(322) Ningbo Jinding also claimed that the Commission has applied an incorrect voltage level for the electricity tariffs charged to Ningbo Jinding during the IP since the actual voltage level of the company is beyond 12 kV. The Commission reviewed and adjusted the benchmark in relation to the voltage level of Ningbo Jinding, as confirmed by evidence collected in the RCC exercise, relevant for the electricity tariffs charged to Ningbo Jinding during the IP.
3.9.3.3. Inland freight and import duties adjustment applied to the benchmark of the raw materials
(323) Ningbo Jinding claimed that the Commission wrongly calculated inland freight based on a percentage of the value of the raw material, while the freight for the raw material purchases is usually determined on the basis of purchase volume. This party noted that the Commission itself has a consistent practice of allocating transport costs over volume, rather than the value of the material. In addition, the Commission should have taken into account the actual distance of transportation to Ningbo Jinding.
(324) Wenzhou argued that it is sufficient to ensure that the price of the raw materials on an ex works basis is undistorted and that any addition of transportation cost should be consistent with the actual delivery term for purchases of raw materials by the Chinese exporting producers. Consequently, only the actual transportation cost from the suppliers to Wenzhou should be considered on top of the ex-works price. Further Wenzhou considered it unreasonable that the transportation costs for raw materials were expressed as a percentage of the reported cost of raw materials, whereas actual transport cost would be calculated on basis of the quantity instead of the value.
(325) Ningbo Jinding further claimed that, there is no basis to add an import duty to the price of the raw material, since Ningbo Jinding purchased its raw materials in China and did not pay any import duties. Also, the GTA data is based on CIF prices, therefore it includes additional costs such as international transport, insurance, and handling costs, which were not applicable for the domestic purchases and should therefore be deducted.
(326) Wenzhou Junhao also reiterated its comment on the first note that all raw materials for the product under investigation of Wenzhou Junhao were purchased domestically. Wenzhou Junhao argued that the import price (CIF) to Thailand, which the Commission took as a basis to determine an undistorted raw material price, may include higher delivery expenses than domestically purchased raw materials.
(327) The Commission considered that, according to Article 2(6a)(a) of the basic Regulation, the normal value should reflect the undistorted price of the raw materials in the representative country (in this case Thailand) as the relevant proxy to construct the normal value in the country of origin. It should therefore reflect the price that a producer of fasteners would pay in Thailand for the raw materials delivered at the factory gate. If international transport costs or import duties were not added, the resulting benchmark would not reflect the undistorted price on the Thai market, but merely the average CIF price in the countries exporting the raw materials in question. This would be contrary to Article 2(6a)(a) of the basic Regulation.