Full opinion text
OPINION AND ORDER Kelly, Judge: Before the court for review is the U.S. Department of Commerce’s (“Department” or “Commerce”) Final Results of Redeter-mination filed pursuánt to the court’s decision in Vinh Hoan Corp. v. United States, 39 CIT -, 49 F.Supp.3d 1285 (2015) (“Vinh Hoan”). See Final Results of Redetermination Pursuant to Vinh Hoan Corporation et al. v. United States, 49 F.Supp.3d 1285 (2015), Aug. 3, 2015, ECF No. 132 (“Remand Results”). In Vinh Hoan, the court remanded Commerce’s final determination in the eighth administrative review of the antidumping duty order covering certain frozen fish fillets from the Socialist Republic of Vietnam (“Vietnam”) for Commerce to reconsider and provide further explanation regarding its: (1) surrogate country selection; (2) determination to decline to adjust Vinh Hoan’s margin calculation to exclude glazing weight; and (3) treatment of all of Plaintiff Vinh Hoan Corporation’s (“Vinh Hoan”) sales to one customer as consignment sales where record evidence indicated they were not consignment sales. See Vinh Hoan, 39 CIT at - - -, 49 F.Supp.3d at 1291-1326; see also Certain Frozen Fish Fillets From the Socialist Republic of Vietnam, 78 Fed. Reg. 17,350 (Dep’t Commerce Mar. 21, 2013) (final results of antidumping duty administrative review and new shipper reviews; 2010-2011) (“Final Results”), as amended, 78 Fed. Reg. 29,323 (Dep’t Commerce May 20, 2013) (“Amended Final Results”); Issues and Decision Memorandum for the Final Results of the Eighth Administrative Review and Aligned New Shipper Reviews for Certain Frozen Fish Fillets from the Socialist Republic of Vietnam, A-552-801, (Mar. 13, 2013), available at http:// ia.ita.doc.gov/frn/summary/vietnam/2013-06550-l.pdf (last visited May 20, 2016) (“Final Decision Memo”). The court also granted Defendant’s request for a voluntary remand for Commerce to reconsider its calculation for offsetting respondent’s fish oil byproduct. See Vinh Hoan, 39 CIT at - - -, 49 F.Supp.3d at 1321-22. The court reserved judgment on the surrogate value (“SV”) issues relating to respondents’ factors of production (“FOP”), see id. at -, 49 F.Supp.3d at 1291, and those issues are now before the court for review as well. BACKGROUND On September 26, 2011, Commerce initiated this eighth antidumping, duty (“AD”) administrative review covering subject imports entered during the period of review (“POR”), August 1, 2010 through July 31, 2011. See Initiation of Antidumping and Countervailing Duty Administrative Reviews and Requests for Revocations in Part, 76 Fed. Reg. 61,076 (Dep’t Commerce Oct. 3, 2011). On August 30, 2012, Commerce issued its preliminary determination. See Certain Frozen Fish Fillets From the Socialist Republic of Vietnam, 77 Fed. Reg. 56,180 (Dep’t Commerce Sept. 12, 2012) (preliminary results of the eighth antidumping duty administrative review and ninth new shipper reviews, partial rescission of review, and intent to revoke order in part) (“Prelim. Results”). Because Commerce treats Vietnam as a nonmarket economy (“NME”), id. at 56,181, it selected a surrogate market economy country to value the FOPs used in producing the subject merchandise to determine normal value. Id. at 56,183. Commerce preliminarily chose Bangladesh as the primary surrogate country. Id. at 56,184. In its final results, Commerce changed its primary surrogate country selection to Indonesia. See Final Results, 78 Fed. Reg. at 17,351; see also Final Decision Memo at 27. Vinh Hoan commenced this action, which was subsequently consolidated with actions filed by Anvifish Joint Stock Company (“Anvifish”) and Vinh Quang Fisheries Corporation (“Vinh Quang”); Vietnam Association of Seafood Exporters and Producers (“VASEP”); Binh An Seafood Joint Stock Company (“Binh An”); and Catfish Farmers of America, an association of processors and growers, and individual U.S. catfish processors, America’s Catch, Alabama Catfish Inc. dba Harvest Select Catfish, Inc., Heartland Catfish Company, Magnolia Processing, Inc. dba Pride of Pond, and Simmons Farm Raised Catfish, Inc. (collectively “CFA”), challenging various aspects of Commerce’s final determination. See Order on Consolidation and Briefing Schedule, July 23, 2013, ECF No. 31. Each party filed a Rule 56.2 motion for judgment on the agency record challenging Commerce’s Final Results. See Vinh Hoan Corporation’s Rule 56.2 Mot. J. Upon Agency R., Nov. 14, 2013, ECF No. 45; Pl.’s Rule 56.2 Mot. J. Upon Agency R., Nov. 14, 2013, ECF No. 41; Pl.’s Rule 56.2 Mot. J. Upon Agency R., Nov. 14, 2013, ECF No, 38; Mot. J. Agency R. Under USCIT Rule 56.2, Nov. 14, 2013, ECF No. 40 (“Binh An Mot.”); Pls.’ Rule 56.2 Mot. J. Upon Agency R., Nov. 14, 2013, ECF No. 43. In Vinh Hoan, the court held that Commerce’s primary surrogate country selection of Indonesia was" contrary to law and not supported by substantial evidence. Vinh Hoan, 39 CIT at - - -, 49 F.Supp.3d at 1296-1321. The court remanded Commerce’s primary surrogate country selection and directed Commerce to: (1) consider 2011 gross national income (“GNI”) record evidence in its primary surrogate country selection, id. at - - -, 49 F.Supp.3d at 1296-1302; (2) consider the relative differences in GNI between Vietnam and potential surrogate country candidates as well as differences in data quality, id. at - - -, 49 F.Supp.3d at 1302-06; (3) to the extent Commerce continues to rely upon non-fish FOPs to make its primary surrogate country selection, evaluate the alternative data sources based upon all of its selection criteria, id. at -, - - -, 49 F.Supp.3d at 1306, 1309-11; and (4) weigh economic comparability against the strengths and weaknesses of the factors data in making its surrogate country selection. Id. at -, 49 F.Supp.3d at 1303. The court also held that Commerce’s application of facts available for certain costs pertaining to consignment sales to a specific customer, id. at - - -, 49 F.Supp.3d at 1322-23, and Commerce’s use of a FOP ratio in which the denominator included glazing weight were not supported by substantial evidence. Id. at - - -, 49 F.Supp.3d at 1323-26. Finally, the court granted Defendant’s request. for a voluntary remand for Commerce to reconsider its calculation for respondents’ fish oil byproduct offset. Id. at - - -, 49 F.Supp.3d at 1321-22. The court reserved judgment on the parties’ other challenges to Commerce’s selection of SV data sources to value respondents’ FOPs. See id. at -, 49 F.Supp.3d at 1291. Commerce issued its draft remand rede-termination on May 14, 2015. See Draft Results of Redetermination Pursuant to Vinh Hoan Corporation et al. v. United States, 49 F.Supp.3d 1285 (2015), PD 5, bar code 3276279-01 (May 14, 2015) (“Draft Remand Redetermination”). The parties submitted comments on various issues within Commerce’s Draft Remand Redetermination. See Binh An Comments on Draft Remand Redetermination, PD 9, bar code 3277761-01 (May 21, 2015); Vinh Hoan Comments on Draft Results of Remand Determination Pursuant to Vinh Hoan Corporation et al. v. United States, 49 F.Supp.3d 1285 (2015), PD 12, bar code 3280579-01 (June 1, 2015) (“Vinh Hoan Comments on Draft Remand”); Petitioners’ Comments on Draft Remand Redeter-mination, PD 13, bar code 3280875-01 (June 2, 2015). The parties filed comments with the court regarding Commerce’s remand results on October 23,2015. See PI. VASEP’s Comments Resp. to Department of Commerce’s Final Results of Redetermination, Oct. 23, 2015, ECF No. 148 (“VASEP Comments”); PL’s Comments Final Results Redetermination Pursuant to Remand, Oct. 23, 2015, ECF No. 149 (“Vinh Hoan Comments”); Comments Final Results of Redetermination Pursuant to Vinh Hoan Corporation et al. v. United States, 49 F.Supp.3d 1285 (2015), Oct. 23, 2015, ECF No. 150 (“Binh An Comments”); Pls.’ Comments Def.’s Remand Results, Oct. 26, 2015, ECF No. 151 (“CFA Comments”). Defendant and Defendant-Intervenors filed replies to the comments on Commerce’s Remand Results on February 24, 2016. See Def.’s Resp. Pls.’ Remand Comments, Feb. 24, 2016, ECF No. 171 (“Def.’s Resp. Remand Comments”); Def.-Intervenors’ Reply to Comments Def.’s Remand Results, Feb. 24, 2016, ECF No. 172. The court sustains Commerce’s selection of Indonesia as its primary surrogate country, its determination to adjust Vinh Hoan’s margin calculations to reflect net weight sales, and its treatment of Vinh Hoan’s consignment sales. However, the court remands to Commerce its determination to cap the SV of fish oil and to take the absolute value of the [[]] within its byproduct offset calculations for reconsideration and explanation consistent with this opinion. . On the issues in Commerce’s final determination for which the court reserved judgment in Vinh Hoan, the court sustains Commerce’s SV data selections for the following inputs: (1) labor; (2) financial ratios; (3) inland freight and brokerage and handling; (4) frozen broken meat; (5) fresh broken meat; and (6) fish waste, fish belly, and fish skin. The court also sustains Commerce’s determination not to exclude the “freight-in” expense within the selling, general, and administrative expense reported in the financial statements selected to value respondents’ financial ratios. However, the court remands Commerce’s SV data selections for rice husk and sawdust for further consideration and explanation. JURISDICTION AND STANDARD OF REVIEW The court continues to have jurisdiction pursuant to section 516A(a)(2)(B)(iii) of the Tariff Act of 1930, as amended, 19 U.S.C. § 1516a(a)(2)(B)(iii) (2012), 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 anti-dumping duty order. “The court shall hold unlawful any determination, finding, or conclusion found ... to be unsupported by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. § 1516a(b)(l)(B)(i). “The results of a redetermination pursuant to court remand are also reviewed ‘for compliance with the court’s remand order.’ ” Xinjiamei Furniture (Zhangzhou) Co. v. United States, 38 CIT -, -, 968 F.Supp.2d 1255, 1259 (2014) (quoting Nakornthai Strip Mill Public Co. v. United States, 32 CIT 1272, 1274, 587 F.Supp.2d 1303, 1306 (2008)). DISCUSSION In its remand determination, Commerce reconsidered its primary surrogate country selection, its treatment of consignment expenses for certain sales, its calculation of Vinh Hoan’s offset calculations for fish oil and other byproducts, and its calculation of Vinh Hoan’s margin to adjust for glazing weight in its FOP usage ratio (collectively “Remand Issues”). In Vinh Hoan, the court deferred all. remaining issues (“Reserved Issues”), which could have been affected by Commerce’s reconsideration of its primary surrogate country selection. I. Remand Issues A, Surrogate Country Selection 1. Record GNI Data and Relative Economic Comparability In Vinh Hoan, the court held that Commerce must consider 2011 GNI data that it had accepted as record evidence in its economic' comparability analysis. Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1299. The court directed Commerce to compare the relative economic comparability of the countries on the list of potential surrogate countries generated by Commerce’s Office of Policy (“OP List”) because “a" comparison of the- [Bangladeshi Department of Agriculture Marketing, Ministry of Agriculture online pangasius price data (“DAM Data”) ] and [Indonesian Aquaculture Statistics (“IAS Data”) ]” does not make the choice of Indonesia “so clear cut that weighing the relative GNIs of the countries would not improve Commerce’s selection of the best available information.” Id. at - - -, 49 F.Supp.3d at 1304-05. VASEP and Binh An argue that, once 2011 GNI data on the record is considered, Indonesia is not economically comparable to Vietnam. VASEP Comments 7; Binh An Comments ,1. Defendant responds that Commerce found Indonesia economically comparable to Vietnam after considering all GNI data on the record as well as relative differences between the GNI data of’ potential surrogate countries.' Def.’s Resp. Remand Comments 5-6. The .court finds that Commerce reasonably concluded that Vietnam and Indonesia are at comparable levels of economic development based upon 2010 and 2011 GNI data. In NME AD proceedings, Commerce values FOPs “based on the best available information regarding the values of such factors in a market economy country or countries considered to be appropriate by the administering ■ authority.” 19 U.S.C. § 1677b(c)(l). To the extent possible, Commerce. shall use “the prices or costs of factors of production in one or more market ecqnomy countries that are—(A) at a level of economic development comparable to that of the npnmarket economy country, and (B) significant producers of comparable merchandise.” 19 U.S.C. § 1677b(c)(4). Commerce’s regulatory preference is to “value all factors in a single surrogate country.” 19 C.F.R. § 351.408(c)(2) (2012). To implement this preference: (1) the Office of. Policy (“OP”) assembles “a list of potential surrogate countries that are at a comparable level of economic development to the NME country,” whose per. capita GNIs fall within a range of comparability to the per capita GNI of the NME; (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 Import Admin., U.S. Dep’t Commerce, Non-Market Economy Surrogate Country Selection Process, Policy Bulletin 04.1 (2004), available at http://enforcement.trade.gov/policy/bull04-l.html (last visited May 20, 2016) (“Policy Bulletin 04.1”). Under Commerce’s practice, “[t]he surrogate countries on the list are not ranked and should be considered equivalent in terms of economic comparability.” Id. at 2. If more than one country is economically comparable to the NME country and a significant producer of comparable merchandise, Commerce selects the country with the best factors data based upon the data’s: (1) specificity to the input; (2) tax and import duty exclusivity; (3) contemporaneity with the period of review; and (4) public availability. Jd. In its remand results, Commerce reviewed the per capita GNIs of the countries on the OP List, noting “the per capita GNI of Bangladesh ($640) is approximately half that of Vietnam ($1,100), and the per capita GNI of Indonesia ($2,580) is approximately twice that of Vietnam.” Remand Results 8. Commerce also reviewed the 2011 World Bank GNI data, and Commerce recognized that “the differences in per capita GNI for both Bangladesh ($770) and Indonesia ($2,940) grew apart from Vietnam ($1,260) from 2010.” Id. Commerce determined that, while Vietnam’s GNI was twice that of Bangladesh and half that of Indonesia, the differences in GNI in either relative or absolute terms are not significant enough.to render the countries at different levels of economic development. ■ Id. In the broader context of world economic development Commerce found that the GNI disparities were not significant. Id. Commerce’s determination that Indonesia was economically comparable to Vietnam is reasonable in light of GNI data on the record. VASEP, Binh An, and Vinh Hoan argue that Commerce’s economic comparability analysis, which likened differences in economic comparability to .a staircase in its remand results, renders the economic comparability prong of the statute irrelevant to Commerce’s surrogate country selection process. VASEP Comments 8-9; Vinh Hoan Comments 1-2; Binh An Comments 1. VASEP argues Commerce concedes that Indonesia is not at the same level of economic development as Vietnam by acknowledging Vietnam is on a different step in Commerce’s staircase analogy when 2011 GNI data is considered. VASEP Comments ,8. These arguments are únpersuasive. Commerce chose a country from its OP List here. See Surrogate Country List, PD 22,' bar code 3042499-01 (Nov. 22, 2011). Commerce considered the relative differences in GNI of the countries on the OP List in light of 2010 and 2011 data, as the court directed. VASEP’s argument implicitly relies upon the premise that the OP List, or a step in Commerce’s analogy, sets the outer limits of economic comparability. VASEP cites no authority to support such a reading, and this reading ignores the discretion given to Commerce by the statute and Commerce’s methodology for generating the OP List. On remand, Commerce considered the changes in GNI between 2010 and 2011, and compared the relative economic comparability of the countries on the OP List in light of those changes. Remand Results 9. VASEP suggests no reason why it is unreasonable for Commerce to consider Indonesia at a comparable level of economic development as Vietnam based upon their. 2010 and 2011 GNIs. VASEP and Binh An also argue that the GNI range of the OP List, as originally composed based upon 2010 GNI data, limits Commerce’s selection of a primary surrogate country. VASEP Comments 8; Binh An Comments 1. Yet, VASEP cites to no authority for this proposition. None of the cases VÁSEP cites support the notion that Commerce’s OP List sets the limits of economic comparability. 2. Evaluation of Whole Fish In Vinh Hoan, the court ordered Commerce to further explain why certain facts that detracted from its specificity finding do not undermine its conclusion that the superiority of IAS Data supported selecting Indonesia as the primary surrogate country. Vinh Hoan, 39 CIT at - -, 49 F.Supp.3d at 1314-15. In its Remand Results, Commerce has addressed the court’s concerns, and it has provided a reasonable explanation for why it concluded IAS Data was a superior data source for evaluating respondents’ whole live fish. Commerce found that the data is specific because' it covers pangasius hypophthal-mus, the species of pangasius fish grown by respondents. See Remand Results 10-13. Commerce resolved that the presence of pangasius jambal, a different species, in IAS Data did not distort the data because Commerce excluded prices for pangasius jambal by excluding data from paddy and floating net cultures, which it concluded were common cultivation methods for pan-gasius jambal. Id. at 11-12. Commerce also determined the flesh quality differences among species do not affect price because prices for pangasius jambal are similar to those of pangasius hypophthalmus. See id. at 13. As a result, Commerce found that even if small amounts of pangasius jambal were in IAS Data, the price of pangasius hypophthalmus would not be distorted. Id. at 12-13 (citing CFA Surrogate Value Data at Ex. 4, PD 330, bar code 3106818-18 (Nov. 20, 2012); VASEP Rebuttal Surrogate Value Data at Ex. 7A ¶ 4, PD 368, bar code 3108726-04 (Dec. 4, 2012)). Commerce also discounted the notion that the IAS Data contains data of dead fish processed in the industry because it found the IAS publication explicitly excludes fish discarded for any reason and, where fish are processed, the quantities and values recorded are converted to initial live weight. Id. at 15 (citing CFA Surrogate Value Data at Ex. 4, PD 330, bar code 3106818-18 (Nov. 20, 2012)). In contrast, Commerce found the Bangladeshi DAM Data is undervalued by its inclusion of dead fish. Id. at 16. Commerce overlooked apparent differences in farming practices between Indonesia and Vietnam because it found pond production of pangasius hypophthal-mus represents the majority of pangasius production in both Vietnam and Indonesia. Id. at 16-17. Finally, Commerce minimized the impact of frozen pangasius fillet imported into Indonesia because the record evidence submitted by VASEP shows no causal relationship between such imports and the price of whole live fish in Indonesia. Id. at 17. Commerce found that the DAM data and the IAS Data are contemporaneous because both data sources cover the POR. Id. at 18-19. Commerce used both the 2011 and 2010 IAS publications to calculate the whole live fish surrogate value to ensure full POR coverage. Id. at 18. Commerce explained that the additional coverage arose because of its preference to have full coverage. Commerce also found the IAS Data had broader market average representation and a greater volume of pangasi-us production. Id at 19. Commerce also resolved that IAS Data is more reliable because of concerns that DAM fails to adequately vet its data. See id. Commerce has explained and supported its findings and assumptions regarding the superior specificity of IAS Data in comparison to Bangladeshi DAM Data in light of the detracting evidence the court directed it to consider on remand. Additionally, Commerce, as directed by the court, considered the contemporaneity of both data sources and determined that concerns with the DAM Data made the IAS Data the superior source. Therefore, Commerce reasonably determined that IAS Data is superior to Bangladeshi DAM Data for valuing whole-live fish, supporting the selection of Indonesia as the primary surrogate country. 3. Evaluation of Financial Statements In Vinh Hoan, the court held that Commerce relied on circular reasoning when it selected Indonesian PT Dharma Samudera Fishing Industries (“DSFI”) financial statements to value the respondent’s financial ratios over those of Bangladeshi companies, Apex Foods Limited (“Apex”) and Gemini Sea Food (“Gemini”). Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1311. Commerce’s reasoning was circular because it chose the DSFI statements based upon its primary surrogate country selection while, at the same time, appearing to rely upon the selection of the DSFI statements to support its primary surrogate country selection. Id. On remand, Commerce found the Indonesian financial statements from DSFI superior to the Bangladeshi alternatives because DSFI produces comparable merchandise, he., frozen fish fillets, whereas Apex and Gemini do not primarily produce frozen fish fillets. Remand Results 74. Therefore, because Commerce observed DSFI’s production was a closer match to that of respondents,. Commerce concluded the superiority of the Indonesian financial statements favored selecting Indonesia as the primary surrogate country. Id. at 74-75. Vinh Hoan does not challenge Commerce’s conclusion that the closer match of DSFI’s production experience to that of respondents favors selecting Indonesia as the primary surrogate country. See Vinh Hoan Comments on Draft Remand at 22-23; see also Remand Results 73. This conclusion is reasonable. 4. Evaluation of Non-Fish FOPs In Vinh Hoan, the court found that Commerce failed to evaluate all its selection criteria for non-fish FOPs, rendering its finding that Indonesian data is superior to Bangladeshi data to value non-fish FOPs unsupported by substantial evidence. See Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1309. In its remand results, Commerce evaluated each non-fish FOP that it relied on in support of its surrogate country selection' using all of its selection criteria. See Remand Results 19-27, 57-78. For labor, Commerce selected the Indonesian International Labor Organization Chapter 5B data from 2008 (“ILO Chapter 5B Data”) because Commerce found that the Indonesian data is more specific than the Bangladeshi alternative. Id. at 21-22, 75. With regard to frozen broken meat and fish oil, Commerce had only two surrogate value sources before it, which are both from Indonesia. Id. at 28-29, 65, 79-80. For fresh broken meat, foreign brokerage and handling, inland freight, rice husk, fish waste, fish belly, fish skin, and fish meal, Commerce concedes that it does not rely upon its selection of SV data to support its decision to select Indonesia as the primary surrogate country. Id. at 19, 60-61, 68-72, 78. Commerce argues that its SV data selections for sawdust and fish oil support its selection of Indonesia, but, as discussed below, the court, is remanding those selections for further consideration and explanation. 5. Weighing of Economic Comparability Against Data Considerations In Vinh Hoan, the court held that, in order to select Indonesia as its primary surrogate country, Commerce must weigh data considerations against differences in economic comparability that may have favored selecting Bangladesh. See Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1306. On remand, Commerce reasonably determined that significant concerns with Bangladeshi data sources outweigh the modest relative and absolute differences in per capita GNI between Vietnam and Indonesia. Commerce found that “although Bangladesh’s GNI is closer in absolute terms to Vietnam’s than is Indonesia’s GNI, ... data considerations outweigh the relatively modest differences in per capita GNI.” Remand Results 9. No party challenges the reasonableness of Commerce’s weighing of data considerations concerning both fish and non-fish FOPs as they relate to surrogate country selection. Rather, VA-SEP challenges the very premise that Commerce may engage in such a weighing in light of the fact that Indonesia’s 2011 GNI pushed it outside the range of GNIs on the OP List. See VASEP Comments 11. VASEP and Binh An argue that Commerce ignored its practice for selecting a primary surrogate country by failing to work through the criteria sequentially to exclude Indonesia on economic comparability grounds before considering data concerns. See VASEP Comments 11; Binh An Comments 1. However, as already discussed, despite the presence of 2011 GNI data on the record, Commerce reasonably found Indonesia economically comparable to Vietnam and a significant producer of comparable merchandise. Commerce’s practice permits it to select the country with the best factors data in such circumstances. See Policy Bulletin 04.1 at 4. Commerce weighed the relative economic comparability of Indonesia in light of its quality of data as compared to the other potential surrogate countries and reasonably selected Indonesia as the primary surrogate country. B. Consignment Sales/Use of Facts Available In Vinh Hoan, the court remanded Commerce’s determination to treat all. sales to one of Vinh Hoan’s customers as consignment sales. Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1323. In its remand results, Commerce reconsidered its decision, and found that “only some of the sales by Vinh Hoan’s customer were consignment sales.” Remand Results 42. Commerce further found that the sale arrangement continued from 2009 until February 2011, “at which point the two parties agreed that Vinh Hoan would make a one-time sale to its customer to purchase the remaining inventory.” Id. On remand, Commerce decided to treat only sales from Vinh Hoan’s customer that entered cold storage pursuant to a consignment arrangement as consignment sales. Id, Accordingly, on remand Commerce applied the “credit expenses and inventory carrying costs solely to Vinh Hoan’s consignment sales to the customer with which it had a consignment agreement.” Id. No party commented on or challenged Commerce’s decision on remand. Commerce has complied with the court’s order and its decision is reasonable. C. Adjustment to Normal Value to Reflect Glazing In Vinh Hoan, the court held that Commerce’s determination not to exclude glazing weight from the FOP usage ratio was not supported by substantial evidence. See Vinh Hoan, 39 CIT at - - -, 49 F.Supp.3d at 1323-24. In its remand results, Commerce reconsidered Vinh Hoan’s gross weight denominator, he., inclusive of glazing, for FOP usage ratios and found that it “should recalculate Vinh Hoan’s margin using the net weight denominator.” Remand Results 42. Commerce adjusted Vinh Hoan’s FOP database from a gross weight basis to a net weight basis. Id. To do so, Commerce reopened the record and “requested that Vinh Hoan submit a revised FOP database using the net quantity denominator that is on the record.” Id. at 44. Commerce used this revised database to calculate Vinh Hoan’s margin on a net weight basis on both the normal value and export price sides of its margin calculations. Id. Commerce considered the discrepancy between the reporting bases, and followed its practice to ensure an accurate comparison. See id. at 43-44. Therefore, Commerce’s determination is supported by substantial evidence. Vinh Hoan objects to Commerce’s approach on remand because it claims that the decision is unsupported by the record. Vinh Hoan Comments 17. Vinh Hoan argues that Commerce’s finding that Vinh Hoan reported its U.S. sales on a net weight basis is incorrect and that it did not sell any glazed products during the POR. Id. Defendant responds that Vinh Hoan failed to raise any arguments about whether, it reported sales on a net weight basis in its comments to the Draft Remand Re-determination. Defi’s Resp. Remand Comments 23. Therefore, Defendant argues Vinh Hoan has failed to exhaust its administrative remedies. “[T]he Court of International Trade shall, where appropriate, require the exhaustion of administrative remedies.” 28 U.S.C. § 2637(d). Exhaustion of administrative remedies is a doctrine that holds “that no one is entitled to judicial relief for a supposed or threatened injury until the prescribed administrative remedy has been exhausted.” Consol. Bearings Co. v. United States, 348 F.3d 997, 1003 (Fed.Cir.2003). The court generally “takes a ‘strict view’ of the requirement that parties exhaust their administrative remedies before [Commerce] in trade cases.” Corus Staal BV v. United States, 502 F.3d 1370, 1379 (Fed.Cir.2007). Here, despite the clear opportunity to do so in its comments to Commerce’s Draft Remand, Vinh Hoan failed to object to Commerce’s determination'. See Vinh Hoan Comments on Draft Remand. Therefore, the court does not address Vinh Hoaris arguments because it has failed to exhaust its administrative remedies, and Commerce’s remand redetermination, on this issue is sustained. D. Fish Oil Byproduct Value Defendant requested a voluntary remand to reconsider its calculation of Vinh Hoaris fish oil byproduct offset. See Def.’s Resp. Pis.’ Mots. J. Upon Agency R. 79-80, May 22, 2014, ECF No. 77 (“Def.’s Resp. Br.”), In Vinh Hoan, the court granted Defendant’s request. See Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1322. Since the court granted Defendant’s remand request for Commerce to revisit its calculations, the court did not review Commerce’s determination to use a constructed value in lieu of import data to value Vinh Hoaris fish oil byproduct. The court addresses that issue now. In its remand results, Commerce found that the Indonesian GTA import data under' HTS 1504.20.9000, “Fish Fats & Oils & Their Fractions Exc Liver, Refined Or Not, not chemically Mod” is the best available information to value this by-product, and that a constructed value (“CV”) for fish oil is appropriate based upon record evidence related to the nature of Vinh Hoaris fish oil by-product. Remand Results 44. Vinh Hoan challenges Commerce’s determination to “cap” the value of fish oil by constructing a value. See Vinh Hoan Comments 7-10. Defendant responds that Commerce’s determination to apply a constructed value as a cap to value Vinh Hoaris fish oil byproduct was reasonable because: (1) the value of its fish oil import exceeded the value of the main input if the raw import data were used; and (2) the HTS category, by its terms, includes refined fish oil, and record evidence indicates the fish oil produced by Vinh Hoan is unrefined. Def.’s Resp. Remand Comments 25. While Commerce purports to be using Indonesian import data as a surrogate value for fish oil, it appears that what Commerce calls a “cap” is a rejection of the import data in favor of a constructed value. If it is, Commerce has not explained the reasonableness of that decision. The court remands this issue to Commerce for further consideration and explanation. In NME cases, Commerce obtains a normal value by valuing FOPs used to produce the subject merchandise and adding “an amount for general expenses and profit plus the cost of containers, coverings, and other expenses.” 19 U.S.C. § 1677b(c)(l). Commerce values the FOPs “based on the best available information regarding the values of such factors in a market economy country or countries.” Id. Commerce uses the same methodology to “offset production costs incurred by a respondent with the sale of by-products generated during the production process.” See Final Decision Memo at 34 (citing 19 U.S.C. § 1677b(c); Guangdong Chems. Imp. & Exp. Corp. v. United States, 30 CIT 1412, 1422, 460 F.Supp.2d 1365, 1373 (2006)); see also Tianjin Magnesium Int’l Co., v. United States, 34 CIT 980, 993, 722 F.Supp.2d 1322, 1336 (2010) (explaining that “[t]he antidumping statute does not prescribe a method for calculating byproduct offsets instead leaving the decision to the technical expertise of the Department.”). Commerce has broad discretion in deciding what constitutes the best available information because the term is not defined in the statute. See QVD Food Co. v. United States, 658 F.3d 1318, 1323 (Fed.Cir.2011). However, Commerce must ground its selection of the best available information in the overall purpose of the AD statute, calculating accurate dumping margins. See CS Wind Vietnam Co., Ltd. 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). On remand, Commerce “continues to find that Indonesian GTA import data under HTS 1504.20.9000, 'Fish Fats & Oils & Their Fractions Exc Liver, Refined Or Not, not chemically Mod’ is the best available information to value [Vinh Hoan’s fish oil byproduct].” Remand Results 44. However, Commerce continued to use a constructed value to. cap the Indonesian import data. Commerce explained the purpose of the cap is to remedy the fact that Indonesian import data includes refined fish oil in addition to the unrefined fish oil produced by Vinh Hoan. Id. at 80. Commerce found that Vinh Hoan’s fish oil was “only unrefined oil that is minimally processed, stored in a vat, and sold unpack-aged.” Id. (citing Verification of the Sales and Factors of Production Response of Vinh Hoan Corporation in the 2010-2011 Administrative Review of Certain Frozen Fish Fillets' from the Socialist Republic of Vietnam at 33, 39-40, PD 393, bar code 3110870-01 (Dec. 14, 2010)). Commerce concluded it would be illogical to value an unrefined byproduct from' unmanipulated Indonesian import data because doing so would result in a SV for Vinh Hoan’s unrefined fish oil ($3.10/kg) greater than the whole fish SV generated by Commerce ($1.79/kg). Id. at 79-80. However, Commerce has a prescribed methodology for valuing FOPs, including byproducts of selecting the best available data from possible sources using well established criteria such as specificity, representativeness and contemporaneity among others. See Policy Bulletin 04.1 at 4. Here, Commerce purports to be following this methodology, but it seems to have applied a constructed value that does not use the import category in any meaningful way. Commerce acknowledged that it has constructed a value for fish oil. Commerce called that constructed value calculation a “cap.” The notion of a cap implies that the product of the calculation will then be applied to existing import data for fish oil. Commerce’s description of its methodology appears to acknowledge this concept, see Remand Results 80, yet Commerce apparently did not apply the constructed value to existing import data on fish oil in any way. It seems to have simply - used the constructed value yielded by its calculation as the SV for fish oil. Commerce failed to explain why its change in methodology is reasonable. Although the court cannot say Commerce unreasonably determined that Vinh Hoan’s fish oil is a low value-added product, see id. at 30, Commerce has not explained why it is reasonable to depart from its normal methodology of choosing the best SV data source to value respondents’ fish oil byproduct. Commerce may have good reason to go beyond its stated methodology and construct a value, but Commerce needs to state what it is doing and explain why it is reasonable so that the court may review Commerce’s methodology and determination. The court cannot review whether Commerce’s choice of Indonesian import data is reasonable when it is unclear how, to what extent, or even if Commerce used Indonesian import data for fish oil in calculating a SV for Vinh Hoan’s fish oil. The court remands Commerce’s fish oil determination for further consideration and explanation and does not reach Vinh Hoan’s challenges with respect to Commerce’s calculations of the constructed value for fish oil. E. Offset Calculations for Byproducts In Vinh Hoan, the court granted Defendant’s request for a voluntary remand for Commerce to reconsider its calculations concerning Vinh Hoan’s byproduct offsets. See Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1322; see also Def.’s Resp. Br. 79-80. As a result, the court did not review CFA’s challenge to Commerce’s determination with respect to its byproduct offset calculation. The court addresses that issue now. On remand, Commerce continues to [[ ]] Vinh Hoan’s normal value because of a byproduct offset even though the costs of producing that byproduct [[ ]]. Instead of [[ ]] the costs to Vinh Hoan’s normal value or ignoring the number altogether, Commerce converted the [[ ]] number to a [[ ]], he., took an absolute value, and [[]] normal value. See Remand Results 82; see also Certain Frozen Fish Fillets from the Socialist Republic of Vietnam: Remand Redetermination of Antidumping Duty Administrative Review; 2010-2011: Final Re-determination Analysis Memorandum for Vinh Hoan Corporation at Attach. I, CD 4, bar code 3295865-01 (Aug. 3, 2015). Commerce has failed to provide a reasonable explanation for using an absolute value, which had the effect of [[ ]]. Defendant responds that Commerce’s calculation was reasonable and consistent with its practice to offset a byproduct’s commercial value by its production costs. Def.’s Resp. Remand Comments at. 30 (citing Guangdong Chems. Imp. & Exp. Corp., 30 CIT at 1422, 460 F.Supp.2d at 1373). Commerce does not contest that Vinh Hoan’s [[ ]], but its only response to CFA’s challenge is that Vinh Hoan’s actual costs must be reflected in its byproduct offset calculation. See Remand Results 82. The court does not find this reasoning persuasive. On remand, Commerce must reconsider its byproduct offset calculation or provide a reasonable explanation why granting such an offset is reasonable in such circumstances. II. Reserved Issues Prior to remand, plaintiffs filed Rule 56.2 motions challenging Commerce’s selection of SV data to value respondents’ labor, sawdust, rice husk, financial ratios, including “freight-in” for the selling, general and administrative (“SG&A”) expense ratio, inland freight and brokerage and handling, and byproducts produced by Vinh Hoan, including frozen broken meat, fresh broken meat, and fish waste byproducts. See Mem. Law Supp. Vinh Hoan Corporation’s Mot. J. Upon Agency R. 19-50, Nov. 14, 2013, ECF No. 39; Errata Memo. Vinh Hoan Corporation’s Mem. Supp. 56.2 Mot., Nov. 21, 2013, ECF No. 53 (collectively “Vinh Hoan Br.”); Mem. Law Supp. PL’s Rule 56.2 Mot. J. Upon Agency R. 57-61, Nov. 14, 2013, ECF No. 37 (“VASEP Br.”); Mem. P. & A. Supp. Anvifish Joint Stock Company and Vinh Quang Fisheries Corporation for J. Upon Agency R. 26-33, Nov. 14, 2013, ECF No. 42 (“Anvifish & Vinh Quang Br.”); Binh An Mot. In Vinh Hoan, the court noted that Commerce’s consideration of its primary surrogate country selection could impact Commerce’s analysis for all these issues. Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1321. Therefore, the court reserved judgment on these issues until after remand. See id. The court now addresses these issues. A. Labor In its preliminary’ results, Commerce valued labor using 2011 labor wage rate data for fishery workers in Bangladesh published by the Bangladeshi Bureau of Statistics Data. Prelim. Results, 77 Fed. Reg. at 56,185. In its final determination, Commerce valued labor using ILO Chapter 5B Data from Indonesia. Final Decision Memo at 30-31. Vinh Hoan and VA-SEP challenge Commerce’s selection of ILO Chapter 5B Data as the best available information to value respondents’ labor. Commerce reasonably selected ILO Chapter 5B Data to value respondents’ labor FOP. Commerce found the Indonesian data is specific and from the primary surrogate country. Id. at 30. Commerce found that ILO Chapter 5B Data is specific to Vinh Hoan’s labor because “the explanatory notes for subclassification 15 of the ISIC-Revision 3 Standard ... specifically state that the category includes the processing and preservation of fish and fish products.” Id. While Vinh Hoan speculates that the inclusion of labor data from other food-related industries may not render the ILO Chapter 5B Data sufficiently specific, Vinh Hoan Br. 45, it cites no record evidence that such labor data has significantly different pricing from labor within the fish processing industry. Commerce did not follow its normal practice of using ILO Chapter 6A Data because no such data was on the record. Final Decision Memo at 30. While Commerce acknowledged that the ILO Chapter 5B Data is not contemporaneous, it found the ILO Chapter 5B Data otherwise satisfies the balance of its surrogate value criteria. Id. at 30-31. Commerce noted that no other source comported with its practice of selecting labor SV data because neither Philippine nor Bangladeshi sources are from the primary surrogate country. Therefore, Commerce’s determination was reasonable. B. Energy Inputs: Saw Dust and Rice Husk 1. Exhaustion of Administrative Remedies Vinh Hoan argues that Commerce improperly valued respondents’ sawdust FOP using Indonesian GTA import data under HTS 4401.30 which covers “Sawdust and Wood Waste and Scrap.” Vinh Hoan Br. 19-26. Vinh Hoan also argues that Commerce improperly valued rice husk using Indonesian GTA import data under HTS 1213.00 which covers “Cereal Straw and Husks, Unprepared, Whether or Not Chopped, Ground, Pressed or in the Form of Pellets.” Vinh Hoan Br. 26-33. Defendant argues that Vinh Hoan failed to exhaust its administrative remedies regarding the values of these inputs. Def.’s Resp. Br. 53-54. The court finds it is not appropriate to require Vinh Hoan to exhaust these arguments before the agency. Thé overarching purpose of the exhaustion doctrine is to “allow[ ] the agency to apply its expertise, rectify administrative mistakes, and compile a record adequate for judicial review—advancing the twin purposes of protecting administrative agency authority and promoting judicial efficiency.” Carpenter Tech. Corp. v. United States, 30 CIT 1373, 1374-75, 452 F.Supp.2d 1344, 1346 (2006) (citing Woodford v. Ngo, 548 U.S. 81, 88-90, 126 S.Ct. 2378, 165 L.Ed.2d 368 (2006)). Nonetheless, the Court of Appeals for the Federal Circuit has consistently held that the application of exhaustion principles in trade cases is exercised with a measure of discretion by the Court. See, e.g., Corus Staal, 502 F.3d at 1381; Norsk Hydro Canada, Inc. v. United States, 472 F.3d 1347, 1356 n. 17 (Fed.Cir.2006); Consol. Bearings, 348 F.3d at 1003. Requiring a party to exhaust administrative remedies may not be appropriate where doing so would require it to speculate as to one of many courses the agency might take. Requiring such speculation would not promote administrative efficiency. Here, in its preliminary results, Commerce valued sawdust and rice husk using import data from Bangladesh and the Philippines, respectively. See 8th Administrative Review, and Aligned 9th New Shipper Reviews, of Certain Frozen Fish Fillets from the Socialist Republic of Vietnam: Surrogate Values for the Preliminary Results at 5, PD 469, bar code 3137856-01 (Aug. 30, 2012) (“Prelim. Surrogate Value Memo”). With regard to sawdust, Vinh Hoan raised concerns with the specificity and reliability of 2006 UN Comtrade data from Bangladesh under HTS 4401.30. See Vinh Hoan General Issues Case Brief at 5-7, PD 400, bar code 3111845-01 (Dec. 21, 2012) (“Vinh Hoan General Case Br.”). In addition, Vinh Hoan cited several CBP rulings of value-added products classified under the tariff heading it placed on the record, which it contended demonstrated that the heading would not “accurately apply to the simple sawdust used by Respondents.” Id. at 5-6. In light of the fact that Commerce changed its surrogate country selection and its selected data souree between its preliminary and final determinations, the court does not require any more of Vinh Hoan at the administrative level to preserve its argument. Commerce was aware of Vinh Hoan’s specificity-driven objections to this import data under HTS heading, which are the very same objections raised here. Commerce could have addressed these arguments in its final determination-, but it did not. Likewise for rice husk, Vinh Hoan could not be expected to speculate whether Commerce might change course between its preliminary and final results. Vinh Hoan had no objection to Commerce’s determination in the preliminary results and it had no notice that Commerce’s chosen source was even under consideration before Commerce’s final determination. Vinh Hoan made all the arguments it could be expected to make before Commerce in its case brief. Therefore, it is not appropriate to require Vinh Hoan to exhaust its arguments before the agency before making them here. 2. Sawdust Commerce’s selection of Indonesian import data under HTS 4401.30 to value respondents’ sawdust FOP is not supported by substantial evidence. Commerce failed to respond to arguments and record evidence that significantly detracts from its determination that Indonesian import data is specific and reliable. Vinh Hoan placed several Customs Rulings on the record with respect to HTS 4401.30 that show that the heading includes higher value added products. Vinh Hoan also demonstrates that the values contained within the HTS that Commerce used in its SV calculations range from $0.29 per kilogram to $27.23 per kilogram. See Vinh Hoan Br. 22, Attach. 3 (derived from 8th Administrative Review, and Aligned 9th New Shipper Reviews, of Certain Frozen Fish Fillets from the Socialist Republic of Vietnam: Surrogate Values for the Final Results at Ex. 1, PD 436, bar code 3124119-01 (Mar. 13, 2013) (“Final Surrogate Value Memo”)). On remand, it must do so. Both Commerce and Defendant rely heavily on Commerce’s regulatory preference to choose data from a primary surrogate country to support Commerce’s selection of Indonesian import data to value sawdust. See Final Decision Memo at 32; Def.’s Resp. Br. 64. Commerce’s regulation provides that it “normally will value all factors in a single surrogate country.” 19 C.F.R. § 351.408(c)(2). Despite this regulatory preference, the data from the primary surrogate country must also meet Commerce’s stated data selection criteria. Commerce’s explanation that the HTS heading includes “Sawdust” fails to address record evidence that the import data covered other materials and possibly higher value-added materials. Elsewhere in this review, Commerce rejected finding import data specific where it includes data for merchandise other than the input used by respondents. See, e.g„ Final Decision Memo at 40 (concluding the proposed HTS data set for fresh broken fish fillet included “whole unbroken fish fillets”). In light of the record data indicating that nonspecific merchandise may have rendered the HTS category nonspecific, Commerce cannot simply rely upon the fact that the word “sawdust” is in the heading to conclude the data source is specific and not aberrational. 3. Rice Husk Vinh Hoan argues that Commerce’s selection of Indonesian import data under HTS 1213.00 to value rice husk is not specific because the import category is overly broad and contains aberrational values. Vinh Hoan Br. 27-28. Defendant responds only with its exhaustion arguments. Def.’s Resp. Br. 67. The court finds Commerce’s selection of Indonesian import data to value rice husk is not supported by substantial evidence because Commerce failed to address evidence that detracted from its finding that Indonesian import data is specific and non-aberrational. Vinh Hoan points to record evidence suggesting that the prices in the Indonesian import category are aberrational. For example, Vinh Hoan' notes that Commerce’s SV selection resulted in a value of $10.03 per kilogram for rice husk. Vinh Hoan Br. 28-29. Vinh Hoan also notes that the record contained price quotes from two Bangladeshi companies that are specific, showing values ranging from $0.18-$0.19 per kilogram and $0.10-$0.12 per kilogram, respectively. See id. at 30 (citing VASEP Resubmission of Surrogate Value Submission of Nov. 20, 2012 at Exs. 2B-2C, PD 404-405, bar codes 3112136-01-02 (Dec. 26, 2012)). Vinh Hoan also notes that rice husk, like sawdust, is used by respondents as a fuel source in the production of its fish oil and fish meal byproducts. Id. at 26 (citing Vinh Hoan Corporation—Section D Questionnaire Response at 37, PD 62, bar code 3049396-01 (Jan. 3, 2012) (“Vinh Hoan Section D Response”)). Vinh Hoan argues that the SV assigned by Commerce, which represented approximately 11 percent of the normal value of the subject merchandise, does not reflect the minor role it played in its byproduct production process. Id. at 30-31. Moreover, Vinh Hoan argues the Philippine import data in the same HTS category used by Commerce in its preliminary determination resulted in a value of $2.06 per kilogram. Id. at 30 (citing Prelim. Surrogate Value Memo at 5). Vinh Hoan also argues that the Indonesian value is almost five times higher than the value used in Commerce’s preliminary determination. Id. Vinh Hoan argues that this large an increase cannot logically be attributable solely to the change in surrogate -country, but must be attributable to aberrational data or non-specific imports included within the data. Id. Commerce did not address this record evidence. On remand, it must do so. While Commerce may rely on its regulatory preference if the data from the primary surrogate country otherwise meets its criteria, Commerce has not explained why its conclusion that the import data is specific and not aberrational is reasonable in light of this detracting evidence raised by Vinh Hoan. C. Financial Ratios 1. Selection of Financial Statements Anvifish and Vinh Quang chal-lénge Commerce’s selection of Indonesian seafood processor DSFI’s 2011 financial statements to value its financial ratios because they are unreliable and unrepresentative. Anvifish & Vinh Quang Br. 20. Defendant counters that Commerce’s selection of DSFI’s financial statements is supported by substantial evidence. Def.’s Resp. Br. 73-74. The court determines that Commerce’s selection of 2011 financial statements of Indonesian seafood processor DSFI is supported by substantial evidence. Commerce’s practice is to select financial statements by using data from a market economy surrogate company gathered from producers of identical or comparable merchandise in the surrogate country. Final Decision Memo at 28. Commerce applies a three-part test to considering what constitutes comparable merchandise, evaluating:, (1) physical characteristics; (2) end uses; and (3) production processes. Id. Commerce found that DSFI’s 2011 financial statements are contemporaneous, complete, publicly available, from the primary surrogate country, and that the company manufactures merchandise comparable to subject merchandise. Id. at 29. Commerce concluded the company produces'comparable merchandise'because it is a fish' producer. Id. Although Commerce recognized that VASEP and Vinh Hoan had objected that DSFI is not a producer of comparable merchandise because it processes ocean fish, Commerce reasonably concluded its activities are comparable to respondents’ because, like respondents, it processes fresh fish. See id. In its final determination, Commerce concluded that the financial statements of Indonesian company CP Proteinprima are less contemporaneous since these financial statements are from 2007. Id. Commerce also concluded that surrogate financial statements from Bangladeshi and Philippine companies are not the best available information because the DSFI financial statements meet its SV selection criteria and are from the primary surrogate country. At the same time, however, Commerce had also relied upon its selection of the DSFI financial statements to support its surrogate country selection. Id. at 30. In Vinh Hoan, the court instructed Commerce that it could not base its primary surrogate country decision in part on its selection of surrogate financial statements and base its selection of financial statements on its primary surrogate country selection. See Vinh Hoan, 39 CIT at -, 49 F.Supp.3d at 1311. The court reserved review of whether the DSFI statements are the best information available until after Commerce reconsiders its primary surrogate country selection. Id. The court instructed that “Commerce must compare financial statements in the first instance.” Id. As discussed, Commerce found in its remand results that DSFI’s financial statements are the best available information and support the selection of Indonesia as the primary surrogate country. Remand Results 74-75. Anvifish and Vinh Quang argued before Commerce that surrogate financial statements from Apex and Gemini are the best available information because DSFI is not a comparable business and was suffering financial difficulties during the POR. See Final Decision Memo at 28. Commerce specifically addressed these arguments in its final determination, finding that DSFI’s 2011 financial statements are comparable because DSFI produces fresh fish and that DSFI was profitable during the POR and its past financial issues do not impact the suitability of DSFI’s financial statements. Id. at 29. In its remand results, Commerce compared DSFI’s financial statements to those of Apex and Gemini, and, as already discussed, found DSFI’s production is more comparable to that of respondents because DSFI’s core business is frozen fish fillets whereas that of Apex and Gemini is frozen shrimp products. Remand Results 74. Therefore, Commerce reasonably selected 2011 DSFI financial statements as the best available information to value respondents’ financial ratios. Anvifish and Vinh Quang argue that Commerce ignored evidence of DSFI’s poor financial health, including the liabilities still owed during the POR as a result of a bankruptcy in the fiscal year from 2010 through 2011. Anvifish & Vinh Quang Br. 21. Anvifish and Vinh Quang further argue that this bankruptcy resulted in substantial loan and credit restructuring, which undermined Commerce’s conclusion that DSFI was profitable and comparable to respondents’ experience. Id. Yet, Anvifish and Vinh Quang point to no record evidence undermining Commerce’s findings regarding profitability or comparability of the companies’ experiences. Therefore, Commerce’s conclusions are reasonable. Anvifish and Vinh Quang further argue that DSFI’s financial statements are unreliable for purposes of obtaining accurate surrogate financial ratios because “DSFI is. a large, consolidated enterprise with many subsidiaries, some of which are shown to be engaged in fishing operations (marine fishing only) ... [and] DSFI engages in fishing and processing of marine fish (octopus, cuttlefish, tuna, snapper and grouper).” Anvifish & Vinh Quang Br. 22 (citing CFA Surrogate Value Comments , at Ex. 36, PD 155-158, bar codes 3076948-01-04 (May 24, 2012) (“CFA Surrogate Value Comments”)). Anvifish and Vinh Quang argue that such differences “necessarily result in different overhead; [SG&A]; and profit experiences.” Id However, Anvifish and Vinh Quang’s claims about these differences in production processes, and any potential effects upon financial ratios, are not supported by any evidence in the record. In the absence of record evidence supporting their claims of the effects these differences upon financial ratios of DSFI or a similarly situated company, Commerce’s conclusions are reasonable. Therefore, Commerce has compared the available financial statements as instructed by the court and has reasonably selected DSFI’s financial statements as the best available information. 2. “Freight-In” Expenses in SG&A Vinh Hoan challenges Commerce’s inclusion of “freight-in” expenses within respondents’ SG&A expensé ■ ratio. Vinh Hoan Br. 47-48. Defendant argues that Commerce reasonably included these costs in SG&A expenses. Def.’s Resp. Br. ’76. The court agrees with Defendant. • Commerce included the “freight-in” expenses in SG&A because this expense is listed under SG&A in DSFI’s financial statements. Final Surrogate Value Memo at 7, 7 n.28; Eighth Administrative Review and Aligned New Shipper Reviews of Certain Frozen Fish Fillets from the Socialist Republic of Vietnam: Ministerial Error Allegation Memo at 3, PD 466, bar code 3136028-01 (May 9, 2013); see also CFA Surrogate Value Comments at Ex. 36. Vinh Hoan claims the plain meaning of “freight-in” clearly refers to “the cost of transporting raw materials to the plant for use in the production process,” which it argues is included elsewhere in Commerce’s calculations.. Vinh Hoan Br. 48. Given that Vinh Hoan points to no record evidence supporting the notion that DSFI’s “freight-in” reflected the definition it advances, Commerce’s conclusion is reasonable. Vinh Hoan maintains that Commerce’s calculations count the same expenses twice, first within SG&A expenses and again as part of the total materials costs. Vinh Hoan Br. 49. In the alternative, Vinh Hoan argues that these “freight-in” expenses are already included as movement expenses.. Vinh Hoan Br. 49-50. Yet, Vinh Hoan points to no record evidence to support the notion that DSFI’s “freight-in” expense is already captured elsewhere either in DSFI’s financial statements or in Commerce’s calculations. Vinh Hoan’s argument relies upon its speculation as to general accounting practices within the industry. Accordingly, Commerce reasonably declined to exclude these expenses because it treated these expenses as DSFI did in its financial statements. D. Inland Freight and Brokerage and Handling Vinh Hoan challenges Commerce’s use of an assumed weight from the World Bank’s “Doing Business 2012: Indonesia” rather than the container weight on the record from Maersk to calculate respondents’ per-unit inland freight and brokerage and handling expenses. Vinh Hoan Br. 53-54. Defendant counters that Commerce “relied upon the weight (10,000 kg) and container size (20-foot container)” reported in the “Doing Business” report. Def.’s Resp. Br. 78. Commerce reasonably refused to adjust the container weight from the Indonesian data source to reflect that reported by Maersk. In its preliminary results, Commerce valued inland freight and brokerage and handling using the World Bank’s “Doing Business 2011: Bangladesh.” Prelim. Surrogate Value Memo at 7. Commerce found the report gathers information concerning the distance and cost to transport products in a 20-foot container from the largest city in Bangladesh to the nearest seaport. Id.; see also id. at Ex.l. Commerce calculated a per-unit surrogate inland freight and brokerage and handling rate using the weight of a full 20-foot standard container, as provided by Maersk. Id. at 7; see also id. at Ex. 1. The weight provided by Maersk for the preliminary results was 28,200 kilograms. Id. at Ex. 1. Using this weight, Commerce calculated a per-unit SV of inland freigh