Tri Union Frozen Products, Inc. v. United States (163 F. Supp. 3d 1255, 2016)

OPINION AND ORDER

Kelly, Judge:

This consolidated action comes before the court on USCIT Rule 56.2 motions for judgment on the agency record, challenging the U.S. Department of Commerce’s (“Department” or “Commerce”) final determination in the eighth administrative review of the antidumping duty order covering certain frozen warmwater shrimp from the Socialist Republic of Vietnam (“Vietnam”) for the period of February 1, 2012 through January 31, 2013. See Certain Frozen Warmwater Shrimp From the Socialist Republic of Vietnam, 79 Fed. Reg. 57,047 (Dep’t Commerce Sept. 24, 2014) (final results of antidumping duty administrative review, 2012-2013) (“Final Results”), as amended, 79 Fed.Reg. 65,377 (Dep’t Commerce Nov. 4, 2014) (amended final results of antidumping duty administrative review, 2012-2013) (“Amended Final Results”), and accompanying Issues and Decision Memorandum for the Final Results of Certain Frozen Warmwater Shrimp from the Socialist Republic of Vietnam, A-552-802, (Sept. 19, 2014), available at http://enforcement.trade.gov/frn/ summary/vietnam/2014-22732-l.pdf (last visited Mar. 28, 2016) (“Final I & D Memo”); see also Certain Frozen Warm-water Shrimp From the Socialist Republic of Vietnam, 70 Fed.Reg. 5,152 (Dep’t Commerce Feb. 1, 2005) (notice of amended final determination of sales at less than fair value and antidumping duty order) (“ADD Order”).

Plaintiffs Tri Union Frozen Products, Inc., d/b/a Chicken of the Sea Frozen Foods, a/k/a Empress International Ltd.; Mazzetta Company LLC; and Ore-Cal Corporation (collectively “Tri Union”), importers of subject merchandise, commenced this action pursuant to section 516A of the Tariff Act of 1930, as amended, 19 U.S.C. § 1516a (2012). The court consolidated Tri Union’s action with actions filed by Consolidated Plaintiffs Vietnamese Association of Seafood Exporters and Producers and certain of its individual member companies, Vietnamese producers and exporters of subject merchandise (collectively “VASEP”); Quoc Viet Seapro-ducts Processing Trading and Import-Export Co., Ltd. (“Quoc Viet”), a Vietnamese producer and exporter of subject merchandise; and Ad Hoc Shrimp Trade Action Committee (“Ad Hoc Shrimp”), an association of domestic producers of warmwater shrimp. See Order, Dec. 15, 2014, ECF No. 29. In addition to the Rule 56.2 motions for judgment on the agency record filed by the above named parties, Ad Hoc Shrimp filed a response as a defendant-intervenor in opposition to the motions filed by Quoc Viet and VASEP. For the reasons set forth below, Defendant’s request for voluntary remand for Commerce is granted and Commerce’s Final Results and Amended Final Results are sustained in all other respects.

BACKGROUND

Commerce issued the antidumping duty order covering certain frozen warmwater shrimp from Vietnam on February 1, 2005. See generally ADD Order, 70 Fed.Reg. 5,152. On March 29, 2013, pursuant to requests from several companies, including Ad Hoc Shrimp and Quoc Viet, Commerce initiated the eighth administrative review of the ADD Order for the period of February 1, 2012 through January 31, 2013. See Initiation of Antidumping- and Countervailing Duty Administrative Reviews and Request for Revocation in Part, 78 Fed. Reg. 19,197, 19,198-204 (Dep’t Commerce Mar. 29, 2013); see also Ad Hoc Shrimp Request for Administrative Reviews at 1-2, PD 2 at bar code 3120960-01 (Feb. 26, 2013); Quoc Viet Request for Administrative Review and Request for Voluntary Treatment at 1, PD 1 at bar code 3117246-01 (Feb. 1, 2013) (“Quoc Viet Request”).

Due to the large number of companies, Commerce found,' pursuant to 19 U.S.C. § 1677f — 1(c)(2), that it was not practicable to examine all foreign producers and exporters of subject merchandise and instead selected two companies that, according to U.S. Customs and Border Protection import data, accounted for the largest U.S. import entry volume of subject merchandise during the period of review to serve as mandatory respondents — (1) Minh Phu Group (“MPG”); and (2) Soc Trang Seafood Joint Stock Company (“Stapimex”). See Selection of Respondents for Individual Examination Memo at 1-2, 6-8, PD 40 at bar code 3137221-01 (May 24, 2013) (“Respondent Selection Mem.”); see also 19 U.S.C. § 1677f-l(c)(2)(B); Decision Memorandum for Preliminary Results of Antidumping Duty Administrative Review: Certain Frozen Warmwater Shrimp from the Socialist Republic of Vietnam at 1-3, A-552-802, (Mar. 18, 2014), available at http://enforcement.trade.gov/frn/summary/ vietnanV2014-06397-l.pdf (last visited Mar. 28, 2016) (“Prelim. I & D Memo”). Quoc Viet, as part of its request for Commerce to initiate the administrative review, requested to be examined as a voluntary respondent if Commerce decided to limit the review to individually examine particular exporters pursuant to 19 U.S.C. § 1677f-l(c). See Quoc Viet Request at 2. Based on the circumstances of the review, Commerce denied Quoc Viet’s request finding that it would be unduly burdensome and inhibit the timely completion of the review to individually examine any additional respondents. See Selection of Voluntary Respondent Memo at 1-4, PD 122 at bar code 3146779-01 (July 24, 2013) (“Voluntary Respondent Mem.”).

■ As Commerce does when dealing with a nonmarket economy (“NME”), Commerce informed interested parties of potential surrogate countries from which it would consider data to value the factors of production (“FOP”) used to produce the subject imports. See Surrogate Country List at 3, PD 105 at barcode 3143158-01 (July 2, 2013). Interested parties submitted comments regarding primary surrogate country selection on August 30, 2013. See generally Comments on Surrogate Country Selection, PD 133-37 at bar codes 3152484-01-05 (Aug. 30, 2013); ASPA’s Surrogate Country Selection Comments, PD 138 at bar code 3152512-01 (Aug. 30, 2013); Surrogate Country Comments, PD 140 at bar code 3152598-01 (Aug. 30, 2013). On October 28, 2013, interested parties also submitted comments on surrogate values for Commerce to use to value mandatory respondents’ FOPs. See generally Surrogate Value Comments, PD 157-161 at bar codes 3160401-01-05 (Oct. 28, 2013); ASPA’s Comments re Surrogate Values, PD 155 at bar code 3160197-01 (Oct. 28, 2013).

Commerce published its preliminary results on March 24, 2014. See Certain Frozen Warmwater Shrimp From the Socialist Republic of Vietnam, 79 Fed.Reg. 15,941, 15,941 (Dep’t Commerce Mar. 24, 2014) (preliminary results of antidumping duty administrative review; 2012-2013) (“Prelim. Results”). After considering comments from interested parties on surrogate country and values, Commerce selected Bangladesh as the primary surrogate country for purposes of valuing MPG’s and Stapimex’s FOPs for the preliminary results. See Prelim. I & D Memo at 11-15; see also' Prelim. Results, 79 Fed.Reg. at 15,941. Commerce likewise chose to use Bangladeshi data to value the primary FOP, raw shrimp. See . Prelim. I & D Memo at 14-15.

Additionally, Commerce, pursuant to its practice in administrative reviews, applied its recently implemented differential pricing analysis to determine whether “com-parting] ... the weighted average of the normal values to the export prices ... of individual transactions for comparable merchandise” (“A-T”), see 19 C.F.R. § 351.414(b)(3) (2013), was appropriate to calculate dumping margins for both MPG and Stapimex in the preliminary results. See Prelim. I & D Memo at 18-19. According to the results of its differential pricing analysis, Commerce found that MPG’s and Stapimex’s U.S. sales showed a pattern of significant export price differences among purchasers, regions, or time periods that could not be accounted for by “a comparison of the weighted average of the normal values with the weighted average of the export prices” (“A-A”). See 19 C.F.R. § 351.414(b)(1); Prelim. I & D Memo at 18-19. Thus, Commerce preliminarily determined- that application of A-T was appropriate to calculate dumping margins for both MPG and Stapimex in the preliminary results. See Prelim. I & D Memo at 18-19. 'Using Bangladesh as the primary surrogate country and applying A-T, Commerce preliminarily determined that the mandatory respondents were selling the subject merchandise at less than fair value during the period of review and calculated weighted-average dumping margins of 9.75% for Stapimex, applying A-T to all of its U.S. sales, and 4.98% for MPG, applying a combination of A-T and A-A, from which Commerce assigned a rate of 6.37% to separate rate respondents. See Prelim. Results, 79 Fed.Reg. at 15,941-43; see also Prelim. I & D Memo at 9-10. Commerce assigned a Vietnam-wide rate of 25.76% to respondents who were not entitled to a separate rate. See Prelim. Results, 79 Fed.Reg. at 15,943; see also Prelim. I & D Memo at 11.

Interested parties submitted case briefs following the preliminary results commenting on Commerce’s determinations. See generally Quoc Viet and Tri Union Case Brief, PD 233 at bar code 3204780-01 (May 28, 2014) (“Quoc Viet Case Br.”); Case Brief on Behalf of the Ad Hoc Shrimp Trade Action Committee, PD 234 at bar code 3204785-01 (May 28, 2014); Minh Phu Group’s Case Brief, PD 236 at bar code 3204803-01 (May 28, 2014); Resubmission of Minh Phu Group’s Case Brief, PD 250 at bar code 3218837-01 (July 31, 2014).

On September 24, 2014, Commerce published its final results, making no changes to surrogate values or dumping margin calculations from the preliminary results. See Final Results, 79 Fed.Reg. at 57,048. Commerce continued to decline to individually examine Quoc Viet as a voluntary respondent and reiterated its position that reviewing Quoc Viet would be unduly burdensome and inhibit timely completion of the review. See Final I & D Memo at 55-59. Commerce additionally reaffirmed its decision to reject Quoc Viet’s self-calculated dumping margin submissions and MPG’s case brief for containing untimely filed new factual information. See id. at 59-61. Commerce later amended its final results to correct two ministerial errors pursuant to a request from VASEP. See generally Amended Final Results, 79 Fed. Reg. 65,377. Thereafter, this consolidated action ensued challenging Commerce’s determinations in the Final Results.

Tri Union and Quoc Viet challenge Commerce’s decision to select Bangladesh as the primary surrogate country. See Mem. Supp. Mot. Tri Union Frozen Products, Inc. J. Agency R. 7-12, Mar. 30, 2015, ECF No. 48 (“Tri Union Br.”); Mem. Supp. Mot. Quoc Viet Seaproducts Processing Trading and ImporlAExport Co., Ltd. J. Agency R. 25-31, Mar. 30, 2015, ECF No. 46 (“Quoc Viet Br.”). Tri Union and Quoc Viet also challenge that Commerce’s decision to use Bangladeshi data to value all raw shrimp irrespective of species because Indonesian data is the best available information on the record to value mandatory respondents’ consumption of white vannamei shrimp. See Tri Union Br. 12-15; Quoc Viet Br. 31-34.

Quoc Viet separately claims that Commerce’s refusal to individually examine it as a voluntary respondent is not in accordance with law. See Quoc Viet Br. 13-19. Quoc Viet also contends that Commerce unlawfully rejected its submissions following the preliminary results, which included a self-calculated antidumping duty margin for containing untimely filed new factual information. See id. at 19-25. Similarly, VASEP argues that Commerce acted contrary to its own regulations and abused its discretion by rejecting MPG’s case brief for containing untimely filed new factual information. See Resp’t Pis. VASEP and Individual VASEP Members’ Br. Supp. Mot. J. Agency R. 10-16, Mar. 30, 2015, ECF No. 50 (“VASEP Br.”).

VASEP challenges Commerce’s implementation and application of its differential pricing analysis to evaluate whether application of A-T to calculate the mandatory respondents’ dumping margins was warranted in the instant review. See id. at 16-44. Quoc Viet has incorporated VA-SEP’s arguments relating to Commerce’s differential pricing analysis by reference. See Quoc Viet Br. 4. Moreover, VASEP claims Commerce acted against its practice by failing to convert Bangladeshi surrogate values that were denominated in U.S. dollars to Bangladeshi taka before accounting for inflation using a Bangladeshi initiator jrate. See VASEP Br. 44-45.

Lastly, Ad Hoc Shrimp asserts in its Rule 56.2 motion that Commerce’s use of Bangladeshi data to value labor renders the final results of the review unsupported by substantial evidence. See Mot. Ad Hoc Shrimp Trade Action Committee for J. Agency R. Under USCIT Rule 56.2 15-30, Mar. 30, 2015, ECF No. 49-3 (“Ad Hoc Shrimp Br.”).

Defendant United States (“Defendant”) responds that the court should sustain Commerce’s determinations in the final results except for Commerce’s decision to use Bangladeshi labor data, for which Defendant requests a voluntary remand. See Def.’s Resp. Opp’n Pis.’ Mots. J. Agency R. 15-89, Sept. 10, 2015, ECF No. 72 (“Def.’s Resp.”). Ad Hoc Shrimp similarly responds that the court should sustain Commerce’s final results except for Commerce’s decision to use Bangladeshi labor data. See Ad Hoc Shrimp Br. 15-30; Def.-Intervenor Ad Hoc Shrimp Trade Action Committee’s Resp. Consolidated Pis.’ Mots. J. Agency R. Under USCIT Rule 56.2 6-20, Sept. 24, 2015, ECF No. 76.

The court finds that Commerce’s primary surrogate country selection and decision to use Bangladeshi data to value all raw shrimp consumption are supported by substantial evidence and in accordance with law. The court also finds that Commerce’s decision to decline to review Quoc Viet as a voluntary respondent is in accordance with law. Additionally, Commerce’s rejection of Quoc Viet’s margin calculation submissions and rejection of MPG’s case brief for containing untimely filed new factual information are reasonable. Further, the court sustains Commerce’s application of its differential pricing analysis and subsequent use of A-T to calculate the mandatory respondents’ antidumping duty rates. Moreover, the court finds that VASEP has failed to exhaust its administrative remedies with respect to (1) its challenge to the adequacy of Commerce’s explanation for changing its practice of using the Nails test to its differential pricing analysis and (2) its challenge to the manner in which Commerce has accounted for inflation for certain surrogate values. In these respects, Commerce’s final results are sustained. Finally, the court grants Defendant’s request for a voluntary remand for Commerce to reconsider its reliance on Bangladeshi labor data to calculate respondents’ labor FOP. The court reaches its conclusions on the foregoing issues for the reasons discussed below.

JURISDICTION AND STANDARD OF REVIEW

The court has jurisdiction pursuant to 19 U.S.C. § 1516a(a)(2)(B)(iii) and 28 U.S.C. § 1581(c) (2012), which grant the court authority to review actions contesting the final determination in an administrative review of an antidumping duty order. The court will uphold Commerce’s determination unless it is “unsupported by substantial evidence on the record, or otherwise not in' accordance with law.” 19 U.S.C. § 1516a(b)(l)(B)(i).

DISCUSSION

I. Commerce’s Decision to Select Bangladesh as the Primary Surrogate Country is Supported by Substantial Evidence and in Accordance With Law

Tri Union and Quoc Viet both challenge Commerce’s selection of Bangladesh as the primary surrogate country. See Tri Union Br. 7-12; Quoc Viet Br. 25-31. Tri Union and Quoc Viet argue that because the most important FOP of the subject merchandise is raw shrimp, and Indonesian data provides superior data regarding that FOP relative to Bangladeshi data, Commerce’s selection of Bangladesh as the primary surrogate country is unsupported by substantial evidence and not in accordance with law. See Tri Union Br. 7; Quoc Viet Br. 25-26. Defendant argues that Commerce reasonably chose Bangladesh as the primary surrogate country because it offers the “best available information” and is both at a level of economic development comparable to Vietnam and a significant producer of comparable merchandise. See Def.’s Resp. 15-22; see also 19 U.S.C. § 1677b(c)(l), (c)(4). Commerce’s decision to select Bangladesh as the primary surrogate country is supported by substantial evidence and in accordance with law.

In NME antidumping duty proceedings, Commerce generally calculates normal value “on the basis of the value of the factors of production utilized in producing the merchandise ... [together with other costs and expenses].” 19 U.S.C. § 1677b(c)(l). Commerce is obligated to value the FOPs used to produce the subject merchandise on the basis of “the best available information regarding the values of such factors ... in one or more market economy countries that are — (A) at a level of economic development comparable to that of the [NME] country, and (B) significant producers of comparable merchandise.” 19 U.S.C. § 1677b(c)(l), (c)(4). While Commerce has broad discretion in deciding what constitutes the best available information, see QVD Food Co. v. United States, 658 F.3d 1318, 1323 (Fed.Cir.2011) (noting the absence of a definition for “best available information” in the antidumping duty statute), it must ground its selection of the best available information in the overall purpose of the anti-dumping duty statute, calculating accurate dumping margins. See CS Wind Vietnam Co. v. United States, 38 CIT -, -, 971 F.Supp.2d 1271, 1277 (2014) (citing Rhone Poulenc, Inc. v. United States, 899 F.2d 1185, 1191 (Fed.Cir.1990)); see also Parkdale Int’l v. United States, 475 F.3d 1375, 1380 (Fed.Cir.2007).

Although Commerce may use multiple surrogate countries to calculate normal value in NME cases, Commerce’s regulatory preference is to “value all factors in a single surrogate country.” 19 C.F.R. § 351.408(c)(2). To implement this preference, Commerce selects a primary surrogate country using a process tracking the requirements of 19 U.S.C. § 1677b(e)(l) and (4). See generally Import Admin., U.S. Dep’t Commerce, Non-Market Economy Surrogate Country Selection Process, ■ Policy Bulletin 04.1 (2004), available at, http://ia.ita.doc.gov/policy/bull04-l.html (last visited Mar. 28, 2016) (“Policy Bulletin”). Commerce’s Policy Bulletin outlines the following process: (1) the Office of Policy (“OP”), in response to a written request, assembles “a list of potential surrogate countries that are at a comparable level of economic development to the NME country”; (2) Commerce identifies countries from the list “with producers of comparable merchandise”; (3) Commerce “determines whether any of the countries which produce comparable merchandise are ‘significant’ producers of that comparable merchandise”; and (4) if more than one country satisfies steps (l)-(3), Commerce will select “the country .with the best factors data.” See generally id.

To identify, potential surrogate countries that are at a level of economic development comparable to the NME country in accordance with 19 U.S.C. § 1677b(c)(4)(A), Commerce requests its OP to create a list of potential surrogate countries whose per capita gross national income (“GNI”) fall within a range that the OP deems comparable to the GNI of the NME. See id. at 2; see also Surrogate Country List at 1. Thereafter, Commerce evaluates which of the potential surrogate countries are “significant producers of comparable merchandise,” as required by 19 U.S.C. § 1677b(c)(4)(B). See Policy Bulletin at 2-3. If more than one candidate country remains, Commerce considers each country’s data and selects the country that provides the best data for the FOPs. See id. at 4.

Commerce is given broad discretion in assessing what data sources it will rely on in calculating normal value in a NME proceeding given that “best available information” is not defined by statute. QVD Food Co., 658 F.3d at 1323. To determine what constitutes the best available information, Commerce evaluates the quality and reliability of data sources from the remaining countries offered to value respondents’ FOPs favoring data that is: (1) specific to the input in question; (2) representative of a broad market average of prices; (3) net of taxes and import duties; (4) contemporaneous with the period of review; and (5) publicly available. See Policy Bulletin at 4. Commerce prefers to select surrogate value data that satisfy the breadth of these criteria. See Final I & D Memo at 48-49. Commerce has stated that “data quality is a critical consideration affecting surrogate country selection” because “a country ... is not of much use as a primary surrogate if crucial factor price data from that country are inadequate or unavailable.” Policy Bulletin at 4. In reviewing Commerce’s determination of what constitutes the best available information with respect to a particular FOP, it is not for the court to reweigh the evidence, see Trent Tube Div., Crucible Materials Corp. v. Avesta Sandvik Tube AB, 975 F.2d 807, 815 (Fed.Cir.1992), but rather, to determine if the evidence relied upon by Commerce was sufficient to support its determination while considering detracting evidence. See Consol. Edison Co. v. N.L.R.B., 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938); see also Suramerica de Aleaciones Laminadas, C.A. v. United States, 44 F.3d 978, 985 (Fed.Cir.1994).

Here, because Commerce treats Vietnam as a NME, it initiated its surrogate country selection process pursuant to 19 U.S.C. § 1677b(c) as outlined in its Policy Bulletin. See Prelim. I & D Memo at 5, 11; see also Certain Frozen Fish Fillets From the Socialist Republic of Vietnam, 68 Fed.Reg. 4,986, 4,990 (Dep’t Commerce Jan. 31, 2003) (notice of preliminary determination of sales at less than fair value) (stating that Commerce designated Vietnam as a NME country on November 8, 2002 for purposes of antidumping and countervailing duty proceedings as of July 1, 2001). Commerce requested that its OP issue a list of potential surrogate countries that are economically comparable to Vietnam (“OP List”). See Prelim. I & D Memo at 11-12; see also Surrogate Country List at 1. The OP List, which was placed on the record on July 2, 2013, provided the following GNI values from 2011 derived from the World Bank’s World Indicators database, published in 2013, for Vietnam and six countries that Commerce deemed economically comparable to Vietnam: Vietnam $1,270, Bangladesh $780, Pakistan $1,120, India $1,420, Nicaragua $1,510, Bolivia $2,020, Philippines $2,210. See Surrogate Country List at 3; see also Prelim. I & D Memo at 12. Commerce stated that it will rely on data from a country on the OP List unless it determines that “all of these countries are not significant producers of comparable merchandise, do not provide a reliable source of publicly available surrogate data or are unsuitable for use for other reasons, or we find another equally comparable country as an appropriate surrogate.” Prelim. I & D Memo at 12. After reviewing shrimp production information from the Food and Agriculture Organization of the United Nations Fisheries Statistics, Commerce concluded that Bangladesh, India, Nicaragua, Pakistan, and the Philippines are all significant producers of shrimp and that only Bolivia is not a significant producer of shrimp. See id. at 13; see also ASPA’s Surrogate Country Selection Comments at Attach. 1. Although Commerce found that five of the six countries on the OP List were economically comparable to Vietnam and significant producers of comparable merchandise, it only evaluated data from Bangladesh and India in the preliminary results because no party had submitted surrogate value data from the other surrogate country candidates on the OP List. See Prelim. I & D Memo at 13-15.

To determine whether Bangladesh or India offered the best available FOP data, Commerce largely focused its inquiry on which country offered the best data for raw shrimp because “the value of the main input, head-on, shell-on shrimp, is a critical FOP in the dumping calculation as it accounts for a significant percentage of [normal value].” Id. at 14. The competing sources of data were (1) a study conducted by the Network of Aquaculture Centres in Asia-Pacifíc (“NACA”) offering Bangladeshi price data for raw shrimp, compiled by the United Nation’s Food and Agricultural Organization, and (2) an article from AQUA Culture Asia Pacific Magazine (‘AQUA”) offering raw shrimp price data from India. See id. Commerce noted that it placed significant importance on a data source’s ability to value raw shrimp by count size because “the subject merchandise and the raw shrimp input are both sold on a count-size specific basis.” See id. Commerce found that the Indian AQUA data did not meet Commerce’s data selection criteria because the data did not cover particular count-size ranges and did not provide how its pricing information was derived. See id. By contrast, Commerce found that the Bangladeshi NACA data did not have these concerns. See id. at 14-15. Commerce therefore selected Bangladesh as the primary surrogate country for valuing MPG’s and Stapimex’s FOPs in the preliminary results because Bangladesh satisfied the surrogate country criteria and provided the best available information for the most significant FOP, raw shrimp. See id. at 15.

Commerce reaffirmed its selection of Bangladesh as the primary surrogate country in the final results and continued to use the Bangladeshi NACA data to value raw shrimp. See Final I & D Memo at 9-17; see also Final Results, 79 Fed. Reg. at 57,047-48. In reaching its final determination, Commerce defended its selection against arguments that Commerce was required to select Indonesia rather than Bangladesh as the primary surrogate country. Commerce first explained that “there is no substantiated evidence on this record that Indonesia is at a level of economic development comparable to that of Vietnam.” Final I & D Memo at 10. Notwithstanding the inability to measure Indonesia’s level of economic development, Commerce additionally determined that Bangladeshi data for raw shrimp is superi- or to Indonesian data because “the fact that the Indonesian NACA data contain prices for both species is counterbalanced by the fact that they lack prices with respect to certain count sizes as compared to the Bangladeshi NACA data.” Id. at 14. Commerce, moreover, pointed to deficiencies in Indonesian data with regard to financial ratios and labor, whereas Bangladeshi data offered data for all FOPs except for shrimp scrap, which it found to be an insignificant component of the normal value. See id. at 16. Thus, “based on the overall consideration of the statutory criteria and the quality of data,” Commerce continued to find Bangladesh to be the most appropriate choice. Id. at 17.

Commerce’s surrogate country selection is supported by substantial evidence and in accordance with law. In following its standard practice, Commerce identified economically comparable countries that are significant producers of comparable merchandise. Among the economically comparable countries that are significant producers, Commerce selected Bangladesh as the primary surrogate country over the other candidate countries based on its assessment of the data available on the record. Given that Commerce’s surrogate country selection was significantly informed by data for raw shrimp, the reasonableness of Commerce’s surrogate country selection is heavily dependent upon the reasonableness of Commerce’s assessment of the Bangladeshi NACA data and the Indonesian NACA data.

The NACA study, which is the source of both the Bangladeshi and Indonesian data at issue here, was conducted in three countries — Vietnam, Bangladesh, and Indonesia — “with the aim of assessing the impact of the 2004 Indian Ocean tsunami and of the introduction of anti-dumping duties on the shrimp farming sectors of countries in the Asian region.” Surrogate Value Comments at Ex. SV-2 at ii. The mandatory respondents reported sales of up to fifteen count sizes of shrimp. See Final I & D Memo at 14; see also Analysis for the Final Results for Minh Phu Group at 3, CD 186 at bar code 3229573-01 (Sept. 19, 2014) (“MPG Final Analysis”); Analysis for the Final Results of Soc Trang Seafood Joint Stock Company at 3, CD 194 at bar code 3229584-01 (Sept. 19, 2014) (“Stapi-mex Final Analysis”). Count size refers to the size of shrimp, which in this case has been measured by the number of pieces per kilogram (“Pcs/Kg”). The NACA study includes data for the following groupings of count sizes, beginning with the largest and most expensive shrimp: (1) Under 20 Pcs/Kg, ie., U20; (2) 21-30 Pcs/ Kg; (3) 31-44 Pcs/Kg; (4) 45-66 Pcs/Kg; (5) 67-100 Pcs/Kg; (6) Over 100 Pcs/Kg. See MPG Final Analysis at 3; Stapimex Final Analysis at 3. These groupings of count sizes encompass all of the count sizes of shrimp reported by the mandatory respondents. See MPG Final Analysis at 3; Stapimex Final Analysis at 3. The mandatory respondents also reported sales of two species of shrimp — penaeus monodon, ie., black tiger shrimp, and penaeus vannamei, ie., white vannamei shrimp. See Final I & D Memo at 14; see also Surrogate Value Comments at Ex. SV-2 at 3. The NACA study provides data for these two species of shrimp to the extent that they were commonly traded in the country during the time the study was conducted.

Both the Bangladeshi NACA data and the Indonesian NACA data have deficiencies in fully accounting for mandatory respondents’ reported count sizes and species. The Indonesian NACA data “has data for four count sizes of black tiger and three count sizes of vannamei.” Final I & D Memo at 14. Specifically, the Indonesian data contain data for count sizes (2) — (5) of black tiger and (3) — (5) of white vanna-mei. See MPG Final Analysis at 3; Stapi-mex Final Analysis at 3; see also Final I & D Memo at 15 n.47. “In contrast, Bangladesh data has five count sizes for black tiger but no count size data for vanna-mei.” Final I & D Memo at 14. Specifically, the Bangladeshi data contain data for count sizes (1) — (5) of black tiger shrimp. See MPG Final Analysis at 3; Stapimex Final Analysis at 3; see also Final I & D Memo at 15 n.47. “[T]he Indonesian black tiger prices cover about 85 percent of respondents’ reported count sizes, while the vannamei prices cover only between 49 percent and 57 percent of respondents’ reported count sizes,” and the Bangladeshi NACA data “cover over 94 percent of count sizes of black tiger shrimp reported by both respondents.” Final I & D Memo at 15. Neither the Bangladeshi data nor the Indonesian data contain data for count size (6) regardless of species, therefore, both data sources are equivalent in that regard. See id. Simply put, while the Indonesian NACA data is more specific to species by providing independent pricing information for black tiger shrimp and white vannamei shrimp, the Bangladeshi NACA data is more specific to count size pricing information.

' After considering both data sources, Commerce could not “conclude from the record that accounting for prices on a species-specific basis is more accurate than accounting for prices for almost all the count sizes.” Id. at 38. Because the NACA study indicated that “shrimp price depends on the size and seasonal crop ... especially for bigger size [shrimp],” Surrogate Value Comments at Ex. SV-2 at 3, Commerce considered data that offered prices for a broad range of count sizes, even for one species, to be more accurate and superior to species-specific data that offered prices for a limited range of count sizes. See Final I & D Memo at 14-15, 38. Commerce favored the Bangladeshi NACA data and ultimately selected Bangladesh as the primary surrogate country because it found that the Indonesian NACA data, though having data for both species, suffered from a limited availability of prices for a broad range of count sizes. Thus, Commerce chose to rely upon the Bangladeshi NACA data because “what the data for Bangladesh lacks in vannamei prices is outweighed by other factors, such as Bangladesh’s economic comparability to Vietnam ... and a larger range of pricing for count sizes of black tiger shrimp, particularly the largest, most expensive shrimp count size.” Id. at 38. Based on the record before Commerce and its assessment of the available data, Commerce’s decision to select Bangladesh as the primary surrogate country is reasonable.

Tri Union and Quoc Viet disagree with Commerce’s assessment of the competing data sources. Tri Union and Quoc Viet do not dispute Commerce’s determination that the Bangladeshi NACA data satisfies Commerce’s criteria for data quality. In fact, they accept that “the Indonesia NACA data and the Bangladeshi NACA data are equally contemporaneous, publicly available, tax and duty exclusive, and representative of broad market averages,” given that both sources are derived from the same NACA study. Tri Union Br. 9-10; Quoc Viet Br. 28. Instead, they argue that Commerce improperly prioritized count size over species of shrimp in considering data for purposes of surrogate country selection. Tri Union and Quoc Viet contest Commerce’s determination that Bangladeshi data is the best available information because “the NACA data for Bangladesh reflect prices only for a single species of shrimp: monodon, or black tiger shrimp” and yet “the respondents in this segment of the proceeding produced and sold both white vannamei and black tiger shrimp species.” Tri Union Br. 9; Quoc Viet Br. 28. “The same NACA study, however, includes Indonesian prices for both black tiger and white vannamei shrimp raw material.” Tri Union Br. 9; Quoc Viet Br. 28; see also Surrogate Value Comments at Ex. SV-2 at 133-34. Tri Union and Quoc Viet claim that Commerce’s decision to use the Bangladeshi NACA data is unsupported by substantial evidence because Commerce “failed to address the record evidence that demonstrated the significant difference in prices based on shrimp species.” Tri Union Br. 12; Quoc Viet Br. 29-30.

Commerce selected Bangladesh as the primary surrogate country primarily because it offered data for raw shrimp on a wider range of count-specific prices. See Final I & D Memo at 13-16. Commerce, in dismissing Indonesia as the primary surrogate country, made much of the fact that Indonesian data “do not contain as many count-specific prices in the black tiger shrimp category as that of the Bangladeshi data, which have a fuller array of prices for black tiger shrimp that would cover more of the respondents’ reported count sizes.” See id. at 16. Commerce prioritized a country’s data source’s ability to value a broader range of count sizes of mandatory respondents’ reported raw shrimp consumption rather than its ability to value species specific raw shrimp. See Prelim. I & D Memo at 14; Final I & D Memo at 13. The significance Commerce ascribed to count size is supported by record evidence that showed “ ‘shrimp price depends on the size and seasonal crop ... especially for bigger size for both [black tiger shrimp] and [white vannamei shrimp].’ ” Final I & D Memo at 15 (quoting Surrogate Value Comments at Ex. SV-2 at 3). Further, “the subject merchandise and the raw shrimp input are both sold on a count-size specific basis.” Id. at 13. The greater significance given to count size as opposed to species is reinforced by the fact that out of a total of fourteen total physical characteristics of the subject merchandise, count size is listed as the third most important while species is listed as the thirteenth. See id. at 15 n.44; see also Def.’s Resp. 24. Thus, the record supports Commerce’s decision to prefer a data source that provides values for a broader range of count sizes rather than values for specific species. Tri Union Br. 11-12; Quoc Viet Br. 30.

Tri Union and Quoc Viet further argue that “in favor of one additional count-size range in one species, Commerce ignored completely the relevance of species-specificity.” Tri Union Br. 11; Quoc Viet Br. 29-30. Tri Union and Quoc Viet claim that “none of the points made by Commerce explain why the use of the Bangladeshi data, which might require less extrapolation for unavailable count sizes, but are of a different species, results in more accurate calculations than the Indonesian data, which might require more extrapolation for unavailable count sizes, but are of an identical species.” Tri Union Br. 11-12; Quoc Viet Br. 30.

However, a significant portion of the mandatory respondents’ sales are attributable to that one missing count size in the Indonesian data. Commerce found

a large portion of both respondents’ sales are for the larger count sizes which the Indonesian data lacks for both species; ... the Bangladeshi NACA data covers the vast majority of both respondents’ count sizes; ... both respondents sold roughly equal quantities of black tiger shrimp and vannamei shrimp during the POR; ... and ... a large percentage of both respondents’ count sizes would not be covered by Indonesian NACA data.

Final I & D Memo at 14 (citing MPG Final Analysis at 3; Stapimex Final Analysis at 3). Commerce specifically explained that “Indonesian data does not contain prices not only for the largest count-size of shrimp for both species [, i.e., U20], but also for the second largest size of the vannamei species [, i.e., 21-30 Pcs/Kg].” Id. at 38. As a result of these deficiencies, the Indonesian data fails to account for a significant portion of the mandatory respondents’ sales observations and quantity because the larger count sizes, as evidenced by the record, were the most expensive and contributed significantly to their sales. See id. at 15; see also MPG Final Analysis at 2-3; Stapimex Final Analysis at 2-3. While Tri Union and Quoc Viet present evidence showing price differences among species, they are unable to controvert record evidence indicating that count size, not species, is the driving force for the price of raw shrimp.

Tri Union and Quoc Viet additionally argue that Commerce was “[distracted by the non-issue of Indonesia’s economic comparability” in selecting the most appropriate primary surrogate country. See Tri Union Br. 9; Quoc Viet Br. 27. Commerce defended its selection in part due to the absence of Indonesia’s GNI on the record. The data on the record appeared to substantiate the claim that Indonesia is a significant producer of comparable merchandise and contain surrogate values for subject merchandise. See Final I & D Memo at 12-14; see also Surrogate Value Comments at Ex. SV-2. However, any information regarding Indonesia’s level of economic development was absent from the record. See Final I & D Memo at 10. Commerce concluded that “Bangladesh fulfills the surrogate country selection criteria” and “the record of this case does not contain substantiated evidence regarding Indonesia’s GNI that would enable [Commerce] to make a finding that Indonesia was at a level of economic development comparable to Vietnam during this [period of review].” Id. at 12. Commerce informed parties that it would “consider other countries on the case record if the record provides ... adequate information to evaluate them.” Surrogate Country List at 3. However, there was inadequate information on the record to evaluate whether Indonesia is economically comparable to Vietnam. The only reference to Indonesia’s level of economic development on the record is found in MPG’s rebuttal brief, but that reference was “unsubstantiated by any record evidence that [Commerce] could rely upon in evaluating whether Indonesia is at a level of economic development comparable to Vietnam.” Final I & D Memo at 10; see also Minh Phu Group Rebuttal Case Brief at 3, PD 239 at bar code 3206463-01 (June 2, 2014). If an interested party believed that a country not on the OP List, in this case Indonesia, is a country that is economically comparable to Vietnam, it was incumbent on that party to submit that evidence to Commerce so that it could be placed on the record. See QVD Food Co., 658 F.3d at 1324 (providing that “the burden of creating an adequate record lies with [interested parties] and not with Commerce”). Commerce thus selected Bangladesh in part because it was unable to determine whether Indonesia is economically comparable to Vietnam. Tri Union and Quoc Viet contend that the absence of Indonesia’s GNI does not forestall Commerce from selecting Indonesia because “Commerce already has acknowledged that Indonesia is economically comparable to Vietnam.” Reply by Quoc Viet Seaproducts Processing Trading and Import-Export Co., Ltd.; Tri Union Frozen Products Inc.; Mazzet-ta Company LLC; and Ore-Cal Corporation to Def.’s and Def.-Intervenor’s Mem. Resp. Pis.’ Rule 56.2 Mot. J. Agency R. 9, Dec. 3, 2015, ECF No. 87 (“Quoc Viet & Tri Union Reply”). Despite Tri Union’s and Quoc Viet’s protests concerning Commerce’s implicit acknowledgment of Indonesia’s economic comparability, Commerce’s reliance on Indonesian data to value shrimp scrap does not serve to establish that Indonesia is at a level of economic development comparable to Vietnam. Commerce reasonably weighed the record data along with the other surrogate country criteria to support its selection of Bangladesh as the primary surrogate country. Commerce found that Bangladeshi data was superior to Indonesian data and despite both countries being significant producers of merchandise, Commerce could only weigh evidence regarding the relative economic comparability of Bangladesh and India. Therefore, the court cannot say that Commerce’s choice of Bangladesh as the primary surrogate country was unreasonable.

Because Commerce reasonably determined that Bangladesh offered the best available information, Commerce’s decision to select Bangladesh as the primary surrogate country is supported by substantial evidence and in accordance with law.

II. Commerce’s Decision to Use Bangladeshi Data to Value All Raw Shrimp is Supported by Substantial Evidence and in Accordance With Law

Tri Union and Quoc Viet also challenge Commerce’s decision to use Bangladeshi data to value raw shrimp to the extent that Commerce relied upon that data to value mandatory respondents’ consumption of white vannamei shrimp. See Tri Union Br. 12-15; Quoc Viet Br. 31-34. Tri Union and Quoc Viet argue that Indonesian NACA data is the best available information to value white vannamei shrimp, especially for the count sizes the data offered, and Commerce should use that data to supplement the Bangladeshi NACA data for white vannamei shrimp consumption because “black tiger shrimp is valued [[ ]] than white vannamei shrimp of identical sizes.” Tri Union Br. 14-15; Quoc Viet Br. 33. Tri Union and Quoc Viet assert that “[bjecause there are no available Bangladeshi white vannamei surrogate values on the record, substantial evidence required that even if Commerce relied on Bangladesh as the primary surrogate country, then Commerce nonetheless should have used the Indonesian white vannamei surrogate values to value the respondents’ vannamei factors of production.” Tri Union Br. 14; Quoc Viet Br. 33-34. Thus, they argue Commerce was required to cure whatever deficiencies the Bangladeshi data has regarding white van-namei shrimp with the Indonesian species-specific data and that Commerce on remand should either “use the available Indonesian white vannamei shrimp pricing data to value the respondents’ consumption of white vannamei shrimp or demonstrate why using the Bangladeshi data results in more accurate calculations.” Tri Union Br. 15; Quoc Viet Br. 34. Defendant maintains that Commerce’s reliance on Bangladeshi NACA data for valuing all raw shrimp is supported by substantial evidence because “count-size, not species specification, is a crucial factor in determining surrogate values” and Tri Union and Quoc Viet fail to demonstrate that using a species-specific data source leads to more accurate calculations. See Def.’s Resp. 26-27. Commerce’s decision to use the Bangladeshi NACA data to value all raw shrimp, including white vannamei shrimp, is supported by substantial evidence and in accordance with law.

As previously stated, Commerce shall, to the extent possible, value FOPs based on the best available information from market economy countries that are economically comparable to the NME country and significant producers of comparable merchandise. See 19 U.S.C. § 1677b(c)(l), (c)(4). In selecting the best available information, Commerce evaluates the quality and reliability of data sources from the remaining countries offered to value respondents’ FOPs favoring data that is: (1) specific to the input in question; (2) representative of a broad market average of prices; (3) net of taxes and import duties; (4) contemporaneous with the period of review; and (5) publicly available. See Policy Bulletin at 4.

While Commerce determined that the Bangladeshi NACA data is the best available information, the Indonesian NACA data made available independent pricing information for three count sizes of white vannamei shrimp that the Bangladeshi NACA data lacked. Notwithstanding the availability of white vannamei shrimp data, Commerce chose not to supplement the Bangladeshi NACA data with the Indonesian white vannamei shrimp data. In making its decision, Commerce (1) relied upon the absence of any record evidence regarding Indonesia’s level of economic development, (2) incorporated its reasons for determining that the Bangladeshi NACA data is superior to the Indonesian NACA data to value raw shrimp, (3) cited its practice and regulatory preference for valuing all FOPs in a single surrogate country, see 19 C.F.R. § 351.408(c)(2), and (4) explained that supplementing the Bangladeshi NACA data with the Indonesian NACA data for white vannamei shrimp would not lead to more accurate calculations and would, in fact, increase the potential for distortive and inaccurate calculations. See Final I & D Memo at 37-38.

Commerce’s decision here is reasonable. Commerce relied upon its determination that the Bangladeshi NACA data is the best available information to value mandatory respondents’ consumption of raw shrimp. The Indonesian NACA data “has data for four count sizes of black tiger and three count sizes of vannamei.” Id. at 14. “In contrast, Bangladesh data has five count sizes for black tiger but no count size data for vannamei.” Id. Because record evidence informed Commerce that count size, not species, outweighs other considerations for valuing raw shrimp, Commerce chose to use the Bangladeshi NACA data because the Bangladeshi NACA data offers a broad range of count-size specific pricing information while the Indonesian NACA data is lacking in that regard. In making its determination, Commerce explained that it did not make its “determination on a single sub-factor relevant to the data at issue, but rather examined each set of data.” Id. at 14. Thus, Commerce determined that the Indonesian NACA data may be more specific with respect to species, but the Bangladeshi NACA data is more specific with respect to the FOP as a whole. Once Commerce determined that the Bangladeshi NACA data is the best available information, it was reasonable for Commerce to choose to rely on the single data source that is more specific for the FOP in its entirety rather than integrate another data source from another country that is relatively more specific with regard to a component of the FOP.

In the absence of any authority requiring it to use data from multiple countries to value shrimp, Commerce reasonably chose to value shrimp with data from a single country. Commerce explained that “interested parties have not demonstrated that using data with prices for only a limited range of count sizes, albeit for two species, would result in a more accurate margin calculation than using the prices available for almost all count sizes albeit for only one of the species produced and sold by the mandatory respondents.” Id. at 38. Commerce expressed concerns regarding the several calculations necessary to ascribe Indonesia’s pricing structure to Bangladesh to account for species. Commerce explained that “[u]sing this data would ... require even more adjustment than required for the Bangladeshi data to match to the mandatory respondents’ numerous count size ranges of shrimp input,” Id. at 15, and that “after remedying the relative lack of count size value data in the data for Indonesia, any improvement in inaccuracy would likely be outweighed, or at least counterbalanced by, the accuracy loss inherent in this multistep estimation.”. Id. at 38. Commerce was already forced to undergo additional calculations to derive the surrogate values for count' size (6), regardless of which data source it chose to use. To use the Indonesian NACA data to value mandatory respondents’ sales of white vannamei shrimp would also require additional calculations on the other end of the spectrum to extrapolate the prices for the largest and second largest count size for white vannamei shrimp. See id. Commerce decided that it would be more accurate to only rely upon the Bangladeshi NACA data to value raw shrimp because “extensive extrapolation from smaller to larger count-sizes would have required assumptions and undermined any potential benefits of species-specific data.” Def.’s Resp. 26; see also Final I & D Memo at 38. Thus, Commerce found that using the Indonesian NACA data to supplement the Bangladeshi- NACA data would not lead to more accurate margin calculations because the Indonesian NACA data is lacking, even for white vannamei shrimp information.

Commerce’s reasons for refusing to incorporate the Indonesian NACA data in its calculations suffice to demonstrate that its decision is supported by substantial evidence and in accordance with law. While the Indonesian NACA data provides for species-specific data where Bangladeshi NACA data does not, that fact alone does not render Commerce’s exclusive use of the Bangladeshi NACA data unsupported by substantial evidence. There is no authority that requires Commerce to further manipulate the data it determines is the best available information. Commerce’s determination is further supported by the concern that using two data sources from two countries would potentially lead to dis-tortive and inaccurate calculations. Taken together, Commerce’s decision to use the Bangladeshi NACA data to value all raw shrimp, including white vannamei shrimp, is reasonable.

In response to Commerce’s preference to value all FOPs in a single surrogate country, Tri Union and Quoc Viet argue that “where information from the primary surrogate country is either unavailable or unreliable, Commerce will rely on information from a secondary surrogate country.” Tri Union Br. 14; Quoc Viet Br. 32. Without citing to any authority, they assert that “[bjecause there are no available Bangladeshi white vannamei surrogate values on the record, substantial evidence required that ... Commerce ... use[ ] the Indonesian white vannamei surrogate values to value the respondents’ vannamei factors of production.” Tri Union Br. 14; Quoc Viet Br. 33. The only support for their argument is a reference to when Commerce had chosen Indonesia as the primary surrogate country in a previous review, but chose to rely on data from another country to value a particular FOP. Tri Union Br. 14 n. 27; Quoc Viet Br. 32-33 n. 71. When a primary surrogate country does not have usable data for a particular FOP, Commerce does look to other countries to find the best available information to value that FOP. However, when Commerce has determined information from the primary surrogate country to be the best available information for a FOP, it does not follow that, absent extraordinary circumstances, Commerce is additionally required to use information from a second country to manipulate and cure any and every deficiency in the primary surrogate country data.

Lastly, Tri Union and Quoc Viet argue that “Commerce is simply wrong to have claimed ... that interested parties had not demonstrated that the use of Indonesian white shrimp surrogate values would result in more accurate antidumping margin calculations.” Tri Union Br. 14; Quoc Viet Br. 33. They argue “Commerce failed to address the record evidence demonstrating that there were significant difference in prices based on shrimp species.” Tri Union Br. 15; Quoc Viet Br. 33. However, Commerce specifically addressed the argument that accounting for the price disparity among species using the Indonesian NACA data would lead to more accurate results. While Tri Union and Quoc Viet contend that the price of shrimp differs depending on the species, “[t]here is- no indication on the record that shrimp prices in Bangladesh are species-driven.” Final I & D Memo at 38. In fact, Commerce found that “record evidence shows that ‘shrimp price depends on the size and seasonal crop ... especially for bigger size {shrimp}.’ ” Id. (quoting Surrogate Value Comments at Ex. SV-2). Commerce found “no record evidence to suggest that the shrimp price structure between Indonesian black tiger prices and vannamei prices would be the same or similar to that in Bangladesh.” Id. Commerce concluded that “ascrib[ing] Indonesia’s pricing structure to Bangladesh would ... require several successive calculations ... [and] any improvement in accuracy would likely be outweighed, or at least counterbalanced by, the accuracy loss inherent in this mul-tistep estimation.” Id. Commerce was not concerned with the .complexity of such calculations, but rather, it was concerned with the extensive extrapolation necessary to derive pricing information for the two largest count sizes of white vannamei shrimp. See id.

Therefore, Tri Union and Quoc Viet are unable to demonstrate that Commerce’s refusal to supplement the Bangladeshi NACA data with the Indonesian NACA white vannamei shrimp data is unreasonable.

III. Commerce’s Decision Not to Select Quoc Viet as a Voluntary Respondent is Reasonable

Quoc Viet argues Commerce’s refusal to individually examine it and calculate its own antidumping duty rate as a voluntary respondent is contrary to law. See Quoc Viet Br. 13-19. Quoc Viet contends that “Commerce failed to apply the appropriate legal standard under 19 U.S.C. § 1677m in determining whether individual examination of Quoc Viet as a voluntary respondent would have been unduly burdensome and would have inhibited the timely completion of the review.” Id. at 14. Defendant dismisses Quoc Viet’s argument as erroneous, insisting that Commerce correctly determined not to grant Quoc Viet’s voluntary respondent requests. See Def.’s Resp. 28-38. Defendant maintains that “examination of an additional company, beyond the mandatory respondents already selected, would have been unduly burdensome and inhibited the timely completion of the review.” Id. at 28. The court finds that Commerce’s decision not to individually examine Quoc Viet is reasonable.

In an administrative review of an antidumping duty order, Commerce must calculate individual antidumping duty rates for each known exporter or producer of subject merchandise covered by the review, i.e., respondents. See 19 U.S.C. §§ 1675(a)(1)(B), 1677f-l(c)(l). The statute therefore requires that Commerce collect data with respect to sales of subject merchandise from each respondent and calculate individual rates. However, the statute provides for an exception to Commerce’s requirement to individually examine and assign antidumping duty rates for all respondents:

(2) Exception

If it is not practicable to make individual weighted average dumping margin determinations under paragraph (1) because of the large number of exporters or producers involved in the investigation or review, [Commerce] may determine the weighted average dumping margins for a reasonable number of exporters or producers by limiting its examination to—

(A) a sample of exporters, producers, or types of products that is statistically valid based on the information available to [Commerce] at the time of selection, or

(B) exporters and producers accounting for the largest volume of the subject merchandise from the exporting country that can be reasonably examined.

19 U.S.C. § 1677f-l(c)(2). Thus, if there is a large number of exporters or produe-ers covered in an administrative review, Commerce may limit the review to individually examine and “determine the weighted average dumping margins for a reasonable number of exporters or producers.” Id.

When Commerce invokes this exception, as it has done so here, it typically limits the review to individually examine “exporters and producers accounting for the largest volume of the subject merchandise from the exporting country” according to U.S. Customs and Border Protection import data. See Proposed Methodology for Respondent Selection in Antidumping Proceedings, 75 Fed.Reg. 78,678, 78,678 (Dep’t Commerce Dec. 16, 2010) (request for comment) (stating that Commerce has used this option in “virtually every one of its proceedings”); see also 19 U.S.C. § 1677f-l(c)(2)(B). Those exporters and producers that account for the largest import volume of subject merchandise are then selected as mandatory respondents. Commerce collects sales data from these mandatory respondents by issuing questionnaires and individually examines each of the mandatory respondents to calculate their respective antidumping duty rates.

If not initially selected as a mandatory respondent, a respondent may request to be individually examined as a voluntary respondent pursuant to 19 U.S.C. § 1677m(a). A voluntary respondent is individually examined like a mandatory respondent and is given an antidump-ing duty rate based on its own sales of subject merchandise rather than assigned an antidumping duty rate based on the weighted average rates calculated for the mandatory respondents. However, Commerce may nevertheless refuse to individually examine the respondent as a voluntary respondent even if the respondent otherwise satisfies the statutory requirements for voluntary respondent treatment. The relevant language of the governing statute provides:

(a) Treatment of voluntary responses in countervailing or antidumping duty investigations and reviews

In any ... review under section 1675(a) of this title in which [Commerce] has, under section 1677f-1(c)(2) of this title ..., limited the number of exporters or producers examined, ... [Commerce] shall establish ... an individual weighted average dumping margin for any exporter or producer not initially selected for individual examination under such sections who submits to [Commerce] the information requested from exporters or producers selected for examination, if—

(1) such information is so submitted by the date specified—

(A) for exporters and producers that were initially selected for examination, or

(B) for the foreign government, in a countervailing duty case where [Commerce] has determined a single country-wide rate; and

(2) the number of exporters or producers who have submitted such information is not so large that, individual examination of such exporters or producers would be unduly burdensome and inhibit the timely completion of the investigation.

19 U.S.C. § 1677m(a). Thus, in limited reviews, Commerce must individually examine and calculate an antidumping duty rate for any respondent that timely provides Commerce with the information requested from the mandatory respondents, so long as the number of potential voluntary respondents “is not so large that individual examination of such exporters or producers would be unduly burdensome and inhibit the timely completion of the investigation.” Id.

Here, Quoc Viet requested to be examined as a voluntary respondent as part of its request for Commerce to initiate an administrative review of the ADD Order. See Quoc Viet Request at 1. On May 24, 2013, Commerce limited the number of respondents to be examined in this review, but deferred decidi