Anti-dumping and Countervailing Program

OTTAWA, June 23, 2006

File No. 4214-12
AD1358

File No. 4218-21
CVD 118

DECISION

Pursuant to subsection 31(1) of the Special Import Measures Act, the President of the Canada Border Services Agency initiated an investigation on June 8, 2006, respecting the alleged injurious dumping of certain copper pipe fittings originating in or exported from the United States of America, the Republic of Korea and the People’s Republic of China and the alleged injurious subsidization of certain copper pipe fittings originating in or exported from the People’s Republic of China.

TABLE OF CONTENTS

Summary
Background
Interested Partie Product Information Classification of Imports
Like Goods
Canadian Industry
Standing
The Canadian Market
Evidence of Dumping Negligibility and Insignificance of Dumping
Evidence of Subsidizing Estimated Amount of Subsidies
Amount of Subsidy and Volume of Subsidized Goods
Negligibility and Insignificance - Subsidy
Evidence of Injury
Non-Dumping/Subsidy Factors
Threat of Injury
Conclusion
Consultations
Scope of the Investigation
Future Action
Retroactive Duty on Massive Importations
Undertakings
Publication
Information
Appendix 1 – List of Subject Goods

Summary

1. On April 25, 2006, the Canada Border Services Agency (CBSA) received a complaint from Cello Products Inc. (Cello) of Cambridge, Ontario, concerning the alleged injurious dumping of certain copper pipe fittings originating in or exported from the United States of America (United States) and produced by or on behalf of Elkhart Products Corporation, Lee Brass Company, Nibco Inc. and Mueller Industries Inc., their respective affiliates, successors and assigns, the Republic of Korea (Korea) and the People’s Republic of China (China) and the alleged injurious subsidizing of certain copper pipe fittings originating in or exported from China.  The CBSA informed Cello on May 9, 2006, pursuant to subsection 32(1) of the Special Import Measures Act (SIMA)¹ that the complaint was properly documented.  On the same date, the CBSA notified the governments of the United States, Korea, and China that a properly documented complaint concerning the subject goods had been received.  As well, the government of China (GOC) was provided with the non-confidential version of the subsidy portion of the complaint.
   
   
2. The complainant provided evidence that the subject goods have been dumped and that copper pipe fittings from China has been subsidized.  Further, the evidence discloses a reasonable indication that the dumping and subsidizing have caused injury and are threatening to cause injury to the Canadian industry producing these goods.
   
   
3. On June 8, 2006, the President of the CBSA:
   
   
   • initiated a dumping investigation pursuant to subsection 31(1) of SIMA, with respect to certain copper pipe fittings from the United States, Korea and China; and
     
     
   • initiated a subsidy investigation pursuant to subsection 31(1) of SIMA, with respect to certain copper pipe fittings from China.
     
     
4. As China is listed under Part I of the DAC List of Aid Recipients² maintained by the Organization for Economic Co-operation and Development, the CBSA will extend developing country status to China for purposes of the subsidy portion of this investigation only.  Therefore, China is eligible for the higher insignificance (amount of subsidy) and negligibility (volume of subsidized goods) thresholds for the termination of a subsidy investigation involving a developing country.

Background

5. This is the second investigation that the CBSA has conducted concerning copper pipe fittings.  The first case that was conducted by the CBSA (then Revenue Canada Customs
   and Excise) in 1993³, resulted in a final determination of dumping and a positive injury finding by the Canadian International Trade Tribunal (Tribunal) concerning certain copper pipe fittings originating in or exported from the United States and produced by or on behalf of Elkhart, Nibco and Mueller, their successors and assigns⁴.  The finding was rescinded on October 16, 1998⁵.  In its decision to rescind it’s finding, the Tribunal indicated that there was a likelihood of resumed dumping of copper pipe fittings in Canada but it was not likely to cause material injury to the domestic industry.

Interested Parties

Complainants

6. The complainant, Cello, is the major Canadian producer of certain copper pipe fittings.  The complainant’s address is:

   Cello Products Inc.
   210 Avenue Road
   P.O.Box 37
   Cambridge, Ontario
   N1R 5S9

Exporters

7. The CBSA has identified 43 potential exporters of the subject goods from customs import documentation.

Importers

8. The CBSA has identified 77 potential importers of the subject goods from customs import documentation.

Product Information

Definition

9. For the purpose of this investigation, the subject goods are defined as:

   Solder joint pressure pipe fittings and solder joint drainage, waste and vent pipe fittings, made of cast copper alloy, wrought copper alloy or wrought copper, for use in heating, plumbing, air conditioning and refrigeration applications, originating in or exported from the United States of America, the Republic of Korea and the People’s Republic of China, restricted to the products enumerated in Appendix 1. 

10. Appendix 1 contains a specific listing of copper pipe fittings, that constitute subject goods, broken down into the following categories: Adaptors (female, male and other); Bushings; Couplings; Elbows; Flanges; Pressure Tees; Unions; P/S traps; DWV TY’s; DWV Y’s; and Caps and Cleanouts.
    
    
11. For further clarity, Appendix 1 contains explanatory notes covering size (i.e., metric vs. imperial) as well as nominal vs. inside diameter and type of fitting (i.e., cast vs. wrought).  Appendix 1 also contains an Abbreviation Chart used in the list of models of copper pipe fittings.

Additional Product Information

12. Solder joint copper pipe fittings are used to connect copper pipes, tubes or other fittings to one another.  The connections are made by fitting two pieces together and heating the ends of the tubing and fitting, and filling the gap between the two with melted solder which solidifies on cooling to form a strong, leakproof connection.  The fittings can also be used to connect copper tubing to other metal systems by use of threaded fittings.  However, at least one end of a fitting is always soldered.  Finally, the connection can also be made using epoxy or similar gluing methods.
    
    
13. Solder joint copper pipe pressure fittings may be used in conveying liquids (e.g. potable water), gases and air under pressure in residential, industrial, commercial and institutional buildings.  Copper pipe pressure fittings are also used in a variety of air-conditioning and refrigeration (ACR) applications.  The types of fittings used in air conditioning applications are typically identified by reference to their outside diameters, whereas the same fittings used in non-air conditioning applications such as plumbing and heating are typically identified by reference to their inside or “nominal” diameters.  Apart from the reference to diameter, a fitting for an air conditioning application is the same as a fitting for a non-air conditioning application.
    
    
14. Solder joint copper pipe drainage, waste and vent (DWV) fittings are used primarily to convey waste from buildings to sewers and for venting purposes under low-pressure conditions.
    
    
15. Female and male adaptors are used to connect a copper tube to an iron pipe or a water heater.  Other adapters include ferrules that are used to join a copper tube to a cast-iron pipe in older installations.  Bushings are used to reduce the diameter of other fittings.  Couplings are used to join tubes of either the same size or two different sizes to make longer runs through buildings.  Elbows are used to change the direction of a copper tube by either 45° or 90°.  Flanges and unions are used to provide a connection that can be either unscrewed or unbolted for maintenance or repairs.  Tees are used to allow a copper line to be split into two separate lines.  There are pressure tees and drainage tees; TY’s (90°) and Y’s (45°).  Traps are used to trap water to prevent sewer gases from coming back into a building.  Cleanouts are used to provide access to drainage systems in case of blockage; and caps are removable plugs used to permit inspection and access for the purpose of clearing an obstruction.
    
    
16. Solder joint pipe fittings manufactured in Canada and the United States are made to the standards of the ASME (American Society of Mechanical Engineers) / ANSI (American National Standards Institute) and to the standards of the MSS (Manufacturers Standardization Society).

Production Process

17. Copper pipe fittings may be either cast brass, produced from copper alloy ingots and recycled cast brass scrap, or wrought copper, produced from extruded copper tube or hollows.
    
    
18. Cast fittings are produced in Canada by Cello using the green-sand casting process.  Each fitting has a wooden, plastic or aluminum pattern, which is close to the same size and shape as the finished casting.  A sand core for each fitting is made, using an aluminum or steel core box.  Sand cores are made from resin-coated sand that is hardened to shape by heating in gas fired core machines.  There are other methods of making sand cores, including sand mixed with air-cured materials, which form solid sand cores without heat.  The sand core forms the inside shape and surface of the fitting when the liquid brass is poured into the mould.  A mould is made by filling a form flask with conditioned sand, binder and water to give it strength, and by pressing the pattern into it.  This leaves a hollow impression that forms the outside of the casting.  The sand core is set into this hollow impression once the pattern is removed and the mould is closed.  Molten brass at the proper temperature is then poured into the mould through a hollow sprue that leads to runners and gates and finally into the space between the outside surface of the core and the inside surface of the conditioned sand mould.  The metal is allowed to cool and solidify, forming the raw casting.  The resultant raw casting is removed from the mould by vibration and is cleaned and conditioned in preparation for machining.
    
    
19. Castings are machined on special-purpose reaming machines, turret lathes or computer numerical control (“CNC”) lathes.  All cast fittings have at least one end reamed to allow a copper tube to be joined to it using one of the joining methods described above.  The other end or ends (tees) are either reamed, tapped (internally threaded) or has a male thread cut onto it.
    
    
20. Wrought fittings, the most prevalent types being tees, couplings, elbows and adaptors, are produced in a variety of ways.
    
    
21. Wrought tees are produced from lengths of heat-treated (fully annealed or softened) wrought copper tubing that is cut into short slug lengths.  After the tubing is cut, the resulting tee slugs are compressed in a hydraulic press, forming the tee branch.  Another machine then decaps the branches and sizes the three ends to make a finished product that is ready for cleaning and packaging.
22. Straight couplings (e.g. ¾-in. x ¾-in.) are in a finished state after they have been cut from the copper tubing.  Reducing couplings and bushings are produced from straight-cut slugs.  A specialty machine expands one end of the straight-cut slug to produce a finished fitting.  Alternatively, one end is either hit down or spun down to a smaller size to form a reducing coupling or bushing.
    
    
23. Elbows are produced from lengths of heat-treated copper tubing, using special bending equipment that bends the elbows to the proper degree (45º or 90º) and saw cuts the elbows.  Another machine then swedges (expands) the ends to create uniform cup dimensions.  The ends of the elbows are then "faced" to provide a square soldering cup.
    
    
24. Female and male wrought copper adapters can be made from machining hollow octagons or hexagons on CNC lathes or by hitting heavy wall tubing or solid copper rods on hydraulic presses.

Classification of Imports

25. The subject goods are properly classified in Chapter 74 of the Customs Tariff under the following Harmonized System (HS) classification numbers:
    
    

    HS 74.12	Copper tube or pipe fittings (for example, couplings, elbows, sleeves).
    7412.10.00	of refined copper
    7412.10.00.11	Pressure type: Wrought
    7412.10.00.19	Pressure type: Other
    7412.10.00.20	Drainage type
    7412.20.00	of copper alloys
    7412.20.00.11	Pressure type: Forged
    7412.20.00.12	Pressure type: Cast
    7412.20.00.19	Pressure type: Other
    7412.20.00.20	Drainage type

Like Goods

26. Like goods, in relation to any other goods, are goods that are identical in all respects or, in the absence of identical goods, are goods of which the uses and other characteristics closely resemble those of the other goods.
    
    
27. Copper pipe fittings, identified in Appendix 1, compete directly with and have the same end uses as the subject goods imported from the named countries.  The goods produced in Canada and the subject goods are completely substitutable.  Therefore, the CBSA has concluded that copper pipe fittings produced by the Canadian industry constitute like goods to the subject goods.
    
    
28. While the subject goods include copper pipe fittings for pressure and drainage applications and, within each group, wrought and cast fittings, they all share common materials, manufacturing processes, physical characteristics, functional uses, end uses and distribution and marketing methods.  For purposes of the investigation, the CBSA holds that the subject goods comprise a single class of goods.
    
    
29. In 1993, the Tribunal concluded that cast and wrought fittings comprised a single class of goods.⁶ In 1995, a Binational Panel upheld the Tribunal’s decision that all copper pipe fittings comprised a single class of goods.⁷  In its inquiry concerning the anti-dumping investigation of carbon steel pipe nipples, threaded couplings and adaptor fittings from China, the Tribunal based its decision to treat all subject goods as a single class of goods on the same rational used in its 1993 finding on copper pipe fittings.⁸

Canadian Industry

30. Cello was founded in 1946 in Cambridge, Ontario as a manufacturer of cast copper alloy solder joint pipe fittings.  Wrought copper and wrought copper alloy solder joint pipe fittings were added to the product line in the 1960's.  Today, Cello produces an extensive line of wrought and cast brass copper pipe fittings, in sizes ranging from ⅛-in. to 8-in.  In addition to manufacturing the goods subject to the complaint, Cello manufactures brass fittings and flanges.  Cello employs approximately 75 people.
    
    
31. Bow Plumbing Group Inc. (Bow) was founded in 1949 as a manufacturer of various plastic products including some specialty plumbing items.  Bow began production of wrought copper and wrought copper alloy solder joint pipe fittings in 1991 when the company acquired the assets of Emco Canada, a former manufacturer of copper pipe fittings.
    
    
32. A third Canadian producer, Streamline Copper & Brass Ltd., Strathroy, Ontario, ceased production in January 2002.
    
    
33. In order to verify that Cello and Bow are the only manufacturers of cast copper alloy, wrought copper and wrought copper alloy solder joint pipe fittings for use in heating, plumbing, air conditioning and refrigeration applications in Canada, the CBSA referred to a number of industry and trade association sources for Canada and North America⁹.  The CBSA’s research did not disclose any other Canadian manufacturers of the products.

Standing

34. SIMA requires that the following conditions be met in order to initiate an investigation:
    
    
    • the complaint is supported by domestic manufacturers whose production represents more than 50% of the total production of like goods by those domestic manufacturers who express either support for or opposition to the complaint; and
      
      
    • the production of the domestic manufacturers who support the complaint represents 25% or more of the total production of like goods by the domestic industry.
      
      
35. For the consideration of standing under SIMA, domestic industry means the domestic producers as a whole of the like goods except that, if a domestic producer is related to an exporter or importer of allegedly dumped or subsidized goods, or is an importer of such goods, “domestic industry” may be interpreted as meaning the rest of those domestic producers.  Cello has stated that neither the complainant nor Bow are related to importers or exporters of the subject goods.
    
    
36. Based on an analysis of information provided in the complaint, as well as information provided with respect to the only other Canadian producer, Bow Plumbing Group Inc, the CBSA has estimated that the complaint is supported by domestic manufacturers whose production represents more than 50% of Canadian production of the like goods.  The CBSA is satisfied that the standing requirements of subsection 31(2) of SIMA have been met.

The Canadian Market

37. Cello provided confidential data for its sales of like goods from its own production from 2002 to 2005 and for the periods July to December 2004 and 2005.  Cello provided similar information that it received from Bow.  As Cello and Bow are the only manufacturers in Canada it is not possible to provide the companies’ Canadian sales in this public document without divulging confidential information.
    
    
38. Cello submitted import data for the same period from Industry Canada’s Strategis – Trade Data Online¹⁰ for the HS 74.12.  Strategis publishes data only on the value of imports under the HS 74.12.  Cello made adjustments to the Strategis data to eliminate data for other possible products included in the tariff item.
    
    
39. The CBSA reviewed actual import data from customs documentation for copper pipe fittings obtained from the CBSA Customs Commercial System database, through the Facility for Information Retrieval Management (FIRM) for the period from 2002 to the first quarter of 2006, and from a sampling of Customs entry documentation from 2005.  On the basis of its analysis, the CBSA observed that Cello had overstated the value of imports and therefore concluded that the CBSA’s estimate of the value of imports was more appropriate.  The table presented below provides the CBSA estimate of the value of imports of the subject goods for the years 2002 to 2005, inclusive as well as the first quarters of 2005 and 2006.
    
    

40. The CBSA’s analysis of imports revealed errors made by importers reporting the volume of goods.  While the unit of measure required for this classification number is kilograms, the FIRM data revealed many instances for Korea and China, and to a lesser degree for the United States, where the volume of subject goods was measured in terms of number of pieces, cases and cartons.  Consequently, it was necessary for the CBSA to adjust the import data to provide a more reasonable estimate of the volume of imports.  The table presented below provides the CBSA’s estimate of the volume of imports of the subject goods for the years 2002 to 2005, inclusive as well as the first quarters of 2005 and 2006.

41. The CBSA’s analysis of import data appears to support the complainant’s claims that imports of subject goods from Korea and China have been increasing and are substantial in nature.  The CBSA’s analysis of import data for the United States shows a marginal decline from 2002 through 2005, but also discloses an increase between the first quarters of 2005 and 2006.  However, based on the fact that imports under the HS 74.12 include non-subject goods, the CBSA presents these results with a note of caution.  The anti-dumping investigation will allow the CBSA to refine its estimate of import data with respect to all three of the named countries.

Evidence of Dumping

42. The complainant alleges that certain copper pipe fittings from the named countries have been injuriously dumped into Canada.  Dumping occurs when the export price of the goods is below the normal value of the goods sold to importers in Canada.
    
    
43. Normal values are generally based on the domestic selling price of the goods in the country of export, or on the full cost of the goods including general, selling and administrative (GS&A) expenses, plus a reasonable amount for profits.  The export price of imported goods is generally determined as being the lesser of the importer’s purchase price or the exporter’s selling price to Canada, less all charges and expenses resulting from the exportation of the goods.
    
    
44. The complainant’s allegations of dumping are based on a comparison of estimated normal values of the subject goods and estimated export prices to Canada.

Normal Values

United States

45. The complainant was unable to obtain information on domestic selling prices of the subject goods in the United States.  However, Cello indicated that in the United States market it routinely competes with the named exporters, and that it considers its own selling prices in the United States to be a reasonable indication of the selling prices of the named United States exporters in their domestic market.
    
    
46. The complainant estimated normal values for fourteen benchmark products in every two-month period of 2005.  These periods were January/February, March/April, May/June, July/August, September/October and November/December.  Cello provided pricing information for each two-month period in 2005 to reflect the rising cost of copper, the largest element of cost in copper fittings and ultimately the price of the final product.  Benchmark products were selected with a view to covering the spectrum of Cello’s product line (wrought pressure, wrought drainage, cast pressure, cast drainage) and including the major types of items (elbows, couplings, bushings, tees and adapters).  In order to estimate normal values conservatively, the complainant indicated that it attempted to use its lowest selling prices in the United States.  In estimating normal values, Cello deducted freight and export charges from its selling prices.  In addition, the complainant deducted an amount that represents the highest level of commission that it pays on sales in the United States.
    
    
47. Given Cello’s knowledge of the copper pipe fitting market and presence in the United States market, the CBSA considers Cello’s selling prices as an acceptable estimate for establishing normal values in the United States.

Korea

48. The complainant was unable to obtain information on domestic selling prices of the subject goods in Korea.  In the absence of such information, normal values could not be estimated on the basis of domestic sales, in accordance with section 15 of SIMA
    
    
49. Cello estimated normal values for ten benchmark products based on its costs of production as of the end of its 2005 fiscal year i.e., March 31, 2005.  Although benchmark products were selected on the same basis as that used to select benchmark products for the United States, the complainant estimated normal values for benchmark products for which it was able to estimate export prices.  In this instance, all ten benchmark products were wrought pressure fittings.  Cello estimated normal values in accordance with paragraph 19(b) of SIMA based on the complainant’s own cost of production with a downward adjustment of 50% in labour-related expenses associated with variable and fixed overhead costs to reflect lower wage rates in Korea.¹²  The complainant based amounts for GS&A expenses and profit on the 2004 financial results for a major Korean producer of the subject goods.  In addition, Cello provided raw material costs for each two-month period in 2005.
    
    
50. The CBSA considers it reasonable to use the complainant’s estimate of cost of production.  While the CBSA accepted Cello’s decision to use the Korean manufacturer’s financial results to estimate GS&A expenses and an amount for profit, it applied amounts for GS&A expenses and profit as a percentage of Cost of Goods Sold. ¹³  Finally, the CBSA used Cello’s raw material costs for each two-month period in 2005 to estimate normal values for all of 2005.

China

51. The complainant was unable to obtain information on domestic selling prices of the subject goods in China.  In the absence of such information, normal values could not be estimated on the basis of domestic sales, in accordance with section 15 of SIMA.
    
    
52. Cello estimated normal values for fifteen benchmark products as of March 31, 2005.  The benchmark products consisted of wrought pressure, cast pressure and cast drainage fittings.  Cello estimated normal values using the methodology described in paragraph 19(b) of SIMA based on the complainant’s own cost of production in 2005 for the benchmark products with a downward adjustment to labour costs to reflect lower wage rates in China. ¹⁴  The complainant used its own GS&A expenses as a proxy for Chinese GS&A expenses.  In the absence of any knowledge of the profit margin realized by Chinese manufacturers on sales of copper pipe fittings in their domestic market, Cello used a nominal amount equal to 5%.  Cello also provided raw material costs for each of the two-month periods in 2005.
    
    
53. The CBSA considers reasonable the complainant using its own cost of production with a downward adjustment to reflect lower wage rates in China.  However, the CBSA concluded that as GS&A expenses would also be lower in China relative to Canada, it would be more appropriate to estimate such expenses based on the 2004 financial results for the Korean manufacturer.  On the basis that Cello’s usage of a 5% profit was similar to the amount used to estimate normal values for Korea, the CBSA accepted Cello’s estimate of 5% for purposes of estimating normal values for China.
    
    

Export Prices

United States

54. Cello used its own selling prices to a Canadian customer to estimate the export prices of subject goods from the named exporters in the United States.  Cello considers this to be a conservative estimate of export prices indicating that selling prices of subject goods have been and continue to be below Cello's pricing in Canada.
    
    
55. In its own determination of export price, the CBSA analyzed actual import data from customs documentation in 2005.  For imports of subject goods between importers that are related to the named exporters in the United States, the prices found for the representative models on the examined invoices to related importers were for the most part higher than the normal values estimated by the complainant.  However, the CBSA is of the opinion that the prices on these invoices may not be considered a reliable estimate of export price due to the relationship between the exporter and the importer.  A similar conclusion was reached in the first anti-dumping investigation.¹⁵  Accordingly, the CBSA accepted the complainant’s estimated export prices.
    
    
56. Where actual import data on the selling prices of the fourteen representative models was available between exporters and non-related importers, the CBSA used the customs documentation to estimate export prices.  In such cases, the export price was calculated as the value on the invoice, less freight costs (based on the complainant’s estimates of freight costs).
    
    

Korea

57. Cello estimated export prices using CIF (Cost of Product plus Insurance plus Freight) selling prices from a distributor’s price list for copper pipe fittings from Korea.  The complainant applied downward adjustments of 3% each for sales commission earned by the distributor and for insurance and freight on prices quoted on a CIF basis. 
    
    
58. In its own determination of export price, the CBSA analyzed actual import data from customs documentation in 2005.  The CBSA was able to identify nine of the ten benchmark products and accordingly it estimated export prices for these nine products.

China

59. Cello estimated export prices for the selected wrought pressure fittings on the basis of FOB (Free on Board) selling prices listed in a price list from a Chinese producer of copper pipe fittings.  The FOB selling prices listed on the price list were adjusted upward to reflect increases in the price of copper on the London Metal Exchange between October 2004 and March 2005.
    
    
60. For cast pressure and cast drainage fittings, Cello estimated export prices based on its own selling prices to a Canadian customer in 2005 taking into account a freight deduction and an importer distributor mark-up.  The complainant believes that its estimates of export prices for the cast fittings are conservative on the basis that its selling prices have been consistently higher than prices offered by its Chinese competitors.
    
    
61. In its own determination of export price, the CBSA analyzed actual import data from customs documentation in 2005.  The CBSA was able to identify five of the fifteen benchmark products and accordingly it estimated export prices for these five products.

Margin of Dumping

United States

62. The complainant provided calculations for estimated margins of dumping for the fourteen benchmark products.  The estimated margins of dumping for the fourteen benchmark products ranged from 4.1% to 195.8%¹⁶, when expressed as a percentage of export price.
    
    
63. The CBSA estimated margins of dumping for the same fourteen products.  The CBSA’s estimated margins of dumping for the fourteen benchmark products ranged from 2.3% to 196%, expressed as a percentage of export price.  The overall weighted average margin of dumping found for the fifteen benchmark fittings, 20.2%, is held to be the CBSA’s estimated margin of dumping for subject copper pipe fittings originating in or exported from the United States.

Korea

64. The complainant provided calculations for estimated margins of dumping for the ten benchmark products.  The estimated margins of dumping for the ten benchmark products ranged from 2.5% to 116.8%, when expressed as a percentage of export price.
    
    
65. The CBSA estimated margins of dumping for eight of the nine benchmark products as one of the benchmark products had not been dumped.  The CBSA’s estimated margins of dumping for the eight benchmark products ranged from 1.3% to 187.3%, expressed as a percentage of export price.  The overall weighted average margin of dumping found for the eight benchmark fittings, 96.1%, is held to be the CBSA’s estimated margin of dumping for all subject copper pipe fittings originating in or exported from Korea.

China

66. The complainant provided calculations for estimated margins of dumping for the fifteen benchmark products.  The estimated margins of dumping ranged from 12.9% to 181.5%, when expressed as a percentage of export price.
    
    
67. Based on the estimated normal values and export prices described above, the CBSA determined that all five benchmark products that it identified from the customs documentation were dumped.  The CBSA estimated margins of dumping for the five products.  The CBSA’s estimated margins of dumping for the five benchmark products ranged from 20.5% to 109.4%, expressed as a percentage of export price.  The overall weighted average margin of dumping found for the five benchmark cast fittings, 48.3%, is held to be the CBSA’s estimated margin of dumping for all subject copper pipe fittings originating in or exported from China. 

Negligibility and Insignificance of Dumping

68. Under section 35 of SIMA, if, at any time before the President makes a preliminary determination, the President is satisfied that the margin of dumping of the goods of a country is insignificant or the actual and potential volume of dumped goods of a country is negligible, the President must terminate the investigation with respect to that country.  Pursuant to subsection 2(1) of SIMA, a volume of dumped goods of less than 3% of total imports is considered negligible and a margin of dumping of less than 2% of the export price is defined as insignificant.  The CBSA performed preparatory “negligibility” and “insignificance” tests based on the available data, as shown below. The information available indicates that the volume of dumped goods from the United States and from Korea and China would not be considered negligible and that the margin of dumping would not be regarded as insignificant.

Evidence of Subsidizing

69. In accordance with SIMA, a subsidy exists if there is a financial contribution by a government of a country other than Canada that confers a benefit on persons engaged in the production, manufacture, growth, processing, purchase, distribution, transportation, sale, export or import of goods.  A subsidy also exists in respect of any form of income or price support within the meaning of Article XVI of the General Agreement on Tariffs and Trade, 1994, being part of Annex 1A to the World Trade Organization (WTO) Agreement, that confers a benefit.
    
    
70. Pursuant to subsection 2(1.6) of SIMA, a financial contribution exists where:
    
    
    • (a)  practices of the government involve the direct transfer of funds or liabilities or the contingent transfer of funds or liabilities;
      
      
    • (b)  amounts that would otherwise be owing and due to the government are exempted or deducted or amounts that are owing and due to the government are forgiven or not collected;
      
      
    • (c)  the government provides goods or services, other than general governmental infrastructure, or purchases goods; or
      
      
    • (d)  the government permits or directs a non-governmental body to do any thing referred to in any of paragraphs (a) to (c) where the right or obligation to do the thing is normally vested in the government and the manner in which the non‑governmental body does the thing does not differ in a meaningful way from the manner in which the government would do it.
    
    
    
71. If a subsidy is found to exist, it may be subject to countervailing measures if it is specific.  A subsidy is considered to be specific when it is limited, in law, to a particular enterprise or is a prohibited subsidy.  An “enterprise” is defined under SIMA as also including a “group of enterprises, an industry and a group of industries”.  Any subsidy which is contingent, in whole or in part, on export performance or on the use of goods that are produced or that originate in the country of export is considered to be a prohibited subsidy, and is, therefore, automatically considered to be specific for the purposes of a subsidy investigation.

72. Notwithstanding that a subsidy is not specific in law, a subsidy may also be considered specific if:
    
    
    • (a)  there is exclusive use of the subsidy by a limited number of enterprises;
      
      
    • (b)  there is predominant use of the subsidy by a particular enterprise;
      
      
    • (c)  disproportionately large amounts of the subsidy are granted to a limited number of enterprises; and
      
      
    • (d)  the manner in which discretion is exercised by the granting authority indicates that the subsidy is not generally available.
      
      
73. For purposes of a countervailing duty investigation, the CBSA refers to a subsidy that has been found to be specific as an “actionable subsidy” meaning that it is subject to countervailing measures if the imported goods under investigation have benefited from the subsidy
    
    
74. The complainant has alleged that the subject goods from China are being subsidized.  The alleged subsidies include the following:
    
    
    • Special economic zone (SEZ) incentives.
    • Grants provided for export performance and employing common workers.
    • Preferential loans.
    • Loan guarantees by the GOC.
    • Income tax credits, refunds and exemptions:
      • Reduced corporate tax rate for export-oriented enterprises.
      • Exemption/reduction of corporate income tax during designated tart-up period.
      • Income tax refund of amounts further invested in Special Economic Zones.
      • Exemption/reduction in local income tax for Special Economic Zone Enterprises.
    • Relief from duties and taxes on materials and machinery.
    • Reductions in land use fees.
    • Purchase of goods from State-owned Enterprises.
    • Zhejiang Province – Strategic Plan for Local Copper Processing Industry.
    
    
75. In addition, the CBSA has also identified Grants.

Special Economic Zone Incentives

76. It is the CBSA’s understanding that the GOC applies a lower rate of tax on corporate income for those companies located in Special Economic Areas and that these companies may benefit from other incentives offered by SEZs.
    
    
77. In its recent New and Full Notification Pursuant to Article XVI:1 of the GATT 1994 and Article 25 of the SCM Agreement to the World Trade Organization (WTO) ¹⁷, China identified the following programs:
    
    

    X	Preferential tax policies for enterprises with foreign investment established in special economic zones (excluding Shanghai Pudong area).
    XI	Preferential tax policies for enterprises with foreign investment established in the costal economic open areas and in the economic and technological development zones.
    XII	Preferential tax policies for enterprises with foreign investment established in Pudong area of Shanghai.
    XIII	Preferential tax policies for enterprises with foreign investment established in the Three Georges of Yangtze River Economic Zone.
    XIV	Preferential tax policies in the western regions

    
    
    
78. While the CBSA was unable to determine through an analysis of public Web sites whether any of the potential exporters are Foreign Invested Enterprises (FIEs), the physical location of some of the firms appears to support such a conclusion.
    
    
79. The CBSA identified certain importations of Chinese copper pipe fittings that were shipped directly from a Chinese port that but sold by vendors located in Chinese Taipei.  The publication, China Hand, states

    
    

    “Taiwanese companies commonly use offshore vehicles as a front for their mainland China businesses.  According to a survey published in 2004 by Fortune China Monthly, a Chinese language magazine…there were 68,115 Taiwanese businesses based on the mainland, with clusters around Shanghai municipality and the provinces of Fujian, Guangdong, Jiangsu and Zhejiang.”¹⁸ (emphasis added)  In addition, “Xiamen is home to three designated ‘Taiwanese investment zones; Jimei, Haicang and Xinglin…Taiwan firms represent 40% of ventures in the Xiamen Special Economic Zone.”¹⁹

80. In the CBSA’s anti-dumping and subsidy investigation involving outdoor Barbeques ²⁰, a number of FIEs located in China were affiliated with trading companies located in Hong Kong and Chinese Taipei.  This gives CBSA reason to conclude that Chinese manufacturers of copper pipe fittings conducting business with vendors in Chinese Taipei, are FIEs.
    
    
81. It is also the CBSA’s understanding that the GOC may provide various benefits and incentives to enterprises in China located within SEZs.  The various benefits and incentives are outlined below:
    
    
    • (a)  Tariff exemptions on imported materials.
      
      
    • (b)  Reduction of corporate income tax.
      
      
    • (c)  Value Added Tax (VAT) exemptions.
      
      
    • (d)  Special land tax and land use exemptions.
      
      
    • (e)  Preferential costs of services and infrastructure provided by government bodies or state-owned enterprises.
      
      
    • (f)  Exemption/Reduction in Local Income tax for SEZ Enterprises.
      
      
    • (g)  Income Tax Refund of Amounts Further Invested in SEZs.
    
    
    

Grants Provided for Export Performance and Employing Common Workers

82. In its recent WTO notification, China identified the following program:

    Preferential tax policies for enterprises which provide employment for unemployed people

83. It is the CBSA’s understanding that the GOC may be providing grants to enterprises in China based upon export performance and the employment of common workers.

Preferential Loans

84. There is information that the GOC may be providing loans to enterprises in China at preferential interest rates and financing terms.  These loans may be being made directly by the GOC or indirectly via financial institutions in China.

Loan Guarantees by the GOC

85. There is information that the GOC may be providing loan guarantees to enterprises in China.  These loan guarantees may be made directly by the GOC or indirectly via financial institutions in China.

Income Tax Credits, Refunds and Exemptions

86. It is the CBSA’s understanding that the generally applicable income tax rate for all enterprises in China is 33%, regardless if the enterprise is a Domestically Invested Enterprise (DIE), Foreign Invested Enterprise (FIE) or State-owned-Enterprise (SOE).  It is the CBSA’s understanding that foreign-invested productive enterprises, foreign invested enterprises that are export-oriented, technology-intensive and knowledge-intensive enterprises and foreign-invested advanced technology enterprises are levied at a lower taxrate.
    
    
87. It is the CBSA’s understanding that the GOC allows enterprises that purchase domestically made machinery (machinery made in China), subject to certain limitations, to offset any increase in taxable income in comparison to the prior year up to a maximum amount equal to 40% of the domestic equipment purchase price and that any amount, up to the maximum amount equal to 40% of the domestic equipment purchase price that is not used as an offset in that taxation year, may be carried forward to future taxation years up to a maximum of 5 years.
    
    
88. It is the CBSA’s understanding that research and development expenses incurred by foreign-invested enterprises may be offset by 150% from the taxable income of the year.
    
    
89. It is the CBSA’s understanding that foreign-invested companies are eligible for a rebate of the corporate income tax paid when profits are re-invested in the enterprises to increase the registered capital, or are used to set up other new enterprises with operation terms of longer than 5 years or for the organization and expansion of export-oriented enterprises or advanced technology enterprises.
    
    
90. It is the CBSA’s understanding that the GOC allows an exemption from and further reduction of income tax for those foreign-invested productive enterprises, foreign-invested advanced technology enterprises, and foreign invested enterprises during a designated start-up period (usually five years or more).  
    
    
91. It is the CBSA’s understanding that foreign-invested enterprises of industries and sectors in which foreign investment is encouraged by the government are granted an exemption or reduction in sub-provincial income taxes (e.g., local income tax).
    
    
92. In its recent WTO notification, China identified the following programs:
    
    

    I	Preferential Tax Policies for Foreign-Invested Enterprises.
    II	Preferential Tax Policies for Foreign-Invested Export Enterprises.
    VI	Preferential tax policies for enterprises with foreign investment which are technology intensive and knowledge-intensive.
    VIII	Preferential tax policies for enterprises with foreign investment recognized as high or new technology enterprises established in the State high or new technology industrial development zones, and for advanced technology enterprises invested in and operated by foreign businesses.
    IX	Preferential tax policies for enterprises recognized as high or new technology enterprises established in the State high or new technology industrial development zones.
    XXIII	Preferential tax policies for township enterprises.
    XXVII	Preferential tax policies for the research and development of foreign-invested enterprises.
    LVIII	Preferential tax policies for foreign invested enterprises and foreign enterprises which have establishments or place in China and are engaged in production or business operations purchasing domestically produced equipments.
    LIX	Preferential tax policies for domestic enterprises purchasing domestically produced equipments for technology upgrading purpose.

Relief from Duties and Taxes on Materials and Machinery

93. It is the CBSA’s understanding that certain enterprises are refunded import Value Added Tax (VAT) on the following products at the indicated percentages:
    
    
    • (a) Raw Copper Materials - 30% Refund of VAT
      
      
    • (b) Forging and Casting Products – 35% Refund of VAT
      
      
    • (c) Dies Products – 70% - Refund of VAT
      
      
    • (d) Numerically Controlled Machine Tool Products – 100% Refund of VAT
      
      
94. In its recent WTO notification, China identified the following programs:
    
    

    LX	Exemption of tariff and import VAT for the imported technologies and equipments
    LXXV	Refund of import VAT of raw copper materials
    LXXVI	Preferential tax treatment for casting and forging products
    LXXVII	Preferential tax treatment to dies products
    LXXVIII	Preferential tax treatment to numerically controlled machine tool products

Reductions in Land Use Fees

95. There is information that the GOC may be providing a reduction in land use fees to enterprises in China.

Purchase of Goods from State-owned Enterprises

96. There is information that the GOC may be providing goods and/or services to enterprises in China.  These goods and/or services may be being provided directly by the GOC or indirectly via state-owned enterprises.

Zhejiang Province – Strategic Plan for Local Copper Processing Industry

97. There is information that the Zhejiang Economic and Trade Commission may be providing benefits to manufacturers in the copper industry that are located in the Zhejiang Province by means of policy, tax and financial measures.  On November 11, 2004, the Zhejiang Provincial government announced that it intended to support the copper processing industry with “policy, tax and financial measures…to enhance cooperation with foreign companies, to bring in foreign investment and to enlarge their sales via exports.”²¹  By providing financial assistance to the copper processing industry that includes manufacturers of the subject goods, it appears that the GOC has targeted a specific industry or group of industries pursuant to paragraph 2(7.2)(a) of SIMA.

Grants

98. It is our understanding that there are several grants available to Small and Medium Enterprises (SMEs) in China.  SMEs that are initially financed with self-owned capital may receive grants.  Those enterprises financed mainly with loans may receive an interest discount with a rate decided by the amount of loans and the interest rate in the same term published by People’s Bank of China.  Grants are also provided to SMEs or enterprises and organizations that provide services to SMEs for the purpose of: (1) holding or participating in overseas exhibitions, (2) accreditation fee for quality management system, environment management system or for the product, (3) promotion in the international market, (4) exploring a new market, (5) holding trainings and symposiums, (6) overseas bidding.
    
    
99. In its recent WTO notification, China identified the following programs:
    
    

    XXXII	Development funds for SMEs
    XXXIII	Fund for international market exploration by SMEs

    
    
    
100. The CBSA has also identified other grants in its past investigations, specifically:

Conclusion

101. Based on the above, it is reasonable to conclude that the named subsidy programs outlined above are available to the exporters of copper pipe fittings in China.  In examining these programs, the CBSA will request information from the various levels of the GOC and from exporters and manufacturers of the subject goods to determine whether these programs confer countervailable benefits on the subject goods.

Estimated Amount of Subsidies

102. In the absence of available information, the complainant has not been able to determine the value of the alleged subsidies on a per-unit basis, although these programs are believed to significantly lower the cost of production and the selling prices of the subject goods exported to Canada. 
     
     
103. The CBSA has estimated the amount of subsidies provided to copper pipe fitting manufacturers in China as follows:
     
     

Export-Contingent Subsidies

104. Section 10 of SIMA provides that, in the case of export contingent subsidies, where all or a portion of the margin of dumping is attributable to the export subsidy, the amount of anti-dumping duty is equal to the portion of the margin of dumping that is not attributable to the export subsidy.  In such instances, the amount of subsidy and the margin of dumping off-set one another, thus avoiding double-counting.
     
     
105. The CBSA believes that the weighted average margin of dumping found for the subject goods may be at least partially attributable to certain export-contingent subsidies as described above.  Therefore, the estimated weighted average margin of dumping of 48.3% of the export price includes a component that reflects the estimated benefit attributable to the various subsidy programs.  The proportions of estimated margin that are attributable to dumping and subsidization cannot be determined at this time, given the lack of available information.

Domestic Subsidies

106. The CBSA has estimated an amount of subsidy attributable to non-export-oriented domestic programs and incentives.  This amount was estimated by comparing the cost of production estimated by Cello for the five benchmark products of subject goods to the export prices determined by the CBSA.  In cases where goods were imported into Canada at prices lower than the estimated cost of production of the goods, the difference is assumed to be attributable to domestic subsidy programs.  The CBSA estimates that the weighted average amount of domestic subsidy to be equal to 17.4% of the export price of the subject goods.  

Amount of Subsidy and Volume of Subsidized Goods

107. Under section 35 of SIMA, if, at any time before the President makes a preliminary determination, the President is satisfied that the amount of subsidy on the goods of a country is insignificant or the actual and potential volume of subsidized goods of a country is negligible, the President must terminate the investigation with respect to that country. 
     
     
108. Further, according to section 41.2 of SIMA, the President is required to take into account paragraph 10 of Article 27 of the WTO Subsidies Agreement when conducting subsidy investigations.  This provision stipulates that in an investigation involving a developing country, an amount of subsidy of less than 2% of the value of the goods will be considered insignificant and a volume of subsidized goods of less than 4% of total imports will be considered negligible.  As China is being considered as a developing country for purposes of this investigation, these differential amounts will apply.

Negligibility and Insignificance - Subsidy

109. The overall weighted average margin of dumping and amount of export-contingent subsidy is estimated to be equal to 48.3%, when expressed as a percentage of export price.  An additional amount for domestic subsidies is estimated to be equal to 17.4%, expressed as a percentage of export price.  The CBSA estimates that 100% of the subject goods have been dumped and/or have benefited from export-contingent subsidies, and that 100% of the subject goods have benefited from domestic subsidies.  The CBSA is, therefore, satisfied that the estimated amount of subsidy and volume of subsidized goods are well above the thresholds outlined above.

Evidence of Injury

110. The complainant has alleged that the subject goods have been or are being dumped and subsidized, and that such dumping and subsidizing has caused injury or is threatening to cause injury to 1the production of copper pipe fittings in Canada.  In support of its allegations, Cello has provided evidence of price erosion, price suppression, lost sales, declining market share, reduced profits and profit margins and reduced employment.
     
     
111. In the following analysis of injury the CBSA cannot release specific quantitative data, as it relates primarily to the complainant and to a lesser degree to Bow and would result in the disclosure of confidential information.  The information is, therefore, presented without reference to specific numbers.

Price Erosion

112. Cello claims that the alleged dumped and subsidized goods have caused it to experience significant price erosion of like goods in Canada.  This price erosion has taken the form of increasing discounts, increasing rebates or a combination of both.
     
     
113. Cello presented evidence of price erosion expressed on a price per pound basis for specific customer accounts between FY 2002 and 2005 and for the periods July to December 2004 and 2005.  Cello claims that price increases in the most recent period were only achieved at the expense of significantly reduced sales volume.
     
     
114. Cello also presented evidence of price erosion for specific benchmark products.  The complainant’s evidence, which addressed the majority of benchmark products for which it estimated margins of dumping, shows the same pattern as presented for specific customer accounts.
     
     
115. Finally, Cello also presented evidence of price erosion in its import activity reports, recorded between June 2004 and March 2006.  These reports summarize conversations/meetings between Cello and its customers in which Cello was forced to lower its prices of the like goods in order to compete with price offerings of the subject goods from the United States and China.
     
     

Price Suppression

116. At the same time that Cello has experienced price erosion as a result of the alleged dumped and subsidized subject goods, the company has faced increased production costs, largely as a result of increases in the price of copper.  Cello provided information from the London Metal Exchange ²⁴ showing that the world price of copper increased approximately 220% from March 2002 to November 2005.  The world price of copper largely dictates the price of copper tube and ingot Cello purchases to manufacture copper pipe fittings.  Cello provided invoices relating to its purchases of copper tube and ingot.
     
     
117. Cello provided evidence of price suppression by comparing its average cost of tube and ingot with its average revenue for wrought and cast fittings between FY 2002 and 2005 and for the periods July to December 2004 and 2005.  Cello’s evidence clearly shows that during this period, the complainant’s raw material average costs increased while its average revenue per pound declined.

Lost Sales

118. Cello has alleged that dumped and subsidized imports have been responsible for the company losing sales.  In certain instances, Cello lost sales because of its inability to lower prices whereas in other instances, it still lost sales after lowering prices.  A number of Cello’s import activity reports, recorded between June 2004 and March 2006, cover sales lost to subject goods from Korea and China.

Declining Market Share

119. On the basis of its estimate of the value of imports and value of sales by Canadian producers, Cello has alleged that in spite of a stronger market for copper pipe fittings since 2002, Canadian producers have lost market share in the face of dumped and subsidized imports from the named producers in the United States, Korea and China.
     
     
120. Based on its analysis, the CBSA has formed the opinion that while the market for copper pipe fittings has grown since 2002, both Cello and Bow have not benefited from an increased demand.  Instead, Canadian producers have witnessed their share of the market declining at the expense of imports from Korea and China.

Reduced Profits and Profit Margins

121. Cello alleges that the allegedly dumped and subsidized goods have resulted in reduced gross margins and net income (loss) before taxes.  In support of this allegation, Cello provided its audited financial statements for FY 2003 through FY 2005, as well as for the period April to December 2005 for sales of all products and for sales like goods in Canada.
     
     
122. In the Tribunal’s Statement of Reasons from 1998, the same year the original finding concerning copper pipe fittings was rescinded, the Tribunal made the following observation about the Canadian producers’ financial performance:
     
     
123. “The Tribunal is persuaded that, having benefited from five years of protection afforded by the finding, the industry is now on a solid financial footing.  Consolidated industry financial data reveal that sales of copper pipe fittings throughout the period of review were highly profitable. Gross margins approaching 50 percent of industry sales and net profits in the 30 to 40 percent range suggest that industry financial results have been outstanding”.²⁵
     
     
124. Although specific details of Cello’s recent financial performance cannot be disclosed, the CBSA can state that the Tribunal’s assessment made in 1998 stands in sharp contrast to Cello’s financial performance in recent years.

Reduced Employment

125. In the second quarter of 2005, Cello was forced to lay off a number of factory workers as a result of the dumped and subsidized imports.  Cello has indicated that Bow was also forced to lay off factory workers in 2005 for the same reason.

Volume of Dumped and Subsidized Imports

126. In 2005, the volume of subject goods dumped from the United States, Korea and China was estimated to be 24.1%, 20.6% and 11.0%, respectively, of total imports²⁶.  The CBSA considers the estimated volume of dumped goods has had a significant injurious impact on Canadian producers of copper pipe fittings.  Similarly, the CBSA considers the estimated volume of subsidized imports from China has also had a significant injurious impact on Canadian producers of copper pipe fittings. 

Magnitude of the Margin of Dumping and Amount of Subsidy

127. The CBSA considers the estimated margins of dumping and estimated amounts of subsidy have had a significant injurious impact on Canadian producers of copper pipe fittings.

Non-Dumping/Subsidy Factors

128. Cello has stated that it is not aware of any other factors that have had a materially negative impact on the Canadian industry.
     
     
129. As stated earlier, the Canadian dollar has appreciated against the currencies of the United States, China and Korea since 2003.  The CBSA acknowledges that the Canadian producers may have been injured by lower import prices as a result of a stronger Canadian dollar.  However, while the Canadian producers may have had to contend with lower import prices, Canadian producers have also benefited from a stronger Canadian dollar in their purchases of raw material, priced in $US currency.  Despite a competitive advantage in purchasing raw materials, Cello has been unable to raise prices to offset material costs as evidenced in the company’s financial performance. 
     
     
130. Numerous publicly available sources report that there is a shift in demand from copper pipe to PEX tubing²⁷.  However, copper fittings for PEX tubing are not interchangeable with fittings designed to be used with copper pipes.
     
     
131. While raw material copper prices as well as prices for plastics and polyethylene raw materials used in competing products have both risen to record highs, there is some concern expressed that there may be a shift from copper pipe to plastic tubing in the face of higher prices.  However, based on statements made by a United States exporter in its 2005 Annual Report, profitability has increased as a result of being able to increase its selling prices to more than offset its higher raw material costs.²⁸
     
     
132. In summary, the CBSA has not identified any significant non-dumping/subsidizing factors that have had a materially negative impact on the Canadian industry.

Threat of Injury

133. Cello contends that the significant growth in imports from China and Korea suggests that producers in the named countries have an interest in growing their presence in the Canadian market.  Cello states that their “market intelligence indicates that producers in China and Korea have production capabilities that dwarf the size of the Canadian market”.²⁹
     
     
134. Insofar as Cello participates in the United States market for copper pipe fittings, it is aware of the production capabilities of certain exporters.  This knowledge has led Cello to believe that those exporters can supply the entire Canadian market.  The Tribunal reached a similar view in 1998.³⁰

Conclusion

135. The CBSA is satisfied that Cello has sufficiently demonstrated that the injury it has suffered is due to the dumping and subsidization of subject goods imported into Canada.  The CBSA considers reasonable the complainant’s position that if the dumping and subsidizing of certain copper pipe fittings from the United States, Korea and China is not rectified, Canadian producers will continue to suffer from price erosion and price suppression, lost sales, declining market share, reduced profits and profit margins and reduced employment.  Finally, the CBSA is satisfied that the information provided in the complaint has established a reasonable indication that the dumping and subsidizing is also threatening to cause injury.
     
     
136. The information presented by Cello in its complaint, together with supplementary data available to the CBSA, substantiates the complainant’s allegation that certain solder joint pressure pipe fittings and solder joint drainage, waste and vent pipe fittings, made of cast copper alloy, wrought copper alloy or wrought copper, for use in heating, plumbing, air conditioning and refrigeration applications, originating in or exported from the United States of America, the Republic of Korea and the People’s Republic of China have been dumped and subsidized.  The information also discloses a reasonable indication that this dumping and subsidizing has caused injury and is threatening to cause injury to the Canadian industry producing these goods.  Consequently, a dumping investigation and subsidy investigation was initiated on June 8, 2006 in respect of this matter under section 31(1) of the SIMA.

Consultations

137. On June 5, 2006, consultations were conducted between Canadian government officials and representatives of the GOC, in accordance with Article 13.1 of the WTO Subsidies Agreement.  All comments and concerns put forward have been taken into consideration.

Scope of the Investigation

138. The CBSA will conduct an investigation to determine whether the subject goods have been dumped and subsidized.
     
     
139. All parties have been clearly advised of the CBSA’s information requirements and the time frames for providing their responses.
     
     
140. Information related to export sales has been requested from potential exporters and potential importers, concerning their shipments of subject goods imported into Canada during the Period of Investigation (POI) of April 1, 2005 to March 31, 2006.  This data will be used to estimate export prices and ultimately to determine whether the subject goods have been dumped.
     
     
141. Information related to export sales has been requested from the fifteen potential exporters in China, concerning all subject goods shipped to Canada during the POI of January 1, 2005 to March 31, 2006.  This data will be used to estimate an amount of subsidy if the subject goods have been subsidized.
     
     
142. Information related to potential actionable subsidy programs has been requested from the GOC concerning financial contributions made to manufacturers of subject goods shipped to Canada during the POI of January 1, 2005 to March 31, 2006.  This data will be used to estimate an amount of subsidy if the subject goods have been subsidized.
143. These POIs encompass a sufficient length of time to accurately reflect the exporters' price levels to Canada and relates to the time period during which the Canadian industry alleges that the injurious dumping and subsidizing has occurred.   In addition, the volumes of subject goods imported during this period are of sufficient quantities to ensure that the pricing practices of the exporters are accurately portrayed and do not represent a temporary aberration or anomaly.
     
     
144. It is the CBSA’s intention to conduct an anti-dumping investigation with respect to potential exporters from each of the named countries of the subject goods.  Although the complainant has named specific parties in the United States that form the basis of its complaint for this country, the CBSA has elected to conduct this part of the anti-dumping investigation by considering all potential exporters in the United States.  This decision is based on observations made by the Tribunal in its review of the finding in 1998.  In its review, the Tribunal concluded that the degree of substitutability between imports from unnamed parties in the United States and the like goods made by Canadian producers was likely to be similar to that of the substitutability between imports of the subject goods from the named parties and the like goods produced in Canada.  The Tribunal found that degree of substitutability to be moderate to high.³¹
     
     
145. Based on its review of customs documentation, the CBSA identified approximately 1,300 exporters using HS Heading 74.12 for shipments of goods originating in or exported from the United States during the period January 1, 2005 to December 31, 2005.  However, a majority of the exporters shipped small quantities and only eighty-five exporters shipped what CBSA considers to be commercial quantities (i.e. shipments valued at $100,000 or more).  The CBSA considered the $100,000 threshold for designation as commercial quantity as reasonable and appropriate after an analysis of the importation data from the CBSA Customs database.  The complainant identified six exporters of the subject goods.  All six exporters shipped commercial quantities and together accounted for 81.7% of the total value of imports of subject goods.  The CBSA also identified an additional seven potential exporters of subject goods that shipped commercial quantities.  Collectively, the thirteen exporters accounted for 96.8% of the total value of subject goods.
     
     
146. In view of the large number of exporters, the CBSA used the above sampling criteria to send an exporter/manufacturer dumping Request for Information (RFI) at the initiation of the investigation to those thirteen exporters.
     
     
147. Based on its review of customs documentation, the CBSA identified approximately fifteen exporters using HS Heading 74.12 for shipments of goods originating in or exported from Korea during the period January 1, 2005 to December 31, 2005.  The CBSA sent exporter/manufacturer dumping RFIs at the initiation of the investigation to those fifteen exporters.
     
     
148. Based on its review of customs documentation, the CBSA identified ninety exporters using HS Heading 74.12 for shipments of goods originating in or exported from China during the period January 1, 2005 to December 31, 2005.  However, a majority of the exporters shipped small quantities and only fifteen exporters shipped commercial quantities.  These fifteen exporters identified by the CBSA accounted for 84.0% of the total value of imports of subject goods.
     
     
149. In view of the large number of exporters, the CBSA used the above sampling criteria to send an exporter/manufacturer dumping RFI at the initiation of the investigation to those fifteen exporters.
     
     
150. The CBSA sent RFIs to all importers that had shipments from the thirteen exporters from the United States and from each group of the fifteen exporters from Korea and China.  In total, the CBSA sent an RFI to seventy-seven importers for the dumping and subsidy investigation. 

Future Action

151. The Tribunal will conduct a preliminary inquiry to determine whether the evidence discloses a reasonable indication that the dumping and subsidizing of the goods has caused or is threatening to cause injury to the Canadian industry.  The Tribunal must make its decision within 60 days after the date of the initiation of the investigation, by August 8, 2006.  If the Tribunal concludes that the evidence does not disclose a reasonable indication of injury to the Canadian industry, the investigation will be terminated.
     
     
152. If the Tribunal finds that the evidence discloses a reasonable indication of injury to the Canadian industry and the ongoing CBSA investigation reveals that the goods have been dumped and/or subsidized, the CBSA will make a preliminary determination of dumping and/or subsidizing within 90 days after the date of the investigation initiation, by September 6, 2006.  Where circumstances warrant, this period may be extended to 135 days from the date of the initiation of the investigation.
     
     
153. If, in respect of any of the named countries, the CBSA’s investigation reveals that imports of the subject goods have not been dumped or in the case of China, subsidized, that the margin of dumping or amount of subsidy is insignificant, or that the actual and potential volume of dumped or subsidized goods is negligible, the investigation will be terminated with respect to those countries.
     
     
154. Imports of subject goods released by customs on and after the date of a preliminary determination of dumping and/or subsidizing may be subject to provisional duty in an amount not greater than the estimated margin of dumping, or the estimated amount of subsidy, on the imported goods.
     
     
155. Should the CBSA make a preliminary determination of dumping and/or subsidizing, the investigation will be continued for the purpose of making a final determination within 90 days after the date of the preliminary determination.
     
     
156. If a final determination of dumping and/or subsidizing is made, the Tribunal will continue its inquiry and hold public hearings into the question of material injury to the Canadian industry.  The Tribunal is required to make a finding, with respect to the goods to which the final determination of dumping and/or subsidizing applies, not later than 120 days after the CBSA preliminary determination.
     
     
157. In the event of an injury finding by the Tribunal, imports of subject goods released by customs after that date will be subject to anti-dumping duty equal to the applicable margin of dumping, and a countervailing duty in an amount equal to the amount of any actionable subsidy on the imported goods.  Should both anti-dumping and countervailing duty be applicable to subject goods, the amount of any anti-dumping duty may be reduced by the amount that is attributable to an export subsidy.

Retroactive Duty on Massive Importations

158. When the Tribunal conducts an inquiry concerning material injury to the Canadian industry, it may consider if dumped and/or subsidized goods that were imported close to or after the initiation of the investigation, constitute massive importations over a relatively short period of time and have caused injury to the Canadian industry.
     
     
159. Should the Tribunal issue such a finding, anti-dumping and countervailing duties may be imposed retroactively on subject goods imported into Canada and released by customs during the period of 90 days preceding the day of the CBSA making a preliminary determination of dumping and/or subsidizing.
     
     
160. In respect of importations of subsidized goods that have caused injury, however, this provision is only applicable where the CBSA has determined that the whole or any part of the subsidy on the goods is a prohibited subsidy, as explained in the section “Evidence of Subsidizing”, above.  In such a case, the amount of countervailing duty applied on a retroactive basis will equal the amount of subsidy on the goods that is a prohibited subsidy.

Undertakings

161. After a preliminary determination of dumping by the CBSA, an exporter may submit a written undertaking to revise their selling prices to Canada so that the margin of dumping or the injury caused by the dumping is eliminated.  An acceptable undertaking must account for all or substantially all of the exports to Canada of the dumped goods.
     
     
162. Similarly, after a preliminary determination of subsidizing by the CBSA, foreign governments may submit written undertakings to eliminate the subsidy on the goods exported or to eliminate the injurious effect of the subsidy, by limiting the amount of the subsidy or the quantity of goods exported to Canada.  Alternatively, exporters with the written consent of their government may undertake to revise their selling prices, so that the amount of the subsidy or the injurious effect of the subsidy is eliminated.
     
     
163. Interested parties may provide comments regarding the acceptability of undertakings within nine days of the receipt of an undertaking by the CBSA.  The CBSA will maintain a list of parties who wish to be notified should an undertaking proposal be received.  Those who are interested in being notified should provide their name, telephone and fax numbers, mailing address and email address, if available, to one of the officers identified in the “Information” section of this document, below.
     
     
164. If an undertaking were to be accepted, the investigation and the collection of provisional duties would be suspended.  Notwithstanding the acceptance of an undertaking, an exporter may request that the CBSA’s investigation be completed and that the Tribunal complete its injury inquiry.

Publication

165. Notice of the initiation of this investigation is being published in the Canada Gazette pursuant to subparagraph 34(1)(a)(ii)of SIMA.

Information

166. Interested parties are invited to file written submissions presenting facts, arguments, and evidence that they feel are relevant to the alleged dumping and/or subsidizing.  Written submissions should be forwarded to the attention of one of the officers identified below.
     
     
167. To be given consideration in this initial phase of the investigation, all information should be received by the CBSA by July 17, 2006.
     
     
168. Any information submitted to the CBSA by interested parties concerning this investigation is deemed to be public information unless clearly marked “confidential”.  Where the submission by an interested party is confidential, a non-confidential version of the submission must be provided at the same time.  This non-confidential version will be made available to other interested parties upon request.
     
     
169. Confidential information submitted to the CBSA will be disclosed on written request to independent counsel for parties to these proceedings, subject to conditions to protect the confidentiality of the information.  Confidential information may also be released to the Tribunal, any court in Canada, or a WTO dispute settlement panel.  Additional information respecting the Directorate’s policy on the disclosure of information under SIMA may be obtained by contacting one of the officers identified below or by visiting the Directorate’s Web site at the address below.
     
     
170. The investigation schedule and a complete listing of all exhibits and information will be available at http://www.cbsa-asfc.gc.ca/sima-lmsi/i-e/menu-eng.html.  The exhibits listing will be updated as new exhibits and information is made available.
     
     
171. This Statement of Reasons has been provided to persons directly interested in these proceedings.  It is also posted on the Directorate’s Web site at the address below.  For further information, please contact Peter Dupuis and Jody Grantham as follows:
     
     

 

Solder joint pressure pipe fittings and solder joint drainage, waste and vent pipe fittings, made of cast copper alloy, wrought copper alloy or wrought copper, for use in heating, plumbing, air conditioning and refrigeration applications, originating in or exported from the United States of America, the Republic of Korea and the People’s Republic of China

The following information is to be taken into consideration in identifying copper pipe fittings (subject goods) being investigated by the Canada Border Services Agency (CBSA):

1. The subject goods are identified in terms of imperial measurement, i.e. inches. The CBSA is also investigating subject goods that encompass the metric equivalents of the imperial measurement. The term metric equivalent refers to those fittings that are soft converted equivalents of the imperial sized fittings and does not include fittings made specifically in metric dimensions.
   
   
2. The subject goods are identified either as a wrought product or as a cast product. Where a subject good contains an asterisk (“ * ”) the CBSA is investigating both the wrought product and the cast product.
   
   
3. The subject goods are identified in terms of nominal size. Plumbing and heating fittings are marked according to nominal sizes that correspond to the inside diameters, while fittings for air conditioning and refrigeration are based on actual outer diameter sizes. The CBSA is also investigating subject goods that are described in terms of their outside diameter size. To determine the nominal size of a fitting that is measured in terms of it’s outside diameter size, always subtract 1/8" from the outside diameter size.
   
   
4. The subject goods are identified using abbreviated terms provided by the complainant (Cello Products Inc.). The following is a list of the terms:
   
   

Abbreviation Chart
WP	Wrought Pressure	FTG	Fitting End (Street End)
WD	Wrought Drainage	LT	Long Turn
CP	Cast Pressure	MJ	Mechanical Joint
CD	Cast Drainage	DE	Drop Ear
C	Copper Tube Cupped End or Sweat End	DWV	Drainage Waste, Vent
M	Male NPT Thread	TY	90°Drainage Tee
FE	Female NPT Thread	Y	45° Drainage Tee
SJ	Slip Joint End

Subject Copper Pipe Fittings - Female Adapters

1-1/4 CXFE CD ADAPTER *	1-1/2 FTGXFE CD ADAPTER *
1-1/2 CXFE CD ADAPTER *	1-1/2 X 1-1/4 CXFE CD ADAPTER *
3 FTGXFE CD ADAPTER *	2 CXFE CD ADAPTER *
3 CXFE CD ADAPTER *	4 CXFE CD ADAPTER *
1/2 CXFE CP ADAPTER *	1/2 X 3/8 CXFE CP ADAPTER *
1/2 X 3/4 CXFE CP ADAPTER *	3/4 CXFE CP ADAPTER *
3/4 X 1/2 CXFE CP ADAPTER *	3/4 X 1 CXFE CP ADAPTER *
3/4 X 1-1/4 CXFE CP ADAPTER *	3/4 X 1-1/2 CXFE CP ADAPTER *
1 C X FE CP ADAPTER *	1 X 1/2 CXFE CP ADAPTER *
1 X 3/4 C X FE CP ADAPTER *	1 X 1-1/4 CXFE CP ADAPTER *
1-1/4 CXFE CP ADAPTER *	1-1/4 X 1/2 CXFE CP ADAPTER *
1-1/4 X 3/4 CXFE CP ADAPTER *	1-1/4 X 1 CXFE CP ADAPTER *
3/4 X 1/2 FTGXFE CP ADAPTER *	1 FTGXFE CP ADAPTER *
1-1/2 CXFE CP ADAPTER *	1-1/2 X 3/4 CXFE CP ADAPTER *
1-1/2 X 1 CXFE CP ADAPTER *	1-1/2 X 2 CXFE CP ADAPTER *
2 CXFE CP ADAPTER *	2-1/2 C X FE CP ADAPTER *
3 CXFE CP ADAPTER *	1/2 CXFE CP DROP EAR ADAPTER
3/4 CXFE CP DROP EAR ADAPTER	1/2 CXFE CP HIGH EAR ADAPTER *
4 CXFE CP ADAPTER *	5 C X FE CP ADAPTER *
6 C X FE CP ADAPTER *	1-1/4 CXFE WD ADAPTER *
1-1/4 X 1-1/2 CXFE WD ADAPTER *	1-1/4 FTGXFE WD ADAPTER *
1-1/2 FTGXFE WD ADAPTER *	2 FTGXFE WD ADAPTER *
1-1/2 CXFE WD ADAPTER *	1-1/2 X 1-1/4 CXFE WD ADAPTER *
1-1/2 X 2 CXFE WD ADAPTER *	3 FTGXFE WD ADAPTER *
2 C X FE WD ADAPTER *	2 X 1-1/2 CXFE WD ADAPTER *
3 C X FE WD ADAPTER *	1/4 C X FE WP ADAPTER *
3/8 C X FE WP ADAPTER *	3/8 X 1/4 CXFE WP ADAPTER *
3/8 X 1/2 CXFE WP ADAPTER *	1/2 C X FE WP ADAPTER *
1/2 X 1/4 CXFE WP ADAPTER *	1/2 X 3/8 CXFE WP ADAPTER *
1/2 X 3/4 CXFE WP ADAPTER *	1/2 X 1 CXFE WP ADAPTER *
5/8 X 1/2 CXFE WP ADAPTER *	5/8 X 3/4 CXFE WP ADAPTER *
3/4 C X FE WP ADAPTER *	3/4 X 1/2 CXFE WP ADAPTER *
3/4 X 1 CXFE WP ADAPTER *	3/4 X 1-1/4 CXFE WP ADAPTER *
3/4 X 1-1/2 CXFE WP ADAPTER *	1 C X FE WP ADAPTER *
1 X 1/2 CXFE WP ADAPTER *	1 X 3/4 CXFE WP ADAPTER *
1 X 1-1/4 CXFE WP ADAPTER *	1 X 1-1/2 CXFE WP ADAPTER *
1-1/4 C X FE WP ADAPTER *	1-1/4 C X 3/4 FE WP ADAPTER *
1-1/4 X 1 CXFE WP ADAPTER *	1-1/4 X 1-1/2 CXFE WP ADAPTER *
1-1/4 X 2 CXFE WP ADAPTER *	1/4 FTGXFE WP ADAPTER *
3/8 FTGXFE WP ADAPTER *	3/8 X 1/4 FTGXFE WP ADAPTER *
1/2 FTGXFE WP ADAPTER *	1/2 X 1/4 FTGXFE WP ADAPTER *
1/2 X 3/8 FTG X FE ADAPTER *	1/2 FTG X 3/4 FE WP ADAPTER *
3/4 FTGXFE WP ADAPTER *	3/4 FTG X 1/2 FE WP ADAPTER *
1 FTGXFE WP ADAPTER *	1 FTG X 3/4 FE WP ADAPTER *
1-1/4 FTGXFE WP ADAPTER *	1-1/2 FTGXFE WP ADAPTER *
2 FTGXFE WP ADAPTER *	1-1/2 C X FE WP ADAPTER *
2-1/2 FTGXFE WP ADAPTER *	1-1/2 C X 1 FE WP ADAPTER *
1-1/2 X 1-1/4 CXFE WP ADAPTER *	1-1/2 X 2 CXFE WP ADAPTER *
3 FTGXFE WP ADAPTER *	2 C X FE WP ADAPTER *
2 X 1 C X FE WP ADAPTER *	2 X 1-1/4 CXFE WP ADAPTER *
2 X 1-1/2 CXFE WP ADAPTER *	2-1/2 C X FE WP ADAPTER *
3 C X FE WP ADAPTER *

Subject Copper Pipe Fittings - Male Adapters

1-1/4 CXM CD ADAPTER *	1-1/4X1-1/2 CXM CD ADAPTER *
1-1/2 FTGXM CD ADAPTER *	1-1/2 CXM CD ADAPTER *
1-1/2X1-1/4 CXM CD ADAPTER *	2 CXM CD ADAPTER *
2 X 1-1/2 CXM CD ADAPTER *	3 CXM CD ADAPTER *
4 CXM CD ADAPTER *	1/2 CXM CP ADAPTER *
1/2 X 3/4 CXM CP ADAPTER *	3/4 CXM CP ADAPTER *
3/4 X 1/2 CXM CP ADAPTER *	3/4 X 1-1/4 CXM CP ADAPTER *
1 CXM CP ADAPTER *	1 X 1/2 CXM CP ADAPTER *
1 X 1-1/4 CXM CP ADAPTER *	1 X 1-1/2 CXM CP ADAPTER *
1-1/4 CXM CP ADAPTER *	1-1/4 X 1/2 CXM CP ADAPTER *
1-1/4 X 1 CXM CP ADAPTER *	1-1/2 CXM CP ADAPTER *
1-1/2 X 3/4 CXM CP ADAPTER *	2 CXM CP ADAPTER *
2 X 1-1/2 C X M CP ADAPTER *	2-1/2 CXM CP ADAPTER *
3 CXM CP ADAPTER *	4 CXM CP ADAPTER *
5 CXM CP ADAPTER	6 CXM CP ADAPTER
1-1/2 M X 1-1/2 OD WD ADAPTER *	1-1/4 CXM WD ADAPTER *
1-1/4X1-1/2 CXM WD ADAPTER *	1-1/2 FTGXM WD ADAPTER *
2 FTGXM WD ADAPTER *	1-1/2 CXM WD ADAPTER *
1-1/2 X 1-1/4 CXM WD ADAPTER *	1-1/2 X 2 CXM WD ADAPTER *
2 CXM WD ADAPTER *	2 X 1-1/2 CXM WD ADAPTER *
3 CXM WD ADAPTER *	4 CXM WD ADAPTER *
1-1/4 CXM WD FLUSH TRAP ADAPTER *	1-1/2 CXM WD FLUSH TRAP ADAPTER *
2 CXM WD FL TRAP ADAPTER *	1-1/2 CXM WD SCULLY BUSHING *
2 CXM WD SCULLY BUSHING *	1/4 CXM WP ADAPTER *
1/4 X 3/8 CXM WP ADAPTER *	1/4 X 1/2 CXM WP ADAPTER *
3/8 CXM WP ADAPTER *	3/8 X 1/4 CXM WP ADAPTER *
3/8 X 1/2 CXM WP ADAPTER *	1/2 CXM WP ADAPTER *
1/2 X 1/4 CXM WP ADAPTER *	1/2 X 3/8 CXM WP ADAPTER *
1/2 X 3/4 CXM WP ADAPTER *	1/2 X 1 CXM WP ADAPTER *
5/8 X 1/2 CXM WP ADAPTER *	5/8 X 3/4 CXM WP ADAPTER *
3/4 CXM WP ADAPTER *	3/4 C X 3/8 WP M ADAPTER *
3/4 X 1/2 CXM WP ADAPTER *	3/4 X 1 CXM WP ADAPTER *
3/4 X 1-1/4 CXM WP ADAPTER *	3/4 X 1-1/2 CXM WP ADAPTER *
1 CXM WP ADAPTER *	1 X 1/2 CXM WP ADAPTER *
1 X 3/4 CXM WP ADAPTER *	1 X 1-1/4 CXM WP ADAPTER *
1 X 1-1/2 CXM WP ADAPTER *	1 X 2 CXM WP ADAPTER *
1-1/4 CXM WP ADAPTER *	1-1/4 X 3/4 CXM WP ADAPTER *
1-1/4 X 1 CXM WP ADAPTER *	1-1/4 X 1-1/2 CXM WP ADAPTER *
1-1/4 X 2 CXM WP ADAPTER *	1/4 FTGXM WP ADAPTER *
3/8 FTGXM WP ADAPTER *	1/2 FTGXM WP ADAPTER *
1/2 X 3/8 FTGXM WP ADAPTER *	1/2 X 3/4 FTGXM WP ADAPTER *
3/4 FTGXM WP ADAPTER *	3/4 X 1/2 FTGXM WP ADAPTER *
1 FTGXM WP ADAPTER *	1 X 3/4 FTGXM WP ADAPTER *
1-1/4 FTGXM WP ADAPTER *	1-1/2 FTGXM WP ADAPTER *
2 FTGXM WP ADAPTER *	1-1/2 CXM WP ADAPTER *
2-1/2 FTGXM WP ADAPTER *	1-1/2 X 1 CXM WP ADAPTER *
1-1/2 X 1-1/4 CXM WP ADAPTER *	1-1/2 X 2 CXM WP ADAPTER *
3 FTG X M WP ADAPTER *	2 CXM WP ADAPTER *
2 X 1-1/4 CXM WP ADAPTER *	2 X 1-1/2 CXM WP ADAPTER *
2 X 2-1/2 C X M WP ADAPTER *	2-1/2 CXM WP ADAPTER *
2-1/2 X 2 CXM WP ADAPTER *	3 CXM WP ADAPTER *
4 CXM WP ADAPTER *	1/2 X 3/4 C X HOSE WP ADAPTER *

Subject Copper Pipe Fittings – Other Adapters

1-1/4 X 2 CXSP CD FERRULE *	1-1/2 X 2 CXSP CD FERRULE *
1-1/2 X 3 CXSP CD FERRULE *	2 CXSP CD FERRULE *
2 X 3 CXSP CD FERRULE *	2 X 4 CXSP CD FERRULE *
3 CXSP CD FERRULE *	3 X 4 CXSP CD FERRULE *
4 CXSP CD FERRULE *	3 X 4 CXSP CD ECCENTRIC FERRULE *
1-1/4 X 2 CXMJ CD ADAPTER *	1-1/4 X 3 CXMJ CD ADAPTER *
1-1/2 X 2 CXMJ CD ADAPTER *	1-1/2 X 3 CXMJ CD ADAPTER *
1-1/2 X 4 CXMJ CD ADAPTER *	2 X 3 CXMJ CD ADAPTER *
2 X 4 CXMJ CD ADAPTER *	3 CXMJ CD ADAPTER *
3 X 4 CXMJ CD ADAPTER *	4 CXMJ CD ADAPTER *
6 C X M J CD ADAPTER *	1-1/4 FTGXSJ CD ADAPTER *
4 ACT(3S)X1-1/2C-30 CD ROOF ADAPTER *	4 ACT(3S) X 2C-30 CD ROOF ADAPTER *
4 SOIL(5A)X 1-1/2 C CD ROOF ADAPTER *	4 SOIL(5A)X 2 C CD ROOF ADAPTER *
5ACT 4SX 3C CD ROOF ADAPT CALGARY *	5S X 3C CD ROOF ADAPT REGINA *
1-1/2 SJXODX3/4M/1/2FE CD CONDENSATE TEE	2 C X SJ CD ADAPTER *
2 C X MJ WD ADAPTER *	1-1/4 FE X SJ WD ADAPTER *
1-1/2 FE X SJ WD ADAPTER *	1-1/2 X1-1/4 FE X SJ WD ADAPTER *
1-1/4 FTG X SJ WD ADAPTER *	1-1/2 FTG X SJ WD ADAPTER *
1-1/2 X 1-1/4 FTG X SJ ADAPTER *	1-1/4 M X SJ WD ADAPTER *
1-1/2 M X SJ WD ADAPTER *	1-1/2 X 1-1/4 M X SJ WD ADAPTER *
1-1/4 C X SJ WD ADAPTER *	1-1/4 X 1-1/2 CXSJ WD ADAPTER *
1-1/2 C X SJ WD ADAPTER *	1-1/2 X 1-1/4 CXSJ WD ADAPTER *
2 C X SJ WD ADAPTER *	1/2 CXM WP FLUSH VALVE ADAPTER *
3/4 CXM WP FLUSH VALVE ADAPTER *

Subject Copper Pipe Fittings – Bushings

3 X 1-1/2 FTGXC CD BUSHING *	5 X 4 FTGXC CP BUSHING *
6 X 2 FTGXC CP BUSHING *	6 X 3 FTGXC CP BUSHING *
6 X 4 FTGXC CP BUSHING *	6 X 5 FTGXC CP BUSHING *
1 X 1/2 FTGXFE CP FLUSH BUSHING *	1-1/4 X 1 FTGXFE CP FLUSH ADAPTER *
1 1/2 FTG X 1 FE C CP FLUSH BUSHING *	1-1/2X1-1/4 FTGXC W WD BUSHING *
2 X 1-1/4 FTGXC WD BUSHING *	2 X 1-1/2 FTGXC WD BUSHING *
3 X 1-1/4 FTGXC WD BUSHING *	3 X 1-1/2 FTGXC WD BUSHING *
3 X 2 FTGXC WD BUSHING *	4 X 2 FTGXC WD BUSHING *
4 X 3 FTGXC WD BUSHING *	1-1/4 CXM WD TRAP BUSHING *
1-1/2 CXM WD TRAP BUSHING *	2 CXM WD TRAP BUSHING *
3/8 X 1/8 FTGXC WP BUSHING *	3/8 X 1/4 FTGXC WP BUSHING *
1/2 X 1/4 FTGXC WP BUSHING *	1/2 X 3/8 FTGXC WP BUSHING *
5/8 X 1/4 FTGXC WP BUSHING *	5/8 X 3/8 FTGXC WP BUSHING *
5/8 X 1/2 FTGXC WP BUSHING *	3/4 X 1/4 FTGXC WP BUSHING *
3/4 X 3/8 FTGXC WP BUSHING *	3/4 X 1/2 FTGXC WP BUSHING *
3/4 X 5/8 FTGXC WP BUSHING *	1 X 3/8 FTGXC WP BUSHING *
1 X 1/2 FTGXC WP BUSHING *	1 X 5/8 FTGXC WP BUSHING *
1 X 3/4 FTGXC WP BUSHING *	1-1/4 X 1/2 FTGXC WP BUSHING *
1-1/4 X 3/4 FTGXC WP BUSHING *	1-1/4 X 1 FTGXC WP BUSHING *
1-1/2 X 1/2 FTGXC WP BUSHING *	1-1/2 X 3/4 FTGXC WP BUSHING *
1-1/2 X 1 FTGXC WP BUSHING *	1-1/2 X1-1/4 FTGXC WP BUSHING *
2 X 1/2 FTGXC WP BUSHING *	2 X 3/4 FTGXC WP BUSHING *
2 X 1 FTGXC WP BUSHING *	2 X 1-1/4 FTGXC WP BUSHING *
2 X 1-1/2 FTGXC WP BUSHING *	2-1/2 X 1 FTGXC WP BUSHING *
2-1/2 X 1-1/4 FTGXC WP BUSHING *	2-1/2 X 1-1/2 FTGXC WP BUSHING *
2-1/2 X 2 FTGXC WP BUSHING *	3 X 1/2 FTGXC WP BUSHING *
3 X 3/4 FTGXC WP BUSHING *	3 X 1 FTGXC WP BUSHING *
3 X 1-1/4 FTGXC WP BUSHING *	3 X 1-1/2 FTGXC WP BUSHING *
3 X 2 FTGXC WP BUSHING *	3 X 2-1/2 FTGXC WP BUSHING *
3-1/2 X 2 FTGXC WP BUSHING *	3-1/2 X 2-1/2 FTGXC WP BUSHING *
3-1/2 X 3 FTGXC WP BUSHING *	4 X 1-1/4 FTGXC WP BUSHING *
4 X 1-1/2 FTGXC WP BUSHING *	4 X 2 FTGXC WP BUSHING *
4 X 2-1/2 FTGXC WP BUSHING *	4 X 3 FTGXC WP BUSHING *
4 X 3-1/2 FTGXC WP BUSHING *	1/2 X 1/4 FTGXC WP FLUSH BUSHING *
1/2 X 3/8 FTGXC WP FLUSH BUSHING *	5/8 X 3/8 FTGXC WP FLUSH BUSHING *
3/4 X 1/2 FTGXC WP FLUSH BUSHING *	1 X 1/2 FTGXC WP FLUSH BUSHING *
1 X 3/4 FTGXC WP FLUSH BUSHING *	1-1/4X3/4 FTGXC W FL BUSHING *
1-1/4 X 1 FTGXC WP FLUSH BUSHING *	1-1/2 X 1 FTGXC WP FLUSH BUSHING *
1-1/2 X 1-1/4 FTGXC WP FLUSH BUSHING *	2 X 1-1/2 FTGXC WP FLUSH BUSHING *
1 X 1/2 FE WP FLUSH BUSHING *	1-1/4 X 3/4 FE WP FLUSH BUSHING *
1-1/4 X 1 FTGXFE WP FLUSH BUSHING *	1-1/2 X 1 FTGXFE WP FLUSH BUSHING *

Subject Copper Pipe Fittings – Couplings

3/4 CXC CP COUPLING *	1-1/4 CXC CP COUPLING *
4 CXC CP COUPLING *	5 X 3 CXC CP COUPLING *
5 X 4 CXC CP COUPLING *	6 X 2 CXC CP COUPLING *
6 X 3 CXC CP COUPLING *	6 X 4 CXC CP COUPLING *
6 X 5 CXC CP COUPLING *	1/2 CXC CP JET DRAIN COUPLING
3/4 CXC CP JET DRAIN COUPLING	1 CXC CP JET DRAIN COUPLING
3/4 X 1/2 CXC CP ECCENTRIC COUPLING *	1 X 1/2 CP ECCENTRIC COUPLING *
1 X 3/4 CXC CP ECCENTRIC COUPLING *	1-1/4 X 1/2 CP ECCENTRIC COUPLING *
1-1/2 X 1 CXC CP ECCENTRIC COUPLING *	1-1/2 X 1-1/4 CXC CP ECCENTRIC COUPLING *
2 X 1-1/4 CXC CP ECCENTRIC COUPLING *	2 X 1-1/2 CXC CP ECCENTRIC COUPLING *
3 X 2 CXC CP ECCENTRIC COUPLING *	3/4 CXC CP CROSSOVER COUPLING *
1/2C X 1M X 1/2 FE CP BOILER COUPLING	1/2 X 1 X 1/2 CXMXFE CP BOILER COUPLING
1-1/4 CXC WD COUPLING *	1-1/2 CXC WD COUPLING *
1-1/2X 1-1/4 CXC WD COUPLING *	2 CXC WD COUPLING *
2 X 1-1/4 CXC WD COUPLING *	2 X 1-1/2 CXC WD COUPLING *
3 CXC WD COUPLING *	3 X 1-1/4 CXC WD COUPLING *
3 X 1-1/2 CXC WD COUPLING *	3 X 2 CXC WD COUPLING *
4 CXC WD COUPLING *	4 X 1-1/2 CXC WD COUPLING *
4 X 2 CXC WD COUPLING *	4 X 3 CXC WD COUPLING *
4 X 1-1/2 CXC CD COUPLING *	4 X 3 CXC CD COUPLING *
6 CXC WD COUPLING *	1-1/4 CXC WD COUPLING NO STOP *
1-1/2 CXC WD COUPLING NO STOP *	2 CXC WD COUPLING NO STOP *
3 CXC WD COUPLING NO STOP *	4 CXC WD COUPLING NO STOP *
1/8 CXC WP COUPLING *	1/4 CXC WP COUPLING *
1/4 X 1/8 CXC WP COUPLING *	3/8 CXC WP COUPLING *
3/8 X 1/4 CXC WP COUPLING *	1/2 CXC WP COUPLING *
1/2 X 1/8 CXC WP COUPLING *	1/2 X 1/4 CXC WP COUPLING *
1/2 X 3/8 CXC WP COUPLING *	5/8 CXC WP COUPLING *
5/8 X 1/4 CXC WP COUPLING *	5/8 X 3/8 CXC WP COUPLING *
5/8 X 1/2 CXC WP COUPLING *	3/4 CXC WP COUPLING *
3/4 X 1/4 CXC WP COUPLING *	3/4 X 3/8 CXC WP COUPLING *
3/4 X 1/2 CXC WP COUPLING *	3/4 X 5/8 CXC WP COUPLING *
1 CXC WP COUPLING *	1 X 3/8 CXC WP COUPLING *
1 X 1/2 CXC WP COUPLING *	1 X 5/8 CXC WP COUPLING *
1 X 3/4 CXC WP COUPLING *	1-1/4 CXC WP COUPLING *
1-1/4 X 1/2 CXC WP COUPLING *	1-1/4 X 3/4 CXC WP COUPLING *
1-1/4 X 1 CXC WP COUPLING *	1-1/2 CXC WP COUPLING *
1-1/2 X 1/2 CXC WP COUPLING *	1-1/2 X 3/4 CXC WP COUPLING *
1-1/2 X 1 CXC WP COUPLING *	1-1/2 X 1-1/4 CXC WP COUPLING *
2 CXC WP COUPLING *	2 X 1/2 CXC WP COUPLING *
2 X 3/4 CXC WP COUPLING *	2 X 1 CXC WP COUPLING *
2 X 1-1/4 CXC WP COUPLING *	2 X 1-1/2 CXC WP COUPLING *
2-1/2 CXC WP COUPLING *	2-1/2 X 3/4 CXC WP COUPLING *
2-1/2 X 1 CXC WP COUPLING *	2-1/2 X 1-1/4 CXC WP COUPLING *
2-1/2 X 1-1/2 CXC WP COUPLING *	2-1/2 X 2 CXC WP COUPLING *
3 CXC WP COUPLING *	3 X 3/4 CXC WP COUPLING *
3 X 1 CXC WP COUPLING *	3 X 1-1/4 CXC WP COUPLING *
3 X 1-1/2 CXC WP COUPLING *	3 X 2 CXC WP COUPLING *
3 X 2-1/2 CXC WP COUPLING *	3-1/2 CXC WP COUPLING *
3-1/2 X 3 CXC WP COUPLING *	4 CXC WP COUPLING *
4 X 1-1/2 CXC WP COUPLING *	4 X 2 CXC WP COUPLING *
4 X 2-1/2 CXC WP COUPLING *	4 X 3 CXC WP COUPLING *
4 X 3-1/2 CXC WP COUPLING *	5 CXC WP COUPLING *
6 CXC WP COUPLING *	6 X 2-1/2 WP COUPLINGS *
1-1/4 X 3/4 CXC WP ECCENTRIC COUPLING *	1-1/4 X 1 CXC WP ECCENTRIC COUPLING *
1/8 CXC WP COUPLING NO STOP *	1/4 CXC WP COUPLING NO STOP *
3/8 CXC WP COUPLING NO STOP *	1/2 CXC WP COUPLING NO STOP *
5/8 CXC WP COUPLING NO STOP *	3/4 CXC WP COUPLING NO STOP *
1 CXC WP COUPLING NO STOP *	1-1/4 CXC WP COUPLING NO STOP *
1-1/2 CXC WP COUPLING NO STOP *	2 CXC WP COUPLING NO STOP *
2-1/2 CXC WP COUPLING NO STOP *	3 CXC WP COUPLING NO STOP *
4 CXC WP COUPLING NO STOP *	5 CXC WP COUPLING NO STOP *
6 CXC WP COUPLING NO STOP *	1/2 X 3 CXC WP REPAIR COUPLING
1/2 X 6 C X C WP REPAIR COUPLING	3/4 X 3 C X C WP REPAIR COUPLING
1/8 CXC WP RING COUPLING *	1/4 CXC WP RING COUPLING *
3/8 CXC WP RING COUPLING *	1/2 CXC WP RING COUPLING *
5/8 CXC WP RING COUPLING *	3/4 CXC WP RING COUPLING *
1 CXC WP RING COUPLING *	1-1/4 CXC WP RING COUPLING *
1-1/2 CXC WP RING COUPLING *	2 CXC WP RING COUPLING *
2-1/2 CXC WP RING COUPLING *	3 CXC WP RING COUPLING *
4 CXC WP RING COUPLING *	1/2 X 3-1/4 FTGXC WP SLIDE COUPLING
3/4 X 5 FTGXC WP SLIDE COUPLING	1/2 CXC WP CROSSOVER COUPLING *
3/4 CXC WP CROSSOVER COUPLING *

Subject Copper Pipe Fittings – Elbows

1-1/4 CXC 11-1/4 CD ELBOW *	1-1/2 CXC 11-1/4 CD ELBOW *
2 CXC 11-1/4 CD ELBOW *	3 CXC 11-1/4 CD ELBOW *
4 C X C 11-1/4 CD ELBOW *	1-1/4 CXC 22-1/2 CD ELBOW *
1-1/2 CXC 22-1/2 CD ELBOW *	2 CXC 22-1/2 CD ELBOW *
3 CXC 22-1/2 CD ELBOW *	4 CXC 22-1/2 CD ELBOW *
3 FTGXC 45 CD ELBOW *	4 FTGXC 45 CD ELBOW *
2 CXM CD 45 ELBOW *	1-1/4 CXC 45 CD ELBOW *
1-1/2 CXC 45 CD ELBOW *	2 CXC 45 CD ELBOW *
3 CXC 45 CD ELBOW *	4 CXC 45 CD ELBOW *
1-1/4 CXC 60 CD ELBOW *	1-1/2 CXC 60 CD ELBOW *
2 CXC 60 CD ELBOW *	3 CXC 60 CD ELBOW *
4 CXC 60 CD ELBOW *	1-1/4 CXC CD 90 ELBOW *
1-1/4 FTGXC CD 90 ELBOW *	1-1/2 FTGXC CD 90 ELBOW *
2 FTGXC CD 90 ELBOW *	1-1/2 CXC CD 90 ELBOW *
1-1/2 X 1-1/4 CXC CD 90 ELBOW *	3 CD FTGXC 90 ELBOW *
4 FTGXC CD 90 ELBOW *	2 CXC CD 90 ELBOW *
2X 1-1/4 CXC CD 90 ELBOW *	2 X 1-1/2 CXC CD 90 ELBOW *
1-1/2 CXFE CD 90 ELBOW *	2 CXFE CD 90 ELBOW *
1-1/2 CXM CD 90 ELBOW	2 CXM CD 90 ELBOW
3 CXC CD 90 ELBOW	4 CXC CD 90 ELBOW
1-1/2 CXSJ CD 90 ELBOW	1/2 X 1 CXC CP CLOSE RETURN BEND
3/4 1-3/8 CXC CP CLOSE RETURN BEND	1 X 1-3/4 CXC CP CLOSE RETURN BEND
1/2 C X M CP 45 ELBOW	3/4 C X M CP 45 ELBOW
1-1/4 C X M CP 45 ELBOW	4 CXC CP 45 ELBOW
6 CXC CP 45 ELBOW	1/2 C X C CP 90 ELBOW
1-1/4 CXC CP 90 ELBOW	1-1/4 X 1/2 CXC CP 90 ELBOW
1-1/4 X 3/4 CP 90 ELBOW	1-1/4 X 1 CP 90 ELBOW
1-1/2 X 1/2 CP 90 ELBOW	1-1/2 X 3/4 CXC CP 90 ELBOW
1-1/2 X 1 CXC CP 90 ELBOW	1/4 C X FE CP 90 ELBOW
1/2 CXFE CP 90 ELBOW	1/2 X 3/8 CXFE CP 90 ELBOW
1/2 X 3/4 CXFE CP 90 ELBOW	1/2 X 1 CXFE CP 90 ELBOW
3/4 CXFE CP 90 ELBOW	3/4 X 1/2 CXFE CP 90 ELBOW
3/4 X 1 CXFE CP 90 ELBOW	1 CXFE CP 90 ELBOW
1 X 1/2 C X FE CP 90 ELBOW	1 X 3/4 CXFE CP 90 ELBOW
1-1/4 CXFE CP 90 ELBOW	1-1/4 X 1/2 CXFE CP 90 ELBOW
1-1/4 X 3/4 CXFE CP 90 ELBOW	1-1/4 X 1 CXFE CP 90 ELBOW
2 X 3/4 CXC CP 90 ELBOW	2 X 1 CXC CP 90 ELBOW
2 X 1-1/4 CXC CP 90 ELBOW	1-1/2 CXFE CP 90 ELBOW
1-1/2 X 1 C X FE CP 90 ELBOW	2 CXFE CP 90 ELBOW
3 C X FE CP 90 ELBOW	1/2 CXFE CP 90 DROP EAR ELBOW
1/2C X 3/8FE CP 90 DROP EAR ELBOW	1/2 X 3/4 CXFE CP 90 DROP EAR ELBOW
3/4 CXFE CP 90 DROP EAR ELBOW	3/4C X 1/2FE CP 90 DROP EAR ELBOW
1 CXFE CP 90 DROP EAR ELBOW	1/2 CXFE CP DROP EAR IMPORT 90 ELBOW
1/2 CXFE CP HIGH EAR 90 ELBOW	3/4 CXFE CP HIGH EAR 90 ELBOW
1/2 CXFE CP FLANGE SINK 90 ELBOW	1/2 CXM CP 90 ELBOW
1/2 X 3/8 CXM CP 90 ELBOW	1/2 X 3/4 CXM CP 90 ELBOW
3/4 CXM CP 90 ELBOW	3/4 X 1/2 CXM CP 90 ELBOW
3/4 C X 1 M CP 90 ELBOW	1 CXM CP 90 ELBOW
1 X 3/4 CXM CP 90 ELBOW	1-1/4 CXM CP P 90 ELBOW
1-1/4 X 1 CXM CP 90 ELBOW	1-1/2 CXM CP 90 ELBOW
2 CXM CP 90 ELBOW	1/2 CXC CP DROP EAR 90 ELBOW
3/4 CXC CP 90 DROP EAR ELBOW	1 CXC CP 90 DROP EAR ELBOW
1/2 CXC CP HIGH EAR 90 ELBOW	3/4 CXC CP HIGH EAR 90 ELBOW
6 CXC CP 90 ELBOW	1/2C X 1/8FE X 1/2C CP BASE TEE *
1/2C X 1/8FE X 3/4C CP BASE TEE *	3/4C X 1/8FE X 3/4C CP BASE TEE *
1C X 1/8FE X 1 C CP BASE TEE *	1-1/4C X 1/8FEX1-1/4C CP BASE TEE *
3/4FE X 1/8FE X 3/4C CP BASE TEE	1-1/4 CXFTG WD 45 ELBOW *
1-1/2 FTGXC WD 45 ELBOW *	2 FTGXC WD 45 ELBOW *
3 C X FTG WD 45 ELBOW *	1-1/4 CXC WD 45 ELBOW *
1-1/2 CXC WD 45 ELBOW *	2 CXC WD 45 ELBOW *
3 CXC WD 45 ELBOW *	1-1/4 CXC WD 90 ELBOW *
1-1/4 FTGXC WD 90 ELBOW *	1-1/2 FTGXC WD 90 ELBOW *
2 FTGXC WD 90 ELBOW *	1-1/2 CXC WD 90 ELBOW *
2 CXC WD 90 ELBOW *	3 CXC WD 90 ELBOW *
1-1/2 CXC WD 90 LT ELBOW *	2 CXC WD 90 LT ELBOW *
1/4 CXC WP 45 ELBOW *	3/8 CXC WP 45 ELBOW *
1/2 CXC WP 45 ELBOW *	5/8 CXC WP 45 ELBOW *
3/4 CXC WP 45 ELBOW *	1 CXC WP 45 ELBOW *
1-1/4 CXC WP 45 ELBOW *	1/4 FTG X C WP 45 ELBOW *
3/8 FTGXC WP 45 ELBOW *	1/2 FTGXC WP 45 ELBOW *
5/8 FTGXC WP 45 ELBOW *	3/4 FTGXC WP 45 ELBOW *
1 FTGXC WP 45 ELBOW *	1-1/4 FTGXC WP 45 ELBOW *
1-1/2 FTGXC WP 45 ELBOW *	2 FTGXC WP 45 ELBOW *
1-1/2 CXC WP 45 ELBOW *	2-1/2 FTGXC WP 45 ELBOW *
2 CXC WP 45 ELBOW *	2-1/2 CXC WP 45 ELBOW *
3 CXC WP 45 ELBOW *	4 CXC WP 45 ELBOW *
1/4 CXC WP 90 ELBOW *	3/8 CXC WP 90 ELBOW *
1/2 CXC WP 90 ELBOW *	5/8 CXC WP 90 ELBOW *
3/4 CXC WP 90 ELBOW *	3/4 X 1/2 CXC WP 90 ELBOW *
1 CXC WP 90 ELBOW *	1 X 1/2 CXC WP 90 ELBOW *
1 X 3/4 CXC WP 90 ELBOW *	1-1/4 CXC WP 90 ELBOW *
1-1/4 X 1 CXC WP 90 ELBOW *	1/4 FTGXC WP 90 ELBOW *
3/8 FTGXC WP 90 ELBOW *	1/2 FTGXC WP 90 ELBOW *
5/8 FTGXC WP 90 ELBOW *	3/4 FTGXC WP 90 ELBOW *
1 FTGXC WP 90 ELBOW *	1-1/4 FTGXC WP 90 ELBOW *
1/2 FTGXFTG WP 90 ELBOW *	3/4 FTG X FTG WP 90 ELBOW *
1-1/2 FTGXC WP 90 ELBOW *	2 FTGXC WP 90 ELBOW *
1-1/2 CXC WP 90 ELBOW *	2-1/2 FTGXC WP 90 ELBOW *
1-1/2CX 1-1/4C WP 90 ELBOW *	2 CXC WP 90 ELBOW *
2-1/2 CXC WP 90 ELBOW *	3 CXC WP 90 ELBOW *
4 CXC WP 90 ELBOW *	1/2 CXC WP 90 VENT ELBOW *
3/4 CXC WP 90 VENT ELBOW *	1 CXC WP 90 VENT ELBOW *
1/4 CXC LT WP 90 ELBOW	3/8 CXC LT WP 90 ELBOW
1/2 CXC LT WP 90 ELBOW	5/8 CXC LT WP 90 ELBOW
3/4 CXC LT WP 90 ELBOW	1 CXC LT WP 90 ELBOW
1-1/4 CXC LT WP 90 ELBOW	1/4 CXFTG LT WP 90 ELBOW
3/8 C X FTG LT WP 90 ELBOW	1/2 C X FTG LT WP 90 ELBOW
5/8 CXFTG LT WP 90 ELBOW	3/4 CXFTG LT WP 90 ELBOW
1 CXFTG LT WP 90 ELBOW	1-1/4 CXFTG LT WP 90 ELBOW
1-1/2 CXFTG LT WP 90 ELBOW	2 CXFTG LT WP 90 ELBOW
1-1/2 CXC LT WP 90 ELBOW	2 CXC LT WP 90 ELBOW

Subject Copper Pipe Fittings – Flanges

3 X 4 CXC CD CLOSET FLANGE *	4 X 4 CXC CD CLOSET FLANGE *
4 CD CAULKING FLOOR FLANGE *	3 X 4 CD ECCENTRIC CLOSET FLANGE *
3 X 4 FITTING CD CLOSET FLANGE	4 CD LEAD 8 OZ CLOSET FLANGE
3 X 4 CD M J CLOSET FLANGE *	4 CD 14OZ LEAD CLOSET FLANGE
1/2 CP COMPANION FLANGE - 125#	3/4 CP COMPANION FLANGE - 125#
1 CP COMPANION FLANGE - 125#	1-1/4 CP COMPANION FLANGE - 125#
1-1/2 CP COMPANION FLANGE - 125#	2 CP COMPANION FLANGE - 125#
2-1/2 CP COMPANION FLANGE - 125#	3 CP COMPANION FLANGE - 125#
3-1/2 CP COMPANION FLANGE #125	4 CP COMPANION FLANGE - 125#
5 CP COMPANION FLANGE - 125#	6 CP COMPANION FLANGE - 125#
8 CP COMPANION FLANGE - 125#	1/2 CP COMPANION FLANGE - 150#
3/4 CP COMPANION FLANGE - 150#	1 CP COMPANION FLANGE - 150#
1-1/4 CP COMPANION FLANGE - 150#	1-1/2 CP COMPANION FLANGE - 150#
2 CP COMPANION FLANGE - 150#	2-1/2 CP COMPANION FLANGE - 150#
3 CP COMPANION FLANGE - 150#	3-1/2 CP COMPANION FLANGE #150
4 X 9 CP COMPANION FLANGE - 150#	5 CP COMPANION FLANGE - 150#
6 CP COMPANION FLANGE -150#	8 CP COMPANION FLANGE - 150#
1/2 CP COMPANION FLANGE - 300#	1 X 5 CP COMPANION FLANGE - 300#
1-1/4 CP COMPANION FLANGE - 300#	1-1/2 X 6-1/2 CP COMPANION FLANGE-300#
2 CP COMPANION FLANGE - 300#	2-1/2 CP COMPANION FLANGE - 300#
3 X 8-1/4 CP COMPANION FLANGE - 300#	4 CP COMPANION FLANGE - 300#
1-1/2 CP BLIND COMPANION FLANGE	2 X 6 CP BLIND COMPANION FLANGE
3 X 7-1/2 CP BLIND COMPANION FLANGE	13-1/2 X 8 CP BLIND COMPANION FLANGE
8 COMP CP FLANGE 125# SILVER BRZD	3 COMP CP FLANGE 150# SILVER BRZD
8 COMP CP FLANGE 150# SILVER BRZD

Subject Copper Pipe Fittings – Pressure Tees

1/2 CXCXC CP DROP EAR TEE	1/2 CXCXFE CP TEE
1/2 X 1/2 X 1/4 CXCXFE CP TEE	1/2C X 1/2C X 3/8FE CP TEE
1/2 X 1/2 X 3/4 CXCXFE CP TEE	3/4 CXCXFE CP TEE
3/4C X 1/2C X 1/2FE CP TEE	3/4 X 1/2 X 3/4 CXCXFE CP TEE
3/4 X 3/4 X 3/8 CCFE CP TEE	3/4C X 3/4C X 1/2FE CP TEE
3/4 X 3/4 X 1 CXCXFE CP TEE	1 CXCXFE CP CP TEE
1 X 1 X 1/2 CXCXFE CP TEE	1 X 1 X 3/4 CXCXFE CP TEE
1-1/4 CXCXFE CP TEE	1-1/4 X 1-1/4 X 1/2 CCFE CP TEE
1-1/4 X 1-1/4 X 3/4 CCFE CP TEE	1-1/4X1-1/4X1 CCFE CP TEE
1-1/2 CXCXFE CP TEE	1-1/2X1-1/2X1/2 CCFE CP TEE
1-1/2 X 1-1/2 X 3/4 CCFE CP TEE	1-1/2 X 1-1/2 X 1 CCFE CP TEE
1/2 CXFEXFE CP TEE	1/2C X 3/4FE X 1/2FE CP TEE
3/4 C X FE X FE CP TEE	3/4 C X 3/4 FE X 1/2 FE CP TEE
2 CXCXFE CP TEE	2 X 2 X 1/2 CXCXFE CP TEE
2 X 2 X 3/4 CXCXFE CP TEE	2 X 2 X 1 CXCXFE CP TEE
1/2 CXCXFE CP DROP EAR TEE	3/4 CXCXFE CP DROP EAR TEE
3/4C X 3/4C X 1/2FE W/B CP TEE	3/8 C X FE X C CP TEE
1/2 CXFEXC CP TEE	1/2C X 1/2FE X 3/4C CP TEE
1/2C X 3/4FE X 1/2C CP TEE	3/4 CXFEXC CP TEE
3/4 X 1/2 X 1/2 CXFEXC CP TEE	3/4C X 1/2FE X 3/4C CP TEE
3/4C X 3/4FE X 1/2C CP TEE	1 CXFEXC CP TEE
1C X 1/2FE X 1C CP TEE	1 X 3/4 X 1 CXFEXC CP TEE
1-1/4 CXFEXC CP TEE	1-1/4 X 1/2 X 1-1/4 CXFEXC CP TEE
1-1/4 X 3/4 X 1-1/4 CXFEXC CP TEE	1-1/2 C X FE X C CP TEE
1-1/2X1/2X1-1/2 CXFEXC CP TEE	1-1/2X3/4X1-1/2 CXFEXC CP TEE
1/2 FEXFEXC CP TEE	3/4 FEXFEXC CP TEE
3/4FE X 1/2FE X 1/2C CP TEE	3/4FE X 1/2FE X 3/4C CP TEE
3/4FE X 3/4FE X 1/2C CP TEE	2 C X FE X C CP TEE
2 X 1/2 X 2 CXFEXC CP TEE	2 X 3/4 X 2 CXFEXC CP TEE
1/2FE X 3/4M X 1/2C CP TEE	1/2 CXCXCXC CP CROSS *
3/4 CXCXCXC CP CROSS *	1 CXCXCXC CP CROSS *
1-1/2 CXCXCXC CP CROSSES *	2 CXCXCXC CP CROSS *
3/4 CXFTGXC CP TEE *	2 X 2 X 3 CXCXC CP TEE *
2-1/2 X 1/2 X 2-1/2 CP TEE *	2-1/2 X 1-1/2 X 1-1/2 CP TEE *
5 CXCXC CP TEE *	5 X 5 X 3 CXCXC CP TEE *
6 CXCXC CP TEE *	3/4FE X 1/8 FE X 3/4C WP BASEBOARD TEE *
1/8 CXCXC WP TEE *	1/4 CXCXC WP TEE *
3/8 CXCXC WP TEE *	1/2 CXCXC WP TEE *
1/2 X 1/2 X 3/4 CXCXC WP TEE *	3/4 CXCXC WP TEE *
3/4 X 1/2 X 1/2 CXCXC WP TEE *	3/4 X 1/2 X 3/4 CXCXC WP TEE *
3/4 X 3/4 X 1/4 CXCXC WP TEE *	3/4C X 3/4C X 3/8C CXCXC WP TEE *
3/4 X 3/4 X 1/2 CXCXC WP TEE *	1 CXCXC WP TEE *
1 X 1/2 X 1/2 CXCXC WP TEE *	1 X 1/2 X 3/4 CXCXC WP TEE *
1 X 1/2 X 1 CXCXC WP TEE *	1 X 3/4 X 1/2 CXCXC WP TEE *
1 X 3/4 X 3/4 CXCXC WP TEE *	1 X 3/4 X 1 CXCXC WP TEE *
1 X 1 X 3/8 CXCXC WP TEE *	1 X 1 X 1/2 CXCXC WP TEE *
1 X 1 X 3/4 CXCXC WP TEE *	1-1/4 CXCXC WP TEE *
1-1/4 X 1/2 X 1/2 CXCXC WP TEE *	1-1/4 X 1/2 X 3/4 CXCXC WP TEE *
1-1/4 X 1/2 X 1 CXCXC WP TEE *	1-1/4 X 1/2 X 1-1/4 CXCXC WP TEE *
1-1/4 X 3/4 X 1/2 CXCXC WP TEE *	1-1/4 X 3/4 X 3/4 CXCXC WP TEE *
1-1/4 X 3/4 X 1 CXCXC WP TEE *	1-1/4 X 3/4 X 1-1/4 CXCXC WP TEE *
1-1/4 X 1 X 1/2 CXCXC WP TEE *	1-1/4 X 1 X 3/4 CXCXC WP TEE *
1-1/4 X 1 X 1 CXCXC WP TEE *	1-1/4 X 1 X 1-1/4 CXCXC WP TEE *
1-1/4 X 1-1/4 X 1/2 CXCXC WP TEE *	1-1/4 X 1-1/4 X 3/4 CXCXC WP TEE *
1-1/4C X 1-1/4C X 1C CXCXC WP TEE *	1-1/2 CXCXC CXCXC WP TEE *
1-1/2 X 1/2 X 1/2 CXCXC WP TEE *	1-1/2 X 1/2 X 3/4 CXCXC WP TEE *
1-1/2 X 1/2 X 1 CXCXC WP TEE *	1-1/2 X 1/2 X 1-1/4 CXCXC WP TEE *
1-1/2 X 1/2 X 1-1/2 CXCXC WP TEE *	1-1/2 X 3/4 X 1/2 CXCXC WP TEE *
1-1/2 X 3/4 X 3/4 CXCXC WP TEE *	1-1/2 X 3/4 X 1 CXCXC WP TEE *
1-1/2 X 3/4 X 1-1/4 CXCXC WP TEE *	1-1/2 X 3/4 X 1-1/2 CXCXC WP TEE *
1-1/2 X 1 X 1/2 CXCXC WP TEE *	1-1/2 X 1 X 3/4 CXCXC WP TEE *
1-1/2 X 1 X 1 CXCXC WP TEE *	1-1/2 X 1 X 1-1/4 CXCXC WP TEE *
1-1/2 X 1 X 1-1/2 CXCXC WP TEE *	1-1/2 X 1-1/4 X 1/2 CXCXC WP TEE *
1-1/2 X 1-1/4 X 3/4 CXCXC WP TEE *	1-1/2 X 1-1/4 X 1 CXCXC WP TEE *
1-1/2 X 1-1/4 X 1-1/4 CXCXC WP TEE *	1-1/2 X 1-1/4 X 1-1/2 CXCXC WP TEE *
1-1/2 X 1-1/2 X 1/2 CXCXC WP TEE *	1-1/2 X 1-1/2 X 3/4 CXCXC WP TEE *
1-1/2 X 1-1/2 X 1 CXCXC WP TEE *	1-1/2 X 1-1/2 X 1-1/4 CXCXC WP TEE *
2 CXCXC CXCXC WP TEE *	2 X 1/2 X 2 CXCXC WP TEE *
2 X 3/4 X 2 CXCXC WP TEE *	2 X 1 X 3/4 CXCXC WP TEE *
2 X 1 X 1 CXCXC WP TEE *	2C X 1C X 1-1/4C CXCXC WP TEE *
2 X 1 X 1-1/2 CXCXC WP TEE *	2 X 1 X 2 CXCXC WP TEE *
2 X 1-1/4 X 1/2 CXCXC WP TEE *	2 X 1-1/4 X 3/4 CXCXC WP TEE *
2 X 1-1/4 X 1 CXCXC WP TEE *	2 X 1-1/4 X 1-1/4 CXCXC WP TEE *
2 X 1-1/4 X 1-1/2 CXCXC WP TEE *	2 X 1-1/4 X 2 CXCXC WP TEE *
2 X 1-1/2 X 1/2 CXCXC WP TEE *	2 X 1-1/2 X 3/4 CXCXC WP TEE *
2 X 1-1/2 X 1 CXCXC WP TEE *	2 X 1-1/2 X 1-1/4 CXCXC WP TEE *
2 X 1-1/2 X 1-1/2 CXCXC WP TEE *	2 X 1-1/2 X 2 CXCXC WP TEE *
2 X 2 X 1/2 CXCXC WP TEE *	2 X 2 X 3/4 CXCXC WP TEE *
2 X 2 X 1 CXCXC WP TEE *	2 X 2 X 1-1/4 CXCXC WP TEE *
2 X 2 X 1-1/2 CXCXC WP TEE *	2-1/2 CXCXC WP TEE *
2-1/2 X 1/2 X 2-1/2 CXCXC WP TEE *	2-1/2 X 3/4 X 1-1/2 CXCXC WP TEE *
2-1/2 X 3/4 X 2-1/2 CXCXC WP TEE *	2-1/2 X 1 X 1-1/4 CXCXC WP TEE *
2-1/2 X 1 X 1-1/2 CXCXC WP TEE *	2-1/2 X 1 X 2 CXCXC WP TEE *
2-1/2 X 1 X 2-1/2 CXCXC WP TEE *	2-1/2 X 1-1/4 X 1-1/4CXCXC WP TEE *
2-1/2 X 1-1/4 X 1-1/2 CXCXC WP TEE *	2-1/2 X 1-1/4 X 2 CXCXC WP TEE *
2-1/2 X 1-1/4 X 2-1/2 CXCXC WP TEE *	2-1/2 X 1-1/2 X 1 CXCXC WP TEE *
2-1/2 X 1-1/2 X 1-1/4 CXCXC WP TEE *	2-1/2 X 1-1/2 X 1-1/2 CXCXC WP TEE *
2-1/2 X 1-1/2 X 2 CXCXC WP TEE *	2-1/2 X 1-1/2 X 2-1/2 CXCXC WP TEE *
2-1/2 X 2 X 1/2 CXCXC WP TEE *	2-1/2 X 2 X 3/4 CXCXC WP TEE *
2-1/2 X 2 X 1 CXCXC WP TEE *	2-1/2 X 2 X 1-1/4 CXCXC WP TEE *
2-1/2 X 2 X 1-1/2 CXCXC WP TEE *	2-1/2 X 2 X 2 CXCXC WP TEE *
2-1/2 X 2 X 2-1/2 CXCXC WP TEE *	2-1/2 X 2-1/2 X 1/2 CXCXC WP TEE *
2-1/2 X 2-1/2 X 3/4 CXCXC WP TEE *	2-1/2 X 2-1/2 X 1 CXCXC WP TEE *
2-1/2 X 2-1/2 X 1-1/4 CXCXC WP TEE *	2-1/2 X 2-1/2 X 1-1/2 CXCXC WP TEE *
2-1/2 X 2-1/2 X 2 CXCXC WP TEE *	3 CXCXC WP TEE *
3 X 3/4 X 3 CXCXC WP TEE *	3 X 1 X 3 CXCXC WP TEE *
3 X 1-1/4 X 3 CXCXC WP TEE *	3 X 1-1/2 X 1-1/4 CXCXC WP TEE *
3 X 1-1/2 X 1-1/2 CXCXC WP TEE *	3 X 1-1/2 X 2-1/2 CXCXC WP TEE *
3 X 1-1/2 X 3 CXCXC WP TEE *	3 X 2 X 1/2 CXCXC WP TEE *
3 X 2 X 1 CXCXC WP TEE *	3 X 2 X 1-1/4 CXCXC WP TEE *
3 X 2 X 1-1/2 CXCXC WP TEE *	3 X 2 X 2 CXCXC WP TEE *
3 X 2 X 2-1/2 CXCXC WP TEE *	3 X 2 X 3 CXCXC WP TEE *
3 X 2-1/2 X 3/4 CXCXC WP TEE *	3 X 2-1/2 X 1 CXCXC WP TEE *
3 X 2-1/2 X 1-1/4 CXCXC WP TEE *	3 X 2-1/2 X 1-1/2 CXCXC WP TEE *
3 X 2-1/2 X 2 CXCXC WP TEE *	3 X 2-1/2 X 2-1/2 CXCXC WP TEE *
3 X 2-1/2 X 3 CXCXC WP TEE *	3 X 3 X 1/2 CXCXC WP TEE *
3 X 3 X 3/4 CXCXC WP TEE *	3 X 3 X 1 CXCXC WP TEE *
3 X 3 X 1-1/4 CXCXC WP TEE *	3 X 3 X 1-1/2 CXCXC WP TEE *
3 X 3 X 2 CXCXC WP TEE *	3 X 3 X 2-1/2 CXCXC WP TEE *
4 CXCXC WP TEE *	4 X 1-1/2 X 3 CXCXC WP TEE *
4 X 2 X 2 CXCXC WP TEE *	4 X 2 X 3 CXCXC WP TEE *
4 X 2-1/2 X 2-1/2 CXCXC WP TEE *	4 X 2-1/2 X 3 CXCXC WP TEE *
4 X 3 X 2 CXCXC WP TEE *	4 X 3 X 2-1/2 CXCXC WP TEE *
4 X 3 X 3 CXCXC WP TEE *	4 X 4 X 1/2 CXCXC WP TEE *
4 X 4 X 3/4 CXCXC WP TEE *	4 X 4 X 1 CXCXC WP TEE *
4 X 4 X 1-1/4 CXCXC WP TEE *	4 X 4 X 1-1/2 CXCXC WP TEE *
4 X 4 X 2 CXCXC WP TEE *	4 X 4 X 2-1/2 CXCXC WP TEE *
4 X 4 X 3 CXCXC WP TEE *	5 X 5 X 2 CXCXC WP TEE *

Subject Copper Pipe Fittings – Unions

2-1/2 CXFE CP UNION *	2-1/2 CXC CP UNION *
2 CXM CP UNION *	2-1/2 C X M CP UNION *
3 CXC CP UNION *	3/4 CXM CP UNION ELBOW
3/4 CXC WP UNION *	1 CXC WP UNION *
1-1/4 CXC WP UNION *	1-1/2 C X C WP UNION *
1/2 C X FE WP UNION *	3/4 C X FE WP UNION *
1 C X FE WP UNION *	2 CXC WP UNION *
1-1/4 C X FE WP UNION *	1-1/2 C X FE WP UNION *
2 C X FE WP UNION *	1/2 C X M WP UNION *
3/4 C X M WP UNION *	1 C X M WP UNION *
1-1/4 C X M WP UNION *	1-1/2 C X M WP UNION *
2 C X M WP UNION *

Subject Copper Pipe Fittings – P-Traps

1-1/4 CXC CD P-TRAP BODY N/CO	1-1/2 C X C CD P-TRAP BODY N/CO
2 C X C CD P-TRAP BODY N/CO	3 C X C CD P-TRAP BODY N/CO
1-1/4 CD P TRAP - N/CO	1-1/4 CD P TRAP-N/CO- ELBOW
1-1/2 P TRAP - N/CO-	1-1/2 CD P TRAP-N/CO-ELBOW
2 CD P TRAP - N/CO	2 CD P TRAP-N/CO-ELBOW
3 CD P TRAP - N/CO	3 CD P TRAPS-N/CO-ELBOW
1 1/4 CD S TRAP N/CO	1 1/2 CD S TRAP N/CO
1-1/4 CD S TRAP - W/CO	1-1/2 CD S TRAP - W/CO
2 CD S TRAP W/CO	1-1/2 C X C CD P-TRAP BODY - W/CO
2 C X C CD P-TRAP BODY - W/CO	1-1/4 CD P TRAP - W/CO
1-1/4 CD P TRAP-W/CO-ELBOW	1-1/2 CD P TRAP W/CO
1-1/2 CD P TRAP-W/CO-ELBOW	2 CD P TRAP - W/CO
2 CD P TRAP-W/CO-ELBOW	3 CD P TRAP - W/CO
3 CD P TRAP-W/CO-ELBOW	3 X 6 X 1-1/2 X 1-1/2 CD DRUM TRAP
1-1/2 CD P TRAP L/CO GROUND SWIVEL	1-1/2 CD P TRAP W/CO GROUND SWIVEL

Subject Copper Pipe Fittings – DWV TY’s

1-1/4 CXCXCXC CD DOUBLE WASTE FTG	1-1/2 CXCXCXC CD DOUBLE WASTE FTG
1-1/2 1-1/4 1-1/4 1-1/4 CXCXCXC CD DOUBLE WASTE FTG	1-1/2 1-1/4 1-1/2 1-1/2 CXCXCXC CD DOUBLE WASTE FTG
1-1/2 1-1/2 1-1/4 1-1/4 CXCXCXC CD DOUBLE WASTE FTG	2 1-1/2-1-1/4-1-1/4 CXCXCXC CD DOUBLE WASTE FTG
2 1-1/2 1-1/2 1-1/2 CXCXCXC CD DOUBLE WASTE FTG	1-1/4 CXCXC CD TY *
1-1/2 CXCXC CD TY *	1-1/2 X 1-1/4 X 1-1/4 CXCXC CD TY *
1-1/2 X 1-1/4 X 1-1/2 CXCXC CD TY *	1-1/2 X 1-1/2 X 1-1/4 CXCXC CD TY *
3 FTG X C X C CD TY *	3 X 3 X 1-1/4 FTGXCXC CD TY *
3 X 3 X 1-1/2 FTGXCXC CD TY *	3 X 3 X 2 FTGXCXC CD TY *
2 CXCXC CD TY *	2 X 1-1/4 X 1-1/4 CXCXC CD TY *
2 X 1-1/4 X 1-1/2 CXCXC CD TY *	2 X 1-1/4 X 2 CXCXC CD TY *
2 X 1-1/2 X 1-1/4 CXCXC CD TY *	2 X 1-1/2 X 1-1/2 CXCXC CD TY *
2 X 1-1/2 X 2 CXCXC CD TY *	2 X 2 X 1-1/4 CXCXC CD TY *
2 X 2 X 1-1/2 CXCXC CD TY *	1-1/2 CXCXFE CD TY *
2 CXCXFE CD TY	2 X 1-1/2 X 1-1/2 CXCXF CD TY
3 CXCXC CD TY *	3 X 1-1/2 X 1-1/4 CXCXC CD TY *
3 X 2 X 1-1/2 CXCXC CD TY *	3 X 3 X 1-1/4 CXCXC CD TY *
3 X 3 X 1-1/2 CXCXC CD TY *	3 X 3 X 2 CXCXC CD TY *
4 CXCXC CD TY *	4 X 4 X 1-1/2 CXCXC CD TY *
4 X 4 X 2 CXCXC CD TY *	4 X 4 X 3 CXCXC CD TY *
1-1/4 CXCXCXC CD DOUBLE TY	1-1/2 CXCXCXC CD DOUBLE TY
1-1/2 1-1/2 1-1/4 1-1/4 CXCXCXC CD DOUBLE TY	1-1/2 1-1/4 1-1/4 1-1/4 CXCXCXC CD DOUBLE TY
2 CXCXCXC CD DOUBLE TY	2 X 2 X 1-1/4 X 1-1/4 CXCXCXC CD DOUBLE TY
2 X 2 X 1-1/2 X 1-1/2 CXCXCXC CD DOUBLE TY	3 CXCXCXC CD DOUBLE TY
3 X 3 X 1-1/4 X 1-1/4 CXCXCXC CD DOUBLE TY	3 X 3 X 1-1/2 X 1-1/2 CXCXCXC CD DOUBLE TY
3 X 3 X 2 X 2 CXCXCXC CD DOUBLE TY	4 CXCXCXC CD DOUBLE TY
4 X 4 X 2 X 2 CXCXCXC CD DOUBLE TY	4 X 4X 3 X 3 CXCXCXC CD DOUBLE TY
1-1/4 CXCXCXC CD DOUBLE LONG TURN TY	1-1/2 CXCXCXC CD DOUBLE LONG TURN TY
1-1/2 1-1/2 1-1/4 1-1/4 CXCXCXC CD DLT TY	2 CXCXCXC CD DOUBLE LONG TURN TY
2 X 2 X 1-1/4 X 1-1/4 CXCXCXC CD DLT TY	2 X 2 X 1-1/2 X 1-1/2 CXCXCXC CD DLT TY
1-1/2 CXCXC LONG TURN CD TY	2 CXCXC LONG TURN CD TY
3X3X3X1-1/2 CXCXCXC SIDEOUT RH CD TY	3X3X3X1-1/2 CXCXCXC SIDEOUT LH CD TY

Subject Copper Pipe Fittings – DWV Y’s

1-1/4 CXCXC CD 45 Y *	1-1/2 CXCXC CD 45 Y *
1-1/2CX 1-1/4CX 1-1/4C CD 45 Y *	1-1/2CX 1-1/4CX 1-1/2C CD 45 Y *
1-1/2CX 1-1/2CX 1-1/4C CD 45 Y *	2 CXCXC 45 CD Y *
2CX 1-1/4CX 1-1/4C CD 45 Y *	2CX 1-1/4CX 1-1/2C CD 45 Y *
2CX 1-1/4CX 2C CD 45 Y *	2CX 1-1/2CX 1-1/4C CD 45 Y *
2CX 1-1/2CX 1-1/2C CD 45 Y *	2CX 1-1/2CX 2C CD 45 Y *
2CX 2CX 1-1/4C CD 45 Y *	2CX 2CX 1-1/2C CD 45 Y *
3 CXCXC CD 45 Y *	3C X 2C X 2C CD 45 Y *
3CX 3CX 1-1/4C CD 45 Y *	3CX 3CX 1-1/2C CD 45 Y *
3CX 3CX 2C CD 45 Y *	4 CXCXC CD 45 Y *
4CX 4CX 2C CD 45 Y *	4CX 4CX 3C CD 45 Y *
1-1/4 CXCXCXC CD 45 DOUBLE Y	1-1/2 CXCXCXC CD 45 DOUBLE Y
1-1/2 1-1/2 1-1/4 1-1/4 CXCXCXC CD DOUBLE Y	2 CXCXCXC CD 45 DOUBLE Y
2 X 2 X 1-1/4 X 1-1/4 CXCXCXC CD DOUBLE Y	2 X 2 X 1-1/2 X 1-1/2 CXCXCXC CD DOUBLE Y
3 CXCXCXC CD 45 DOUBLE Y	3 X 3 X 1-1/2 X 1-1/2 CXCXCXC CD DOUBLE Y

Subject Copper Pipe Fittings – Caps and Cleanouts

5 CP TUBE END CAP *	6 CP TUBE END CAP *
1-1/2 CXC/O CD TUBE END CLEANOUT *	3 CD CXC/O TUBE END CLEANOUT *
3 FTGXC/O CD CLEANOUT - FLUSH TYPE *	4 FTGXC/O CD CLEANOUT - FLUSH TYPE *
1-1/4 FTGXC/O CD CLEANOUT - FULL PLUG *	1-1/2 FTGXC/O CD CLEANOUT - FULL PLUG *
2 FTGXC/O CD CLEANOUT - FULL PLUG *	3 FTGXC/O CD CLEANOUT - FULL PLUG *
4 FTGXC/O CD CLEANOUT - FULL PLUG *	1-1/4 CXCXCO CD LINE CLEANOUT
1-1/2 CXCXCO CD LINE CLEANOUT	2 CXCXCO CD LINE CLEANOUT
3 CXCXCO CD LINE CLEANOUT	4 CXCXCO CD LINE CLEANOUT
1-1/2 CXCXCO CLEANOUT-FULL PLUG	2 CXCXCO CD CLEANOUT - FULL PLUG
3 CXCXCO CD CLEANOUT - FULL PLUG	1-1/4 CXCO WD TUBE END CLEANOUT *
1-1/2 CXCO WD TUBE END CLEANOUT *	2 CXCO WD TUBE END CLEANOUT *
3 CXCO WD TUBE END CLEANOUT *	1-1/4 WD FLUSH FTGXCO CLEANOUT *
1-1/2 FTGXCO WD CLEANOUT-FLUSH TYPE *	1-1/2 X 1 FTGXCO WD CLEANOUT - FLUSH *
2 FTGXCO WD CLEANOUT-FLUSH TYPE *	1-1/4 FTGXCO WD CLEANOUT FULL PLUG *
1-1/2 FTGXCO WD CLEANOUT FULL PLUG *	2 FTGXCO WD CLEANOUT FULL PLUG *

---

1. R.S. 1985, c. S-15.
2. OECD, DAC List of Aid Recipients – As at 1 January 2003, online: http://www.oecd.org/dataoecd/35/9/2488552.pdf
3. Certain Solder Joint Pipe Fittings from the United States, Anti-dumping Investigation No. 4258-35 – AD 1003, initiated February 5, 1993.
4. Tribunal Statement of Reasons re: Decision of Injury regarding certain solder joint pressure pipe fittings and solder joint drainage, waste and vent fittings originating in or exported from the United States and produced by or on behalf of Elkhart Products Corporation, Nibco Inc. and Mueller Industries, Inc., their successors and assigns, October 18, 1993, Tribunal Inquiry No.: NQ-93-001.
5. Tribunal Statement of Reasons re: Order rescinding finding regarding certain solder joint pressure pipe fittings and solder joint drainage, waste and vent fittings originating in or exported from the United States and produced by or on behalf of Elkhart Products Corporation, Nibco Inc. and Mueller Industries, Inc., their successors and assigns,
   October 16, 1998,Tribunal Review No.: RR-97-008.
6. Supra note 4.
7. NAFTA Memorandum Opinion and Order re: Pipe fittings from the United States of America (Injury) – FTA Chapter 19, NAFTA Secretariat File No.: CDA-93-1904.11, February 13, 1995.
8. Tribunal Statement of Reasons re: Decision of Injury regarding certain carbon steel pipe nipples, threaded couplings and adaptor fittings originating in or exported from China, Inquiry No.:  NQ-2002-004, July 16, 2003.
9. The CBSA reviewed various Web sites on the Internet particularly the following Web sites:  The Canadian Institute of Plumbing and Heating; The Canadian Copper and Brass development Association; The Heating and Refrigeration Institute of Canada; and Industry Canada’s Strategis. 
10. Trade data can be sourced at the following Web site: http://strategis.ic.gc.ca/sc_mrkti/tdst/engdoc/tr_homep.html.
11. In view of the fact that Cello has presented evidence of injury using pounds as a measurement of volume, the CBSA has adjusted import volume from kilograms to pounds using a conversion ratio of 1 kilogram equalling 2.204622622 pounds.
12. Based on public information of the United States Department of Labor contained in Appendix 13 of Cello’s complaint.
13. Cello’s amounts for GS&A and profit had been established as a percentage of Net Sales.
14. Based on the average minimum wage rates for the provinces of Shandong, Guangdong and Zhejiang, as published by China Labour Market at http://www.lm.gov.cn/gb/salary/2005-04/30/content_70889.htm, the complainant adjusted its average hourly wage rate for machine operators to CD $0.43/hour.
15. Revenue Canada Customs and Excise Statement of Reasons re:  certain solder joint pressure pipe fittings and solder joint drainage, waste and vent fittings originating in or exported from the United States and produced by or on behalf of Elkhart Products Corporation, Nibco Inc. and Mueller Industries, Inc., their successors and assigns, Anti-dumping Investigation No. 4258-35 - Case No. AD 1003, February 5, 1993.
16. The margin of dumping for each representative model for the full year 2005 was estimated by the complainant as a simple average of the magnitudes of the margins of dumping for the six two-month periods in 2005.  Taking into account all of margins of dumping for every two-month period where Cello was able to estimate a normal value and export price, the complainant’s estimates of margin of dumping ranged from 11.3% to 155.4%.
17. WTO Committee on Subsidies and Countervailing Measures, New and Full Notification Pursuant to Article XVI:1 of the GATT 1994 and article 25 of the SCM Agreement, People’s Republic of China (G/SCM/N/123/CHN), 13, April 2006.
18. The Economist Intelligence Unit Limited 2005, China Hand, April 2005, Chapter 4, Investing, page 9.
19. The Economist Intelligence Unit Limited 2005, China Hand, May 2005, Chapter 5, Investment Locations,
    pages 39-40.
20. e="_ftn4" title="" id="_ftn4">   Outdoor Barbeques, CBSA File No. 4218-16 - Case No. CVD 102.
21. Article downloaded from the Internet entitles “Zhejiang Government Aims to develop a Major Copper [Industry]”, www.chinaScrap.com 2004-11-19.
22. CBSA Statement of Reasons re: Final Determination of Laminate Flooring from China File No. 4218-19, Case No. CVD 104, June 2, 2005.
23. Ibid.
24. Refer to Chart 1 of Cello’s complaint.  The Web site for the London Metal Exchange is http://www.lme.co.uk/dataprices_pricegraphs.asp .
25. Supra note 5, page 18.
26. The CBSA considers these estimates conservative in light of the fact that imports from other countries were not adjusted to exclude non-subject goods.
27. Pex being an acronym for cross-linked polyethylene pipe.
28. Taken from page 4 of the 2005 Annual Report of Mueller Industries Inc.  The company’s 2005 Annual Report can be found at: http://library.corporate-ir.net/library/98/987/98707/items/190139/2005AnnualReport.pdf.
29. Refer to page 34 of Cello’s complaint. 
30. Supra note 5, p. 12.
31. Tribunal Pre-Hearing Staff Report, Review No.:RR-97-008, page 59.