Ukraine’s association of ferroalloy producers, UkrFa, wrote the ITC in favor of eliminating the US duty on imports of silicomanganese. The group said pointed out that the original duties date back to before the US granted Ukraine market economy status. “as of today, Ukrainian producers are operating on the basis of market principal. It means that all decisions regarding production and distribution are guided by the price signals created by the forces of supply and demand…The order of 1994 was issued against an industry that is fully “renovated” and does not exist anymore and, therefore, such an order should be terminated as it does not comply with the current situation.
The group also wants the ITC to eliminate the Stakhanovsk Ferro- Alloy Work from its consideration of being part of the Ukraine pointing out the government no longer has control over the region where the plant is located.
Finally UkrFa said the US is no longer a target market for Ukrainian silicomanganese. “It’s important to mention that since 2015, Ukrainian products have been exported to markets of the EU countries under the terms of the Association Agreement that established Deep and Comprehensive Free Trade Area. Such a new condition of market access for Ukrainian products to the EU resulted in significant increase of Ukrainian export to the EU countries. The share of the EU countries in Ukrainian exports of Silicomanganese was 50% in 2017. Obviously, the European market became the most favorable and convenient for Ukrainian exporters given the access conditions and geographical proximity.
Given such a long time of measures being in force, Ukrainian producers has lost their distribution channels in the U.S. and found other markets for their product. Considering the loss of part of Ukrainian production facilities that resulted in export reduction it is unlikely that Ukraine would sharply increase its exports to the U.S. if measures are allowed to lapse.”