Full opinion text
OPINION RIDGWAY, Judge: Pending before the Court are the Final Results of Redetermination Pursuant to Court Remand, filed by the U.S. Department of Commerce pursuant to the decision in Bond Street I. See generally Final Results of Redetermination Pursuant to Court Remand: Hand Trucks and Certain Parts Thereof from the People’s Republic of China (“Remand Results”); Bond Street, Ltd. v. United States, 33 CIT-, 637 F.Supp.2d 1343 (2009) (“Bond Street I”). Bond Street I remanded to Commerce the agency’s determination that the Stebco Portable Slide-Flat Cart (style no. 390009 CHR) — imported by Plaintiff Bond Street, Ltd., a New York importer of business and travel products — falls within the scope of the antidumping duty order on hand trucks from the People’s Republic of China. See Bond Street I, 33 CIT at-, 637 F.Supp.2d at 1351-52; Hand Trucks and Certain Parts Thereof from the People’s Republic of China: Scope Ruling on Steb-co Portable Slide-Flat Cart Inv. No. A-570-891 (May 30, 2007) (Administrative Record (“A.R.”) Doc. No. 12) (“Scope Ruling”); Notice of Antidumping Duty Order: Hand Trucks and Certain Parts Thereof From the People’s Republic of China, 69 Fed.Reg. 70,122 (Dec. 2, 2004) (“Antidumping Order”). In particular, Bond Street I ruled that Commerce’s Scope Ruling could not be sustained because the agency had “failed to ... make a determination as to whether the toe plate of the Stebco cart can ‘slide[ ] under a load for purposes of lifting and/or moving the load,’ ” an operational/functional requirement set forth in the Antidumping Order, and the central focus of this litigation. See Bond Street I, 33 CIT at -, 637 F.Supp.2d at 1350 (quoting, inter alia, An-tidumping Order, 69 Fed.Reg. 70,122). On remand, Commerce “found through testing [of] Bond Street’s Stebco Cart that [the cart] is adept at sliding under a load for the purposes of lifting/moving that load. Additionally, once the projecting edge/toe plate is slid under a load, the projecting edge/toe plate remain[s] stable and there [is] no difficulty in lifting and moving the load.” See- Remand Results at 4; see also id. at 1, 3-4, 9-10, 12. Commerce thus concluded that — in addition to possessing the four specific physical characteristics required by the Antidumping Order — the Stebco cart also has “the operational and functional ability to slide under a load for the purposes of lifting and/or moving that load.” See id. at 4; see also id. at 1-2, 10, 12. Commerce’s Remand Results therefore reaffirmed the agency’s earlier determination that the Stebco cart falls within the scope of the Antidumping Order. See Remand Results at 1-2, 9, 12. Bond Street contends that “the tests conducted by [Commerce] do not provide a basis for ... find[ing] that the Stebco [cart] ... slide[s] under a load” within the meaning of the Antidumping Order, and that the agency failed to properly consider certain tests conducted by Bond Street and the agency itself. See Plaintiffs Comments on Final Results of Redetermination Pursuant to Court Remand (“Pl.’s Brief’) at 2, 3. In addition, Bond Street critiques the adequacy of Commerce’s explanation of its remand determination, and raises various other procedural objections. See, e.g., id. at 3^1. Bond Street concludes that the Remand Results are not supported by substantial evidence in the record, and are otherwise not in accordance with law. See generally id.; Plaintiffs Reply to Defendant’s Response to Bond Street’s Comments Upon Commerce’s Remand Results (“PL’s Reply Brief’). Bond Street argues that the Court therefore should “reject Commerce’s remand results and either remand the matter once again ..., or alternatively enter judgment for Bond Street based upon the facts of record.” See PL’s Reply Brief at 6. In contrast, the Government and the DefendanNIntervenors — Gleason Industrial Products, Inc. and Precision Products, Inc. (collectively, “Domestic Manufacturers”)- — contend that the Remand Results comply fully with the instructions in Bond Street I, and are both supported by substantial evidence and otherwise in accordance with law. The Government and the Domestic Manufacturers therefore argue that Commerce’s remand determination should be sustained in all respects. See generally Comments on Final Results of Redetermination Pursuant to Court Remand (“Def.-Ints.’ Brief’); Defendant’s Response to Bond Street’s Comments Upon Commerce’s Remand Results (“Def.’s Brief’). Jurisdiction lies under 28 U.S.C. § 1581(c) (2000). For the reasons set forth below, the Remand Results, including Commerce’s remand determination concluding that the Stebco cart is within the scope of the Antidumping Order, must be sustained. I. Background In December 2004, the Department of Commerce published an antidumping duty order covering hand trucks and certain parts thereof from the People’s Republic of China. See Notice of Antidumping Duty Order: Hand Trucks and Certain Parts Thereof From the People’s Republic of China, 69 Fed.Reg. 70,122 (Dec. 2, 2004) (“Antidumping Order”). The first section of the Antidumping Order (captioned “Scope of Order”) expressly defines the covered merchandise, identifying four specific required physical characteristics, in addition to the operational/funetional requirement that is at issue in this action: A complete or fully assembled hand truck is a hand-propelled barrow consisting of [1] a vertically disposed frame having [2] a handle or more than one handle at or near the upper section of the vertical frame; [3] at least two wheels at or near the lower section of the vertical frame; and [4] a horizontal projecting edge or edges, or toe plate, perpendicular or angled to the vertical frame, at or near the lower section of the vertical frame. The projecting edge or edges, or toe plate, slides under a load for purposes of lifting and/or moving the load. .... That the vertical frame, handling area, wheels, projecting edges or other parts of the hand truck can be collapsed or folded is not a basis for exclusion of the hand truck from the scope of the [Antidumping Order].... Finally, that the hand truck may exhibit physical characteristics in addition to the vertical frame, the handling area, the projecting edges or toe plate, and the two wheels at or near the lower section of the vertical frame, is not a basis for exclusion of the hand truck from the scope of the [Anti-dumping Order]. Examples of names commonly used to reference hand trucks are hand truck, convertible hand truck, appliance hand truck, cylinder hand truck, bag truck, dolly, or hand trolley.... Excluded from the scope [of the Anti-dumping Order] are small two-wheel or four-wheel utility carts specifically designed for carrying loads like personal bags or luggage in which the frame is made from telescoping tubular material measuring less than % inch in diameter[.] Antidumping Order, 69 Fed.Reg. at 70,122 (“Scope of Order” section) (emphasis added). A. Commerce’s Scope Ruling on the Stebco Cart After the Antidumping Order issued, Bond Street sought a ruling from Commerce that the Stebco cart is beyond the scope of the Order, and is therefore not subject to antidumping duties under that Order. See Bond Street Request for Scope Ruling (A.R. Doc. No. 1). Bond Street argued that the Stebco cart is not a “hand truck” within the meaning of the Antidumping Order, but — rather—a collapsible “portable luggage cart,” designed for “personal uses such as carrying luggage, carrying personal bags, or a salesman storing the cart in his car to carry in many samples[ ] or sample cases together at one time to avoid multiple trips.” See id. at 2, 4; see also id. at 3; A.R. Doe. No. 4 at 3. According to Bond Street, several physical features of the Stebco cart — ie., its collapsible toe plate, the placement of a bungee cord hook, and the absence of a kick plate — make it impossible for the cart to “slidef ] under” a load for purposes of lifting and/or moving the load, as required by the express terms of the Antidumping Order. See A.R. Doc. No. 1 at 3. Bond Street asserted that those particular features of the Stebco cart mean that — as a practical matter — “items must be lifted onto the [toe] plate for purposes of lifting and/or moving [them].” Id. at 2 (emphasis added); see also id. at 4; A.R. Doc. No. 4 at 4; A.R. Doc. No. 11 at 2-3. Commerce analyzed Bond Street’s Request for Scope Ruling under the framework of 19 C.F.R. § 351.225(k)(l) (2006), finding “the descriptions of the merchandise” to be dispositive. See Hand Trucks and Certain Parts Thereof from the People’s Republic of China: Scope Ruling on Stebco Portable Slide-Flat Cart Inv. No. A-570-891 (May 30, 2007) (A.R. Doc. No. 12) at 8 (“Scope Ruling”). In its Scope Ruling, Commerce determined that the Stebco cart incorporates all four of the requisite physical characteristics of a hand truck specified in the scope language of the Antidumping Order- — (1) a vertical frame, (2) at least one handle, (3) two or more wheels, and (4) a projecting edge or toe plate. Id. at 8. Commerce also reviewed each of the three physical features of the Stebco cart that Bond Street highlighted — ie., the collapsible toe plate, the bungee cord hook, and the lack of a kick plate, and determined that none of them placed the Stebco cart beyond the scope of the Antidumping Order. See id. at 3, 8. In addition, Commerce found that — because the cart’s frame includes telescoping tubing with a diameter of greater than % inch — the Stebco cart does not fall within the Antidumping Order’s express exclusion of “small ... utility carts specifically designed for carrying loads like personal bags or luggage in which the frame is made from telescoping tubular material measuring less than % inch in diameter.” See id. at 8-9; Antidumping Order, 69 Fed.Reg. at 70,122 (express exclusion in “Scope of Order” section). In light of the findings summarized above, Commerce’s Scope Ruling concluded that the Stebco cart falls within the scope of the Antidumping Order. See A.R. Doc. No. 12 at 8-9. However, Commerce failed to test the Stebco cart. Nor did Commerce’s Scope Ruling make any finding on the ability of the cart’s toe plate to “slide[ ] under a load for purposes of lifting and/or moving the load.” See generally id., passim. B. The Ruling in Bond Street I Bond Street commenced the instant action challenging Commerce’s Scope Ruling. As detailed in Bond Street I, Bond Street’s Motion for Judgment on the Agency Record emphasized that the Antidumping Order requires that the projecting edge or toe plate of subject merchandise “slide[ ] under a load for purposes of lifting and/or moving the load.” See Antidumping Order, 69 Fed.Reg. at 70,122 (“Scope of Order” section). Bond Street argued that the Stebco cart is not capable of sliding under a load in such a manner, and that Commerce therefore should have reached a negative scope determination. See generally Bond Street I, 33 CIT at-, 637 F.Supp.2d at 1344. The Government and the Domestic Manufacturers maintained that the Scope Ruling should be sustained, because the Scope Ruling expressly addressed each of the physical features of the Stebco cart that Bond Street cited in arguing that the cart’s toe plate cannot “slide[] under a load.” See generally Bond Street I, 33 CIT at-, 637 F.Supp.2d at 1350 (discussing Scope Ruling’s analysis of Stebco cart’s collapsible toe plate and cart’s bungee cord hook, as well as cart’s lack of kick plate). As Bond Street I explained, however, Commerce’s Scope Ruling simply missed the point: Contrary to the claims of the Government and the Domestic Manufacturers, ... it is not enough that Commerce analyzed each of the referenced physical characteristics [ — ie., the Stebco cart’s collapsible toe plate, its bungee cord hook, and its lack of a kick plate — ] in isolation. Bond Street has never claimed that the existence of those physical characteristics, in and of themselves, places the Stebco cart beyond the scope of the Antidumping Order. To the contrary, the gravamen of Bond Street’s argument is that those physical characteristics prevent the Stebco cart from having the functional or operational characteristic set forth in the Antidump-ing Order- — that is, that “[t]he projecting edge or edges, or toe plate, slide[ ] under a load.” Bond Street I, 33 CIT at -, 637 F.Supp.2d at 1350-51 (quoting Antidump-ing Order, 69 Fed.Reg. at 70,122). Bond Street I underscored that: [N]owhere in its Scope Ruling ... did Commerce make a determination as to whether the toe plate of the Stebco cart can ‘slide[ ] under a load for purposes of lifting and/or moving’ that load. Nowhere in the Scope Ruling did Commerce address Bond Street’s claim that the collapsible toe plate, the location of the bungee cord hook, and the absence of a kick plate prevent the toe plate of the Stebco cart from ‘slid[ing] under’ a load. Bond Street I, 33 CIT at -, 637 F.Supp.2d at 1351. This matter was therefore remanded to Commerce for further action, to permit the agency “to make a finding as to whether the Stebco cart’s toe plate ‘slides under a load for purposes of lifting and/or moving the load,’ ” as required by the scope language in the Anti-dumping Order. See id., 33 CIT at-, 637 F.Supp.2d at 1351-52 (quoting Anti-dumping Order, 69 Fed.Reg. at 70,122 (“Scope of Order” section)). C. Commerce’s Determination on Remand In the course of the remand proceeding before the agency, Commerce officials conducted a series of three tests using loads of varying weights and dimensions to evaluate the ability of the Stebco cart to “slide[ ] under” a load — the operational/funetional requirement set forth in the language of the Antidumping Order defining the scope of the Order’s coverage. See generally Final Results of Redetermination Pursuant to Court Remand: Hand Trucks and Certain Parts Thereof from the People’s Republic of China at 1, 3-7,12 (“Remand Results”). First, Commerce tested the Stebco cart’s ability to slide under a box of files measuring 10 x 16 x 13 inches and weighing 15 pounds. See id. at 3-4. In addition, Commerce tested the cart’s ability to slide under a box of files measuring 9 x 18 x 11.5 inches and weighing 30 pounds. See id. And, finally, Commerce tested the cart’s ability to slide under an empty two-drawer metal file cabinet measuring 25 x 19.5 x 14.5 inches and weighing 50 pounds. See id. at 4. In conducting its tests, the agency specifically addressed Bond Street’s assertions that the Stebco cart’s collapsible toe plate, its bungee cord hook, and its lack of a kick plate prevent the cart from “slid[ing] under” a load. See id. at 2, 3; see also id. at 4-7. The Remand Results explain that, in each of Commerce’s three tests, the Stebco cart was able to “slide[ ] under” the load: For the lighter [15-pound] box, [Commerce] officials merely rolled the Stebco Cart up to the box and the toe plate slid under the box. With the heavier [30-pound] box, [Commerce] officials leveraged the Stebco Cart with their feet. For the two-drawer metal filing cabinet, [Commerce] officials were able to slide the Stebco Cart’s projecting edge/toe plate under the filing cabinet by slightly tilting the cabinet. Remand Results at 4; see also id. at 11. Based on its testing, Commerce concluded that the Stebco cart “is adept at sliding under a load for the purposes of lifting/moving that load.” Id. at 4. The testing further demonstrated that “once the [Stebco cart’s] projecting edge/toe plate is slid under a load, the projecting edge/toe plate remained stable and there was no difficulty in lifting and moving the load.” Id. And Commerce specifically determined, through testing, that — contrary to Bond Street’s claims — none of the three physical features highlighted by Bond Street prevents the Stebco cart from “slid[ing] under” a load, as specified in the scope language of the Antidumping Order. See id. at 4-5 (addressing the collapsible toe plate); id. at 5-6 (addressing lack of kick plate); id. at 6-7 (addressing location of bungee cord hook); see generally id. at 3, 7. In several rounds of comments on Commerce’s draft Remand Results, Bond Street attacked both the methodology and the results of Commerce’s testing. Bond Street argued, among other things, that Commerce’s “leveraging” of the Stebco cart in the test involving the 30-pound box was not consistent with the manner of the cart’s intended use, and that the Anti-dumping Order did not permit Commerce to “tip” or “tilt” the 50-pound file cabinet in order to slide the Stebco cart under it. See generally Remand Results at 4, 6, 8, 9. Apart from attacking two of Commerce’s three tests on the Stebco cart, Bond Street also criticized the agency for not conducting two additional tests. Specifically, Bond Street argued that Commerce should have tested the cart’s ability to “slide[] under” three stacked boxes, weighing 20 pounds each. See Remand Results at 7, 10. Bond Street further urged Commerce to replicate a test that Bond Street itself had conducted. As the Remand Results explained: Bond Street ... argues that it ... attempted, to no avail, to slide the Stebco Cart under a box measuring 18 x 12 x 10 inches and weighing 50 pounds. Bond Street attached three color photographs [to its comments on the draft Remand Results] purporting to depict the Stebco Cart’s wheels lifting off the ground as the cart’s [toe] plate makes contact with the box and the cart beginning to collapse on a second attempt. Id. at 7. Bond Street emphasized the design of the Stebco cart’s toe plate, contrasting it with that of a so-called “typical hand truck” and arguing that the thickness of the Stebco cart’s toe plate “makes sliding [it] under [the] loads of many boxes extremely difficult, if not impossible.” See id. at 8 (quoting Bond Street comments on draft Remand Results (S.A.R. Doc. No. 2) at 3); see also id. at 7. Similarly, Bond Street emphasized that the Stebco cart has a relatively low load capacity, which Bond Street sought to contrast with the load capacities of “typical” hand trucks contemplated by the Antidumping Order. See id. at 10; see also Bond Street I, 33 CIT at - n. 5, 637 F.Supp.2d at 1347 n. 5 (noting that maximum load capacity of Stebco cart is 275 pounds). Apparently rejecting Commerce’s test using the 30-pound box (due to “leveraging”) as well as the agency’s test using the 50-pound file cabinet (due to “tilting”), Bond Street insisted that Commerce’s “success at sliding the Stebco Cart under one load” — i.e., the 15-pound box — could not justify Commerce’s determination that the Stebco cart falls within the scope of the Antidumping Order. See Remand Results at 8; see also id. at 9 (noting Bond Street’s argument that Commerce’s “limited testing ... cannot support its proposed finding that the subject cart is designed to slide under a load”). In its final Remand Results, Commerce individually addressed each of Bond Street’s objections. Commerce explained that — contrary to Bond Street’s assumption — the agency’s use of “leveraging” in its test using the 30-pound box did not involve “lifting [the Stebco cart’s] wheels off the ground [in order] to slide [the] load onto the toe plate.” See Remand Results at 8, 10-11. Instead, “[Commerce] officials press[ed] against a portion of the Stebco Cart with their feet to give support to the cart.” Id. at 10. The Remand Results further noted that “[t]he Order’s scope language is silent with respect to the operation of [a] hand truck,” except to require that “the projecting edge/toe plate ... slide under a load for purposes of lifting and/or moving the load.” Id. at 10-11. As to Bond Street’s objection to Commerce’s file cabinet test, Commerce rejected Bond Street’s argument that “the Order’s language is not inclusive of carts with projecting edges or toe plates capable of sliding under a load only when the load is tilted.” See Remand Results at 11. Commerce noted that “the Order is silent with respect to the tilting of the items that are to be moved and/or lifted by the hand truck,” and stated that the agency has consistently ruled in the past that hand carts are not excluded from the scope of the Antidumping Order merely because they are capable of “sliding] under” a load only if that load is tipped or tilted. Id. Commerce also addressed Bond Street’s efforts to contrast the design of the Stebco cart with that of so-called “typical hand trucks.” In particular, Commerce pointed out that the Antidumping Order is silent on the issue of load capacity. See Remand Results at 10 (noting that “the language of the Order does not require an analysis of weight limitations”). In addition, Commerce characterized as “misplaced” Bond Street’s emphasis on “the 2.41 mm width difference between the Stebco Cart’s projecting edge or ... toe plate” and that of a hypothetical “typical hand truck[ ].” Id. As the Remand Results explained, the Anti-dumping Order requires only that a hand cart be able to “slide[ ] under” a load; the relative “efficiency and ease of ... use” in sliding any particular hand cart under a load “speaks to end-user satisfaction rather than scope inclusion/exclusion.” Id. (footnote omitted); see also id. at 5. Finally, the Remand Results rejected Bond Street’s contention that “sliding the Stebco Cart under one load does not warrant finding the cart to be within the scope of the Order.” See Remand Results at 8; see also id. at 9. Commerce disputed Bond Street’s math, and, more fundamentally, dismissed Bond Street’s claim that — to fall within the scope of the Antidumping Order — a hand cart must be able to perform “hand truck tasks” on all items (or at least “all items it was designed or intended to move”). See id. at 8, 9, 11. The Remand Results stated: [C]ontrary to Bond Street’s assertion, it is not the case that [Commerce] was successful at sliding the Stebco Cart under only a single load.... [W]e tested [the] Stebco Cart on two boxes of different weights, and on a two-drawer filing cabinet demonstrating the Stebco Cart’s ability to slide under and move different loads of different sizes. We further disagree with Bond Street in its contention that the Order requires that the hand truck in question must perform “the tasks of a hand truck on all of the items it was designed or intended to move.” ... [T]he Order does not exclude hand trucks designed with a primary use. We find neither a literal requirement in the Order’s scope language nor a suggestion to this effect. The Order’s scope language is additionally silent on the hand truck’s item-specific limitations. Id. at 11; see also id. at 9 (acknowledging the Domestic Manufacturers’ point that— even if a hand cart cannot slide under some loads, the cart nevertheless falls within the scope of the Order if the cart can slide under other loads). Because there is no requirement that a hand cart be able to perform “hand truck tasks” on “all items it was designed or intended to move,” and the Antidumping Order requires only that a hand cart within the scope of the Order be capable of “sliding] under” an unspecified load, Commerce concluded that — in light of the results of the agency’s three tests — the additional tests advocated by Bond Street were not necessary. See id. at 10 (explaining that Bond Street’s proposed test involving stack of three boxes weighing 20 pounds each was not necessary, because Commerce’s testing was sufficient to “con-firme ] that the Stebco Cart possesses the fundamental functional and operative capability to slide under a load”); see also id. at 9,11. The Remand Results concluded that, “notwithstanding the collapsible and angled design of the toe plate, the location of the bungee cord hook, and the absence of a kick plate,” Bond Street’s Stebco cart “is adept at sliding under a load for the purposes of lifting/moving that load”; that “once the projecting edge/toe plate is slid under a load, the projecting edge/toe plate remained stable and there was no difficulty in lifting and moving the load”; and that the Stebco cart thus “has the operational and functional ability to slide under a load for the purposes of lifting and/or moving that load,” and therefore falls “within the scope of the Order.” See Remand Results at 3-4, 12; see also id. at 1-2, 5, 6-7, 9-11. Commerce therefore reaffirmed the determination in its Scope Ruling. See id. at 1-2, 3, 9 & n. 2, 12. II. Standard of Review In reviewing a challenge to a ruling by Commerce on the scope of an anti-dumping order (i.e., a determination as to “whether a particular type of merchandise is within the class or kind of merchandise described in an existing ... antidumping ... duty order”), the agency’s determination must be upheld unless it is found to be “unsupported by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. §§ 1516a(a)(2)(B)(vi), 1516a(b)(1)(B)(i) (2000); see Walgreen Co. v. United States, 620 F.3d 1350, 1354 (Fed. Cir.2010); see also Diamond Sawblades Mfrs. Coalition v. United States, 33 CIT -, -, 650 F.Supp.2d 1331, 1352 (2009), aff'd, 626 F.3d 1374 (Fed.Cir.2010) (explaining that “[judicial] review of agency determinations issued pursuant to a court-ordered remand is governed by the same standard of review used in reviewing the [agency’s] original determination”). “[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 Consol. Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938)). Moreover, any determination as to the substantiality of evidence “must take into account whatever in the record fairly detracts from its weight,” including “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, 340 U.S. at 487-88, 71 S.Ct. 456). On the other hand, the mere fact that “it [may be] possible to draw two inconsistent conclusions from evidence in the record ... does not prevent Commerce’s determination from being supported by substantial evidence.” Am. Silicon Techs, v. United States, 261 F.3d 1371, 1376 (Fed.Cir.2001); see also Consolo v. Federal Maritime Commission, 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966) (same). Finally, while Commerce must explain the bases for its decisions, “its explanations do not have to be perfect.” NMB Singapore Ltd. v. United States, 557 F.3d 1316, 1319 (Fed.Cir.2009). However, “the path of Commerce’s decision must be reasonably discernable,” to support judicial review. Id. In the case at bar, Bond Street maintains that Commerce’s remand determination is not supported by “substantial evidence on the record,” and that it is also “otherwise not in accordance with law.” III. Analysis Bond Street challenges the Remand Results on both substantive and procedural grounds. On the merits, Bond Street contests the validity of the tests on which Commerce relies to establish that — in the words of the Antidumping Order — the Stebco cart will “slide[ ] under a load for purposes of lifting and/or moving the load.” See generally sections III.A-III.C, infra; see also Antidumping Order, 69 Fed.Reg. at 70,122 (“Scope of Order” section). As a matter of procedure, Bond Street argues that Commerce should have consulted with the parties in determining the agency’s test methodology. See section III.D.l, infra. In addition, Bond Street disputes the adequacy of the rationale provided in the Remand Results on issues including Commerce’s choice of test procedures, Commerce’s treatment of various tests, and Commerce’s decision not to conduct some additional testing that Bond Street proposed. See sections III.D.2-III. D.3, infra. Bond Street further contends that Commerce failed to properly address certain specific physical features of the Stebco cart. See section III.D.4, infra. Ultimately, Bond Street concludes that the Remand Results are not supported by substantial evidence in the record. See section III.E, infra. As discussed in greater detail below, however, Bond Street’s arguments are far wide of the mark. Bond Street’s challenge to the Remand Results must therefore fail, and Commerce’s remand determination that the Stebco cart will “slide[] under a load for purposes of lifting and/or moving the load” — and thus falls within the scope of the Antidumping Order— must be sustained. See Remand Results at 1-2, 3-4, 9-10, 12; Antidumping Order, 69 Fed.Reg. at 70,122. A. Bond Street’s Challenge to Commerce’s File Cabinet Test Bond Street’s principal challenge to Commerce’s remand determination is Bond Street’s claim that the agency’s “testing methodology” contravened “the plain meaning of the language” of the Antidumping Order. Pl.’s Reply Brief at 4; see also Pl.’s Brief at 8. Focusing on the phrase “slide[] under” as that phrase is used in the Order, Bond Street argues that Commerce erred by “tipping” or “tilting” the load in the course of testing whether the Stebco cart could “slide[] under” a two-drawer metal filing cabinet. In particular, Bond Street contends that the dictionary definition of “slide [under]” does not permit “tipping” or “tilting” a load, and that Commerce has “impermissibly change[d] the scope” of the Antidumping Order. See generally PL’s Brief at 4, 7-9; PL’s Reply Brief at 4, 5 n. 7; Audio Recording of Oral Argument on Remand Results (“Audio Recording”) at 19:40-20:33, 27:06-28:53, 29:13-30:29, 31:13-32:14, 32:56-33:09, 42:11-43:16, 45:25-46:04, 1:02:41-1:04:03,1:05:47-1:06:10. Bond Street’s argument is predicated on a fundamental misreading and misapplication of the phrase “slide[ ] under.” Bond Street points to nothing in the dictionary definition of “slide [under]” which (either explicitly or implicitly) precludes the “tipping” or “tilting” at issue here. Nor can Bond Street do so. It is not the Stebco cart that was “tipped” or “tilted” in this case, it was the load; and it is the cart that must “slide[ ] under.” As a matter of pure logic, the “tipping” or “tilting” of a load says nothing about the motion or movement of a hand cart, which — to fall within the scope of the Antidumping Order — must “slide[ ] under” the load (whether the load is first “tipped”/“tilted,” or not). See generally, e.g., Audio Recording at 1:43:53-1:45:10 (counsel for the Government explains that the Stebco cart “slid under the load in a smooth motion” when the file cabinet was tipped or tilted “in a common sense way”); id. at 1:59:51-1:59:56, 2:00:11-2:00:29 (same). Here, there is no dispute that the Stebco cart “move[d] or pass[ed] smoothly or easily” under the file cabinet, with the cabinet “slightly tiltfed].” See Remand Results at 4; see also id. at 11; Def.-Ints.’ Brief at 2, 4; Def.’s Brief at 2-4, 9; Audio Recording at 1:43:53-1:44:33, 2:00:11-2:00:29. Compare, e.g., Final Scope Ruling: Expeditors Tradewin, LLC, on behalf of Ameristep Corporation Inc. at 7 (May 18, 2007) (ruling that carts are beyond scope of Order, because they cannot “slide[ ] under” load, even “by tipping the load slightly”). Further, as the Government notes, the Remand Results explained that the Anti-dumping Order is silent on the “tipping”/“tilting” of loads, and, moreover, that Commerce’s determination in this case is consonant with a line of other cases that have ruled that various hand carts are within the scope of the Antidumping Order even though they “slide[] under” a load only if the load is “tipped” or “tilted” first. See Def.’s Brief at 9-10; see also Remand Results at 11 & n. 6. In Gleason Products, for example, the court ruled that the Antidumping Order covers a “welding cart” (model 93851), because that cart is “capable of sliding under a load if the load is slightly tipped. ” Gleason Indus. Prods., Inc. v. United States, 32 CIT -, -, 556 F.Supp.2d 1344, 1348-49 (2008) (emphasis added). Indeed, there are certain types of hand trucks that are indisputably within the scope of the Antidumping Order even though it is necessary to “tip” or “tilt” the very loads that the hand trucks are specifically designed to carry. See, e.g., Audio Recording at 25:59-26:27, 2:08:42-2:09:28 (discussing “cylinder hand truck” at issue in Gleason); see also Antidumping Order, 69 Fed.Reg. at 70,122 (listing “cylinder hand truck” among the “names commonly used to reference hand trucks”). In short, contrary to Bond Street’s assertions, there is nothing “unauthorized” about “tipping”/“tilting” a load in order to slide a cart under it. See Pl.’s Brief at 4. Bond Street’s reliance on the dictionary definition of “slide [under]” is misplaced. And, as Commerce noted in the Remand Results, the Antidumping Order itself “is silent with respect to the tilting of the items that are to be moved and/or lifted.” See Remand Results at 11; see also Def.’s Brief at 9. Moreover, Commerce’s consistent and longstanding practice has been to include within the scope of the Antidump-ing Order hand carts that are capable of “sliding] under” a load, even if only when the loads are “tipped”/“tilted.” See Remand Results at 11; Def.’s Brief at 9 (and rulings cited there). Indeed, the “tipping”/“tilting” of loads has received the judicial imprimatur. See Def.’s Brief at 9 (citing Gleason Prods., 32 CIT at -, 556 F.Supp.2d at 1348-49). Bond Street has pointed to nothing to distinguish this case from the numerous other cases where Commerce and the courts have permitted “tipping”/“tilting.” Bond Street’s objections to Commerce’s “tipping”/“tilting” of the load — and, in particular, Bond Street’s objections to the agency’s file cabinet test — must therefore be rejected. B. Bond Street’s Challenge to Commerce’s 15-Pound and 30-Pound Box Tests Although Bond Street cannot claim that Commerce’s tests using 15- and 30-pound boxes involved “tipping” or “tilting” of those loads, Bond Street nevertheless contests their validity based on what Bond Street dismisses as the “extremely light loads.” See Pl.’s Brief at 3; see also id. at 5 (referring to Commerce’s “choice of very light loads”). Arguing that “the two boxes of files weighted] a mere 15 and 30 pounds, respectively,” Bond Street asserts that “hand trucks covered by the Order generally have a carrying capacity within the 200 to 1,000 pound range.” See id. at 4; Pl.’s Reply Brief at 5; Audio Recording at 51:32-51:42; see generally PL’s Brief at 4-5, 7; PL’s Reply Brief at 5-6. Bond Street’s attempt to read the Anti-dumping Order to include a minimum load capacity rests on a false premise, however, and its arguments as a whole are not persuasive. See generally Remand Results at 8, 10; Def.’s Brief at 4, 5-8; Audio Recording at 1:36:14-1:36:25, 1:37:30-1:37:49,1:52:32-1:53:10. As an aside, while Bond Street represents that “hand trucks covered by the Order generally have a carrying capacity within the 200 to 1,000 pound range” (see Pl.’s Reply Brief at 5 (emphasis added)), the administrative record is devoid of evidence to support that assertion. It is true that the original 2003 petition initiating the antidumping duty proceeding that ultimately resulted in the Antidumping Order at issue here generally described hand trucks in terms of, inter alia, the specified load capacity. See Vertex Int'l, Inc. v. United States, 30 CIT 73, 81 n. 11, 2006 WL 160295 (2006) (referring to language in 2003 petition generally describing load capacity of hand trucks). Significantly, however, the load capacity language in the 2003 petition specifically was not carried over into the Antidumping Order itself. See Antidumping Order, 69 Fed.Reg. 70,-122 et seq. (expressly defining “Scope of Order” in detail, with no mention whatsoever of any sort of minimum (or maximum) load capacity); see also Remand Results at 10 (explaining that “the language of the Order does not require an analysis of weight limitations”); Def.’s Brief at 5; Audio Recording at 1:36:14-1:36:25, 1:52:32-1:53:10. Because the scope of the Anti-dumping Order is not defined in terms of load capacity, it simply cannot be said — as a factual matter — that “hand trucks covered by the Order generally have a carrying capacity” of any particular weight (much less “the 200 to 1,000 pound range” that Bond Street alleges). Even more to the point, as a matter of law, the language concerning load capacity that appeared in the 2003 antidumping petition cannot override the Antidumping Order, and accordingly is of little relevance at best. The Court of Appeals has emphasized that it is “[t]he language of the order, not the petition” which controls. See Tak Fat Trading Co. v. United States, 396 F.3d 1378, 1386 (Fed.Cir.2005). “The scope of [an] order can be clarified but it cannot be changed by the interpretive process.” Id., 396 F.3d at 1383. Thus, although “the petition and the investigation may provide valuable guidance as to the interpretation of [a] final order,” they “cannot substitute for language in the order itself.” Duferco Steel, Inc. v. United States, 296 F.3d 1087, 1097 (Fed.Cir.2002); see also Walgreen Co., 620 F.3d at 1357 (same); Def.’s Brief at 6. Moreover, “a predicate for the interpretive process is language in the order that is subject to interpretation.” Tak Fat Trading Co., 396 F.3d at 1383. Here, Bond Street has identified no language dealing with load capacity in the Antidumping Order — much less language that requires “clarification” or “interpretation.” Instead, Bond Street seeks a wholesale re-write of the Order, to include a load capacity limitation that the drafters of the Order specifically elected not to include. This Bond Street may not do. In light of this focus on the language of the Antidumping Order itself as the “cornerstone” of any analysis (see Walgreen Co., 620 F.3d at 1357 (citation omitted)), Commerce’s longstanding and consistent practice in the application and administration of the Antidumping Order- — -from the initial drafting of the Order, up to the present day — has excluded any and all consideration of load capacity. See generally Def.’s Brief at 6-7; Audio Recording at 1:37:30-1:37:49. For example, in drafting the language defining the scope of the Antidumping Order during the original an-tidumping duty investigation, Commerce evaluated various scope exclusion requests. In addressing one such request (which sought the exclusion of a certain portable, collapsible “luggage cart”), Commerce explained that the language concerning load capacity which appeared in the 2003 antidumping petition did not constitute a request for an exclusion from the scope of the Antidumping Order, underscoring that: [L]oad capacity is not a factor in the scope of the investigation. The reference to load capacity (ie., “loads generally not exceeding 1000 pounds”) in the petition appears in a general description of the subject merchandise, not in the petitioners’ recommended scope language, or elsewhere in the current scope of this investigation. Scope Exclusion/Clarification Requests: Alton Industries, Inc.; Safco Products Company; A.J. Wholesale Distributors, Inc.; and Wilmar Corporation at 5 (Oct. 6, 2004); see also id. at 3 et seq. (rejecting, inter alia, argument that “although the scope of the investigation makes no reference to load capacity, the petitioners were only concerned about heavy-duty hand trucks with 600 lbs. or larger load capacities”); Def.’s Brief at 6-7; Audio Recording at 1:37:30-1:87:49. And, over the years, Commerce has steadfastly maintained its position on the irrelevance of load capacity in its scope rulings (such as that in. the case at bar), throughout the agency’s administration of the Antidumping Order. For example, in one such scope ruling, Commerce rejected arguments that a particular “trolley” was not within the scope of the Order because the trolley “can be used to move luggage” and has a “vertical weight capacity of ... only 150 lbs.” See Final Scope Ruling: Total Trolley, LLC at 4, 8-9 (Jan. 10, 2005). Commerce there stated: [Hjand truck load capacity was not a factor in the scope of the [original anti-dumping duty] investigation. The reference to load capacity (ie., “loads generally not exceeding 1000 pounds”) in the [2003 antidumping] petition appears in a general description of the subject merchandise, not in the petitioners’ recommended scope language, or elsewhere in the current scope of the Order. Id. at 8-9; see also Audio Recording at 1:37:30-1:37:49. Commerce determined that the merchandise at issue in Total Trolley was within the scope of the Anti-dumping Order. See Total Trolley at 1, 10; see also Def.’s Brief at 7. As the Government properly concludes, for the reasons outlined above, “Commerce’s selection of items to test on the Stebco Cart was not limited by considerations of weight, but rather, [was simply designed to determine] whether the Stebco Cart could £slide[] under a load for the purposes of lifting and/or moving the load.’ ” Def.’s Brief at 7 (quoting Anti-dumping Order, 69 Fed.Reg. at 70,122). It is nevertheless worth noting that, while Bond Street essentially contends that — to fall within the scope of the Antidumping Order — hand trucks should have a load capacity “within the 200 to 1,000 pound range” (see PL’s Reply Brief at 5; see also Audio Recording at 51:32-51:42) — Bond Street has conceded that the Stebco cart itself is actually “designed to carry/move load(s) up to a maximum weight of 275 pounds” (with an “ideal” load of 150 pounds). See PL’s Reply Brief at 5; see also Def.’s Brief at 6 (citing A.R. Doc. No. 4); Audio Recording at 1:38:18-1:38:28; Bond Street I, 33 CIT at-n. 5, 637 F.Supp.2d at 1347 n. 5 (citation omitted). In other words, even if the scope of the Antidumping Order were limited to hand trucks with a load capacity “within the 200 to 1,000 pound range” (which it clearly is not), such a criterion would not serve to exclude the Stebco cart from the scope of the Order. The loads used by Commerce in the two tests at issue — a 15-pound box and a 30-pound box, of different dimensions — were selected not because they were particularly light, but rather because they were representative of the types of loads that Bond Street has stated the Stebco cart is generally intended to carry. See Audio Recording at 1:31:59-1:33:41 (discussing A.R. Doc. No. 4); id. at 1:35:16-1:35:47 (discussing A.R. Doc. No. 1); id. at 1:55:37-1:56:00; see also Def.’s Brief at 7. Because load capacity is not “germane” to determining whether a particular hand cart is within the scope of the Antidumping Order (see Def.’s Brief at 7), Commerce reasonably conducted its tests using loads such as those that the Stebco cart is used to carry. The purpose of the agency’s tests was to determine whether the Stebco cart would “slide[] under” such loads — and it did. See Remand Results at 1, 3-7, 9-12; Pl.’s Brief at 4 (conceding that Commerce “was able to slide the cart under two boxes of files”); Def.-Ints.’ Brief at 1-2; Def.’s Brief at 2-5, 7-8; Audio Recording at 50:53-51:25, 1:17:48-1:17:57, 1:27:19-1:27:41, 1:31:15-1:31:58. Boxes filled with files weighing 15 pounds and 30 pounds may be relatively light loads, but they are loads nonetheless. See Audio Recording at 1:31:15-1:31:22, 1:34:46-1:35:10. Moreover, a cart may be needed to carry a load that is cumbersome due to its dimensions, even if the load is relatively light. Simply stated, Bond Street’s attempt to read into the Antidumping Order a load capacity limitation must fail. Bond Street’s broad assertions that the hypothetical “typical” hand truck has a load capacity “within the 200 to 1,000 pound range” lacks any evidentiary basis in the record. More importantly, the drafters of the Antidumping Order expressly declined to include in the Order the load capacity language that appeared in the 2003 anti-dumping duty petition,, on which Bond Street relies; and it is the language of the Order itself that controls. Moreover, in its administration of the Antidumping Order over the years, Commerce has consistently declined to consider load capacity in determining whether any particular hand cart falls within the scope of the Order. Like Bond Street’s objections to Commerce’s “tipping”/“tilting” of a load in testing the Stebco cart (discussed in section III.A, above), Bond Street’s claims challenging the weight of the loads used in Commerce’s tests must also be rejected. C. Bond Street’s Reliance on the Design of the Stebco Cart Distilled to its essence, Bond Street’s challenge to the weight of the two boxes that Commerce used to test the Stebco cart is little more than the “flip side” of Bond Street’s objection to the “tipping”/“tilting” of the file cabinet in Commerce’s third test. Bond Street objects to the 15-pound and 30-pound boxes (which did not require “tipping” or “tilting”) as too light, while — at the same time — Bond Street objects to the file cabinet test because the heavier weight of the file cabinet required Commerce to “tip” or “tilt” that load in order to slide the Stebco cart under it. Specifically, Bond Street contrasts the file cabinet test with the tests using the 15-pound and 30-pound boxes of files, arguing that the Stebco cart was able to “slide[ ] under” the boxes due to “the light weight of the load,” and not “the design of the toe plate.” See PL’s Reply Brief at 5; see also PL’s Brief at 3, 4, 5; Audio Recording at 48:24-48:32, 50:53-51:25, 1:17:44-1:18:00. According to Bond Street, Commerce needed to “tip”/“tilt” the Stebco cart in the file cabinet test because, otherwise, “the toe plate collapses when [a] user pushes the cart towards a [heavier] load.” See PL’s Reply Brief at 2-4; see also PL’s Brief at 7-8 (asserting that, without “tipping”/“tilting” the file cabinet, “the Stebco cart was unable to slide under the load because the toe plate began to collapse when pushed against the [file] cabinet,” and that^-when Bond Street tested Stebco cart using a 50-pound box of copy paper, without “tipping”/“tilting” the load — “Bond Street’s test ... showed the collapse of the toe plate”); id. at 4, 5-6; PL’s Reply Brief at 2, 3-4, 5 & n. 7; Audio Recording at 19:50-20:33, 1:21:13-1:21:30. Bond Street thus seeks to make much of the design of the Stebco cart, and attempts to distinguish that design from the design of hand trucks within the scope of the Antidumping Order (in terms of intended use, weightdoad-bearing capacity, and such). See, e.g., Pl.’s Brief at 4, 5, 6, 7 n. 7, 9; PL’s Reply Brief at 2, 5. However, aside from the physical and functional characteristics specifically set forth in the Antidumping Order, the design of any particular hand cart has no bearing on whether or not the hand cart falls within the scope of the Order. If a hand cart has the requisite four physical characteristics (including a “projecting edge or edges, or toe plate”), and if the hand cart is not expressly excluded from the Antidumping Order’s coverage, the hand cart falls within the scope of the Order, whatever its design, provided that “[t]he projecting edge or edges, or toe plate, slides under a load for purposes of lifting and/or moving the load.” Anti-dumping Order, 69 Fed.Reg. at 70,122 (emphasis added); see also Remand Results at 11-12; Def.’s Brief at 7-8; Audio Recording at 1:34:31-1:34:44, 1:35:57-1:36:14, 1:47:48-1:48:12, 1:51:42-1:52:12. Thus, the fact that the Stebco cart may be “designed to move relatively light items such as luggage and sample cases” is of no moment. See PL’s Brief at 4 (emphasis added); see also, e.g., PL’s Reply Brief at 5. The Antidumping Order expressly states that merchandise within the scope of the Order may be “suitable for any use.” Antidumping Order, 69 Fed.Reg. at 70,122; see also Remand Results at 9, 11 (explaining that “the Order does not exclude hand trucks designed with a primary use”); Def.’s Brief at 7-8; Audio Recording at 1:34:31-1:34:44 (stating that Order covers both “heavy-duty hand trucks and lightweight hand trucks”); id. at 1:35:57-1:36:26; id. at 1:47:48-1:48:12 (explaining that design and intended use of cart are not determinative of inclusion in or exclusion from scope of Order; salient issue is whether cart is capable of “sliding] under” a load); id. at 1:51:42-1:52:12. The load-bearing capacity of the Stebco cart is likewise irrelevant. See section III.B, supra. Similarly, contrary to Bond Street’s assertions, the Antidumping Order includes no requirement — much less a “clear requirement” — restricting the Order’s coverage to only those hand carts that feature toe plates specifically “designed to slide under a load.” Compare Pl.’s Brief at 8-9 (emphasis added) with Antidumping Order, 69 Fed.Reg. at 70,122 (expressly defining “Scope of Order”). Indeed, the word “design” does not appear anywhere in the text of the Antidumping Order, except in the language of the express exclusion (which all agree has no application here). See Antidumping Order, 69 Fed. Reg. 70,122. Moreover, Bond Street conspicuously cites no authority for the proposition that a hand cart’s inclusion within the scope of the Antidumping Order is dependent upon whether the toe plate is “designed” to “slide[ ] under” a load. To fall within the scope of the Anti-dumping Order, it is necessary only that the toe plate of a hand cart be capable of “sliding] under a load,” as is the toe plate of the Stebco cart here. See 69 Fed.Reg. at 70,122; see also, e.g., Bond Street I, 33 CIT at -, 637 F.Supp.2d at 1350 (declining to sustain Commerce’s initial scope ruling because agency “failed to make a determination as to whether the toe plate of the Stebco cart can ‘slide[] under a load’ ” (emphasis added)); Gleason Indus. Prods., Inc. v. United States, 31 CIT 393, 398, 2007 WL 781196 (2007) (explaining that, to fall within scope of Order, “a hand truck must be able to slide under a load” (emphasis added)); Gleason Prods., 32 CIT at -, -, 556 F.Supp.2d at 1347, 1349 (explaining that coverage under Order “hinges on whether ... [the subject] carts possess projecting edges capable of sliding under a load,” and remanding as to one model for agency determination whether that model “is capable of sliding under a load” (emphases added)); Gleason Indus. Prods., Inc. v. United States, 32 CIT -, -, 2008 WL 4649652 *3 (2008), aff'd, 335 Fed.Appx. 49 (Fed.Cir.2009) (holding that scope language of Order requires “that the hand cart’s projecting edge must be capable of sliding under a load” (emphasis added)); Vertex Int’l, Inc. v. United States, 30 CIT 73, 81, 2006 WL 160295 (2006) (reversing Commerce’s determination that garden cart was within scope of Order, explaining that agency determination was contrary to the sole record evidence “regarding the garden cart’s ability to slide under a load to lift or carry it” (emphasis added)). In sum, Bond Street’s emphasis on the specific design of the Stebco cart lies at the very heart of its challenge to Commerce’s Remand Results. But Bond Street’s focus on design is misplaced. Aside from the physical and functional characteristics specifically set forth in the Antidumping Order (and assuming that the express exclusion set forth in the Order does not apply), the design of any particular hand cart has no bearing whatsoever on whether or not the hand cart falls within the scope of the Antidumping Order. Bond Street’s contentions to the contrary have no merit. D. Bond Street’s Procedural Objections Apart from its substantive challenges to the tests that Commerce conducted, Bond Street also raises a laundry list of procedural objections. As discussed below, however, Bond Street’s procedural arguments — like its substantive arguments— cannot carry the day. 1. Whether Commerce Was Obligated to Seek Comments on Test Methodology Bond Street argues that, as a general principle, it “would not have been unreasonable to expect [Commerce] to have requested comments from all interested parties on how to test the Stebco cart.” See PL’s Brief at 3. But it is telling that Bond Street cites no authority for its implication that Commerce was required to “seek ... input from the parties.” See id. at 3; see also Def.’s Brief at 5. The bottom line is that, whether or not it would have been “reasonable” for Commerce to solicit the parties’ views on potential testing methodologies, the agency here was under no obligation to do so. Bond Street’s suggestion to the contrary lacks any foundation in the law. 2. The Adequacy of Commerce’s Rationale for Selection of Test Procedures Bond Street further faults Commerce for assertedly “offering] no explanation or reason” as to how the agency decided to test the Stebco cart. See PL’s Brief at 3. Bond Street specifically targets Commerce’s tests using the 15-pound and 30-pound boxes of files, arguing that the agency “should [have] offer[ed] a plausible explanation or reason” for what Bond Street characterizes as the “extremely light loads employed” in those tests. See id.; see also PL’s Reply Brief at 5-6. Bond Street contends that greater explanation is particularly warranted in the case at bar, because Commerce conducted tests using a standard 10-ream box of copy paper weighing 50 pounds in E & B Gift-ware, a similar case which involved a “personal luggage cart.” See Pl.’s Reply Brief at 3 n. 3 (referring to Scope Ruling on E & B Giftware, LLC’s ML6275C Personal Luggage Cart at 7); see also id. at 5; Audio Recording at 55:29-56:03 (noting that load used in Commerce’s test in E & B Giftware case was same as load used by Bond Street in the instant case); Remand Results at 7 (noting that Bond Street’s test in the instant case involved box weighing 50 pounds). Bond Street’s assertions notwithstanding, the Remand Results spoke directly to the notion that the loads used in Commerce’s tests were “extremely light.” In particular, the Remand Results rebutted the unspoken premise of Bond Street’s argument, explaining — as detailed in section III.B, above — that the scope of the Antidumping Order is not defined in terms of any minimum load capacity. See Remand Results at 10 (explaining that “the language of the Order does not require an analysis of [the] weight limitations” of a hand cart in determining whether or not the cart is within the scope of the Order); see also Antidumping Order, 69 Fed.Reg. at 70,122 (defining “Scope of Order” with no reference to a hand cart’s load capacity); Def.’s Brief at 5-7; section III.B & n. 17, supra (explaining that loads used in testing Stebco cart were selected to be representative of types of loads that Steb-co cart is generally intended to carry). To the extent that Bond Street faults the Remand Results for not directly addressing the test that Commerce conducted in the E & B Giftware ease, it is enough to note that Bond Street failed to raise that argument in the course of the remand proceeding before Commerce. Commerce can hardly be faulted for not anticipating in its Remand Results an argument that Bond Street did not make until some three months after the Remand Results issued, when Bond Street filed its Reply Brief with the Court. See Pl.’s Reply Brief at 3 n. 3. In any event, as discussed in section III.D.3.a (immediately below), the Remand Results expressly addressed the test that Bond Street itself conducted using a 50-pound box of copy paper — the exact same load that Commerce used in testing the hand cart that was at issue in the E & B Giftware case. See Remand Results at 7; Audio Recording at 55:29-56:03. In addition, the Remand Results further explained that Commerce tested the Stebco cart using an empty two-drawer file cabinet weighing 50 pounds' — again, the exact same weight as the 10-ream box of copy paper that Commerce used to test the hand cart at issue in E & B Giftware. See Remand Results at 4 (stating that file cabinet weighed 50 pounds); see also id. at 7 (stating that box used in Bond Street’s test weighed 50 pounds); Audio Recording at 55:29-56:03. In short, it is entirely unclear what more Commerce could reasonably be expected to have said. Under the circumstances presented here, Commerce’s justification of its test procedures in the Remand Results was more than adequate, not only explaining that the scope of the Antidump-ing Order is not defined in terms of load capacity, but — in addition — also addressing the test that Bond Street conducted on the Stebco cart, which involved the same 50-pound load used in the E & B Giftware case (as well as a second test involving another 50-pound load). 3. The Adequacy of Commerce’s Treatment of Certain Tests Bond Street similarly contends that the Remand Results failed to adequately address both the results of the test conducted by Bond Street and the results of Commerce’s own test on the 50-pound file cabinet, and, further, that Commerce should have “offer[ed] a reasonable explanation or justification for ignoring or rejecting the tests proposed by Bond Street.” See PL’s Brief at 3; see also id. at 4, 6; Pl.’s Reply Brief at 2 & n. 2, 3-4, 5-6. None of these claims are persuasive, a. The Test Conducted by Bond Street In the course of the remand proceeding, Bond Street submitted to Commerce evidence concerning a test conducted by Bond Street, in which Bond Street asserts that it attempted unsuccessfully to slide the Stebco cart under an unopened box— measuring 18 x 12 x 10 inches, weighing 50 pounds, and containing ten reams of copy paper — without “tipping”/“tilting” the load. See Remand Results at 7; see generally Pl.’s Brief at 2, 5 & n. 5, 6, 8; Pl.’s Reply Brief at 2 & n. 2, 5 & n. 7. To document that test, Bond Street provided Commerce with “three color photographs purporting to depict the Stebco [c]art’s wheels lifting off the ground as the cart’s [toe] plate makes contact with the box[,] and the cart beginning to collapse on a second attempt.” See Remand Results at 7; see also Pl.’s Reply Brief at 2; S.A.R. Doc. No. 2 at Attachments 1, 1A, & IB (photos of Bond Street’s test); id. at 2-3 (describing Bond Street’s test and photos thereof). Rather incredibly, Bond Street states that the Remand Results “make[ ] no mention of Bond Street’s test.” See PL’s Reply Brief at 2; see also Pl.’s Brief at 3 (charging Commerce with “ignoring or rejecting” Bond Street’s test); id. at 6 (asserting that the Remand Results do not “discuss or comment on Bond Street’s new test”). Quite to the contrary, the Remand Results include a more detailed explanation of Bond Street’s test than do Bond Street’s own briefs filed with the Court. Compare Remand Results at 7 (describing methodology and results of Bond Street’s test, with specificity) with Pl.’s Brief at 3 (referring generally to a test “conducted on the Stebco cart by ... Bond Street”); id. at 4 (referring to “Bond Street’s testing of the cart”); id. at 5 (asserting that Steb-co cart “was not able to slide under ... a 50-pound box of copy paper”); id. at 5 n. 5 (alluding to “Bond Street’s test”); id. at 6 (referring broadly to “Bond Street’s new test”); id. at 8 (stating that “Bond Street’s test” demonstrated “the collapse of the toe plate when pushed against the box of copy paper”); and Pl.’s Reply Brief at 2 (stating only that Bond Street submitted to Commerce “a series of photographs depicting the unintended collapse of the [Stebco cart’s] vertical frame when the user attempted to slide the toe plate under an unopened box of copy paper containing ten reams of paper”); id. at 5 & n. 7 (referring to test “made by Bond Street utilizing the Stebco cart”). In sum, there is simply no truth to Bond Street’s claim that Commerce “ignored” or “rejected” the test that Bond Street conducted. See PL’s Brief at 3. The Remand Results themselves demonstrate that Commerce was plainly cognizant of the details of Bond Street’s test, including the test methodology and the test results. See Remand Results at 7. Moreover, the Remand Results clearly explain why there was no need for Commerce to replicate Bond Street’s test and why the results of that tes