Full opinion text
OPINION RIDGWAY, Judge: Seven plaintiff Chinese producers and exporters of fresh garlic commenced this action to challenge 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 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 Review, 71 Fed.Reg. 26,329 (May 4, 2006) (“Final Results”); see also Issues and Decision Memorandum for the Administrative Review and New Shipper Reviews of the Antidumping Duty Order on Fresh Garlic from the People’s Republic of China (April 26, 2006) (Pub.Doc. No. 462) (“Issues and Decision Memorandum”); Zhengzhou Harmoni Spice Co. v. United States, 33 CIT 453, 617 F.Supp.2d 1281 (2009) (“Jinan Yipin I ”); Jinan Yipin Corp. v. United States, 35 CIT -, 800 F.Supp.2d 1226 (2011) (“Jinan Yipin II”). Jinan Yipin I analyzed the seven issues raised by the plaintiff Chinese producers/exporters, sustaining Commerce’s determination as to two of the issues and remanding the remaining five to the agency. See generally Jinan Yipin I, 33 CIT at 458, 514-15, 617 F.Supp.2d at 1289, 1334. Jinan Yipin II reviewed Commerce’s First Remand Determination, filed pursuant to Jinan Yipin I. See generally Final Results of Redetermination Pursuant to Court Remand (“First Remand Determination”). As to one of the five issues addressed therein, there were no objections. Jinan Yipin II sustained the First Remand Determination as to that issue, and, upon analysis, remanded the other four to Commerce for further consideration. See generally Jinan Yipin II, 35 CIT at-,-, 800 F.Supp.2d at 1235, 1315-16. Now pending before the court is Commerce’s Second Remand Determination, filed pursuant to Jinan Yipin II. See generally Final Remand Results of Redeter-mination Pursuant to Second Remand (“Second Remand Determination”). The Domestic Producers (i.e., the Fresh Garlic Producers Association and its four constituent members), Defendant-Intervenors in this action, challenge the Second Remand Determination as to one of the four issues addressed therein. See generally Defendant-Intervenors’ Comments Regarding Second Remand Redetermination (“Def.-Ints.’ Brief’); Defendant-Intervenors’ Reply Comments Regarding Second Remand Redetermination (“Def.-Ints.’ Reply Brief’). For their part, the Government and the three Plaintiff Chinese producers/exporters — i.e., Jinan Yipin Corporation, Ltd. (“Jinan Yipin”), Linshu Dading Private Agricultural Products Co., Ltd. (“Linshu Dading”), and Sunny Import and Export Co., Ltd. (“Sunny”) (collectively, the “Chinese Producers”) — urge that the Second Remand Determination be sustained in all respects. See Defendant’s Response to Comments Regarding Rede-termination Pursuant to Court Remand (“Def.’s Response Brief’) at 1-2,16; Plaintiffs’ Response to Defendant-Intervenors’ Comments Regarding Second Remand Re-determination (“Pis.’ Response Brief’) at 6. Jurisdiction lies under 28 U.S.C. § 1581(c) (2000). For the reasons detailed below, Commerce’s Second Remand Determination is sustained. 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 Jinan Yipin I, 33 CIT 453, 617 F.Supp.2d 1281; Final Results, 71 Fed.Reg. 26,329. Jinan Yipin I analyzed each of the seven issues that the plaintiff Chinese producers/exporters raised, sustaining Commerce’s determination as to two issues and remanding the other five for further consideration. See generally Jinan Yipin I, 33 CIT at 458, 514-15, 617 F.Supp.2d at 1289, 1334. Specifically, Jinan Yipin I sustained Commerce’s use of the agency’s intermediate input methodology to value raw garlic bulbs. See id., 33 CIT at 458, 458-66, 514, 617 F.Supp.2d at 1289, 1289-95, 1334. Jinan Yipin I similarly sustained Commerce’s surrogate financial ratios against the Chinese producers’ allegations of “double-counting” of certain labor-related expenses (ie., “provident fund” and “gratuity” expenses). See id., 33 CIT at 458, 506-14, 514, 617 F.Supp.2d at 1289, 1327-34, 1334. In contrast, Jinan Yipin I remanded for further consideration Commerce’s valuation of certain “factors of production” necessary for the cultivation and export of fresh garlic — in particular, (1) raw garlic bulbs, (2) labor, (3) ocean freight, (4) cardboard packing cartons, and (5) plastic jars and lids. See id., 33 CIT at 458, 466-73, 473-80, 481-87, 487-98, 498-506, 514-15, 617 F.Supp.2d at 1289, 1295-1301, 1301-07, 1307-12, 1312-21, 1321-1327, 1334. In its First Remand Determination, Commerce revalued raw garlic bulbs, labor, and ocean freight. See First Remand Determination at 5-15, 15-38, 38-41. On the other hand, Commerce continued to value cardboard packing cartons and plastic jars and lids 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 first remand, Commerce recalculated the weighted-average anti-dumping duty margin for Jinan Yipin as 55.18% (up from 29.52%), for Linshu Dad-ing 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. Commerce’s First Remand Determination was the subject of Jinan Yipin II. See generally Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1226. In the absence of any objections to the First Remand Determination’s treatment of the surrogate value for ocean freight, Commerce’s determination on that issue was sustained. See generally id., 35 CIT at-,-,-, 800 F.Supp.2d at 1235-36, 1276-79, 1315 (sustaining First Remand Determination as to ocean freight expenses). However, the agency’s treatment of the four remaining issues — ie., the surrogate values for raw garlic bulbs, labor expenses, cardboard packing cartons, and plastic jars and lids — remained in dispute. In light of the Chinese Producers’ arguments and the Government’s request for a voluntary remand, Jinan Yipin II once again remanded to Commerce the issue of labor expenses. See generally id., 35 CIT at-, -, -, 800 F.Supp.2d at 1236, 1274-76, 1315-16. Similarly, the issues of the valuation of raw garlic bulbs, cardboard packing cartons, and plastic jars and lids also were remanded to Commerce yet again. See generally id., 35 CIT at-, -, -, -, • — -, 800 F.Supp.2d at 1236, 1236-74, 1279-1307, 1307-15, 1315-16. In its Second Remand Determination, Commerce has revalued raw garlic bulbs, using data from the Indian Agricultural Marketing Information Network (“Ag-marknet”) for garlic grown in the five “long-day zone” states of India. See Second Remand Determination at 1,10,12-17, 31, 36. Commerce also has now recalculated the surrogate labor rate in accordance with the agency’s revised methodology. See id. at 1, 24-31, 38 (relying on Antidumping Methodologies in Proceedings Involving Non-Market Economies: Valuing the Factor of Production: Labor, 76 Fed.Reg. 36,092 (June 21, 2011); also reconsidering valuation of labor data reflected in surrogate financial ratios, and revising average surrogate financial ratios accordingly). In addition, to value cardboard packing cartons as well as plastic jars and lids for purposes of the Second Remand Determination, Commerce has implicitly adopted the fundamental reasoning of Jinan Yipin II and has therefore relied on the domestic Indian price quotes that the Chinese Producers had placed on the administrative record, in lieu of the Indian import statistics that the agency relied on in its prior determinations in this case. See Second Remand Determination at 1, 23-24, 38. As a result of these changes, the Second Remand Determination calculates the margins for both Jinan Yipin and Linshu Dading to be 0.00%, and 0.04% for Sunny. See id. at 1-2. Although they do not dispute Commerce’s revised surrogate values for labor, cardboard packing cartons, and plastic jars and lids, the Domestic Producers contest the Second Remand Determination as to the surrogate value for raw garlic bulbs. See generally Def.-Ints.’ Brief; Def.-Ints.’ Reply Brief. Specifically, the Domestic Producers contend that this matter must be remanded to Commerce yet again “to select a surrogate value that is specific to the fresh garlic exported to the United States by the [Chinese Producers].” Def.-Ints.’ Brief at 2; see also id. at 21-22; Def.-Ints.’ Reply Brief at 2, 10-11. In contrast, the Government' and the Chinese Producers urge that the Second Remand Determination be sustained in all respects. See Def.’s Response Brief at 1-2, 16; Pis.’ Response Brief at 6. 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 Alea-ciones 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 1819-20. 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 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 As Jinan Yipin II explained, 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 Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1233 (citing 19 U.S.C. §§ 1673, 1677(34), 1677b(a)); see generally Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1233-35. 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 (ie., 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 the subject merchandise is exported from an NME country and 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 “deter-minéis] 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(e)(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.” 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) (“Policy Bulletin 04.1”); see also .First Remand Determination at 42 (quoting Policy Bulletin and stating that it reflects agency’s “well-established practice for determining the reliability and appropriateness of surrogate values”). 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 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.” Id. 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 instructions in Jinan Yipin II, Commerce’s Second Remand Determination reconsidered and revised the surrogate value for raw garlic bulbs, as well as the surrogate values for labor, cardboard packing cartons, and-plastic jars and lids. As discussed in greater detail below, that determination is sustained in all respects. A. Surrogate Value for Raw Garlic Bulbs In the administrative review at issue, rather than valuing the Chinese Producers’ so-called “growing” and “harvesting” factors of production (ie., the garlic seed, water, pesticides, herbicides, fertilizer, plastic film, labor, and other “inputs” (commodities) consumed by Chinese producers in cultivating and harvesting whole raw garlic bulbs), 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 Jinan Yipin I, 33 CIT at 456-57, 460-61, 617 F.Supp.2d at 1288, 1291; see also Jinan Yipin II, 35 CIT at -, 800 F.Supp.2d at 1236. Jinan Yipin I rejected the Chinese Producers’ objections to Commerce’s use of its intermediate input methodology here. See Jinan Yipin I, 33 CIT at 458, 466, 514, 617 F.Supp.2d at 1289, 1295, 1334; see generally id., 33 CIT at 458-66, 617 F.Supp.2d at 1289-95 (reviewing the Chinese Producers’ objections to intermediate input methodology). On the other hand, Jinan Yipin I sustained the Chinese Producers’ challenge to the surrogate value for raw garlic bulbs 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 458, 469-71, 473, 514-15, 617 F.Supp.2d at 1289, 1298-99, 1301, 1334; see generally id., 33 CIT at 466-73, 617 F.Supp.2d at 1295-1301 (analyzing Chinese Producers’ challenge to surrogate valuation of raw garlic bulbs). As Jinan Yipin 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 Jinan Yipin I, 33 CIT at 467, 617 F.Supp.2d at 1296; see also Issues and Decision Memorandum at 42 (same). In the Final Results, Commerce calculated a surrogate value for raw garlic bulbs using data from the Indian Agricultural Marketing Information Network (“Agmarknet”) for a category of garlic referred to as “China” garlic. See Jinan Yipin I, 33 CIT at 467-68, 617 F.Supp.2d at 1296-97; Issues and Decision Memorandum at 39-44, 47; see also Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1236-37. As support for Commerce’s finding that the “China” category of 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 Jinan Yipin I, 33 CIT at 469, 617 F.Supp.2d at 1297-98; see also Issues and Decision Memorandum at 40-41; Domestic Producers’ Surrogate Value Submission (Pub.Doc. No. 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 relatively large bulb size; that the bulb size of local, native garlic typically grown and sold in the Indian market is significantly smaller; 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 Jinan Yipin I, 33 CIT at 468-69, 617 F.Supp.2d at 1297; Issues and Decision Memorandum at 41-44. Based on this and other information, the Final Results concluded that the Ag-marknet data for “China” category garlic must represent sales of large-bulb garlic from India’s long-day zone. See Jinan Yipin I, 33 CIT at 469, 617 F.Supp.2d at 1298; see also Issues and Decision Memorandum at 40-42. However, as Jinan Yipin I emphasized, the Agmarknet data provide no description of the physical characteristics of “China” garlic (or any other category of garlic reflected therein). See Jinan Yipin I, 33 CIT at 468-71, 617 F.Supp.2d at 1297-99; see also Issues and Decision Memorandum at 42 (noting that Agmarknet data do not include descriptions of categories of garlic reflected in the data). Noting that the Final Results apparently relied on the Ag-marknet data “based on nothing more than perhaps the name of the variety, and the fact that [the “China” category] had a higher weighted-average price,” Jinan Yi-pin I held that the Final Results were therefore “largely speculative and conclu-sory” and “lack[ed] adequate support in the evidentiary record.” See Jinan Yipin I, 33 CIT at 468-70, 617 F.Supp.2d at 1297-98. Jinan Yipin I concluded that, absent some proof of the physical characteristics of “China” garlic, the Final Results’ calculation of a surrogate value based on Agmarknet data for that category of garlic was not supported by substantial evidence and could not be sustained on the then-existing record. See id. The valuation of raw garlic bulbs was thus remanded to the agency for further consideration. See id., 33 CIT at 458, 473, 514-15, 617 F.Supp.2d at 1289, 1301, 1334. In addition to the Chinese Producers’ concerns about product specificity (discussed above), Jinan Yipin I addressed a number of other issues. See generally Jinan Yipin I, 33 CIT at 471-73, 617 F.Supp.2d at 1299-1301. Among other things, 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 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 472, 617 F.Supp.2d at 1300. The Chinese Producers thus contended that the Final Results “impermissi-bly 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. Jinan Yipin 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 Ci.e., garlic bulb).” See id. Jinan Yipin 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 472-73, 617 F.Supp.2d at 1300. Citing the concerns identified in Jinan Yipin I (particularly the lack of any physical description of “China” garlic and the various other categories of garlic reflected in the Agmarknet data), the First Remand Determination declined to rely on the Ag-marknet data. See First Remand Determination at 5, 7-8, 15. Instead, the First Remand Determination relied on an additional set of data, which Commerce placed on the record in the course of the first remand proceeding — ie., 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; see also Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1238. The First Remand Determination concluded that the Azadpur APMC data constituted “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 First Remand Determination at 14; Azadpur APMC data; see also Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1239. Accordingly, to establish the “product specificity” of the Azadpur APMC data, Commerce had to rely on the Domestic Producers’ Market Research Report. See First Remand Determination at 11; Market Research Report at 21. Jinan Yipin II closely critiqued — and roundly rejected — the First Remand Determination’s use of the Azadpur APMC data, concluding that “[s]erious issues exist as to the contemporaneity, representativeness, and product specificity of those data.” Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1273; see generally id., 35 CIT at-, 800 F.Supp.2d at 1236-74. Jinan Yipin II went so far as to note the existence of “record evidence suggesting] that [the First Remand Determination] may not have valued the intermediate input at all, and — instead—may have valued a final product.” Id., 35 CIT at-, 800 F.Supp.2d at 1273. The issue of the calculation of a surrogate value for raw garlic bulbs therefore was remanded to Commerce yet again. See id., 35 CIT at-, 800 F.Supp.2d at 1273-74. In the course of the most recent remand proceeding, Commerce reopened the administrative record to allow the parties to submit additional information concerning the valuation of raw garlic bulbs, as well as garlic seed. See Second Remand Determination at 4-5, 7-9. In the resulting Second Remand Determination, Commerce reaffirmed its conclusion that the agency’s intermediate input methodology “results in a more accurate dumping margin than the use of the traditional [factors of production] methodology.” Id. at 9-10; see also id. at 10-12. Commerce further determined, based on a comprehensive review of the strengths and weaknesses of all data on the record, that the Agmarknet data (on which the Final Results were based) constitute the best available information for use in calculating a surrogate value for raw garlic bulbs. See id. at 1, 9-10, 12-23, 31-37. However, rather than relying on data for a single category of garlic (i e., the “China” category) as Commerce did in the Final Results, the Second Remand Determination instead uses the average for the six specific Agmarknet categories of garlic grown in the five “long-day zone” states in India (i.e., Punjab, Haryana, Himachal Pradesh, Jammu and Kashmir, and Uttar-anchal) — the regions where longer periods of sunlight result in large-bulb garlic similar to the Chinese garlic at issue here. See id. at 1, 10, 12, 13, 15, 31-32. In addition, Commerce also made certain adjustments, which are not at issue here, to address the Chinese Producers’ concerns about “captur[ing] the farm gate prices.” See id. at 10, 17-19. Using these “filtered” Agmarknet data, Commerce calculated a final weighted-average price of 8.35 rupees per kilogram to value raw garlic bulbs for purposes of the Second Remand Determination. See id. at 36-37; compare id. at 12 (specifying 8.3471 rupees per kilogram). Neither the Chinese Producers nor the Domestic Producers contest the Second Remand Determination’s use of the Ag-marknet database in calculating a surrogate value for raw garlic bulbs. Similarly, neither party contests Commerce’s decision to “filter” the Agmarknet data set so as to use only data for garlic grown in India’s five long-day zone states. Indeed, like the Government, the Chinese Producers maintain that the surrogate value calculated in the Second Remand Determination based on that “filtered” data set should be sustained. See Def.’s Response Brief at 1-2, 7, 15, 16; Pis.’ Response Brief at 1, 6. However, the Domestic Producers contend that the data should be further filtered, such that Commerce should use data for only three of the six Agmarknet categories of garlic that are reflected in the Second Remand Determination’s calculations. See generally Def.-Ints.’ Brief at 2-3, 11-16, 21-22; Def.-Ints.’ Reply Brief at 2,10. Specifically, the Domestic Producers emphasize that the Chinese garlic at issue here has a bulb diameter of 50 millimeters (“mm”) or greater, and that not all of the garlic that is grown in India’s long-day zone states has a comparable bulb size. See Def.-Ints.’ Brief at 8-16; Def.-Ints.’ Reply Brief at 3, 4, 9-10. The Domestic Producers argue that the data set used in the Second Remand Determination thus is overly broad and not sufficiently “product-specific” to the Chinese Producers’ garlic, and that the data set should be further limited to exclude data on categories of garlic that — according to the Domestic Producers — do not have a bulb diameter comparable to the Chinese Producers’ garlic. See Def.-Ints.’ Brief at 11-16, 21-22; Def.-Ints.’ Reply Brief at 2,10. There is no dispute that the subject Chinese garlic bulbs have a diameter of 50 mm or greater. See, e.g., Second Remand Determination at 13; Def.’s Response Brief at 5. Similarly, there is no dispute that not all garlic grown in India’s long-day zone states has a bulb diameter of 50 mm or more. See, e.g., Second Remand Determination at 32; Pis.’ Response Brief at 2. Moreover, in principle, there is no question but that it would be optimal to exclude from Commerce’s calculations all data on garlic bulbs with a diameter of less than 50 mm, to render the surrogate value data perfectly “product-specific” to the subject Chinese garlic bulbs. See, e.g., Policy Bulletin 04.1 (expressing Commerce preference for data “specific to the input in question”); Jinan Yipin II, 35 CIT at -, 800 F.Supp.2d at 1304 (explaining that “ ‘product specificity1 logically must be the foremost consideration in determining ‘best available information,’ ” because — if data is not sufficiently product-specific — it is irrelevant whether data satisfies other criteria set forth in Policy Bulletin 04.1). However, perfect data is virtually non-existent in the real world. See general ly Second Remand Determination at 9 (“acknowledging] that all of the surrogate value sources placed on the record to value garlic bulb are imperfect”); id. at 20 (same); Def.-Ints.’ Brief at 11 (quoting and concurring in the Second Remand Determination’s observation); Def.’s Response Brief at 13,14. Here, after careful consideration, Commerce concluded in its Second Remand Determination that (notwithstanding the Domestic Producers’ claims) the evidence simply does not establish that further filtering the Agmarknet data set would in fact render the data more product-specific, and that — based on the existing record — any attempt to further filter the data would be fraught with the potential for distortion. See Second Remand Determination at 32, 36. Commerce therefore determined that “the subset of the Agmarknet data that reflects values for Indian domestic garlic grown in the [long-day zone states] is the best available information to value garlic bulb,” “results in the most [product-]specific surrogate value,” and “is far superior to the other data sources on the record” for use in calculating an appropriate surrogate value. See id. at 12,17, 20. As discussed below, under the circumstances of this case, that determination was a reasonable one. See generally Def.’s Response Brief at 5, 14; Pis.’ Response Brief at 1, 6. The Domestic Producers maintain that, of the six Agmarknet categories of garlic included in the data set used in the Second Remand Determination’s calculations, three of those categories — denominated “Desi,” “Average,” and “Other” — have bulb diameters that are not comparable to the Chinese Producers’ garlic and should be excluded from Commerce’s surrogate value calculation. See Def.-Ints.’ Brief at 12-16, 21-22; Def.-Ints.’ Reply Brief at 5-8, 10 (reiterating arguments concerning “Desi,” “Average,” and “Other” categories). In other words, the Domestic Producers contend that the Agmarknet data set for the five long-day zone states used in Commerce’s surrogate value calculation should be limited to include only data for the three categories of garlic that Agmark-net denominates as “China,” “New Medium,” and “Garlic.” See generally Def.-Ints.’ Brief at 11-21 (captioned “The Department Should Rely on Values for ‘China,’ ‘Garlic,’ and ‘New Medium’ Varieties to Calculate a Surrogate Value”). Commerce rejected the Domestic Producers’ argument, concluding that — contrary to their claims — “the record does not support filtering the data for the undefined Ag-marknet designations ‘Desi,’ ‘Average,’ and ‘Other.’ ” See Second Remand Determination at 32. In an effort to support their claim that the “Desi,” “Average,” and “Other” categories of garlic are characterized by small bulb size, the Domestic Producers argue that the Agmarknet data set used in the Second Remand Determination includes more data points for those three categories than for the other three categories (ie., “China,” “New Medium,” and “Garlic”) and that the prices for the “Desi,” “Average,” and “Other” categories are lower than the prices for the “China,” “New Medium,” and “Garlic” categories. See Def.-Ints.’ Brief at 14, 16; Def.-Ints.’ Reply Brief at 7-8. The Domestic Producers further argue that this is consistent with the Market Research Report, which indicates generally that garlic production in India is dominated by local varieties with smaller bulb sizes and a lower value. See Def.-Ints.’ Brief at 16; Def.-Ints.’ Reply Brief at 6-8. The Domestic Producers maintain that it therefore follows inexorably that the lower-priced categories of garlic reflected in the Agmarknet data, by definition, have a bulb size smaller than the Chinese Producers’ garlic at issue here. See, e.g., Def.- Ints.’ Brief at 16; Def.-Ints.’ Reply Brief at 7, 8. However, as noted in Jinan Yipin I and quoted in the Second Remand Determination, the implication that “higher price” necessarily “equals[] bigger-bulb” is overly simplistic, and is not alone sufficient to compel Commerce to reach the conclusion that the Domestic Producers urge. See generally Jinan Yipin I, 33 CIT at 468, 470-71, 617 F.Supp.2d at 1297, 1299; see also Second Remand Determination at 16, 35; Def.’s Response Brief at 10-11; Pis.’ Response Brief at 5-6. The Domestic Producers also cite certain evidence which they claim proves that the “Desi” category of garlic is limited to local varieties with a smaller bulb size and a lower value. The Domestic Producers note that the Issues and Decision Memorandum that accompanied the Final Results in this matter states that “[t]he term ‘Desi’ is a general term referring to the Indian subcontinent. Thus, ‘Desi’ garlic refers to a variety of garlic which, as the respondents have argued, may be more pungent than Chinese varieties, but is also mostly smaller in size.” See Def.-Ints.’ Brief at 14-15 (quoting Issues and Decision Memorandum at 44 (emphasis added by Domestic Producers)); see also Def.-Ints.’ Reply Brief at 5-6. But see Def.’s Response Brief at 9-10, 11. Similarly, in the course of the most recent remand, the Domestic Producers placed on the administrative record an entry from the Oxford Dictionary defining the term “desi” to mean “local” or “indigenous.” See Def.-Ints.’ Brief at 15 & n. 28; Def.-Ints.’ Reply Brief at 5, 8. But see Def.’s Response Brief at 9-10, 11; Second Remand Determination at 88. But the evidence that the Domestic Producers cite is not nearly as potent as they suggest. The meaning of “desi” in common parlance is not at issue. The open question is the precise definition of the term as it is used by Agmarknet to categorize garlic. As the Second Remand Determination explains, there is simply no evidence that speaks to how the Agmark-net database itself defines “Desi” as the term is used to denominate one of the six categories of garlic at issue. The record is devoid of any evidence documenting the physical characteristics of the garlic that Agmarknet categorizes as “Desi.” See Second Remand Determination at 16, 32, 33, 36. The Domestic Producers’ claim concerning the definition of “Desi” (disposed of above) is the linchpin for the Domestic Producers’ next argument, which seeks to exclude from Commerce’s surrogate value calculations the data concerning the “Average” and “Other” categories of garlic. Beginning from the premise that garlic categorized by Agmarknet as “Desi” garlic is “local” and “indigenous” and thus has smaller-sized bulbs (ie., the proposition addressed immediately above), the Domestic Producers argue that — “because the volume and value for Desi variety transactions are similar to those reported for the ‘Average’ and ‘Other’ varieties, and because ... smaller-sized garlic bulbs in India are sold at lower prices than larger-sized bulbs” — “the only reasonable conclusion” that Commerce could possibly have drawn is that “the transactions involving ‘Average’ and ‘Other’ varieties are comparable to the transactions involving the local, indigenous, small-sized Desi variety garlic bulbs.” See Def.-Ints.’ Brief at 15-16; Def.-Ints.’ Reply Brief at 7. But see Second Remand Determination at 34-36; Def.’s Response Brief at 9-10. The Domestic Producers significantly overstate their case. To the extent that this argument is predicated on, and analogizes from, the Domestic Producers’ assertions concerning the characteristics of garlic categorized by Agmarknet as “Desi,” this argument too must fail. Again, as the Second Remand Determination explains, there is no record evidence documenting the characteristics of any of the six Ag-marknet categories of garlic at issue, including not only the “Desi” category, but also “Average” and “Other,” as well as “China,” “New Medium,” and “Garlic.” See Second Remand Determination at 16, 32, 33, 34, 36. The gravamen of the Domestic Producers’ remaining arguments is that the Ag-marknet data for garlic categorized as “China” garlic should be included in Commerce’s calculation of a surrogate value for raw garlic bulbs. See generally Def.-Ints.’ Brief at 16-21. There is no need to discuss these arguments in any detail, because the data set used in the Second Remand Determination includes the “China” data (in addition to the five other specific categories of garlic included in the Agmarknet data base for India’s five long-day zone states). See Second Remand Determination at 31. Jinan Yipin II explicitly stated that nothing in Jinan Yipin I precluded Commerce from relying on the Agmarknet database, provided that Commerce adequately justified its selection of the specific data that it used. See Jinan Yipin II, 35 CIT at-n. 57, 800 F.Supp.2d at 1272 n. 57. Accordingly, in its Second Remand Determination, Commerce has explained that— rather than confining its data set to the “China” category (as it did in the Final Results) — the agency has calculated surrogate value using the Agmarknet data on all six specific categories of garlic reported for India’s five long-day zone states, including the “China” category. No party has objected to Commerce’s inclusion of the data for “China” category garlic in the agency’s calculations. The Domestic Producers therefore prevail on their claim that the “China” category data is properly included in the Second Remand Determination’s surrogate value calculations. In sum, Commerce’s calculation of a surrogate value for raw garlic bulbs using Agmarknet data for the six categories of garlic reported for India’s five long-day zone states must be sustained. To be sure, the Domestic Producers’ challenges to the specificity of those data are not wholly lacking in substance. Had Commerce made the extrapolations that the Domestic Producers advocate and drawn the inferences that the Domestic Producers urge — and thus excluded from the agency’s surrogate value calculations the Agmarknet data for garlic categorized as “Desi,” “Average,” and “Other” — it is possible that the agency’s determination might have been sustained. But an agency determination cannot be overturned merely because the agency could have reached the opposite result based on the same record. See generally Def.’s Response Brief at 13 (noting that “a reasonable mind could decline to draw the inferences [that the Domestic Producers] urged Commerce to draw in this case”). The evidence that the Domestic Producers cite is neither so clear nor so strong as to require Commerce to reach a result other than that which the agency reached here. As discussed above, “[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. As the “master of antidumping law,” Commerce is entitled to “wide discretion in the valuation of factors of production,” in recognition of the agency’s “special expertise.” See id. (internal quotation marks and citation omitted); Thai Pineapple, 187 F.3d at 1365. Moreover, as the Government underscores, it is the parties to a proceeding that bear the burden of building an adequate record. See Def.’s Response Brief at 13-14 (citing QVD Food Co. v. United States, 658 F.3d 1318, 1324 (Fed.Cir. 2011)). In the instant case, the parties had multiple opportunities to augment the record with relevant information, even as late as the most recent remand proceeding before the agency. The Domestic Producers have proffered no evidence to directly and definitively establish the specific characteristics of the “Desi,” “Average,” and “Other” categories of garlic as those terms are used in the Agmarknet database. Particularly in the absence of such evidence, and in light of all other circumstances, Commerce’s concerns that — on this record — any further “filtering” of the data set could potentially distort the agency’s surrogate value calculation cannot be said to be unreasonable. See Second Remand Determination at 32, 36. Nor is the Second Remand Determination’s calculation of a surrogate value for raw garlic bulbs unsupported by substantial evidence. The Domestic Producers’ arguments to the contrary therefore must fail. B. Surrogate Value for Labor The antidumping statute provides that, in non-market economy cases such as this, the surrogate data used to calculate the value of factors of production must, to the extent possible, come from market economy countries that are at “a level of economic development comparable to that of the nonmarket economy country” at issue — in this case, China. See 19 U.S.C. § 1677b(c)(4)(A). The antidumping statute further provides that, in such cases, the surrogate data must, to the extent possible, come from market economy countries that are “significant producers of comparable merchandise.” See 19 U.S.C. § 1677b(c)(4)(B). For most factors of production, Commerce typically uses values from a single market economy country (known as the “surrogate country” — here, India) that Commerce has determined to be both (a) economically comparable to the non-market economy country in question and (b) a significant producer of the goods at issue. See 19 C.F.R. § 351.408(c)(2). However, as Jinan Yipin I and Jinan Yipin II explained, Commerce in the past treated the cost of labor quite differently than other factors of production. See Jinan Yipin I, 33 CIT at 474, 617 F.Supp.2d at 1301-02; Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1274; see generally Dorbest Ltd. v. United States, 604 F.3d 1363, 1368 (Fed.Cir.2010). Concerned about “wide variances in wage rates between comparable economies,” Commerce historically valued the cost of labor in a non-market economy (“NME”) country case by using a regression-based wage rate “reflective of the observed relationship between wages and national income in a variety of market economy countries.” See Jinan Yipin I, 33 CIT at 474-75, 617 F.Supp.2d at 1302 (internal quotation marks and citations omitted). Thus, in the past, “unlike its valuation of other factors of production in an NME case, Commerce [has based] its surrogate wage rate on data from a broad ‘basket’ of countries, and [has] not limited] itself to market economy countries at a level of economic development comparable to the NME country in question.” See id., 33 CIT at 475, 617 F.Supp.2d at 1302. In the Final Results in this case, Commerce calculated the Chinese Producers’ labor costs using the agency’s standard regression-based wage rate calculation methodology, as set forth in the agency’s regulations. See Jinan Yipin I, 33 CIT at 475-76, 617 F.Supp.2d at 1302-03; 19 C.F.R. § 351.408(c)(3). Using that methodology, the agency calculated a surrogate wage rate of $0.97/hour in the Final Results. See Jinan Yipin I, 33 CIT at 476, 617 F.Supp.2d at 1303. Relying heavily on Allied Pacific (which held Commerce’s regulation to be inconsistent with the statute), Jinan Yipin I remanded the issue of the surrogate value for labor to Commerce for further consideration. See Jinan Yipin I, 33 CIT at 458, 473-80, 514-15, 617 F.Supp.2d at 1289, 1301-07, 1334; Allied Pacific Food (Dalian) Co. v. United States, 32 CIT 1328, 1351-65, 587 F.Supp.2d 1330, 1351-61 (2008). On remand, Commerce nevertheless continued to use a regression based methodology, albeit one that was slightly revised. See generally First Remand Determination at 15-38, 59-68. The resulting calculation produced a surrogate wage rate of $0.80/hour for China. See id. at 68; Jinan Yipin II, 35 CIT at -, 800 F.Supp.2d at 1275. In the meantime, however, the Court of Appeals handed down its decision in Dor-best, striking down Commerce’s regulation as inconsistent with the plain language of the statute. See generally Dorbest, 604 F.3d at 1366, 1369-73. The Court of Appeals concluded that the agency’s regulation “improperly require[d] using data from both economically comparable and economically dissimilar countries, and ... improperly use[d] data from both countries that produce comparable merchandise and countries that do not.” See id., 604 F.3d at 1372 (discussing 19 C.F.R. § 351.408(c)(3)). The Government therefore sought a voluntary remand in this action to allow Commerce to recalculate the surrogate value for labor expenses in a manner consistent with Dorbest, which Jinan Yipin II granted. See generally Jinan Yipin II, 35 CIT at -, 800 F.Supp.2d at 1274-76. In the course of the most recent remand, Commerce reconsidered its approach to the calculation of surrogate values for labor expenses, in light of the Court of Appeals’ decision in Dorbest, as well as the decision in Shandong Rongxin. See generally Second Remand Determination at 24-31; Dorbest, 604 F.3d at 1369-73; Shandong Rongxin Import & Export Co. v. United States, 35 CIT-, -, 774 F.Supp.2d 1307, 1315-16 (2011); Def.’s Response Brief at 15 (advising that “[c]on-sistent with Dorbest ..., Commerce no longer is relying upon its regression-based methodology for wage rates”). Concluding that “relying on multiple countries to calculate the wage rate is no longer the best approach,” Commerce altered its methodology, to rely on industry-specific labor cost data from the primary surrogate country — in this case, India. See Second Remand Determination at 26; Antidump-ing Methodologies in Proceedings Involving Non-Market Economies: Valuing the Factor of Production: Labor, 76 Fed.Reg. 36,092 (June 21, 2011); see also Def.’s Response Brief at 15 (explaining that, in Second Remand Determination, “pursuant to [its new methodology], Commerce valued labor by using industry-specific data from India”). As the Second Remand Determination observes, such an approach “is fully consistent with how [Commerce] values all other [factors of production], and results in the use of a uniform basis for [factor of production] valuation — a single surrogate country.” Second Remand Determination at 26. For purposes of the Second Remand Determination here, Commerce relied on 2004 data (as reported in a 2005 publication of the International Labour Organization (“ILO”)), because those data were “the most contemporaneous data that were available” between November 1, 2003 and May 4, 2006 — i.e., “during the conduct of the underlying administrative review.” See Second Remand Determination at 26-27 (explaining, inter alia, that, on remand, agency used labor cost data for India “reported in the ILO Chapter 6A data”). Specifically, Commerce selected “the industry-specific Indian data provided under Sub-Classification 15 ‘Manufacture of food products and beverages’ of the International Standard Industrial Classification— Revision 3-D standard.” See Second Remand Determination at 27. Based on those data, the Second Remand Determination calculated a revised labor rate of 24.50 rupees per hour. Id. As noted above, neither the Chinese Producers nor the Domestic Producers have objected to Commerce’s revised wage rate calculation as set forth in the Second Remand Determination. See Def.’s Response Brief at 15 (noting that “[n]o party objects to the Second Remand Results with respect to Commerce’s valuation of labor expenses,” and urging that “the Court should sustain Commerce’s Second Remand Results” on the issue); id. at 2 (same); see also Def.-Ints.’ Brief (offering no comments on any issue other than valuation of raw garlic bulbs); Def.-Ints.’ Reply Brief (same); Pis.’ Response Brief (same). Commerce’s determination on this issue is accordingly sustained. C. Surrogate Value for Cardboard Packing Cartons In the Final Results in this case, Commerce valued the cardboard cartons that are used to pack and ship garlic based on Indian import statistics taken from the World Trade Atlas for the Indian tariff subheading 4819. 1010, which covers, among other things, cartons, boxes, and cases made of corrugated paper and paperboard (which were formerly covered by subheading 4819.1001). See Jinan Yipin I, 33 CIT at 488, 617 F.Supp.2d at 1312-13; Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1307. In so doing, the Final Results rejected the other alternative source of data on the record — specifically, four domestic Indian price quotes submitted by the Chinese Producers, which predate the period of review by several months and were obtained from four different Indian box vendors in four different cities, for basic cardboard packing cartons virtually identical to those that the Chinese Producers actually used. See Jinan Yipin I, 33 CIT at 488, 498, 617 F.Supp.2d at 1312, 1321; Jinan Yipin II, 35 CIT at -,-,-& n. 102, 800 F.Supp.2d at 1307, 1308, 1310-11 & n. 102. The Final Results rejected the domestic price quotes because they are not considered “publicly available information.” See Jinan Yipin I, 33 CIT at 489, 617 F.Supp.2d at 1313; Jinan Yipin II, 35 CIT at-, -, 800 F.Supp.2d at 1307-08, 1309; Policy Bulletin 04.1. As Jinan Yipin I observed, however, the Final Results significantly “overstated any potential concerns as to the reliability of the domestic Indian box prices that the agency rejected, ... [and] significantly understated the patent flaws and defects in the Indian import statistics on which the agency relied.” Jinan Yipin I, 33 CIT at 498, 617 F.Supp.2d at 1321 (emphases omitted). Detailing the numerous problems with Commerce’s calculus, Jinan Yi-pin I remanded the issue to the agency for further consideration. See generally id., 33 CIT at 487-98, 617 F.Supp.2d at 1312-21; see also Jinan Yipin II, 35 CIT at -, 800 F.Supp.2d at 1307-09. Commerce’s First Remand Determination was “wholly unresponsive” to Jinan Yipin I on the issue of the use of Indian import statistics versus domestic price quotes for purposes of calculating the surrogate value for cardboard packing cartons. See Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1309; see generally id., 35 CIT at-, 800 F.Supp.2d at 1307-15. As Jinan Yipin II summed up the situation, the First Remand Determination “add[ed] little or nothing to the record on the issue of Commerce’s concerns about the ‘public availability’ of the domestic price quotes and the potential for ‘manipulation’ — the sole basis cited in the Final Results for Commerce’s decision to reject the price quotes in favor of the Indian import statistics,” and instead added “ ‘contemporaneity’ and ‘representativeness’ to Commerce’s list of grounds for rejecting the price quotes.” See id., 35 CIT at-, 800 F.Supp.2d at 1309. Commerce yet again sought to exaggerate the alleged shortcomings of the domestic price quotes, while simultaneously ignoring the obvious (and admitted) problems inherent in the Indian import statistics on which the agency continued to rely. See generally id., 35 CIT at -, 800 F.Supp.2d at 1309-15. Noting that Commerce had seemingly chosen “admittedly distorted Indian import statistics over potentially ‘perfect’ price quotes,” Jinan Yipin II held that the First Remand Determination failed to adequately explain and justify by reference to substantial record evidence the agency’s determination that the Indian import statistics constituted the “best available information” for use in calculating the surrogate value of basic cardboard packing cartons, in light of the acknowledged infirmities in the import statistics. Jinan Yi-pin II, 35 CIT at-, 800 F.Supp.2d at 1315; see generally id., 35 CIT at-, 800 F.Supp.2d at 1309-15. In particular, Jinan Yipin II stated that “[Commerce’s] conclusions that the Indian import statistics [ — as compared to the domestic price quotes — ] are ‘sufficiently specific’ and constitute the ‘best available information’ for use in valuing cardboard cartons” were “unexplained,” “not rational,” and “lack[ed] any sound basis in the administrative record,” and therefore could not be sustained. See id., 35 CIT at-, 800 F.Supp.2d at 1315. The issue was therefore remanded once again, and the agency was cautioned not to simply recycle its earlier arguments, because “no further remands [were] likely.” See id., 35 CIT at -, 800 F.Supp.2d at 1315. Commerce’s Second Remand Determination followed. In the Second Remand Determination, as a surrogate value for cardboard packing cartons, Commerce relied on the four domestic price quotes on the record, implicitly adopting the fundamental reasoning of Jinan Yipin II (and, in turn, Jinan Yipin I). The Second Remand Determination states: The Court found [in Jinan Yipin II] that Commerce had chosen “admittedly distorted Indian import statistics over potentially ‘perfect’ price quotes.” While [Commerce] disagrees with this conclusion, [Commerce] is cognizant of the Court’s admonition that the [agency] is not likely to “get another bite of the apple on this issue.”.... Accordingly, ... [Commerce] has determined, under protest, to use the price quote surrogate values provided on the record by the plaintiffs during the underlying proceeding for this final remand redetermination. Using these price quotes, the surrogate value for cardboard cartons is 32.3750 Rupees per box.... Second Remand Determination at 23-24 (footnotes omitted); see also id. at 1 (stating that Commerce “has applied, under protest, the price quotes on the record of the underlying review as surrogates to value ... cardboard cartons”); cf. Defendant’s Response to Comments Regarding Redetermination Pursuant to Court Remand at 9-11 (April 20, 2012), filed in Taian Ziyang Food Co. v. United States, Court No. 05-00399 (in companion case contesting Commerce’s determinations in administrative review immediately preceding review at issue in this action, which included parallel challenge to agency’s reliance on import statistics versus price quotes in surrogate valuation of cardboard packing cartons, agency ultimately decided to rely on price quotes (as the agency has done here), explaining that “the Remand Results are consistent with the Court’s holding” in Taian Ziyang II, and that “[i]n light of the Court’s concerns about the import statistics, ... Commerce reasonably adopted plaintiffs’ approach and used the domestic price quotes”). As summarized below, and as set forth at length and in exhaustive detail in Jinan Yipin I and Jinan Yipin II, the record evidence — viewed through the lens of Commerce’s criteria in Policy Bulletin 04.1 — weighs solidly in favor of the price quotes. See Jinan Yipin I, 33 CIT at 487-98, 617 F.Supp.2d at 1312-21 (analyzing merits of domestic price quotes versus Indian import statistics for valuation of cardboard packing cartons); Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1307-15 (same); section III, supra (in the introductory text, discussing criteria established in Policy Bulletin 04.1, including “product specificity,” “contemporaneity,” “representativeness,” and “public availability,” in addition to whether prices are “net of taxes and import duties”). As Jinan Yipin II explained, of the five criteria set forth in Policy Bulletin 04.1, “product specificity” logically must be the most important. See Jinan Yipin II, 35 CIT at -, 800 F.Supp.2d at 1304. And it is undisputed that, as discussed in Jinan Yipin I and Jinan Yipin II, the four domestic price quotes on the record of this proceeding are highly “specific to the input in question” — that is, the cardboard packing cartons actually used by the Chinese Producers. See Jinan Yipin I, 33 CIT at 488, 498, 617 F.Supp.2d at 1312, 1321; Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1307-08. Moreover, although the four domestic price quotes are not “contemporaneous” within the meaning of Policy Bulletin 04.1, the price quotes are just a few months outside the period of review. See Jinan Yipin II, 35 CIT at- & n. 102, 800 F.Supp.2d at 1310-11 & n. 102. And, as Jinan Yipin II explained (and as the First Remand Determination itself conceded), contemporaneity is not necessarily a critical factor. See id., 35 CIT at-, 800 F.Supp.2d at 1311 (and authorities cited there). Thus, for example, as discussed immediately below, absent concrete evidence (or even some credible basis to suggest) that prices for basic cardboard packing cartons fluctuate to any significant degree over relatively brief periods of time, the contemporaneity (like the “representativeness”) of the price quotes is of little moment. Like “contemporaneity,” Commerce’s “representativeness” criterion relates to the timing of price information. In contrast to the contemporaneity criterion (which concerns whether the price information is from within the review period at issue), the focus of the representativeness criterion is on whether the price information reflects “review period-wide price averages,” rather than prices for a more limited period of time. See Jinan Yipin II, 35 CIT at-, 800 F.Supp.2d at 1311-12; id., 35 CIT at-, 800 F.Supp.2d at 1292-94 (explaining “representativeness,” in context of surrogate valuation of plastic jars and lids). Commerce’s concern about price quotes for a more limited period of time — like the four price quotes at issue here, all of which are dated either on one day or the very next — is the possibility that the pricing information may not accurately reflect prices throughout the period of review, due to “temporary market fluctuations.” Id., 35 CIT at-& n. 102, 800 F.Supp.2d at 1311-12 & n. 102 (noting that representativeness reflects concern about potential “temporary market fluctuations,” and specifying dates of price quotes for cardboard packing cartons). However, as Jinan Yipin II noted, the administrative record in this proceeding is barren of any evidence whatsoever that might suggest that prices for cardboard packing cartons are subject to any significant volatility. See id., 35 CIT at-, 800 F.Supp.2d at 1311-12. The record is equally definitive on “public availability.” As Jinan Yipin I observed, there is room for debate as to the precise meaning of “public availability.” See generally Jinan Yipin I, 33 CIT at 489-91, 617 F.Supp.2d at 1313-15. But there is no question that