The National Biodiesel Board Fair Trade Coalition submitted comments for the record Dec. 3 on how the U.S. Department of Commerce should conduct recently initiated changed circumstances reviews (CCRs) of U.S. duties on Argentine biodiesel imports. The commerce department imposed countervailing duty (CVD) and antidumping (AD) duty orders in January and April 2018, following investigations that found massively subsidized and dumped biodiesel imports from Argentina had significantly injured U.S. biodiesel producers.

The coalition’s comments state, “[The commerce department] must conduct a rigorous, comprehensive review of all relevant facts since its CVD and AD investigations, and not limit its consideration to the limited facts and narrow time period showcased by the government of Argentina in its requests for reviews.”

In the letter, the coalition further urges the department to undertake reviews that are no less rigorous than its annual administrative review process, with appropriate periods of review, extensive fact-finding, and adherence to strict administrative procedures. The coalition asks the commerce department to review all of Argentina’s actions since January 2017 relating to the provision of below-market priced soybeans to the biodiesel industry through high export taxes. The commerce department invited the comments following a Nov. 19 meeting with NBB representatives.

Kurt Kovarik, NBB’s vice president of federal affairs, added, “Argentina has made more than a dozen changes to its subsidies since January 2017. In fact, throughout 2017—even after [the commerce department] completed its original investigation—Argentina continued to massively subsidize its biodiesel industry. Given this history, [the commerce department] should understand that Argentina is very likely to provide new subsidies to its domestic biodiesel producers in the future. Any outcome from these new changed circumstances reviews should be based only on the record developed during the reviews.”

The letter further recommends that the department issue extensive questionnaires to the government of Argentina and Argentina’s biodiesel industries, establish deadlines for each stage of the newly initiated reviews, and provide an opportunity for public input.