Full opinion text
OPINION RIDGWAY, Judge: In this action, the plaintiff Chinese producers and exporters of fresh garlic challenged the final results of the U.S. Department of Commerce’s tenth administrative review of the antidumping duty order covering fresh garlic from the People’s Republic of China. See generally Zhengzhou Harmoni Spice Co. v. United States, 33 CIT —, 617 F.Supp.2d 1281 (2009) (“Zhengzhou Harmoni /”). Zhengzhou Harmoni I analyzed each of the seven issues that the Chinese producers raised, sustaining Commerce’s determination as to two issues, and remanding the remaining five for further consideration by the agency. See generally id., 33 CIT at —, —, 617 F.Supp.2d at 1289, 1334. Now pending before the court is Commerce’s Remand Determination, filed pursuant to Zhengzhou Harmoni I. See generally Final Results of Redetermination Pursuant to Court Remand (“Remand Determination”). Plaintiffs Jinan Yipin Corporation, Ltd. (“Jinan Yipin”), Linshu Dading Private Agricultural Products Co., Ltd. (“Linshu Dading”), and Sunny Import & Export Ltd. (“Sunny”) — collectively referred to as “the Chinese Producers”— continue to dispute the agency’s treatment of four of the five issues addressed in the agency’s Remand Determination. See generally Plaintiffs’ Comments Regarding the Department’s Remand Redetermination (“Pis. Comments”); Plaintiffs’ Reply to Defendant’s Response Comments Regarding Remand Redetermination (“Pls. Reply Comments”). For its part, the Government seeks a voluntary remand to allow Commerce to recalculate the surrogate value for the Chinese Producers’ labor costs, but contends that the Remand Determination should be sustained in all other respects. See Defendant’s Response to Comments Upon the Remand Redetermination (“Def. Response”) at 1, 31. DefendanG-Intervenors the Fresh Garlic Producers Association and its individual members (Christopher Ranch, L.L.C., The Garlic Company, Valley Garlic, and Vessey and Company, Inc.) — collectively referred to as “the Domestic Producers” — do not oppose the Government’s request for a limited remand to allow the agency to recalculate labor costs, but urge that the Remand Determination be sustained as to all other issues save one, on which the Domestic Producers express no view. See Defendant-Intervenors’ Reply Regarding Agency Remand Redetermination (“Def.-Ints. Reply Comments”) at 1-3. Jurisdiction lies under 28 U.S.C. § 1581(c) (2000). For the reasons detailed below, Commerce’s Remand Determination is sustained in part, and this matter is remanded to the agency for further consideration not inconsistent with this opinion. I. Background Seven Chinese producers and exporters of fresh garlic brought this action to contest various aspects of the Final Results of Commerce’s tenth administrative review of the antidumping duty order on fresh garlic from China, which covered the period from November 1, 2003 through October 31, 2004. See generally Zhengzhou Harmoni I, 33 CIT —, 617 F.Supp.2d 1281; Fresh Garlic from the People’s Republic of China: Final Results and Partial Rescission of Antidumping Duty Administrative Review and Final Results of New Shipper Reviews, 71 Fed.Reg. 26,329 (May 4, 2006) (“Final Results”). Zhengzhou Harmoni I sustained Commerce’s use of its “intermediate input methodology” to value the raw garlic bulb grown by the Chinese Producers, as well as the agency’s inclusion of certain labor-related expenses as part of manufacturing overhead. See Zhengzhou Harmoni I, 33 CIT at —, —, —, 617 F.Supp.2d at 1289, 1295, 1333-34. In contrast, Zhengzhou Harmoni I remanded for further consideration Commerce’s surrogate valuation of certain “factors of production” necessary for the cultivation and export of fresh garlic — specifically (1) raw garlic bulb, (2) labor, (3) ocean freight, (4) cardboard cartons, and (5) plastic jars and lids. See id., 33 CIT at —, —, —, —, —, —, 617 F.Supp.2d at 1289, 1301, 1311-12, 1321, 1327, 1334. Following Zhengzhou Harmoni I but before issuance of Commerce’s Remand Determination, four of the seven Chinese producers that filed the complaint in this action moved for voluntary dismissal. See generally Zhengzhou Harmoni Spice Co. v. United States, 34 CIT —, 675 F.Supp.2d 1320 (2010) (“Zhengzhou Harmoni II ”). Zhengzhou Harmoni II granted the motion and dismissed the four Plaintiffs from this action with prejudice, leaving Jinan Yipin, Linshu Dading, and Sunny (collectively “the Chinese Producers”) as the remaining Plaintiffs and the only subjects of Commerce’s Remand Determination. See id., 34 CIT at —, —, 675 F.Supp.2d at 1324, 1339-40. Commerce thereafter issued its Remand Determination. In the Remand Determination, Commerce revalued raw garlic bulb, labor, and ocean freight. See Remand Determination at 5-15, 15-38, 38-41, 51-59, 59-68. On the other hand, Commerce continued to value cardboard cartons and plastic jars as it had in the Final Results. See id. at 41-46, 46-50, 68-71, 71-74. As a result of its reconsideration in the course of the remand, Commerce recalculated the weighted-average antidumping duty margin for Jinan Yipin as 55.18% (up from 29.52%), for Linshu Dading as 39.51% (up from 22.47%), and for Sunny as 26.67% (up from 10.52%). See id. at 74-75; Final Results, 71 Fed.Reg. at 26,332. The Chinese Producers contend that Commerce’s wage rate calculation and its valuation of raw garlic bulb, cardboard cartons, and plastic jars do not comply with the instructions in Zhengzhou Harmoni I. See generally Pls. Comments; Pls. Reply Comments. The Chinese Producers maintain that these matters therefore should be remanded to the agency for further consideration. See Pls. Comments at 1-2, 18-19, 26, 30, 31; Pls. Reply Comments at 12, 17. The Government seeks a voluntary remand to allow Commerce to recalculate the surrogate value for the Chinese Producers’ labor costs in light of the Court of Appeals’ decision in Dorbest, but maintains that the Remand Determination should be otherwise sustained. See Def. Response at 1, 31; Dorbest Ltd. v. United States, 604 F.3d 1363, 1366, 1369-73 (Fed.Cir.2010). The Domestic Producers do not oppose the Government’s request for a voluntary remand on labor costs, but contend that the Remand Determination should be sustained as to the surrogate valuation of garlic bulb, cardboard cartons, and plastic jars and lids. See Def.-Ints. Reply Comments at 1, 3. The Domestic Producers express no view concerning the Remand Determination on ocean freight expenses. See id. at 1-3. II. Standard of Review In an action reviewing an anti-dumping determination by Commerce, the agency’s determination must be upheld except to the extent that it is 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); see also NMB Singapore Ltd. v. United States, 557 F.3d 1316, 1319 (Fed.Cir.2009). Substantial evidence is “more than a mere scintilla”; rather, it is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Universal Camera Corp. v. Nat’l Labor Relations Bd., 340 U.S. 474, 477, 71 S.Ct. 456, 95 L.Ed. 456 (1951) (quoting Consol. Edison Co. v. Nat’l Labor Relations Bd., 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938)); see also Mittal Steel Point Lisas Ltd. v. United States, 548 F.3d 1375, 1380 (Fed.Cir.2008) (same). Moreover, any evaluation of 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 Corp., 340 U.S. at 487-88, 71 S.Ct. 456); see also Mittal Steel, 548 F.3d at 1380-81 (same). That said, the mere fact that it may be possible to draw two inconsistent conclusions from 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 Comm’n, 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966). Finally, while Commerce must explain the bases for its decisions, “its explanations do not have to be perfect.” NMB Singapore, 557 F.3d at 1319. Nevertheless, “the path of Commerce’s decision must be reasonably discernable,” to support judicial review. Id. (citing Motor Vehicle Mfrs. Ass’n v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983)); see also Timken U.S. Corp. v. United States, 421 F.3d 1350, 1355 (Fed.Cir.2005) (explaining that “it is well settled that an agency must explain its action with sufficient clarity to permit ‘effective judicial review,’ ” and that “[flailure to provide the necessary clarity requires the agency action be vacated”) (quoting Camp v. Pitts, 411 U.S. 138, 142-43, 93 S.Ct. 1241, 36 L.Ed.2d 106 (1973)); see generally 19 U.S.C. § 1677f(i)(3)(A) (requiring Commerce to “include in a final determination ... an explanation of the basis for its determination”). III. Analysis Dumping occurs when goods are imported into the United States and sold at a price lower than their “normal value,” resulting in material injury (or the threat of material injury) to the U.S. industry. See 19 U.S.C. §§ 1673, 1677(34), 1677b(a). The difference between the normal value of the goods and the U.S. price is the “dumping margin.” See 19 U.S.C. § 1677(35). When normal value is compared to the U.S. price and dumping is found, antidumping duties equal to the dumping margin are imposed to offset the dumping. See 19 U.S.C. § 1673. Normal value is typically calculated using either the price in the exporting market (i.e., the price in the “home market” where the goods are produced) or the cost of production of the goods, when the exporting country is a market economy country. See generally 19 U.S.C. § 1677b. However, where — as here — the exporting country has a non-market economy (“NME”), there is often concern that the factors of production used to produce the goods at issue are under state control, and that home market sales may not be reliable indicators of normal value. See 19 U.S.C. § 1677(18)(A). In cases such as this, where Commerce concludes that concerns about the sufficiency or reliability of the available data do not permit the normal value of the goods to be determined in the typical manner, Commerce “determined the normal value of the subject merchandise on the basis of the value of the factors of production,” including “an amount for general expenses and profit plus the cost of containers, coverings, and other expenses.” See 19 U.S.C. § 1677b(c)(1); see generally Ningbo Dafa Chem. Fiber Co. v. United States, 580 F.3d 1247, 1250-51 (Fed.Cir.2009) (briefly summarizing “factors of production” methodology). The antidumping statute requires Commerce to value factors of production “based on the best available information regarding the values of such factors” in an appropriate surrogate market economy country — in this case, India. See 19 U.S.C. § 1677b(c)(1) (emphasis added); see also Shakeproof Assembly Components v. United States, 268 F.3d 1376, 1382 (Fed.Cir.2001); Ningbo, 580 F.3d at 1254 (emphasizing that statute mandates that Commerce “shall” use “best available information” in valuing factors of production). In determining which data constitute the “best available information,” Commerce generally looks to the criteria set forth in its “Policy Bulletin 04.1,” also known as the “NME Surrogate Country Policy Bulletin” and the “Surrogate Country Selection Bulletin.” Policy Bulletin 04.1 explains: In assessing data and data sources, it is [Commerce’s] stated practice to use investigation or review period-wide price averages, prices specific to the input in question, prices that are net of taxes and import duties, prices that are contemporaneous with the period of investigation or review, and publicly available data. See Import Administration Policy Bulletin 04.1, “Non-Market Economy Surrogate Country Selection Process,” at “Data Considerations” (March 1, 2004); see also Remand Determination at 42 (quoting Policy Bulletin 04.1, and stating that it reflects agency’s “well-established practice for determining the reliability and appropriateness of surrogate values under consideration”); id. at 6, 40, 47, 69-70, 73; Issues and Decision Memorandum for the [Tenth] Administrative Review and New Shipper Reviews of the Antidumping Duty Order on Fresh Garlic from the People’s Republic of China (April 26, 2006) (Admin. Record Pub. Doc. 462) (“Issues and Decision Memorandum”) at 60-61, 63 & n. 161, 66. Within this general framework, the statute “accords Commerce wide discretion in the valuation of factors of production in the application of [the statute’s] guidelines.” See Shakeproof, 268 F.3d at 1381 (internal quotation marks and citation omitted); see also Ad Hoc Shrimp Trade Action Committee v. United States, 618 F.3d 1316, 1320 (Fed.Cir.2010) (same); Nation Ford Chem. Co. v. United States, 166 F.3d 1373, 1377 (Fed.Cir.1999) (same). Commerce is recognized as the “master of antidumping law.” See The Thai Pineapple Public Co. v. United States, 187 F.3d 1362, 1365 (Fed.Cir.1999); see also Shakeproof, 268 F.3d at 1381 (acknowledging “Commerce’s special expertise”). And “[t]he process of constructing foreign market value for a producer in a non-market economy country is difficult and necessarily imprecise.” Shakeproof, 268 F.3d at 1381. Nevertheless, Commerce’s discretion is not boundless. In exercising its discretion, Commerce is constrained by the purpose of the antidumping statute, which is “to determine antidumping margins ‘as accurately as possible.’ ” See Shakeproof 268 F.3d at 1382 (quoting Lasko Metal Products, Inc. v. United States, 43 F.3d 1442, 1446 (Fed.Cir.1994)). And, Commerce’s discretion notwithstanding, “a surrogate value must be as representative of the situation in the [non-market economy] country as is feasible.” See Nation Ford, 166 F.3d at 1377 (internal quotation marks and citation omitted). Thus, “[i]n determining the valuation of ... factors of production, the critical question is whether the methodology used by Commerce is based on the best available information and establishes antidumping margins as accurately as possible.” See Ningbo, 580 F.3d at 1257 (emphases added) (quoting Shakeproof 268 F.3d at 1382) (internal quotation marks omitted). In the present case, pursuant to the remand instructions in Zhengzhou Harmoni I, Commerce reconsidered various aspects of the agency’s valuation of the factors of production in the final results of the tenth administrative review of the anti-dumping duty order covering fresh garlic from China. As discussed in greater detail below, Commerce’s determination on remand concerning the surrogate value for the Chinese Producers’ ocean freight costs must be sustained. On the other hand, Commerce’s determinations as to garlic bulb, labor expenses, plastic jars and lids, and cardboard packing cartons must be remanded to the agency once again, for further consideration. A. Valuation of Garlic Bulb In the administrative review at issue, rather than valuing the Chinese Producers’ so-called “growing” and “harvesting” factors of production (i.e., the garlic seed, water, fertilizer, labor, and other “inputs” (commodities) consumed by Chinese producers in cultivating and harvesting whole raw garlic bulb), Commerce broke with its past practice and employed the agency’s “intermediate input methodology” to value the whole raw garlic bulb (the “intermediate input”) itself. See Zhengzhou Harmoni I, 33 CIT at —, —, 617 F.Supp.2d at 1288, 1291. Zhengzhou Harmoni I rejected the Chinese Producers’ objections to Commerce’s use of its intermediate input methodology here. See id., 33 CIT at —, —, —, 617 F.Supp.2d at 1289, 1295, 1334; see generally id., 33 CIT at —, 617 F.Supp.2d at 1289-95 (reviewing the Chinese Producers’ objections to intermediate input methodology). On the other hand, Zhengzhou Harmoni I sustained the Chinese Producers’ challenge to the surrogate value for raw garlic bulb that Commerce calculated for use in the Final Results, principally on the grounds that the record evidence did not establish that the data on which Commerce relied were sufficiently “product-specific.” See id., 33 CIT at —, —, —, —, 617 F.Supp.2d at 1289, 1298-99, 1301, 1334; see generally id., 33 CIT at —, 617 F.Supp.2d at 1295-1301 (analyzing Chinese Producers’ challenge to surrogate valuation of raw garlic bulb). As Zhengzhou Harmoni I explained, the Chinese Producers’ garlic “is a large, high yield, high-quality type of garlic that is distinct from the overwhelming majority of garlic grown in India.” See Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1296; see also Issues and Decision Memorandum at 42 (stating that “the primary characteristic that distinguishes the type of garlic exported by [Chinese producers] from the majority of garlic sold in India” is the significantly larger bulb size of Chinese garlic). In the Final Results, Commerce calculated a surrogate value of 22.91 rupees per kilogram for garlic bulb, using data from the Indian Agricultural Marketing Information Network (“Agmarknet”) for a type of garlic referred to as “China” variety. See Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1296-97; Issues and Decision Memorandum at 39-44, 47. As support for the finding that India’s “China” variety garlic is sufficiently product-specific to the Chinese Producers’ large-bulb garlic, the Final Results relied on information drawn from “Market Research on Fresh Whole Garlic in India,” a June 2003 report prepared by consultants to the Domestic Producers, which the Domestic Producers placed on the record of this administrative review. See Zhengzhou Harmoni I, 33 CIT —, 617 F.Supp.2d at 1297-98; see also Issues and Decision Memorandum at 40-41; Domestic Producers’ Surrogate Value Submission (Admin. Record Pub. Doc. 417), Exh. 33 (“Market Research Report”). Relying on the Market Research Report and additional information on the record, the Final Results explained that Chinese garlic exported to the United States is characterized by its large bulb size (with an average diameter of greater than 40 millimeters); that the bulb diameter of local, native garlic typically grown and sold in the Indian market is a mere 20 to 40 millimeters; and that, in India, cultivation of large-bulb garlic is generally confined to the country’s “long-day” zone, which enjoys longer periods of sunlight. See Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1297; Issues and Decision Memorandum at 41-44; Market Research Report at 4, 7, 11, 12, 17-18. Based on this and other information, the Final Results concluded that the Agmarknet data for “China” variety garlic must represent sales of large-bulb garlic from India’s “long-day” zone. See Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1298; see also Issues and Decision Memorandum at 40-42. But the Agmarknet data provide no description of the physical characteristics of “China” variety garlic (or any other variety of garlic reflected therein). See Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1297-99; see also Issues and Decision Memorandum at 42 (noting that Agmarknet data do not include descriptions of garlic varieties reflected in the data). Noting that the Final Results apparently relied on the Agmarknet data “based on nothing more than perhaps the name of the variety, and the fact that [the “China” variety] had a higher weighted-average price,” Zhengzhou Harmoni I held that the Final Results were therefore “largely speculative and conclusory” and “lack[ed] adequate support in the evidentiary record.” See Zhengzhou Harmoni I, 33 CIT at-, 617 F.Supp.2d at 1297-98. Zhengzhou Harmoni I concluded that, absent some proof of the physical characteristics of “China” variety garlic, Commerce’s decision to use the Agmarknet data in the Final Results was not supported by substantial evidence and could not be sustained on the then-existing record. See id., 33 CIT at —, 617 F.Supp.2d at 1297-98. The valuation of raw garlic bulb was thus remanded to the agency for further consideration. See id., 33 CIT at —, —, —, 617 F.Supp.2d at 1289, 1301, 1334. In addition to the Chinese Producers’ concerns about product specificity (discussed above), Zhengzhou Harmoni I addressed a number of other issues. See generally Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1299-1301. Notably, the Chinese Producers argued that the Agmarknet data actually reflect a final product and not an intermediate input at all. Specifically, the Chinese Producers asserted that, because the Agmarknet prices — by definition — represent fresh garlic sold at market, the prices do not reflect an intermediate product and inherently include post-harvest factors of production. See id., 33 CIT at —, 617 F.Supp.2d at 1300. The Chinese Producers thus contended that the Final Results “impermissibly inflated the surrogate value of fresh garlic by adding additional post-harvest factors of production {e.g., sales, packing, and transportation costs) to a figure that already reflected such costs.” See id., 33 CIT at —, 617 F.Supp.2d at 1300. Zhengzhou Harmoni I instructed Commerce, on remand, to consider “the potential for double counting that may result when using data from the Agmarknet database, which presumably contains information regarding Indian market transactions and is representative of the final garlic product rather than an intermediate garlic product (ie., garlic bulb).” See id., 33 CIT at —, 617 F.Supp.2d at 1300. Zhengzhou Harmoni I specifically cautioned that, “when valuing an intermediate product in [a non-market economy] country case, [Commerce] must find a surrogate representative of that intermediate product.” See id., 33 CIT at —, 617 F.Supp.2d at 1300. On remand, Commerce reexamined the three sets of potential surrogate value data considered in the Final Results, including the Agmarknet prices, although the agency took no action to obtain information on the physical characteristics of the “China” variety garlic reflected in the Agmarknet data and used in the Final Results. See Remand Determination at 6-8, 15. Other than the Agmarknet data, the Remand Determination also reconsidered Indian import statistics derived from the World Trade Atlas for Indian Harmonized Tariff Schedule subheading 0703.2000 (“garlic, fresh or chilled”), as well as Indian price data for garlic seed from the National Horticultural Research and Development Foundation (“NHRDF”), which were placed on the record by the Domestic Producers and relied on by the agency in previous administrative reviews. See id. at 6-7, 15. In the course of the remand, Commerce also placed on the record a fourth set of data, which the agency used to value garlic bulb in the eleventh administrative review (as well as other subsequent reviews) — i.e., information on garlic prices at the produce market near Delhi operated by the Azadpur Agricultural Produce Marketing Committee (“APMC”), as published in the Azadpur APMC’s “Market Information Bulletin,” for the two-and-one-half-month period from May 1, 2006 through July 14, 2006. See id. at 2, 6, 10, 13, 15; Letter from Commerce to All Interested Parties (June 5, 2009) (Remand Pub. Doc. 1) (placing on the record Azadpur APMC’s “Market Information Bulletins” for May 1, 2006-July 14, 2006) (“Azadpur APMC data”); n. 44, infra (discussing use of Azadpur APMC data in subsequent reviews). The Remand Determination emphasized the large bulb size of the Chinese Producers’ garlic (50 mm and above), and the significant role that bulb size plays in garlic pricing. See Remand Determination at 10-11. Citing the concerns identified in Zhengzhou Harmoni I (particularly the lack of any physical description of the garlic reflected in the Agmarknet data), the Remand Determination declined to rely on the Agmarknet data to value garlic bulb. See id. at 5, 7-8, 15. Further, the Remand Determination again rejected the Indian import statistics as “insufficiently specific” due to the “basket” nature of the tariff subheading at issue. See id. at 7, 8, 15; see also Zhengzhou Harmoni I, 33 CIT at —, 617 F.Supp.2d at 1296. The Remand Determination similarly rejected the NHRDF data on garlic seed, concluding that those data would “require a prohibitive level of adjustment” in order to calculate a value for garlic bulb. See Remand Determination at 15; see also id. at 7. Much as Commerce has done in other recent reviews, the Remand Determination based the surrogate value for garlic bulb here on the Azadpur APMC data, averaging the values for “A”-and “S.A.”-grade garlic. See generally Remand Determination at 9-15, 53-59. Relying on the Azadpur APMC data, the Remand Determination calculated a final value of 33.77 rupees per kilogram — a significantly higher figure than the 22.91 rupees per kilogram established in the Final Results. See Analysis for the Redetermination of Remand in the Administrative Review of the Antidumping Duty Order on Fresh Garlic from the Peopie’s Republic of China: Jinan Yipin Corporation, Ltd. (Remand Pub. Doc. 19) at 2; Issues and Decision Memorandum at 39, 44, 47. The Remand Determination concluded that the Azadpur APMC data constitute “the best information available with which to value [the Chinese Producers’] garlic bulb,” even though — much like the Agmarknet data — the Azadpur APMC data do not describe the physical characteristics of the garlic to which they refer. See Remand Determination at 14; Azadpur APMC data. To establish the “product specificity” of the Azadpur APMC data, the Remand Determination therefore relied on the Market • Research Report to find that grade “A” garlic has a bulb diameter of “[a]bove 40 mm (typically 40-55 mm).” See Remand Determination at 11; Market Research Report at 21. Similarly, the Remand Determination relied on information submitted by the Domestic Producers to find that the bulb diameter of “S.A.”-grade garlic is 55 mm or more. See Remand Determination at 11; Domestic Producers’ Comments on New Surrogate Value Information (June 24, 2009) (Remand Pub. Doc. 3) at 4 (explaining that “S.A.”-grade garlic has bulb diameter “greater than 5.5 cm”). Reiterating that a major determinant of the market price of garlic is bulb size, Commerce gave greater weight to bulb size and “product specificity” in choosing the surrogate value on remand. See Def. Response at 7; Remand Determination at 8-9, 10-11, 14 (emphasizing significance of bulb size and garlic prices); id. at 10, 14 (discussing relationship among criteria set forth in Policy Bulletin 04.1). However, the Remand Determination also addressed other criteria set forth in Policy Bulletin 04.1, and concluded that the Azadpur APMC data satisfy those too. For example, the Remand Determination found that the Azadpur APMC data are “publicly available,” noting that — although the Azadpur APMC Bulletins are not available online — the data are “readily available to [the] intended audience,” and “are published on each trading day (six days a week), [are] posted in the APMC’s facilities for public viewing, are electronically archived and are available upon request.” See Remand Determination at 13-14 (discussing public availability of Azadpur APMC data); see also id. at 58 (same). The Remand Determination further found that the Azadpur APMC data are sufficiently “contemporaneous,” explaining that Commerce chose the data set beginning May 1, 2006 because that is the date on which the Azadpur APMC market began differentiating between “A”-and “S.A.’’-grade garlic. See Remand Determination at 14, 58. Because the Azadpur APMC data thus post-date the period of review by more than one-and-one-half years, Commerce deflated the Azadpur APMC value to be contemporaneous with the period of review, using the International Monetary Fund (“IMF”) “Wholesale Price Index.” See Remand Determination at 10, 14-15; Def. Response at 8; see generally Remand Determination at 14, 58 (discussing contemporaneity of Azadpur APMC data). In addition, Commerce also deducted a 6% “market fee” that is assertedly charged on all sales made at the Azadpur APMC market. See Remand Determination at 15, 59. Finally, while the Azadpur APMC data reflect only two-and-one-half months of information (rather than the full year covered by the period of review), the Remand Determination nevertheless found that the data “represent[ ] a broad market average of large-bulb garlic [prices],” reasoning, among other things, that the Azadpur APMC market sells “agricultural products from all over India,” and asserting that the data reflect “a substantial quantity of garlic.” See Remand Determination at 12-13, 57; see generally id. at 12-13, 57-58, 58-59 (discussing “representativeness” of Azadpur APMC data). As detailed below, the Chinese Producers challenge the Remand Determination’s conclusion that the Azadpur APMC data constitute the “best available information” for use in valuing garlic bulb, highlighting this as Commerce’s “most critical surrogate value decision,” and attacking the Azadpur APMC data on multiple fronts. See Remand Determination at 14; Pis. Reply Comments at 3; see generally Pis. Comments at 2-18 (challenging Remand Determination as to valuation of garlic bulb); Pis. Reply Comments at 2-12 (same). The Government defends Commerce’s use of the Azadpur APMC data, arguing that “they were the most product-specific information on the record and also met Commerce’s other preferred criteria for surrogate values,” and asserting that the Remand Determination as to valuation of garlic bulb should therefore be sustained. See Def. Response at 5, 9, 16; see generally id. at 4-16 (addressing Remand Determination as to valuation of garlic bulb). The Domestic Producers support the Remand Determination’s use of the Azadpur APMC data. See Def.-Ints. Reply Comments at 1-2. 1. “Contemporaneity” of Azadpur APMC Data As discussed in the introduction to section III above, Policy Bulletin 04.1 sets forth Commerce’s “well-established criteria for determining the appropriateness of surrogate values under consideration.” See Remand Determination at 6; Policy Bulletin 04.1; see generally section III, supra (discussing, inter alia, Policy Bulletin 04.1). According to that policy, “it is [Commerce’s] stated practice to use ... prices that are contemporaneous with the period of investigation or review.” See Policy Bulletin 04.1 (emphasis added) (quoted in Remand Determination at 6). The Remand Determination further states that “[i]n the selection of surrogate values for garlic bulbs, [Commerce is] ... seeking to select as a surrogate value a ... price average that is ... contemporaneous with the period of review” (i.e., November 1, 2003 through October 31, 2004). See Remand Determination at 6. Nevertheless, the Azadpur APMC data that Commerce ultimately selected to value garlic bulbs on remand date from mid-2006. See Remand Determination at 14. The Chinese Producers criticize the Remand Determination’s use of the Azadpur APMC data, emphasizing that the data are “far from contemporaneous” and, indeed, are the least contemporaneous of the four sets of data on this administrative record. See Pis. Comments at 12; see generally Pls. Comments at 2-3, 12-13; Pls. Reply Comments at 8; Remand Determination at 14, 53, 57-58; Def. Response at 13-14. The Chinese Producers note that the Remand Determination candidly acknowledges that the APMC data are not contemporaneous, but that Commerce concludes that, as adjusted, the APMC prices are the best available information, because the Azadpur APMC data are — according to the Remand Determination — the most product-specific. See Pls. Comments at 12; see also Pls. Reply Comments at 8; Remand Determination at 14. Although the Chinese Producers stress that the Azadpur APMC data are from “approximately two years after the midpoint of the period of review,” the Chinese Producers significantly do not contest any aspect of the methodology that Commerce used to deflate the value that Commerce derived based on the Azadpur APMC data from mid-2006 levels to be contemporaneous with the period of review. See Pis. Comments at 2-3; see also Pls. Reply Comments at 8 (arguing that Azadpur APMC data are “two years removed” from the period of review) (emphasis omitted); see generally Pis. Comments at 12-13 (discussing contemporaneity of Azadpur APMC data, but raising no challenge to deflation methodology); Pls. Reply Comments at 8 (same); Def. Response at 8 (stating that Commerce deflated Azadpur APMC data using the IMF Wholesale Price Index). What the Chinese Producers do dispute — vigorously—is the Government’s assertion that the Remand Determination “reasonably gave greater weight to product-specificity over contemporaneity.” See Def. Response at 13-14 (citing, inter alia, Remand Determination at 14); id. at 7, 8 (same); Pls. Reply Comments at 8; see also Pis. Comments at 12 (arguing that “Commerce’s repeated argument that it must use the non-contemporaneous APMC prices because they are ‘more specific’ ... is unpersuasive”); Remand Determination at 14 (discussing trade-off between product specificity and contemporaneity, and stating that Commerce “does not automatically disregard surrogate value data which are the most specific ... solely on the basis that they are post-[period of review] data”). In particular, the Chinese Producers insist that “it is clear that the [Azadpur] APMC prices are not specific to the intermediate input [garlic] bulb and are heavily inflated and distorted by other unknown factors. A simple deflating of the [Azadpur APMC] prices does not remedy these serious [product specificity] deficiencies.” See Pls. Comments at 12; see also Pls. Reply Comments at 8. The Chinese Producers thus do not actually challenge the Remand Determination’s use of the Azadpur APMC data on grounds of contemporaneity. But see n. 21, infra (questioning Remand Determination’s use of non-contemporaneous Azadpur APMC data to value garlic with a bulb size of 40 mm or more, since the Remand Determination and the Market Research Report indicate that contemporaneous data were available). The Chinese Producers’ true, underlying concerns go to the product specificity of the Azadpur APMC data, and are discussed in section III.A.3, below. 2. “Representativeness” of Azadpur APMC Data Policy Bulletin 04. 1, which sets forth Commerce’s “well-established criteria for determining the appropriateness of surrogate values under consideration,” explains that “it is [Commerce’s] stated practice to use ... review period-wide price averages.” See Policy Bulletin 04.1 (emphasis added) (quoted in Remand Determination at 6). Moreover, throughout the Remand Determination, Commerce repeatedly reiterates that it has “historically chosen to use surrogate values that reflect broad market averages and that cover a sub stantial time period over price data that are obtained from so isolated a time frame as to be subject to temporary market fluctuations.” See, e.g., Remand Determination at 44 (emphases added); id. at 48 (same); Ad Hoc Shrimp Trade Action Committee v. United States, 618 F.3d 1316, 1322 (Fed.Cir.2010) (noting Commerce’s strong preference for “countrywide data,” and explaining that agency resorts to regional information only when countrywide data are not available).”. It is thus Commerce’s standard practice to seek out values that are both temporally and geographically “representative” of the particular input (here, raw garlic bulb) at issue. The Chinese Producers contend that, by using the Azadpur APMC data in the Remand Determination, Commerce failed on both counts. See Pls. Comments at 23 (emphasizing that, inter alia, the Azadpur APMC data “are from a single market” and are “taken from a very limited window of time”). a. Temporal Representativeness Notwithstanding Commerce’s “well-established criteria” and its stated desire to “select as a surrogate value a period-unde price average,” Commerce here elected on remand to calculate a surrogate value for the Chinese Producers’ raw garlic bulb using the Azadpur APMC data, which are not only non-contemporaneous (see section III.A.1, above), but, in addition, represent less than a quarter of a year’s worth of data. See Remand Determination at 6 (emphasis added); see also id. at 9 (noting that Azadpur APMC data cover period May 1, 2006 through July 14, 2006); id. at 71, 74 (acknowledging that Azadpur APMC data “encompass a limited time span” and do not represent full year of data). To be sure, as the Remand Determination observes, “[t]here is no statutory or regulatory requirement that [Commerce] use an entire year” of data. See id. at 57-58. However, while the Remand Determination explains why Commerce selected non-contemporaneous data (beginning May 1, 2006), and explains that the value that Commerce derived from the 2006 data was deflated to be contemporaneous with the period of review at issue here, the Remand Determination is silent as to why Commerce chose to use only two-and-one-half months of data, rather than deflating and using data for an entire year. See id. at 58 (explaining that Azadpur APMC Bulletin began listing prices for “S.A.”-grade garlic as of May 1, 2006). The Remand Determination similarly fails to explain how Commerce has assured itself that data “obtained from so isolated a time frame as to be subject to temporary market fluctuations” in fact are not distorted by such “fluctuations.” See, e.g., Remand Determination at 44; id. at 48 (same). Indeed, the Market Research Report seems to indicate that garlic prices in India are subject to seasonal fluctuation: Being a seasonal crop, the price of garlic (at both the wholesale and retail level) is determined by demand-supply factors. Prices generally remain low during the peak supply period (February to May) when the new crop arrives and begin to rise thereafter peaking towards the end of the year (October-December). Market Research Report at 19; see also id. at 26 (noting that “garlic is a seasonal crop,” and that “domestic garlic prices tend to rise” from “Augush-December”); id. at 19-20, 22 (charting wholesale and retail price trends); Pis. Reply Comments at 8 (referring to “drastic fluctuations of the available ‘A’ and ‘S.A.’ garlic prices from 1000 Rupees to 2425 within the span of just a few months”). The Remand Determination acknowledges that the Azadpur APMC data cover a mere two-and-one-half months, but maintains that the data are nevertheless “broad-based” because the data reflect “a substantial quantity of garlic.” See Remand Determination at 57; see also id. at 71, 74 (stating that Azadpur APMC data reflect “an extremely high volume of sales”); Def. Response at 26 (same). The Remand Determination thus seeks to buttress Commerce’s claims that the Azadpur APMC data are temporally “representative” by asserting that a high volume of garlic sufficiently compensates for the lack of temporal “representativeness.” As the Chinese Producers demonstrate, however, the Remand Determination’s claims as to the representativeness and significance of the Azadpur APMC data cannot withstand scrutiny. See generally Pls. Comments at 9-10; Pls. Reply Comments at 5-6. The Remand Determination’s analysis of the representativeness of the Azadpur APMC data (and, to some extent, the related sections of the Government’s brief) are replete with both fundamental errors in logic and flagrant mistakes of fact. For example, as quoted above, the Remand Determination states that, although the Azadpur APMC data cover only two-and-one-half months, the data “contain a substantial quantity of garlic.” See Remand Determination at 57. As a matter of pure logic, however, the lack of temporal representativeness cannot be cured by the quantity of the commodity or the number of data points reflected in the limited time period. Assume, for example, that a party proffered to Commerce data from some source that reflected 5,000 sales of “S.A.”grade garlic, or data from some source that reflected 50 sales of “S.A.”-grade garlic of 100 pounds each, but all those sales were on a single day. In such a case, no matter how great the total quantity of the commodity sold or the total number of sales reflected in the data, those data logically could not reflect seasonal or other price fluctuations, and therefore could not “represent” a full year of data. The statement in the Remand Determination is thus illogical, because it equates volume or number of sales with temporal representativeness. This flaw in logic pervades and taints the Remand Determination’s entire analysis of representativeness. Commerce’s analysis of temporal representativeness is built on quicksand. The statement from the Remand Determination quoted above is illogical for a second, equally important reason. Even assuming (as the Remand Determination does) that the volume or number of sales compensates (in some fashion) for a lack of temporal representativeness (which it does not), the issue at hand is whether the Azadpur APMC data are sufficiently representative of prices for grades “A” and “S.A.” garlic. However, the statement quoted above asserts simply that the Azadpur APMC data “contain a substantial quantity of garlic,” without reference to grade. See Remand Determination at 57. Thus, as a matter of pure logic, the statement in the Remand Determination does nothing to support the Remand Determination’s claims concerning the representativeness of the Azadpur APMC data as to the specific grades of garlic at issue here. Other statements in the Remand Determination reflect egregious factual errors, and demonstrate that Commerce does not understand either the meaning of the Azadpur APMC data or their limitations. Careful review of the Azadpur APMC data reveals that those data tell Commerce absolutely nothing about the volumes of “A ”- and “S.A.”-grade garlic that were delivered to the Azadpur.APMC market during the two-and-one-half month period, because all Azadpur APMC data on volume are aggregate data for all grades of garlic as a whole. In other words, the Azadpur APMC data on volume are not broken down by grade of garlic. From the Azadpur APMC data on the existing record, it is therefore simply not possible to determine the quantity of grades “A” and “S.A.” garlic that were delivered to the Azadpur APMC market during the two-and-one-half month period. See Azadpur APMC data; Remand Determination at 53, 58 (noting Chinese Producers’ point that Azadpur APMC data specifies only total aggregate volume of garlic, and does not break that figure down by grades of garlic); Pls. Comments at 5, 9-10; Pls. Reply Comments at 6. Moreover, even as to all grades of garlic as a whole, the Azadpur APMC data tell Commerce nothing whatsoever about actual garlic sales (except to the extent that one assumes that all garlic delivered to the Azadpur APMC market eventually sells, at some price), because the Azadpur APMC data provide no specific information on sales, and instead document only arrivals (deliveries) of garlic at the market. See Azadpur APMC data; see also Remand Determination at 53, 58 (noting Chinese Producers’ point that Azadpur APMC data does not document sales, and instead documents only volume of garlic delivered to market); Pis. Comments at 5, 9 (same). But, in any event, even the assumption that all garlic delivered to the market is eventually sold (at some price) does not permit Commerce to derive any information whatsoever as to the volume of sales of “A”-and “S.A.”-grade garlic, because (as discussed immediately above) the Azadpur APMC data provide no information on the volume of “A”-and “S.A.”-grade garlic delivered to the market. See Azadpur APMC data; Pis. Comments at 5, 9-10; Pis. Reply Comments at 6. Further, even the assumption that all garlic delivered to the market is eventually sold (at some price) does not permit Commerce to derive from the Azadpur APMC data any information about the actual dates on which any or all sales were made, or the prices paid for those sales. Numerous statements in the Remand Determination indicate that Commerce fails to grasp even these most basic facts. For example, the Remand Determination states that the Azadpur APMC data “contain[ ] a list of all fruit and vegetable sales on any particular day at the [Azadpur] APMC [market].” See Remand Determination at 9 (emphasis added). As discussed above, however, the Azadpur APMC data in fact include no information whatsoever on any specific sales — much less “a list of all ... [individual] vegetable sales on any particular day,” as the Remand Determination states. See Azadpur APMC data. The statement in the Remand Determination is thus flatly incorrect — as is the Government’s claim that the Azadpur APMC data “included ‘numerous specific garlic sales.’ ” See Def. Response at 7-8 (citation omitted). The Remand Determination further states that the Azadpur APMC data “hote[ ] the weight of each sale, the region from which the produce originates, and the grade or size of the product.” See Remand Determination at 9 (emphases added). But, again, the Azadpur APMC data provide absolutely no sales-specific information, much less information on “each [individual] sale.” The Azadpur APMC data emphatically do not provide information on “the weight,” the “region” of origin, and the “grade or size” of “each sale.” See Azadpur APMC data; Pis. Comments at 9 (explaining that Azadpur APMC data “offer no sales-specific details regarding grades of garlic”). The statement in the Remand Determination is thus demonstrably untrue. Indeed, it is difficult to conceive that such statements could be made by anyone who gave the Azadpur APMC data even the most cursory review. In addition, the Remand Determination states that the Azadpur APMC data “provide[ ] a minimum, maximum, and a modal price for each commodity sold.” See Remand Determination at 9. As discussed above, however, the Azadpur APMC data provide no specific data at all concerning actual individual sales. See Azadpur APMC data. The Azadpur APMC data themselves do not establish (except by inference) that any garlic of any grade was actually sold at the Azadpur APMC market, much less the price that was actually paid for any particular sale. Certainly the data say nothing about any actual sales (much less actual prices paid) for garlic graded “A” and “S.A.” — the only grades of garlic that are at issue here. Elsewhere, the Remand Determination asserts that the Azadpur APMC data are “largely comprised of numerous specific garlic sales from several of the northern long-day growing regions, including Himachal Pradesh, Punjab, and Haryana” (i.e., several of the regions where — according to the Market Research Report — larger-bulbed garlic is grown). See Remand Determination at 12 (emphases added); Def. Response at 7-8; Market Research Report at 16 (stating that India’s “ ‘Long Day’ Zone” includes “Himachal Pradesh, Jammu and Kashmir, Punjab, Haryana, Uttaranchal, [and] Northern Parts of Uttar Pradesh”). Yet again, the Remand Determination refers to “sales,” even though, as discussed above, the Azadpur APMC data provide no sales-specific information whatsoever — much less information on any “specific [individual] garlic sales,” as the Remand Determination asserts. See Remand Determination at 12 (emphasis added); Pls. Comments at 9 (noting that Azadpur APMC data “offer no sales-specific details regarding ... the region in which the garlic was grown”); see also id. at 5. Further, even the data on the aggregate total volume of garlic delivered to the Azadpur market are not broken down by the state from which that garlic arrived. See Azadpur APMC data; Pis. Comments at 5 (explaining that the Azadpur APMC data do not indicate “the amount [of garlic] received [at the market] from each particular state”); Pis. Reply Comments at 6 (same). It thus goes without saying that there is also no basis whatsoever for the Remand Determination’s claim that the Azadpur APMC data are “largely comprised” of sales from the states of Himachal Pradesh, Punjab, and Haryana. See Remand Determination at 12 (emphasis added). Moreover, to the extent that the Remand Determination seeks to suggest that any sales from the specified states (ie., Himachal Pradesh, Punjab, and Haryana) would be, by definition, sales of largerbulbed garlic, that notion is dispelled by the Azadpur APMC data themselves. One of the relatively few things that can be said with certainty based on the Azadpur APMC data is that they clearly list prices for garlic from Himachal Pradesh, Punjab, and Haryana not only for higher, largerbulbed grades (i.e., grades “A” and “S.A.”), but also for garlic of lower grades as well. See Azadpur APMC data (garlic data for, inter alia, July 3, 2006, listing offer prices for grades “B” and “C,” as well as “A” and “S.A.,” from Himachal Pradesh (“HP”), Punjab (“PUN”), and Haryana(“HAR”), as well as other states). In addition, the Remand Determination states that the Azadpur APMC data “for super-A and A grades of garlic contains 198 points of data, representing over one thousand tons of garlic sold over a period of several months.” See Remand Determination at 13; see also Def. Response at 12 (same); Remand Determination at 71, 74 (asserting that Azadpur APMC data “include hundreds of data points”); Def. Response at 26 (same). This statement too is riddled with inaccuracies. As a threshold matter, the claimed “198 points of data” is virtually meaningless. Although the Remand Determination offers no explanation of the provenance of the “198” figure, close review of the Azadpur APMC data reveals that it is nothing more than the total number of offer prices for “A”-and “S.A.”-grade garlic listed (two, three, or four per day) for the two-and-one-half month period. In other words, the Azadpur APMC Bulletin page for May 1, 2006 lists prices for “A”-and “S.A.”grade garlic for “UP/HAR” (ie., Uttar Pradesh and Haryana), which Commerce counts as two “points of data”; and, in addition, the same page of the APMC Bulletin also lists prices for “A”-and “S.A.”grade garlic for “MP/RAJ/KOTA (NC)” (ie., Madhya Pradesh, Rajasthan, and (apparently) the city of Kota), which Commerce counts as another two “points of data,” for a total of four “points of data” for May 1, 2006. Commerce continued this same counting process, reviewing the Azadpur APMC data for each market day in the two-and-one-half month period, and came up with the total of “198 points of data.” As discussed above, however, these “points of data” correlate only to offer prices. As such, the number of “points of data”- — whether 198 or even 199,888 — says nothing whatsoever about how many (if any) sales of “A”-and “S.A.”grade garlic were actually made during the two-and-one-half month period, or the prices actually paid in any such sales. Any implication that the figure reflects 198 sales of “A”-and “S.A.”-grade garlic is absurd. The Remand Determination’s assertion that the “198 points of data” for “super-A and A grades of garlic” represent “over one thousand tons of garlic sold over a period of several months” is even more inaccurate. See Remand Determination at 13. First, the Remand Determination again suggests that the Azadpur APMC data include actual sales figures, which they do not. Moreover, the reference to “over one thousand tons” of “super-A and A grades of garlic” is a reference to the page of the Azadpur APMC data that is captioned “Prices of Garlic, S.A. Grade, May 1st-July 14th 2006,” which lists at the bottom of the column “Tons” the total “1,032.” See Remand Determination at 13; Azadpur APMC data. As the caption on the page itself indicates, the price data reflected there are limited solely to “S.A.”grade garlic — and to “S.A.”-grade garlic from the state of Himachal Pradesh, at that. See Azadpur APMC data (page eaptioned “Prices of Garlic, S.A. Grade, May lst-July 14th 2006,” listing “HP” (Himachal Pradesh) under column captioned “State”). Thus, contrary to Commerce’s representations in the Remand Determination, the page of Azadpur APMC data at issue includes no data whatsoever on grade “A” garlic; and, even as to grade “S.A.” garlic, the page does not include all “S.A.”-grade garlic, but, rather, only that “S.A.”-grade garlic which came from one particular state. Finally, and most importantly, the figure that the Remand Determination touts — “over one thousand tons” (or 1,032 tons, to be exact) — has no relationship to the grade “S.A.” garlic from Himachal Pradesh that is the subject of the page, or to any other specific grade of garlic. Instead, each of the figures in the “Tons” column represents the total tonnage of garlic of all grades that was delivered to the Azadpur APMC market on the 30 days listed on the page, which totals 1,032 tons. In sum, while the Remand Determination claims that the referenced Azadpur APMC data document the sales of “over one thousand tons” of “super-A and A grades of garlic” over a period of two-and-one-half months (see Remand Determination at 13), the facts are that: (a) the Azadpur APMC volume figures are for deliveries of garlic to the Azadpur APMC market, not for sales; (b) the specific Azadpur APMC data to which the Remand Determination refers do not cover grade “A” garlic, but, rather, are limited to grade “S.A.” — and, in fact, are confined to grade “S.A.” garlic from the state of Himachal Pradesh; and (c) the “over one thousand tons” figure that Commerce trumpets is actually for all grades of garlic (not grades “S.A.” and/or “A”) delivered to the Azadpur APMC market and, moreover, reflects only those deliveries made on those days when grade “S.A.” garlic from Himachal Pradesh was offered for sale. The Remand Determination thus evidences shockingly little comprehension of the Azadpur APMC data. b. Geographic Representativeness As discussed above, the existing administrative record cannot support the Remand Determination’s conclusion that the Azadpur APMC data are temporally representative of the Chinese Producers’ raw garlic bulb. As to geographic representativeness, the Remand Determination emphasizes that it is Commerce’s practice to use “country-wide data” rather than “regional data,” whenever possible. See Remand Determination at 12; see also Def. Response at 6 (stating that Commerce seeks data that are “representative of broad market average prices in India”). But, much like its claims as to the temporal representativeness of the Azadpur APMC data, so too the Remand Determination’s claims that the Azadpur APMC data are geographically representative lack adequate support in the existing record. See generally Remand Determination at 12-13, 54-55, 58 (discussing representativeness of Azadpur APMC data); see also Def.-Ints. Reply Comments at 2 (asserting that Azadpur APMC data reflect “a broad market average in India”). A number of the Remand Determination’s statements are simply not relevant to the issue of geographic representativeness. The Remand Determination states, for example, that the Azadpur APMC market has been designated a “Market of National Importance.” See Remand Determination at 13. Without more, however, that fact is meaningless. There is no indication that designation as a “Market of National Importance” is anything other than some sort of honorary recognition of the market’s historical significance. Certainly there is no indication that the designation is evidence of any fact that bears on the “representativeness” of the data on “A”-and “S.A.”-grade garlic at issue here. Similarly, the Remand Determination’s representation that, as of 2003, the Azadpur APMC market was “not only the largest APMC [market] in India, but ... also the largest in Asia” says nothing whatsoever that is specific to garlic, much less garlic of the particular grades at issue here. See Remand Determination at 13 (■citing Market Research Report at 21). The same is true of the Government’s assertion that the Azadpur APMC market is “the largest fruit and vegetable market in Asia.” See Def. Response at 12. The statement says nothing about garlic, not to mention garlic that is graded “A” or “S.A.” The Remand Determination’s finding that the Azadpur APMC market is “India’s ‘National Distribution Centre’ for several agricultural products, including garlic” at least refers to garlic in general; but, again, the statement is not specific to grades “A” and “S.A.,” and thus is entitled to little, if any, weight in evaluating the representativeness of the Azadpur APMC data. See Remand Determination at 13; see also id. at 71, 74 (asserting that Azadpur market is “major distribution center” of unspecified types of produce). The Remand Determination further asserts that the Azadpur APMC market “covers broad territory in India,” and that “agricultural products from all over India are sold” at the Azadpur market. See Remand Determination at 13. However, it is unclear what is meant by the claim that the market “covers broad territory,” and— in any event — the statement is in no way specific to garlic as a whole, not to mention “A”-or “S.A.”-grade garlic. Similarly, even assuming (without accepting) that the second quoted statement is true as phrased, “agricultural products” in general are not at issue in this action. Even if true, the statement says nothing about the sales of “A”-and “S.A.”-grade garlic at the Azadpur APMC market. Any implication that grade “A” and “S.A.” garlic “from all over India [is] sold at the APMC [market]” is contradicted by another statement in the Remand Determination, which indicates that “the total data set for super-A and A grades of gar-lie” used on remand “comes from a broad array of seven Indian states.” See Remand Determination at 13. But, despite the reference to “seven Indian states,” the sentence actually lists only five states— specifically, “Uttar Pradesh, Rajasthan, Madhya Pradesh, Haryana, and Himachal Pradesh.” See id. In any event, an independent review indicates that the Azadpur APMC data list six states as origins of grades “A” and/or “S.A.” garlic — including the five states listed immediately above, as well as Punjab, plus “KOTA” (which appears to refer to a city). Given that India comprises no fewer than 28 states (as well as a number of official “territories,” including the National Capital Territory of Delhi, where the Azadpur APMC market is located) and given that several major garlic-producing states are not reflected in the Azadpur APMC data, it is clear that “A”- and “S.A.”-grade garlic “from all over India” is not sold at the Azadpur APMC market. See Market Research Report at 7, 9; Azadpur APMC data. Further, the Remand Determination seems to assume that the origin listed in the Azadpur APMC data is the place where the produce (including garlic) was grown. As the Chinese Producers note, however, it does not appear that the location listed in the Azadpur APMC data is necessarily the place where the produce was grown. See Pis. Comments at 9; Azadpur APMC data (column captioned “Name of the Comm. & State”). Certainly there is no record evidence to affirmatively establish that the origin listed in the Azadpur APMC data is the place where the produce was actually grown. And, in fact, there is evidence that appears to indicate to the contrary. For example, the Remand Determination notes that the Market Research Report states that garlic imported from China is sold at the Azadpur APMC market. See Remand Determination at 55; Market Research Report at 21-22, 29. But nowhere do the Azadpur APMC data show China as the origin of any of the garlic listed there. See Azadpur APMC data (column captioned “Name of the Comm. & State”). More to the point, however, the proper focus of Commerce’s geographic “representativeness” criterion is not on matters