producers “can and do produce a broad range of GOES products,” Final Determination at 10, it is not clear that the Japanese and Italian producers would sell the same or similar product to the United States. Specifically, the following evidence detracts from such a finding. First, according to questionnaire responses submitted by the Japanese producers with respect to demand factors, the type of conventional GOES they export to third country markets is a thicker gauge than the GOES favored by U.S. purchasers, and “not compatible with the [conventional GOES] used in the United States.” Pls.’ Mem. at 11; Japanese Producers’ Prehear-ing Br., List 1, Doc. 50, List 2, Doc. 14 at 32; [[ ]] Foreign Producer Questionnaire Resp., List 2, Doc. 59 at 44 (indicating [[ ]]). Second, the testimony of Mr. Mitsuru Tsukakoshi, a Nippon representative, further indicates that the Japanese producers do not intend to start exporting conventional GOES to the United States. Moreover, with respect to pre- and post-revocation behavior, the ITC found the following. With respect to Japan, it is clear that prior to the imposition of the Subject Orders, the Japanese producers exported high permeability GOES and “some conventional, primarily M-3 grade, GOES.” Id. at 9. It is also clear that after the imposition of the Subject Orders, the Japanese producers exported almost exclusively high permeability GOES to the United States. Id. With respect to Italy, imports consisted entirely of conventional (M-6 grade) GOES both before and after the imposition of the Subject Orders. Id. While the ITC indicates that it took pre-order sales of conventional GOES into consideration, it is unclear how these past sales of “some conventional, primarily M-3 grade, GOES” favor a finding that Japanese and Italian conventional GOES would export a fungible product to the United States. Final Determination at 9. One of the conditions of competition found to exist was an increase in the “use of lower, less efficient, and less costly grades of GOES in transformer manufacture.” Id. at 14. However, the ITC made no finding as to whether the Japanese producers would likely produce and sell M-3 grade conventional GOES, or another grade of conventional GOES, for export to the United States. Plaintiffs argue that the Japanese producers do not make the type of conventional GOES used in the United States, and that it is the Japanese producers’ intention to “sell small quantities of high-permeability products, particularly domain refined, that are not available from the U.S. industry.” Tr. at 159; Pls.’ Mem. at 12. At no point does the ITC adequately explain how, taking into account this evidence, it is probable that the Japanese producers will export a type of conventional GOES, M-3 grade or otherwise, that would likely compete with Italian conventional GOES. With respect to Italy, the ITC found that the Italian producer “can and [does] produce a broad range of GOES products,” Final Determination at 10, but does not go any further in its analysis of whether the Italian producer would likely export high permeability GOES to the United States, except to say that “AST may seek to sell some of its high-permeability products in the United States in view of the [[ ]] ... selling these products in the United States and its increased production of high-permeability GOES.” Id. (citing AST’s Posthearing Br., List 2, Doc. 29 at A-1; Petitioners’ Prehearing Br., List 2, Doc. 16, Ex. 3). Without more, the ITC has merely shown that it is now possible for AST to export high permeability GOES to the United States, which, of course, is insufficient to satisfy the likely standard. Nippon III, 26 CIT at -, 2002 WL 31873457, *5. Even considering the prospective nature of a sunset review and the difficulty with which the ITC is faced in gathering concrete evidence of likely future events, the court is not convinced, in light of the detracting evidence, that the ITC has substantially supported, and adequately explained, its determination that the Japanese and Italian producers will likely sell a fungible GOES product in the United States. On remand, the ITC shall explain in detail why it is probable that the Japanese producers will export a type of conventional GOES, M-3 grade or otherwise, that would likely compete with Italian conventional GOES, taking into account the following: (a) evidence that the type •of conventional GOES produced by the Japanese producers for export to third country markets is different in thickness than the GOES favored by U.S. purchasers, and (b) evidence that the Japanese producers intend to “sell small quantities of high-permeability products, particularly domain refined, that are not available from the U.S. industry.” Tr. at 159. In addition, the ITC shall explain in detail how it is probable that the Italian producer will export high permeability GOES such that it would likely compete with Japanese high permeability GOES. The ITC shall address its evidence in the context of an explanation as to whether it is likely, not merely possible, that the subject producers will change their respective product mixes such that Japanese GOES and Italian GOES will likely compete in the U.S. market. Nippon III, 26 CIT at -, 2002 WL 31873457, *5. 2. Channels of Distribution Plaintiffs argue that the ITC’s channels of distribution finding is flawed because it is based on unsupported assumptions. Plaintiffs contend that the ITC incorrectly (1) assumed that Japanese producers “are likely to alter their U.S. product mix if the subject orders are revoked,” in order to sell conventional GOES to the United States and (2) assumed “that the Japanese producers’ distribution patterns would change, such that the Japanese and Italian producers would both sell to lamina-tors/distributors.” Pls.’ Mem. at 13, 12. Plaintiffs argue the record supports neither of these assumptions and contends that the ITC’s findings are devoid of any analysis or record support as to why ... a change in'the Japanese producers’ product mix would cause them to sell more GOES through lami-nators/slitters, or why such a change would increase competition with Italian imports. Rather, the ITC’s findings rest simply on speculation that the Japanese producers would carry over their Mexican sales practices to the United States — a fact that the Commission itself seems to recognize. Id. at 13 (emphasis in original) (citing Final Determination at 10). The ITC argues in favor of the conclusion that the Japanese producers’ pattern of sales (to end users) and thus, channels of distribution, is likely to change with an alteration in the product mix shipped to the United States. As the ITC stated in the Final Determination, “Japanese subject producers sell to laminat'ors/slitters for subsequent sale of the GOES in Mexico and presumably could do so in the United States.” Final Determination at 10. In support of this conclusion, the ITC argues that “the record shows that both Japanese and Italian subject producers sell to lami-nators/slitters in Mexico.” Def.’s Mem. at 28. The ITC stresses that “[Plaintiffs’] sales practices (selling GOES to lamina-tors/slitters) in Mexico hinge[] on what type of GOES is sold.” Id. at 27-28. The ITC concludes that “[g]iven that Japanese subject producers would likely sell appreciable quantities of conventional GOES in the United States,” due to, inter alia, the increase in U.S. demand for conventional grades of GOES, “it would be likely that Japanese subject producers would sell to end users and laminators/slitters in the United States as well.” Id. at 28 (emphasis in original). The court finds that the ITC’s conclusion that Japanese and Italian producers are likely to sell in the same or similar channels of distribution is unsupported by substantial evidence. Here, the ITC determined that the Japanese producers would “presumably” start to sell to lamina-tors/slitters in the United States based on an anticipated change in the product mix sold by the Japanese producers in the United States, i.e., “that Japanese subject producers would likely sell appreciable quantities of conventional GOES in the United States.... ” Def.’s Mem. at 28. However, as discussed above, the ITC has not demonstrated that such a change in product mix sold in the United States would be likely. The ITC’s finding that the Japanese producers would sell conventional GOES in the United States, such that Japanese and Italian GOES would likely compete, is unsupported by substantial evidence. Therefore, the basis on which the ITC’s determination with respect to channels of distribution rests is questionable. Moreover, while it may not be logistically impossible, concluding that the Japanese producers “presumably” could sell conventional GOES to lamina-tors/slitters in the United States because it has been doing so in Mexico and Canada is not enough to satisfy the likely standard. While the ITC has discretion in the area of cumulation, it must nonetheless support its decisions with substantial evidence. It has not done so here. On this second remand, the ITC shall, taking into account its finding on remand with respect to fun-gibility, revisit its finding that the Japanese and Italian producers of GOES will .change their patterns of sale, such that “common or similar channels of distribution” for imports from Japan and Italy exist, and an overlap of competition between Japanese and Italian GOES imports would be likely. Wieland Werke, 13 CIT at 563, 718 F.Supp. at 52. The ITC shall support those explanations with substantial evidence that the Japanese and Italian producers will both likely sell to end users, or laminators/slitters. II. LIKELIHOOD OF CONTINUATION OR RECURRENCE OF MATERIAL INJURY Ultimately, the ITC is charged with the duty of determining whether revocation of an antidumping or countervailing duty order would be likely to lead to continuation or recurrence of material injury within a reasonably foreseeable time. In making this determination, the ITC is instructed by statute to consider “the likely volume, price effect, and impact of imports of the subject merchandise on the industry if the order is revoked.... ” 19 U.S.C. § 1675a(a)(1). In reaching its determination, the ITC “shall take into account”: (A) its prior injury determinations, including the volume, price effect, and impact of imports of the subject merchandise on the industry before the order was issued ..., (B) whether any improvement in the state of the industry is related to the order ..., [and] (C) whether the industry is vulnerable to material injury if the order is revoked .... 19 U.S.C. § 1675a(a)(1)(A)-(C). “The presence or absence of any factor which the Commission is required to consider ... shall not necessarily give decisive guidance with respect to the Commission’s determination of whether material injury is likely to continue or recur within a reasonably foreseeable time.... ” 19 U.S.C. § 1675a(a)(6); SAA at 886 (“[T]he Commission must consider all factors, but no one factor is necessarily dispositive.”). The ITC determined in these sunset reviews that there was a likelihood of continuation or recurrence of material injury if the Subject Orders were revoked. See Final Determination at 20; Remand Determination at 17. Plaintiffs challenge the ITC’s likely volume, price effect, and impact determinations as unsupported by substantial evidence. A. Likely Volume Title 19 U.S.C. § 1675a(a)(2) governs the ITC’s determination of likely volume. It states: In evaluating the likely volume of imports of the subject merchandise if the order is revoked ... the Commission shall consider whether the likely volume of imports of the subject merchandise would be significant if the order is revoked ... either in absolute terms or relative to production or consumption in the United States. In doing so, the Commission shall consider all relevant economic factors, including- (A) any likely increase in production capacity or existing unused production capacity in the exporting country, (B) existing inventories of the subject merchandise, or likely increases in inventories, (C) the existence of barriers to the importation of such merchandise into countries other than the United States, and (D) the potential for product-shifting if production facilities in the foreign country, which can be used to produce the subject merchandise, are currently being used to produce other products. 19 U.S.C. § 1675a(a)(2)(A)-(D). In Nippon III, the court found that the ITC had not demonstrated that it had considered these factors, nor had the ITC evaluated whether the likely volume of imports would be significant either in absolute terms or relative to production or consumption in the United States. Thus, the court instructed that on remand, “such consideration must be reasonably discernible.” Nippon III, 26 CIT at -, 2002 WL 31873457, *4. In its Remand Determination, the ITC concluded that “the likely volume of subject imports would be significant in terms of U.S. production and U.S. apparent consumption if the countervailing and anti-dumping duty orders were revoked.” Remand Determination at 10-11. As to its consideration of the factors enumerated in 19 U.S.C. § 1675a(a)(2)(A)-(D), the ITC found, with respect to “any likely increase in production capacity or existing unused production capacity in the exporting country,” 19 U.S.C. § 1675a(a)(2)(A), that the “subject producers indicate[d] that they have no plans to increase capacity within the foreseeable future.... ” Remand Determination at 9. However, the ITC also found that “existing GOES production capacity in both [Japan and Italy] [was] substantial,” and that “subject producers [had] appreciable unused capacity that could be used to produce subject merchandise for the U.S. market if the orders were revoked.” Id. As to the factors enumerated in 19 U.S.C. § 1675a(a)(2)(B)-(D), the ITC found that the nature of the GOES industry prevented these factors from having much relevance. The ITC stated, “[T]he lack of inventories, absence of barriers to importation in other markets, and limited potential for product shifting, did not outweigh other factors which led [the ITC] to conclude that the likely volume of imports would be significant if the orders were revoked.” Id. at 3. These other factors include: (1) the nature of supply and demand in the GOES industry, (2) the export orientation of the subject producers, (3) the range of GOES products offered by Japanese and Italian producers, (4) pricing practices in the United States and other countries during the original and the review periods of investigation (including the incentive of higher prices in the U.S. market as compared with other markets), and (5) patterns of shipments to other markets into which the subject imports are sold. Id. at 4. Plaintiffs argue that the record does not support the ITC’s conclusion that likely volume would be significant in terms of U.S. production and consumption. To the contrary, Plaintiffs maintain that “the facts, information and data concerning each of [the four factors set out in 19 U.S.C. § 1675a(a)(2)] provide substantial evidence that the volume of subject imports likely would not be ‘significant’.... ” Pls.’ Comments at 7 (emphasis in original); Pls.’ Mem. at 23-25. In particular, Plaintiffs assert that: (1) “uncontested evidence shows that GOES producers in Japan and Italy have virtually no unused GOES production capacity and have no plans (and little ability) to add to their existing capacity,” Pls.’ Mem. at 23 (citation omitted); Pls.’ Comments at 8 (“During the first nine months of 2000 — the most recent period for which data were collected — the subject producers did not have excess capacity that could be used to produce significant quantities of GOES for the U.S. market.”(emphasis in original)); (2) “the record shows that subject GOES inventories are effectively non-existent (and thus do not provide Japanese and Italian producers with a means of making significant U.S. sales),” Pls.’ Mem. at 23-24 (citations omitted); (8) “there are no trade barriers in other countries that would cause GOES shipments to be directed towards the United States,” id. at 24 (citations omitted); and (4) “the specialty equipment used to manufacture GOES [i.e., box-annealing equipment and, in the case of domain refined GOES, laser or mechanical scribing equipment,] precludes the subject producers from switching production away from other products in order to increase their U.S. GOES sales.” Id. Plaintiffs complain that the ITC “gave almost no weight to this evidence.” Pls.’ Comments at 7. Plaintiffs also take issue with the ITC’s conclusion that the “purportedly higher prices made the U.S. market ‘particularly attractive’ and provided the subject producers with ‘a primary incentive’ to ship significant quantities of GOES to the United States.” Pls.’ Comments at 17 (citing Remand Determination at 6, 4). For example, Plaintiffs minimize the significance of the Japanese producers’ sales of high permeability GOES in the United States [[ ]] by noting that “only a tiny quantity of GOES [was sold] in the United States during the period of review,” and “the record shows that those sales were made to U.S. customers that were willing to pay a premium for the Japanese product.” Id. (citations omitted). Plaintiffs argue that the subject producers could not supply significant quantities of GOES to the United States without sacrificing sales to other customers because of high capacity utilization rates. Id. at 18. The ITC argues that it complied with the court’s instructions in Nippon III by considering each of the statutory factors set forth in 19 U.S.C. § 1675a(a)(2), as well as other relevant economic factors. Def.’s Comments at 2-3. The ITC further argues that, given the nature of the GOES industry, it properly found that the lack of inventories, the absence of barriers to entry of the subject merchandise into third country markets, and the limited potential for the Japanese and Italian producers to product shift, were “not dispositive- or indeed particularly meaningful.” Id. at 4. As to the finding that the Japanese and Italian GOES producers had “significant production capacity,” the ITC argues that “that the aggregate capacity for both countries was [[ ]] of total U.S. consumption and U.S. production capacity of GOES for [1999].” Def.’s Comments at 5; see Conf. Remand Determination at 10-11. Moreover, although, as Plaintiffs point out, interim data from 2000 show high capacity utilization rates, i.e., [[ ]] for Japanese producers and [[ ]] for the Italian producer, the ITC claims it did not err in finding that “appreciable unused capacity” existed. Def.’s Comments at 6, 5. The ITC argues that “reported capacity utilization rates fluctuated over the period of review, and ... that they will likely fluctuate for the foreseeable future.” Id.; Remand Determination at 10 & n. 56. With respect to other evidence that Plaintiffs argue shows that subject import volume would likely not be significant, i.e., that the demand for GOES among the subject producers’ existing customers was projected to grow rapidly, the ITC contends that “the ITC did not ignore this evidence but came to a different conclusion than did plaintiffs.” Def.’s Comments at 7. Specifically, the ITC found that shipments to other markets have been “erratic” and that GOES sells at higher prices in the U.S. market than in other markets. Id. The ITC claims that this led to its conclusion that “despite increased demand in subject producers’ other export markets, the U.S. market would be a far more attractive market for subject producers seeking the highest price for their product.” Id. In defense of its finding that GOES commands a higher price in the United States than in third country markets, the ITC insists that “the record contains numerous examples that subject producers’ prices for the various grades of the subject product sold in Canada and Mexico are below current domestic prices for competing grades.” Id. at 11 (citing Petitioners’ Prehearing Br., List 2, Doc. 16, Ex. 1 at 64-66; Remand Determination at 6 n. 24). The court finds that the ITC has complied with the instruction in Nippon III to “demonstrate ... (a) that it ... considered] each of the four factors outlined in 19 U.S.C. § 1675a(a)(2)(A)-(D); and (b) that it considered whether, were the Subject Orders revoked, the likely volume of imports of the subject merchandise would be significant either in absolute terms or relative to production or consumption in the United States, pursuant to 19 U.S.C. § 1675a(a)(2).” Nippon III, 26 CIT at -, 2002 WL 31873457, *5. It is evident in the Remand Determination that the ITC considered the factors enumerated in 19 U.S.C. § 1675a(a)(2)(A)-(D) and explained why it considered each factor relevant or not. See Remand Determination at 3 & nn. 22, 54, 55. Furthermore, the ITC considered the significance of likely volume if the Subject Orders were revoked relative to U.S. production and consumption. See, e.g., Conf. Remand Determination at 10, 11 (“In 1999, the last full year for which data were available, the total capacity for both countries was [[ ]] total U.S. consumption and U.S. production of GOES for the same period.” With respect to unused capacity, the ITC found that “[i]n 1999, subject producers ... had [[ ]] short tons of unused capacity, which was equivalent to [[ ]] percent of U.S. production and [[ ]] percent of U.S. apparent consumption for the same year.”). The court notes the following with respect to whether substantial evidence supports the ITC’s finding that GOES prices in the U.S. market are higher, and therefore would likely attract imports. Affidavits submitted by petitioners reveal that the prices at which GOES was sold in the United States are higher than the prices at which it was sold in third country markets. See Petitioners’ Prehearing Br., List 2, Doc. 16, Exs. 11 (Aff. of Robert D. Ross) & 12 (Aff. of Robert I. Psyck). With respect to Japan, this evidence indicates that the purchase price for Japanese GOES was lower than comparable products sold in third country markets. See id., Ex. 12 at 2 ([[ ]]). With respect to Italy, the evidence supports a finding that Italian GOES was purchased at a lower price in third country markets than in the U.S. market. Id., Ex. 11 at 1-2 (“[T]he actual purchase price for AST’s M-6 slit product delivered to [Canada] [was] at [[ ]].... The typical domestic price of Allegheny Ludlum’s M-6 product is [[ ]]. Allegheny Ludlum’s cost to produce M-6 product is [[ ]] Thus, AST is selling its M-6 product at a price [in Canada] that is [[ ]] our cost to produce.”). This evidence reasonably supports the conclusion that GOES commands a higher price in the U.S. market than in other markets. However, in light of the questions to be addressed on remand with respect to likely discernible adverse impact and likely reasonable overlap of competition, the court remands the ITC’s likely volume determination for further consideration. In particular, the ITC is instructed to revisit and explain in detail, with specific citations to the record, its determination that likely volume would be significant in light of the following evidence: (1) with respect to Japan: (a) high capacity utilization rates data reported for 2000, (b) [[ ]], (c) the evidence relating to whether the Japanese producers would likely export conventional GOES to the United States such that it would compete with Italian conventional GOES, and (d) whether it is likely that the Japanese producers’ patterns of sale will change; and (2) with respect to Italy: (a) whether it is likely that AST will sell high permeability GOES to the United States such that it would compete with Japanese high permeability GOES, and (b) whether it is likely that the Italian producer’s patterns of sale will change. The ITC shall also reconsider the above in light of the increase in U.S. demand and domestic production capacity, and strong worldwide demand for GOES, and explain whether these conditions of competition would prevent significant quantities of GOES sales to the United States. Should the ITC decide not to cumulate the subject imports from Japan and Italy, it shall amend its likely volume determination accordingly. B. Likely Price Effects Title 19 U.S.C. § 1675a(a)(3) governs the ITC’s determination with respect to likely price effects: In evaluating the likely price effects of imports of the subject merchandise if the order is revoked ..., the Commission shall consider whether- (A) there is likely to be significant price underselling by imports of the subject merchandise as compared to domestic like products, and (B) imports of the subject merchandise are likely to enter the United States at prices that otherwise would have a significant depressing or suppressing effect on the price of domestic like products. 19 U.S.C. § 1675a(a)(3)(A)-(B). According to the SAA, “in considering the likely price effects of imports in the event of revocation ..., the Commission may rely on circumstantial, as well as direct, evidence of the adverse effects of unfairly traded imports on domestic prices.” SAA at 886. Here, the ITC concluded that “if the orders were revoked, significant volumes of subject imports likely would significantly undersell the domestic like product to gain market share and likely would have significant depressing or suppressing effects on the prices of the domestic like product within a reasonably foreseeable time.” Remand Determination at 15; Final Determination at 18-19. The ITC noted several conditions of competition that it found relevant to its underselling and price depression/suppression findings. First, “the domestic like product and subject imports are substitutable.” Remand Determination at 11. Second, “price is an important factor in purchasing decisions.” Id. Third, “domestic prices have fallen during these reviews and are at lower levels than prices during the original investigations” as a result of “downstream competition from increased U.S. imports of both transformers and laminated/stamped GOES, declining average unit costs of U.S. GOES producers, and increased U.S. imports of GOES from non-subject countries compared with the original investigations.” Id. at 12. The decrease in prices was notable because “it occurred at a time of increasing demand.” Id. Based on these conditions of competition and the pricing data available on the record, the ITC affirmatively determined that there would likely be significant price underselling, and price suppression, by imports of GOES, should the Subject Orders be revoked. The ITC noted that “several large purchasers have manufacturing facilities in both Canada and Mexico as well as the United States,” and that these purchasers “are buying subject GOES from Italy and Japan for [these facilities] at prices that are lower than prevailing U.S. prices.” Remand Determination at 12. Further, the ITC stated that these purchasers “are currently seeking to obtain prices from domestic producers [of] GOES for their U.S. facilities comparable to prices for the subject product shipped to their Canadian and/or Mexican operations.” Id. at 12-13. Moreover, “heightened competition between domestic GOES purchasers and their competitors in Canada and Mexico” would cause U.S. customers to seek lower-priced subject imports if the Subject Orders were revoked. Id. at 13. The ITC found that pressure on U.S. GOES producers to reduce prices, along with the “incentive for the low-priced, subject imports to return to the U.S. market since subject producers would recei