Barcode:4186352-01 C-821-832 INV - Investigation -

C-821-832
Investigation
POI: 01/01/2020 – 12/31/2020
Public Version Business Proprietary Document
E&C/III: KJ

November 29, 2021

MEMORANDUM TO: The File

THROUGH: Eric Greynolds

Program Manager
AD/CVD Operations, Office III

FROM: Kristen Johnson

International Trade Compliance Analyst
Office III, AD/CVD Operations

RE: Countervailing Duty Investigation of Urea Ammonium Nitrate

Solutions from the Russian Federation: All Others Rate for
Preliminary Determination

For the preliminary determination in the above-referenced countervailing duty investigation, the
Department of Commerce has calculated an all others subsidy rate of 9.72 percent ad
valorem. See attached calculations. To calculate the rate, we used publicly ranged
sales values for total exports of subject merchandise to the United States for the period of
investigation (POI) that were reported by the mandatory respondents, PJSC Acron (Acron) and
EuroChem Companies.1

We were unable to calculate a weighted average of the two calculated subsidy rates using
business proprietary sales values reported by the respondents because doing so would reveal
their proprietary information. The attached calculations demonstrate that relying on the
weighted average of the two subsidy rates using respondents’ publicly ranged sales of subject
merchandise to the United States provides a more accurate proxy for the weighted-average rate
using the proprietary data, than relying on a simple average of the respondents’ subsidy rates.

Additionally, because we preliminarily determine that only Acron received benefits from an
export subsidy program during the POI, the export subsidy rate for use as an offset in the
companion antidumping duty investigation is 0.14 percent ad valorem.

1
For purposes of this investigation, the EuroChem Companies are Mineral and Chemical Company EuroChem,
Joint Stock Company, Joint Stock Company Nevinnomyssky Azot, and Azot, Joint Stock Company.

Filed By: Kristen Johnson, Filed Date: 11/30/21 12:54 PM, Submission Status: Approved
 Barcode:4186352-01 C-821-832 INV - Investigation -

Urea Ammonium Nitrate Solutions from the Russian Federation

POI: 01/01/2020 - 12/31/2020
All Others Rate: Preliminary Determination
Public Version

Total Exports (fob) of Subject

Merchandise to the United States Subsidy Rate
Company (Value in RUB) Subsidy Rate (Rounded)
Acron [ ] 9.66%
EuroChem Companies [ ] 9.84%
Total Export Sales Value [ ]
Weighted-Average Rate using propietary sales values:* [ ]
*This is the rate we would have applied if we were able to use the proprietary values.

Proxy #1: Simple Average of the Respondents' Subsidy Rates

Subsidy Rate
Company Subsidy Rate (Rounded)
Acron 9.66%
EuroChem Companies 9.84%
Simple Average Rate 9.75% 9.7500%

Proxy #2: Weighted-Average Rate using Publicly Ranged Export Sales Values

Total Exports (fob) of Subject

Merchandise to the United States Subsidy Rate
Company (Value in RUB) Subsidy Rate (Rounded)
Acron 5,379,990,000 9.66%
EuroChem Companies 2,903,140,458 9.84%
Total Export Sales Value 8,283,130,458
9.72% 9.7200%
Sources:
For the subsidy rates, see Urea Ammonium Nitrate Solutions from the Russian Federation: Preliminary Affirmative Countervailing Duty Determination and
Alignment of Final Determination with Final Antidumping Duty Determination, and accompanying Preliminary Decision Memorandum, signed concurrently with
this memorandum.
For Acron, see Acron's Initial Questionnaire Response, dated October 7, 2021 at Exhibit GEN B-1 (tab "ToS 2020 Acron PAO") for proprietary sales
data (barcode: 4169124-39); and Acron's Supplemental Questionnaire Response, dated November 9, 2021 at Exhibit S1-GEN-B-1 for publicly
ranged sales data (barcode: 4181106-01).

For EuroChem, see EuroChem Companies' Initial Questionnaire Response dated October 7, 2021 at Exhibit 6 for proprietary sales data (barcode: 4169068-
03); and EuroChem Companies' Third Supplemental Questionnaire Response, dated October 31, 2021 at Exhibit 1 for publicly ranged sales data (barcode:
4177293-01).

Filed By: Kristen Johnson, Filed Date: 11/30/21 12:54 PM, Submission Status: Approved