Argentine Beekeepers' Magazine

(Espacio Apícola, March 30th, 2024)According to the regulations of the United States Department of Commerce (DOC), on March 1st, this should have been issued the Preliminary Results of the First Administrative Review of the antidumping tariff order carried out between November 2021 and May 2023. According to the same regulations and given the impossibility of complying with that deadline, the DOC resorted to the maximum period allowed, postponing the publication of the Preliminary Results until next June 28. (according to the memorandum published by the DOC with Barcode: 4507919-01, dated February 13th, 2024).

What happened during these 9 months of review? (HERE our report of December 22nd, 2023) In March 2024 were modified the scenarios mainly about the companies of the countries where there was movement of entry and exit of investigated companies, although in those where there was no such movement facts are also manifested revealing. We are updating our last report on this matter of December 22nd.

HONEY FROM ARGENTINA
ACA and NEXCO, the two Argentine companies investigated during the initial period, appeared to defend their situation in this new instance. Apparently the several dozen documents in which the methodology implemented by the DOC was discussed, for which the DOC itself requested opinions to improve the development of the investigations, were useless. The DOC continues to send questionnaires to be answered by primary producers and middlemen, with the same degree of complexity as always but with the aggravation of choosing small producers who have much less capacity to respond to them. The companies questioned insist on their willingness to collaborate and repeatedly request that the deadlines for the delivery of these questionnaires be postponed. For their part, the petitioners (Sioux H.A. and the A.H.P.A.) return to the same arguments from three years ago, that the beekeepers' cost reports are insufficient and that everything must be expressed in Argentine pesos or accompany the cost statements in dollars with the respective supporting documents in the same currency. A dialogue of the deaf that does not end in anything positive and only produces wear and tear and increases legal fees. It should be noted that based on the exchange gap that existed in Argentina until December 2023, where importers of inputs had to buy dollars at three times the value of the official dollar, it produced a great distortion in which the price of several inputs tripled. Just in these days at the end of March, some prices of imported inputs fell in dollars to values close to those of 2020 (e.g. an active principle against varroa was sold for more than USD 11 per kg in mid-2023, at the beginning of current year it fell to just over USD 8 until this week its price dropped to less than USD 4 per kg, always talking about official dollars to which only some well-off importers had access). The situation led other important honey exporting companies in Argentina, which on another occasion had requested to be investigated in order to quickly access more convenient tariffs, decided not to resort to that mechanism.

HONEY FROM BRAZIL
Anti dumping investigation against Brazilian honeys had been limited to the MELBRAS company because Apiarios Diamante was sanctioned and removed from the initial investigation due to Adverse Facts Availables (AFA). Instead of Apiarios Diamante, Apis Nativa was summoned. Because it was who bought Apiarios Diamante, other company, Minamel asked to occupy their place because of the Change of Circumstances Review (CCR). The DOC refused that as we noted in our last December report.
Then, Apis nativa who was added for this first review, presented a note (Barcode: 4514412-01) pointing out the same difficulties that the Argentine companies NEXCO and ACA have to achieve beekeepers' answer for the DOC's questionnaires on February 26th. Apis nativa proposed that DOC could take their honey purchase price as their production cost, just like what MELBRAS opportunely achieved, in similar circumstances, during the initial investigation. For this reason honey from MELBRAS has a duty of 7,89% only, and this was left for all other exporting companies in Brazil due to the mechanisms that we published in Espacio Apícola magazine #136 unlike the Argentine case.
In addition to this circumstance, both companies were asked to answer a specific questionnaire about their performance. Each was asked to expressly "Describe your company's production facility and outline the processing that is performed on the raw honey".
Melbras, who during the initial investigation maintained that due to the economic and educational condition of the beekeepers who provide the honey, they were not qualified to respond to the questionnaires on production costs, when describing their process they say verbatim: "Melbras is a producer of subject merchandise and sources honey from over 'xx' beekeepers in Brazil. Prior to honey arriving at Melbras, the hive is collected, and the comb is separated from the honey. Comb separation is done both manually and using a centrifuge. The honey is then placed in drums, inspected, classified by crop (floral source), grade (conventional/ organic/ naturland, fair trade), region, and shipped to Melbras". It would seem then that those who would not be able to answer a questionnaire can make the aforementioned differentiations, including those of costs to belong to the 'Fair Trade' certification system. Melbras only have described the process for the DOC (Barcode: 4489960-01).
For its part, the general response of Apis Nativa is more frank and reveals process data that for Apimondia are considered adulterations of honey, a perspective that we could consider very European and of segregation to certain humid subtropical regions. In addition to including the address and a photograph of the processing plant and sales area, it says: "As described in Apis's response to Section D of the Department's Initial Questionnaire, raw unprocessed honey is received at Apis's processing facility where it is weighed, sampled, and labeled. Production commences with the issuance of the production order. Based on the specifications of the honey to be produced, Apis selects the specific drums of raw unprocessed honey that will be blended to produce the final product. The selected drums are inspected and if the honey has crystallized, the drums enter the decrystallization process in a heating room, after which the honey undergoes dehumidification and filtering. The honey is then poured into the mixing tank for blending. The processed honey is then packed in drums, labeled, sampled and weighed or set aside for future production runs".

INDIAN HONEY
Petitioners have been systematically questioning the answers of Indian companies. Regarding Indocan Honey Private Limited, Petitioners sais that Indocan do not present supporting documentation on the accounting reconciliation of their operations in the domestic market and request the DOC to send them more questionnaires (Barcode:4531488-01, December 7, 2023) and presume that the honey that is supposedly for the domestic market is actually for export, or the production costs are mixed, which is why they ask the DOC to request exhaustive documents specifying the different products, their internal codes and their market, especially when Indocan invokes selling monofloral honeys in the domestic market (which would not be the subject of this investigation and should not interfere with the cost analysis) and tax-free. Petitioners also argue that the prices of honey sold in the domestic market in Rupees are aberrant since similar sales would have a huge price difference.
During this, the comment arose that the Indian Government was about to set a minimum export price for honey. On March 14 the Indian International Trade Directory of the Ministry of Commerce and Industry, in Delhi imposed a minimum price (MEP) on honey exports of US$ 2000 per metric ton until December 31st of this year.
This whole approach seems to be very far from a "cost analysis" and simply shows that honey is sold according to the face, the condition, the market in which the client operates.

VIETNAM HONEY
Since the end of the initial investigation in which the intervention of the Vietnamese Government lobbies with senators and representatives of the United States Congress and occasional victims in the United States, this investigation is tainted by interests unrelated to its object itself. It shows, in a very rude manner, the whole operation of this antidumping process against the honeys of the supplier countries questioned.
Currently and around the two Vietnamese companies investigated, "DarkHoney" and "Ban Me Thuot", there is a barrage of presentations made by the petitioners questioning different points of the proposition finally accepted in the primary investigation, the acceptance of the market information coming from India, as a surrogate market, to infer production costs in Vietnam... something that, according to the petitioners, the DOC it self would consider unviable based on the fact that "India does not appear on the Office of Policy's list of countries that are economically comparable to Vietnam" (barcode: 4527096-01, dated March 15, 2024). From then on, what can we add!, without even considering that the discussion on the tariffs imposed on India is also in the process of review.