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Published online by Cambridge University Press: 14 January 2016
The article discusses circumvention and anti-circumvention in international trade with a focus on Australia's anti-circumvention mechanism and in particular the first anti-circumvention investigation in Australia. It identifies the major issues relating to circumvention and anti-circumvention in the GATT/WTO negotiations which have led to the failure of WTO members to conclude uniform rules on anti-circumvention. The article argues that multilateral anti-circumvention rules are necessary to standardize national anti-circumvention laws and practice and discipline unilateral use of anti-circumvention measures. The article further argues that Australia's anti-circumvention law and practice, as reflected in its first anti-circumvention investigation, may have violated WTO rules and is likely to lead to increasing protectionism to cost of WTO members and Australia's FTA trading partners. Australia's unjustified use of anti-circumvention measures is unlikely to foster the development of its import-competing industries and may provoke retaliation by other countries.
1 For a comprehensive work on this issue, see Yanning Yu, Circumvention and Anti-circumvention Measures: The Impact on Anti-Dumping Practice in International Trade (Alphen aan den Rijn: Kluwer Law International, 2008).
2 The issue arose largely due to the EU's introduction of the world's first anti-circumvention laws in 1987, which was followed by the US in 1988. See Yu, Yanning, ‘Circumvention and Anti-circumvention in Anti-dumping Practice: A New Problem in China's Outbound Trade’ 41(5) Journal of World Trade (2007), 1015–1041 CrossRefGoogle Scholar, at 1021–1022.
3 For an introduction and analysis of the anti-circumvention laws and practice in the US and the EU, see Yu, Circumvention and Anti-circumvention Measures, at 60–95, supra n. 1; Ostoni, Lucia, ‘Anti-Dumping Circumvention in the EU and the US: Is There A Future for Multilateral Provisions under the WTO’ 10(2) Fordham Journal of Corporate and Financial Law (2005), 407‒438 Google Scholar, at 416–426.
4 For an overview of Australia's recent reforms of the antidumping system, see Parliament of Australia, Department of Parliamentary Services, Bills Digest No. 82, 2012–13, Customs Amendment (Anti-Dumping Commission) Bill 2013 (7 March 2013).
5 See Sarah Falson, ‘Anti-Dumping: One Small Step for Manufacturers, or One Giant Leap onto the Slippery Slope of Protectionism?’, Manufacturers’ Monthly (27 September 2011), http://www.manmonthly.com.au/news/anti-dumping-one-small-step-for-manufacturers-or-o.
6 See Andrew Percival, ‘Anti-Dumping – Proposed Measures Could Expose Australia to Claims of Increased Protectionism’, Corrs Chambers Westgarth (18 July 2012), http://www.corrs.com.au/thinking/insights/anti-dumping-proposed-measures-could-expose-australia-to-claims-of-increased-protectionism/.
7 See Stephen Kirchner, ‘Time to Dump Australia's Anti-Dumping System’, The Centre for Independent Studies, Issue Analysis No. 141 (5 June 2013), https:// www.cis.org.au/images/stories/issue-analysis/ia141.pdf.
8 See Zhou, Weihuan, ‘Australia's Anti-Dumping and Countervailing Law and Practice: An Analysis of Current Issues Incompatible with Free Trade with China’ 49(6) Journal of World Trade (2015)CrossRefGoogle Scholar. An accepted draft of the article is available at: http://ssrn.com/abstract=2598386.
9 See Anti-Dumping Commission, ‘Aluminium Extrusions from China’, Public Record, http://www.adcommission.gov.au/cases/Pages/CurrentCases/EPR241.aspx.
10 See Terence P. Stewart (ed.), The GATT Uruguay Round: A Negotiating History (1986–1992) (Volume II) (Deventer: Kluwer Law and Taxation Publishers, 1993), at 1616–1640.
11 See Matsushita, Mitsuo, ‘Some International and Domestic Antidumping Issues’ 5(2) Asian Journal of WTO and International Health Law and Policy (2010), 249–268 Google Scholar, at 253–254; supra n. 3, Ostoni, ‘Anti-Dumping Circumvention in the EU and the US’, at 412–413.
12 See supra n. 10, Stewart, The GATT Uruguay Round: A Negotiating History, at 1620.
13 See GATT Secretariat, Decision on Anti-Circumvention, 15 December 1993, The Results of the Uruguay Round of Multilateral Trade Negotiations: the Legal Texts (Geneva: GATT, 1994), at 453, https:// www.wto.org/english/docs_e/legal_e/39-dadp1_e.htm.
14 See WTO, Committee on Anti-Dumping Practices, Minutes of the Meeting Held on 30 October 1995, G/ADP/M/4 (21 February 1996), at 7–10; WTO, Committee on Anti-Dumping Practices, Report (1996) of the Committee on Anti-Dumping Practices, G/L/123 (29 October 1996), at 5.
15 See WTO, Committee on Anti-Dumping Practices, Communication from the Chairman, G/ADP/W/404 (20 March 1997).
16 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by the United States, G/ADP/IG/W/7 (22 April 1998), at 1; also see WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – Toward a Common Understanding on What Constitutes Circumvention?, Paper by the European Community, G/ADP/IG/W/6 (22 April 1998).
17 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by the European Community, G/ADP/IG/W/1 (3 October 1997); WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by the United States, G/ADP/IG/W/2 (8 October 1997).
18 Ibid.
19 See supra n. 16, G/ADP/IG/W/6, at 2; supra n. 17, G/ADP/IG/W/2, at 3.
20 See, for example, WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – An Approach to the Definition of Circumvention, Paper by Canada, G/ADP/IG/W/3 (23 October 1997).
21 See, for example, WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by Turkey, G/ADP/IG/W/5 (3 April 1998).
22 See supra n. 20, G/ADP/IG/W/3.
23 See supra n. 20, G/ADP/IG/W/3, at 3.
24 See supra n. 16, G/ADP/IG/W/6, at 2.
25 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by Japan, G/ADP/IG/W/9 (30 April 1998); WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by Japan, G/ADP/IG/W/15 (30 October 1998).
26 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by Hong Kong, China, G/ADP/IG/W/8 (28 April 1998).
27 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by New Zealand, G/ADP/IG/W/11 (20 October 1998).
28 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by Korea, G/ADP/IG/W/17 (28 May 1999).
29 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 1 – What Constitutes Circumvention?, Paper by Egypt, G/ADP/IG/W/21 (24 March 2000).
30 See supra n. 25. Also see supra n. 26.
31 See supra n. 25, G/ADP/IG/W/9, at 1. Also see supra n. 26.
32 See supra n. 25, G/ADP/IG/W/9.
33 See supra n. 27, G/ADP/IG/W/11.
34 See supra n. 28, G/ADP/IG/W/17, at 3.
35 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Replies to Circumvention Scenarios Presented in the Last Meeting of the Informal Group on Anti-Circumvention, Paper by the European Community, G/ADP/IG/W/30 (12 March 2001); WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Response of the United States to the Paper Presented by the European Communities, Paper by the United States, G/ADP/IG/W/32 (10 April 2001). Also see supra n. 1, Yu, Circumvention and Anti-circumvention Measures, at 91.
36 See supra n. 35, G/ADP/IG/W/30.
37 See supra n. 35, G/ADP/IG/W/30.
38 See supra n. 35, G/ADP/IG/W/32.
39 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Questions Posed by Hong Kong, China regarding the Paper by the European Communities, Paper by Hong Kong, China, G/ADP/IG/W/38 (13 June 2001); WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Follow-up Questions of Hong Kong, China to the United States’ Replies to Questions Posed by Hong Kong, China regarding the Paper by the United States, Paper by Hong Kong, China, G/ADP/IG/W/39 (13 June 2001).
40 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 2 – What is Being Done by Members Confronted by What They Consider to be Circumvention?, Paper by Egypt, G/ADP/IG/W/26 (22 September 2000).
41 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 2 – What is Being Done by Members Confronted by What They Consider to be Circumvention?, Paper by New Zealand, G/ADP/IG/W/25 (22 September 2000); G/ADP/IG/W/35 (17 April 2001); G/ADP/IG/W/47 (19 September 2002).
42 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 2 – What is Being Done by Members Confronted by What They Consider to be Circumvention?, Paper by Japan, G/ADP/IG/W/23 (9 May 2000).
43 See supra n. 42, G/ADP/IG/W/23.
44 See, for example, WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 3 – To What Extent Can Circumvention be Dealt with under the Relevant WTO Rules? To What Extent Can It Not? What Other Options May Be Deemed Necessary?, Paper by the United States, G/ADP/IG/W/44 (22 April 2002); WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Circumvention, Paper by New Zealand, G/ADP/IG/W/44 (24 April 2003).
45 See WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Topic 3 – To What Extent Can Circumvention be Dealt with under the Relevant WTO Rules? To What Extent Can It Not? What Other Options May Be Deemed Necessary?, Paper by Australia, G/ADP/IG/W/48 (16 April 2003).
46 Only a handful of papers have been submitted in relation to newly-developed circumventing activities. See, for example, WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Imports of Unassembled Goods and Parts and Components of A Like Product, Paper by New Zealand, G/ADP/IG/W/51 (21 October 2004); WTO, Committee on Anti-Dumping Practices, Informal Group on Anti-Circumvention, Antidumping Duty ‘Evasion Services’, Paper from the United States, G/ADP/IG/W/54 (17 March 2015). Also see, WTO, Report (2013) of the Committee on Anti-Dumping Practices, G/L/1053 (29 October 2013), at 3; WTO, Report (2014) of the Committee on Anti-Dumping Practices, G/L/1079 (31 October 2014), at 3.
47 See Adamantopoulos, Konstantinos and De Notaris, Diego, ‘The Future of the WTO & the Reform of the Anti-Dumping Agreement’ 24(1) Fordham International Law Journal (2000–2001), 30–61 Google Scholar, at 56–58.
48 See Uría Menéndez, ‘Antidumping Guide: A Latin American Overview for Chinese Exporters’, August 2012, http://www.uria.com/documentos/galerias/2252/imagen/4369/antidumping_ingles.pdf?id=4369.
49 See Gustav Brink, ‘Anti-Dumping in South Africa’, Tralac Working Paper No. D12WP07/2012 (July 2012), at 45–49, http://www.tralac.org/images/docs/4208/d12wp072012-brink-anti-dumping-in-sa-20120725final.pdf.
50 See Manoj Gupta, ‘India Tightens Anti-Dumping Law – Anti-Circumvention Rules Introduced’, Lakshmikumaran and Sridharan Attorneys, http://www.lakshmisri.com/News-and-Publications/Archives/Publication/India-tightens-anti-dumping-law-Anti-circumvention-rules-introduced; also see Government of India, Ministry of Commerce and Industry, Format of Application for Anti-Circumvention Investigation, http://commerce.nic.in/traderemedies/Format_anti_circumvention_investigatin.pdf?id=16.
51 See Laura Puccio, ‘20 Years after Marrakesh: Reconsidering the Effects of Preferential Rules of Origin and Anti-Circumvention Rules on Trade in Inputs and Global Production Networks’, in Christoph Herrmann et al. (ed), European Yearbook of International Economic Law 2014 (Berlin: Springer, 2013), 173–200, at 181.
52 See Australian Government, ‘Streamlining Australia's Anti-Dumping System: An Effective Anti-Dumping and Countervailing System for Australia’ (Canberra: Australian Customs and Border Protection Service, 2011).
53 See John Brumby, ‘Review into Anti-Dumping Arrangements’ (Canberra: Attorney-General's Department, 2012) (Brumby Review).
54 See Parliament of Australia, Parliamentary Business – Circumvention of Anti-Dumping Laws, http://www.aph.gov.au/Parliamentary_Business/Committees/House/Agriculture_and_Industry/Anti-Dumping.
55 See supra n. 52, ‘Streamlining Australia's Anti-Dumping System’, at 24–25.
56 See, for example, Australian Forest Products Association, ‘House of Representatives Agriculture and Industry Committee Inquiry into Australia's anti-circumvention framework’, Submission No. 6 (30 November 2014); BlueScope, ‘Inquiry into Australia's anti-circumvention framework in relation to anti-dumping measures’, Submission No. 9 (1 December 2014). These submissions can be found at http://www.aph.gov.au/Parliamentary_Business/Committees/House/Agriculture_and_Industry/Anti-Dumping/Submissions.
57 See supra n. 53, Brumby Review, at 92.
58 See supra n. 53, Brumby Review, at 92.
59 The Parliament of Australia, House of Representatives, Replacement Explanatory Memorandum, Customs Amendment (Anti-Dumping Measures) Bill 2013, Customs Tariff (Anti-Dumping) Amendment Bill 2013, at 15.
60 See supra n. 3, Ostoni, ‘Anti-Dumping Circumvention in the EU and the US’.
61 For an overview of Australia's antidumping and countervailing investigating procedure, see supra n. 8, Zhou, ‘Australia's Anti-Dumping and Countervailing Law and Practice’, at 3–4. Also see D. Moulis and P. Gay, ‘The 10 Major Problems with the Anti-Dumping Instrument in Australia’ 39(1) Journal of World Trade (2005), 75‒85.
62 Section 269ZDBE(1) of the Act.
63 Section 269ZDBG(1)(a) of the Act.
64 Section 269ZDBG(1)(b) of the Act.
65 Section 269ZDBF(1) of the Act.
66 Section 269ZDBG(1) of the Act.
67 Capral Limited, ‘About Capral Aluminium’, http://www.capral.com.au/Who-we-are.
68 Capral Limited, Application for An Anti-circumvention Inquiry into Avoidance of the Intended Effect of Duty, Aluminium Extrusions Exported from China by PanAsia Aluminium (China) Limited, 19 March 2014 (Application), http://www.adcommission.gov.au/cases/Documents/003-Anti-circumventioninquiry-Application-PUBLIC-Redacted.pdf.
69 See Australian Customs and Border Protection Service, Certain Aluminium Extrusions Exported to Australia from the People's Republic of China, Report to the Minister No. 148 (15 April 2010); Australian Customs and Border Protection Service, Certain Aluminium Extrusions Exported to Australia from the People's Republic of China, Reinvestigation of Certain Findings in Report No. 148 (15 August 2011).
70 See supra n. 68, Application, at 7.
71 Ibid., at 7.
72 Ibid., at 7–10.
73 Ibid., at 11.
74 Ibid., at 11.
75 Ibid., at 12–13.
76 See Anti-Dumping Commission, Certain Aluminium Extrusions Exported from the People's Republic of China, Initiation of An Anti-Circumvention Inquiry into Avoidance of the Intended Effect of Duty, Anti-Dumping Notice No. 2014/31, http://www.adcommission.gov.au/cases/Documents/002-ADN2014-31_000.pdf.
77 See Anti-Dumping Commission, Alleged Circumvention of Certain Aluminium Extrusions Exported from the People's Republic of China, Final Report No. 241 (23 December 2014) (REP 241), http://www.adcommission.gov.au/cases/Documents/039-FINALReport241Anti-circumventioninquiryPUBLICRECORDVERSION.pdf.
78 The inquiry period was amended to give consideration to the possible impact of the Federal Court case brought by PanAsia in relation to the original investigation which case resulted in a change of duty rate. See supra n. 77, REP 241, at 11–12.
79 See supra n. 77, REP 241, at 21.
80 Ibid., at 24–26.
81 Ibid., at 26–33.
82 Ibid., at 33–36.
83 Ibid., at 33–36.
84 Ibid., at 38–42.
85 Ibid., at 42.
86 Ibid., at 42.
87 Ibid., at 42. This subsidy program is the so-called provision of raw materials for the production of final subject goods at prices ‘less than adequate remuneration’. For a discussion of the Australian investigating authorities’ treatment of the subsidy in previous investigations, see supra n. 8, Zhou, ‘Australia's Anti-Dumping and Countervailing Law and Practice’, at 12–14.
88 Ibid., at 43.
89 Ibid., at 49.
90 See Anti-Dumping Commission, Certain Aluminium Extrusions Exported by PanAsia Aluminium (China) Limited from the People's Republic of China, Findings in relation to an Anti-Circumvention Inquiry into the Avoidance of the Intended Effect of Duty, Public Notice under Subsection 269ZDBH(1) of the Customs Act 1901 (21 January 2015), http://www.adcommission.gov.au/cases/Documents/case%20241Public%20Notice%20-%20The%20Australian%20newspaper.pdf.
91 Appellate Body Report, United States – Anti-Dumping Act of 1906, WT/DS136/AB/R, WT/DS162/AB/R, adopted 26 September 2000, para. 124 (US – 1916 Act).
92 Ibid., paras, 122, 126.
93 Ibid., para, 130.
94 Appellate Body Report, United States – Continued Dumping and Subsidy Offset Act of 2000, WT/DS217/AB/R, WT/DS234/AB/R, adopted 27 January 2003, paras. 240, 242.
95 This is not to suggest that the AD Agreement may not apply to customs duties or other forms of measures imposed against dumping in accordance with legislations other than anti-dumping legislation. As the Appellate Body has established in US – 1916 Act and US – Offset Act (‘Byrd Amendment’), whether a measure is considered to be an action against dumping and hence governed by the AD Agreement depends on whether the action is taken in response to situations presenting the constituent elements of ‘dumping’.
96 The author is grateful for one of the reviewers of the article to bring out this point.
97 For a discussion of the laws and practice of ‘anti-absorption’ in the EU, see supra n. 1, Yu, Circumvention and Anti-circumvention Measures, at 196–212; Vermulst, Edwin and Graafsma, Folkert, ‘The Anti-Absorption Provision in EC Anti-Dumping Law’ 2(3) Global Trade and Customs Journal (2007), 129–141 CrossRefGoogle Scholar.
98 The other key elements include (1) the subsidy is provided by a government or any public body, and (2) the subsidy is specific.
99 See Edwin Vermulst, The WTO Anti-Dumping Agreement: A Commentary (New York: Oxford University Press, 2005), at 63–93.
100 Article VI:1 of the GATT 1994 reads: ‘The contracting parties recognize that dumping … is to be condemned if it causes or threatens material injury to an established industry in the territory of a contracting party.’
101 Article 11.1 of the AD Agreement reads: ‘An anti-dumping duty shall remain in force only as long as and to the extent necessary to counteract dumping which is causing injury.’
102 Article 19.1 of the SCM Agreement reads: ‘If … a Member makes a final determination of the existence and amount of the subsidy and that, through the effects of the subsidy, the subsidized imports are causing injury, it may impose a countervailing duty in accordance with the provisions of this Article.’
103 See supra n. 77, REP 241, at 35‒36.
104 See Department of Foreign Affairs and Trade, Consolidated Loose-Leaf Schedule, Schedule I – Australia, at 211–212, http://dfat.gov.au/international-relations/international-organisations/wto/Documents/schedule.pdf.
105 See Anti-Dumping Commission, Dumping Commodities Register, Aluminium Extrusions Exported from the People's Republic of China, at 6, http://www.adcommission.gov.au/measures/Documents/DCR%20-%20aluminium%20extrusions%20-%20150220.pdf.
106 As of the writing of the article, there have been no completed investigations into the Traditional Activities in Australia. For a discussion of the WTO-consistency of anti-circumvention investigations of the Traditional Activities, see supra n. 1, Yu, Circumvention and Anti-circumvention Measures, at 74–75; supra n. 3, Ostoni, ‘Anti-Dumping Circumvention in the EU and the US’, at 426–429.
107 See, for example, GATT Panel Report, EEC – Programme of Minimum Import Prices, Licenses and Surety Deposits for Certain Processed Fruits and Vegetables, L/4687 – 25S/68 (adopted 19 October 1978).
108 See, for example, GATT Panel Report, Canada – Import, Distribution and Sale of Certain Alcoholic Drinks by Provincial Marketing Agencies, DS17/R – 39S/27 (adopted 18 February 1992), paras. 5.27‒5.31.
109 See Department of Foreign Affairs and Trade, About Free Trade Agreements, http://dfat.gov.au/trade/agreements/Pages/about-ftas.aspx.
110 See Department of Foreign Affairs and Trade, China–Australia Free Trade Agreement, http://www.dfat.gov.au/trade/agreements/chafta/Pages/australia-china-fta.aspx. For the key outcomes of the FTA, see Department of Foreign Affairs and Trade, China–Australia Free Trade Agreement, Key Outcomes, http://www.dfat.gov.au/trade/agreements/chafta/fact-sheets/Pages/key-outcomes.aspx.
111 See Law Council of Australia, Inquiry into Australia's Anti-Circumvention Framework in relation to Anti-Dumping Measures, Submission No. 4 (28 November 2014) (Law Council Submission), at 12, http://www.aph.gov.au/Parliamentary_Business/Committees/House/Agriculture_and_Industry/Anti-Dumping/Submissions.
112 See Productivity Commission, Australia's Automotive Manufacturing Industry, Inquiry Report, 31 March 2014, http://www.pc.gov.au/inquiries/completed/automotive/report.
113 See BlueScope, 2013/2014 Annual Reports, http://www.bluescope.com/media/330511/bluescope%20annual%20report%20web.pdf; The Sydney Morning Herald, ‘“Dumping” Squeezes Arrium Profits’, 20 October 2014, http://www.smh.com.au/business/dumping-squeezes-arrium-profits-20141019-118ckp.html.
114 See Capral Aluminium, Half Year 2013 Results Presentation, at 8, http://www.capral.com.au/Results-Presentations.
115 See Anti-Dumping Commission, Aluminium Extrusions Exported from China, Continuation Review, Public Record, http://www.adcommission.gov.au/cases/Pages/CurrentCases/EPR-287.aspx.
116 See Article 11.3 of the AD Agreement, Article 21.3 of the SCM Agreement, and Sections 269TM(1) and (2) and Division 6A of the Act.
117 See supra n. 111, Law Council Submission, at 12.
118 As an evidence of this, the AD Commission initiated three anti-circumvention investigations shortly after the Aluminium Extrusions Investigation against some of its major FTA trading partners such as China and Korea. See Anti-Dumping Commission, Hollow Structural Sections Exported from China, Korea and Malaysia, Public Record, http://www.adcommission.gov.au/cases/Pages/CurrentCases/EPR-291.aspx; Anti-Dumping Commission, Zinc Coated (Galvanised) Steel Exported from Korea, Taiwan and China, Public Record, http://www.adcommission.gov.au/cases/Pages/CurrentCases/EPR-290-Cases-Pages-Current-Cases.aspx; Anti-Dumping Commission, Certain Quenched and Tempered Steel Plate exported from Sweden, Public Record, http://www.adcommission.gov.au/cases/Pages/CurrentCases/EPR-306.aspx.
