APPLICATION OF PHILIPPINERemedies/DTI+Orders...APPLICATION FOR SAFEGUARD MEASURES ON THE IMPORTATION OF MOTOR VEHICLES FROM VARIOUS COUNTRIES I. INTRODUCTION This is an evaluation

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DEPARTMENT OF TRADE AND INDUSTRY

SAFEGUARD MEASURES CASE NAME:

APPLICATION OF PHILIPPINE

METALWORKERS’ ALLIANCE

PUBLIC VERSION

SGM CASE NO. : SG01-2020

DATE : 17 January 2020

REPORT ON THE INITIATION OF A

PRELIMINARY INVESTIGATION ON THE

APPLICATION FOR SAFEGUARD MEASURES ON

THE IMPORTATION OF MOTOR VEHICLES

FROM VARIOUS COUNTRIES

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REPORT ON THE INITIATION OF PRELIMINARY INVESTIGATION ON THE APPLICATION FOR SAFEGUARD MEASURES ON THE IMPORTATION OF

MOTOR VEHICLES FROM VARIOUS COUNTRIES

I. INTRODUCTION

This is an evaluation report on the safeguard measures application filed by the Philippine Metalworkers’ Alliance (PMA). The industry is requesting for the imposition of safeguard measures on the importation of motor vehicles from various countries which are classified under ASEAN Harmonized Tariff Nomenclature (AHTN) Code 87.03 which includes the following subheading classified under 8703.21.10, 8703.21.29, 8703.21.29B, 8703.21.90C, 8703.22.19B, 8703.23.45, 8703.23.51B, 8703.23.52B, 8703.23.53B, 8703.23.54B, 8703.24.50B, 8703.31.20, 8703.31.20B, 8703.32.41, 8703.32.49, 8703.32.51B, 8703.32.59B, 8703.32.91B, 8703.32.91D, 8703.32.91E, 8703.32.99C, 8703.33.41, 8703.33.42, 8703.33.51A, 8703.33.51B, 8703.33.52B, 8703.33.90C and 8703.90.51 as well as 8704.21.19 and 8704.21.29 due to alleged imports surges causing injury to the domestic motor vehicles industry.

A. The Philippine Industry's Petition

A.1 Parties to the Petition - Domestic Industry/Petitioner

Section 6 of RA 8800 (Safeguard Measures Act) provides that “Any person, whether natural or juridical, belonging to or representing a domestic industry may file with the Secretary a verified petition requesting that action be taken to remedy the serious injury or prevent the threat thereof to the domestic industry caused by increased imports of the product under consideration”. Rule 6.4.d of the Implementing Rules and Regulations (IRRs) of RA 8800 further provides that: “All persons who have a right to relief or who will be adversely affected by such relief with respect to the alleged import surges claimed to exist may, upon the discretion of the Secretary or the Commission, join as petitioners or be joined as respondents in one (1) petition, where any question of law or fact common to all such respondents may arise in such action”. PMA is a juridical person belonging to the motor vehicle industry. It is registered with the Department of Labor and Employment (DOLE), as a national union of automotive, iron and steel, electronics and electrical sectors, including affiliates in key automotive industry players.

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A.2. Philippine Metalworkers Alliance - PMA The table below shows the members of PMA

Mitsubishi Motor Workers Union-Philippines (MMWU-P)

Aichi Forging Corporation Specialist Supervisory Union (TBPCSU)

Nagkakaisang Manggagawa sa Silgan (NAMASIL)

Mitsubishi Motor Supervisory Union - (MMPSU)

Pilipinas Kyohritsu Inc. Supervisory Union (PSU)

Century Labor Organization (CLO)

Toyota Motor Philippines Corporation Labor Organization (TMPCLO)

Pilipinas Kyohritsu Inc. Employees Welfare Union (PEWU)

Pilipino Cable Corp. Employees Union Calabarzon (PCCEU- Calabarzon)

Toyota Motor Philippines Corporation Supervisory Union (TMPCLO)

Laguna Daichi Inc. Supervisory Union (LDISU)

Pilipino Cable Corp. Employees Union Camanawa (PCCEU- Camanawa)

Univation Motor Philippines Supervisory Union (UMPSU)

Katolec Philippines Labor Union (KAPLU)

Pilipino Cable Corp. Workers Union (PCCWU)

Univation Motor Philippines Workers Union (UMPWU)

Moriroku Philippines Inc. Workers Union (MPIWU)

Samahan ng Manggagawa sa HMCATV (SMHMCATV)

Isuzu Philippines Corporation Workers Union (IPCWU)

Sohbi Employees Workers Union (SEWU)

Home Lipa Cable Corp. Davao Employees Union (PCCDEU)

Isuzu Philippines Corporation Supervisory Union (IPCAU)

International Wiring System Philippines Corporation United Supervisory Union (IWSPUSU)

Sky Cable Dumaguete Employees Union (PCCDEU)

Toyota Aisin Philippines Labor Union (TAPLU)

International Wiring System Philippines Corporation United supervisory Union (IWSPUSU)

Sterling Workers Union (SWU)

Toyota Aisin Philippines Supervisory Union (TAPSU)

International Wiring system Rank and File Union (IEWPEU)

Atos Workers Organized League (AWOL)

Isuzu Autoparts Supervisory Employees Union (IASEU)

International Electric Wires Philippines Employees (IEWPEU)

Stepan Inc. Employees Labor Union (SPIELU)

Toyota Boshoku Philippines Corporation Supervisory Union (TBPCSU)

Furukawa Employes Welfare Union (FEWU)

Toyota Quezon Avenue Employees Union (TQAEU)

Technol Eight Metalworkers Union (TEMU)

Source: Philippine Metalworkers Alliance

A.3. Industry Overview

The motor vehicle industry represents a significant portion of the global economic activity with extensive upstream and downstream linkages to many diverse industries and sectors. In the past decade, the motor vehicle industry's contributions in output, employment, investments, and exports have been increasing. Moreover, the synergy within the industry has strengthened the linkages between the motor vehicle assemblers and the motor vehicle parts and components manufacturers1. The Philippine motor vehicle industry is comprised of two sectors: the motor vehicle assembly and the motor vehicle parts and components manufacturing.

1 http://boi.gov.ph/wp-content/uploads/2018/02/Automotive-July-3-2017.pdf

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The motor vehicle assembly sector is grouped based on the type of motor vehicles, such as passenger cars, commercial vehicles (utility vehicles, pick-ups, vans, trucks, buses, special purpose vehicles) and motorcycles. There are 272 parts and components manufacturers in the country. The industry has an annual capacity of 250,000 units of parts and components, all vehicle types included, produced by plants rated as compliant with global standards and certified by the International Standards Organization (ISO)2.

A.4. Philippine Motor Vehicle Assembly Sector

The Philippine motor vehicle industry is principally dominated by Japanese automobile manufacturers such as Toyota Motor Phils. Corp. (TMPC), Mitsubishi Motor Phils. Corp. (MMPC), Honda Cars Phils., Inc. (HCPI) and Nissan Motor Phils. Inc. (NMPI). While Pilipinas Hino, Inc. (Hino) and Columbian Motors Corp. (Nissan Diesel) dominate the trucks and buses category. Other vehicle assemblers carry German and Chinese brands.3 DTI obtained data relevant to the Philippine manufacturers of passenger and commercial vehicles. These were consolidated to evaluate the effect of increased imports of motor vehicles in the domestic market as alleged by PMA. 1) Toyota Motor Philippines Corporation Toyota Motor Philippines Corporation was established in August 1988. They started manufacturing xxx in 2016 and xxx in 2018. Toyota is importing xxx models of CBU from Japan, Thailand, and Indonesia. 2) Honda Cars Philippines, Inc. Honda Cars Philippines, Inc. was established in October 1990. They are manufacturing xxx models of passenger cars. Honda is importing xxx models of CBU from Thailand, Japan, and the UK. 3) Isuzu Philippines Corporation. Isuzu Philippines Corporation was established in August 1995. They started their production with xxxx models in 1996. In 2003 and 2017, another xxx models were added to their production line. Isuzu is importing xxx models of CBU from Japan and Thailand. 4) Hyundai Asia Resources, Inc. Hyundai Asia Resources, Inc. was established in August 2011. They started manufacturing xxx in November 2018. Hyundai is importing xxx CBU models from South Korea and China.

2 http://boi.gov.ph/ufaqs/automotive/ 3 http://boi.gov.ph/wp-content/uploads/2018/02/Automotive-July-3-2017.pdf

http://boi.gov.ph/ufaqs/automotive/

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5) Nissan Philippines, Inc. Nissan Philippines Inc. was established in September 2013. They started production in 2014 for the xxx models of passenger and commercial vehicles. As of 2019, xxx is the only model being manufactured by Nissan. Nissan is importing xxx models of CBU from the USA, Japan, and Thailand. A.4. Importers and Exporters of Motor Vehicles The list of importers and exporters of motor vehicles were identified from the data of the Bureau of Customs Single Administrative Document – Import Entry and Internal Revenue Document (SAD-IEIRD). (Attached as Annexes A and B) B. Role of the DTI under RA 8800 (The Safeguard Measures Act)

B.1 Examination of Evidence to Justify Initiation of Investigation

In establishing whether there is sufficient evidence to justify the initiation of the investigation, the Secretary relied on Section 6 paragraph 3 of RA 8800 and its IRRs, "the Secretary shall review the accuracy and adequacy of the evidence adduced in the petition to determine the existence of a prima facie case that will justify the initiation of a preliminary investigation within five (5) days from receipt of the petition."

B.2 Documents Received/Gathered by DTI On the 9th of August 2019, the Philippine Metalworkers Alliance (PMA), on behalf of the Philippine automotive industry, filed for safeguard measures investigation on imports of motor vehicles from various countries. In assessing serious injury, DTI conducted its initial evaluation of the petition and conducted research and data gathering pertinent to the application of PMA. Specifically on the level of sales, production, profit/losses, productivity, capacity utilization, domestic production, etc. These factors were evaluated to assess the impact of increased imports of motor vehicles on the domestic motor vehicle industry. Although data submitted by PMA covers commercial vehicles, DTI included in the evaluation both passenger vehicles and commercial vehicles considering that said products are assembled in the country.

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II. THE PROCESS OF INITIATION OF INVESTIGATION A. Acceptance of the Petition In accepting the petition, the Secretary relied on the following provisions of the IRRs of RA 8800 and its IRR:

Rule 6.3 (b) provides, "the Secretary shall preliminary screen the application if the following conditions are met:

i. The application is signed; ii. All relevant questions are answered or the reasons for the absence of

information are given; and iii. The attachments to the application are complete".

Rule 6.3 (c) provides, "failure to supply all the information sought in the application will lead to the non-acceptance thereof. The Secretary shall check the consistency of the information provided in the application against other information available to him. The Secretary shall clarify any unclear or ambiguous statement with the applicant".

Rule 6.3 (d) provides, "as soon as the requirements are completed, the Secretary shall acknowledge in writing that he has already accepted a properly documented application. The date of the Secretary's letter shall be considered as day zero (0) of the five (5) calendar days within which he is required to determine whether there is sufficient evidence to justify the initiation of an investigation. The Secretary shall issue the letter as soon as practicable from his receipt of a properly documented application. If the applicant decides to give the Secretary further information in support of an application, the five (5) day period herein mentioned shall commence from the date of the submission of the new information. After this period, the Secretary shall no longer entertain any information that may be provided by the applicant".

On 15 January 2020, the Secretary officially informed PMA that their petition has been accepted as a properly documented application.

B. Decision to Initiate Rule 6.4 (a) further provides that "the Secretary shall, within five (5) calendar days from the date of his letter of acceptance of the properly documented application referred to in Rule 6.3 (d), examine the accuracy and adequacy of the evidence submitted to determine the existence of a prima facie case that will justify the initiation of a preliminary investigation. In assessing the sufficiency of evidence provided in the application, the Secretary shall satisfy himself that based on the documents available to him, he can determine that the increased imports of the product under consideration are the substantial cause of the serious injury or threat thereof to the domestic producers of the product under consideration".

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III. SAFEGUARD MEASURES: PARAMETERS FOR EVALUATION A. The Concept and Purpose of Safeguards Section 2 of RA 8800 provides that "the state shall promote the competitiveness of domestic industries and producers based on sound industrial and agricultural development policies, and the efficient use of human, natural and technical resources. In pursuit of this goal and in the public interest, the state shall provide safeguard measures to protect domestic industries and producers from increased imports which cause or threaten to cause serious injury to those domestic industries and producers."

B. The Elements Required by Law As stated under Section 5 of RA 8800 "the Secretary shall apply a general safeguard measure upon a positive final determination of the Commission that a product is being imported into the country in increased quantities, whether absolute or relative to the domestic production, as to be a substantial cause of serious injury or threat thereof to the domestic industry; however, in the case of non-agricultural products, the Secretary shall first establish that the application of such safeguard measures will be in the public interest". C. Determination of Increased Volume of Imports

Rule 7.2 (a) of the IRRs of RA 8800 provides that “the Secretary shall essentially determine whether there has been an increase in the volume of imports, in particular, either in absolute terms or relative to production in the Philippines, The Secretary shall evaluate import data for the last five (5) years preceding the application to substantiate claims of significant increase in import volume. Provided, however, that in some cases, the period may be adjusted to cover a shorter period, if necessary, in order to take into account other considerations that will ensure the appropriateness of the chosen period, e.g. seasonality of product, availability of data or facility in the verification of data."

C.1 Period of Investigation The period of investigation (POI) covers imports of motor vehicles (AHTN 8703 and 8704) from 2014 to 2018. DTI updated the import data up to September 2019. The domestic motor vehicle industry’s overall performance during the POI was also evaluated to establish whether the increased imports are the substantial cause of the serious injury to the domestic industry.

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C.2. Absolute Terms

2.a. Import Volume The POI includes imported motor vehicles4 which entered into the Philippines from 2014 to 2018. The import data were obtained from the Bureau of Customs (BOC), Single Administrative Document-Import Entry and Internal Revenue Document (SAD-IEIRD).

2.a.1 AHTN 87.03 (Passenger Vehicles)

Table 1: Import Volume of Motor Vehicles AHTN Code 87.03 (2014 – Sep. 2019)

Source: Bureau of Customs (SAD-IEIRD)

In 2014-2015, imports of motor vehicles increased by 27,408 units or 18%. In 2016, imported motor vehicles recorded a total of 237,995 units, which is 57,056 units or 32% growth from 2015. Imports remained at pace in 2017, with a 2% increase compared to 2016. In 2018, imports experienced a decline by 15% over the last year, which may be attributed to the implementation of the new tax policy (i.e. Tax Reform for Acceleration and Inclusion - TRAIN law5) which imposes an additional excise tax on automobiles - an ad valorem tax ranging from four percent (4%) to fifty percent (50%) based on the manufacturer’s/assembler’s or importer’s selling price (net of excise and value-added tax at rates). In 2019 (Jan. to Sep.), imports were 74% of 2018. Over the five years, imported motor vehicles have grown by 35%, from 153,531 units in 2014 to 207,248 units in 2018. It was observed that during the POI, motor vehicles are being imported in increased quantities in absolute terms.

2.a.2. AHTN Code 87.04 (Light Commercial Vehicles)

Table 2: Import Volume of Motor Vehicles AHTN Code 87.04 (2014 – Sep. 2019)

Year 2014 2015 2016 2017 2018 2019

(Jan-Sep)

Volume (unit) 17,280 17,898 24,413 37,571 51,969 49,524

Absolute (Increase/(Decrease)

- 618 6,515 13,158 14,398 -

Growth Rate - 4% 36% 54% 38% -

Source: Bureau of Customs (SAD-IEIRD)

4 passenger cars refer to any four-wheeled motor vehicle, which is propelled by gasoline, diesel, electricity or any other motive

power such as hatchbacks, sedans, CUV and SUV, which are designed to transport persons and not primarily to transport goods. Light Commercial Vehicles refer to vehicles whether four-wheeled drive or not, which may be classified under but not limited to the following: utility vehicles, sports utility vehicles, Asian utility vehicles, commuter vans, pick-ups, which are designed to carry both passenger and goods/cargoes. 5 https://www.bir.gov.ph/images/bir_files/internal_communications_1/Full%20Text%20RR%202018/RR%20No.%205-2018.pdf (Bureau of Internal

Revenue Regulations No. 5-2018)

Year 2014 2015 2016 2017 2018 2019 (Jan- Sep)

Volume (unit) 153,531 180,939 237,995 243,129 207,248 125,419

Absolute (Increase/(Decrease)

- 27,408 57,056 5,134 (35,881) -

Growth Rate - 17.85 31.53 2.16 (14.76) -

https://www.bir.gov.ph/images/bir_files/internal_communications_1/Full%20Text%20RR%202018/RR%20No.%205-2018.pdf

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For the period 2014 to 2015, the import volume of motor vehicles (for the transport of goods) under AHTN 87.04 was registered at 17,280 units. In 2015, imports were recorded at 17,898 which indicated a 4% increase over the previous year. Imports in 2016 increased to 24,413 units or by 36% over the last year level. It further recorded a 38% increase in 2018. From January to September 2019, imports were 95% of the 2018 level. During the POI, imports of motor vehicles under AHTN 87.04 showed an increasing trend.

2.b.1 Share of Imports (by Country) – AHTN 87.03 (Passenger Vehicles/Cars)

Table 3: Share of Imports By Country (2014 – September 2019 ) per unit

Source: BOC-IEIRD

2014 to 2018 (POI)

The top three (3) source countries for Philippine motor vehicle imports are Thailand, Indonesia, and South Korea during the POI. Thailand accounted for the largest share of imported motor vehicles to the total Philippine imports during the POI. Indonesia ranked second and South Korea remained in the top three (3), followed by Japan (fourth) and India (fifth). China's notable volume was observed during the period. The Chinese' share of exports of the said product to the total Philippine imports has significantly increased, ranging from approximately 800 units to 6,000 units.

2019 (Jan-Sep)

In 2019 (Jan-Sep), Indonesia climbed up to the first, followed by Thailand (2nd) and South Korea (third). China’s share of imports to the total Philippine imports escalated to approximately 15,000 units of motor vehicles.

Country 2014 % Share 2015 % Share 2016 % Share 2017 % Share 2018 % Share 2019

(Jan to Sept) % Share

Thailand 65,598 43 84,227 47 101,844 43 102,533 42 74,489 36 21,411 17

Indonesia 38,029 25 38,579 21 69,215 29 81,939 34 84,990 41 71,081 57

South Korea 17,396 11 17,867 10 26,500 11 22,704 9 16,607 8 4,160 3

Japan 12,654 8 14,812 8 16,269 7 19,506 8 11,405 6 7,628 6

India 12,300 8 16,295 9 12,020 5 4,213 2 2,888 1 1,949 2

China 915 1 805 0 2,248 1 1,843 1 6,278 3 15,336 12

Major Suppliers

146,892 96 172,585 95 228,096 96 232,738 96 196,657 95 121,565 97

Other Sources 6,639 4 8,354 5 9,899 4 10,391 4 10,591 5 3,854 3

Total: 153,351 100 180,939 100 237,995 100 243,129 100 207,248 100 125,419 100

Indonesia

China

Thailand

Japan

South Korea

India

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2.b.2. Share of Imports from Other Sources

Below are the other sources of motor vehicles (AHTN 87.03) during the period of investigation:

Table 4: Import Volume – Other Sources (2014 – September 2019 ) in units

Source: Bureau of Customs (SAD-IERD)

Country 2014 %

Share 2015 %

Share 2016 %

Share 2017 % Share 2018 %

Share 2019 (Jan

to Sept)

% Share

United States 1,630 1.06 2,930 1.62 2,708 1.14 2,440 1.00 2,474 1.19 575 0.46

Germany 1,519 0.99 2,680 1.48 2,500 1.05 3,671 1.51 1,132 0.55 525 0.42

Belgium 86 0.06 8 0.00 52 0.02 882 0.36 4,366 2.11 1,546 1.23

Malaysia 1,499 0.98 57 0.03 1,245 0.52 99 0.04 1,043 0.50 299 0.24

United Arab Emirates 488 0.32 366 0.20 315 0.13 1,098 0.45 342 0.17 206 0.16

Taiwan, Province of China 10 0.01 4 0.00 1,835 0.77 1 0.00 2 0.00 - -

Mexico 190 0.12 122 0.07 353 0.15 709 0.29 175 0.08 7 0.01

United Kingdom 272 0.18 265 0.15 213 0.09 389 0.16 375 0.18 199 0.16

France 380 0.25 372 0.21 212 0.09 137 0.06 229 0.11 83 0.07

Hungary - - 1,125 0.62 1 0.00 - - - - - -

Canada 363 0.24 42 0.02 49 0.02 159 0.07 64 0.03 146 0.12

Spain 14 0.01 5 0.00 111 0.05 344 0.14 62 0.03 77 0.06

Italy 63 0.04 95 0.05 71 0.03 128 0.05 156 0.08 46 0.04

South Africa - - 116 0.06 125 0.05 71 0.03 52 0.03 27 0.02

Sweden 11 0.01 63 0.03 41 0.02 90 0.04 13 0.01 - -

Hong Kong 31 0.02 44 0.02 21 0.01 49 0.02 71 0.03 62 0.05

Poland - - - - - - 87 0.04 - - - -

Singapore - - 3 0.00 25 0.01 9 0.00 5 0.002 1 0.001

Oman 35 0.02 - - - - - - - - - -

Qatar 6 0.004 26 0.01 1 0.00 1 0.0004 1 0.0005 1 0.001

Saudi Arabia 8 0.01 7 0.00 2 0.001 2 0.0008 6 0.003 2 0.002

Russian Federation - - - - 1 0.000 16 0.01 6 0.003 10 0.01

Guam 12 0.01 - - - - 1 0.0004 - - 2 0.002

Kuwait 7 0.005 - - 3 0.001 1 0.0004 - - - -

Viet Nam 4 0.003 1 0.001 2 0.001 1 0.0004 1 0.0005 2 0.002

Australia - - 2 0.001 - - - - 6 0.003 6 0.005

Netherlands 1 0.001 1 0.001 - - 1 0.0004 5 0.002 - -

Czech Republic - - 7 0.004 - - - - - - - -

Turkey - - - - 1 0.0004 2 0.0008 3 0.001 1 0.001

Bahrain 2 0.001 - - 2 0.001 - - 1 0.0005 1 0.001

Sri Lanka - - - - 5 0.002 - - - - - -

US Virgin Islands 3 0.002 1 0.001 - - - - - - - -

Lebanon - - 2 0.001 1 0.0004 - - - - 1 0.001

Portugal - - 1 0.001 1 0.0004 1 0.0004 - - - -

Andorra - - 2 0.001 - - - - - - - -

Switzerland 1 0.001 1 0.001 - - - - - - - -

Christmas Island - - 2 0.001 - - - - - - - -

Finland 2 0.001 - - - - - - - - - -

Israel 1 0.001 - - - - 1 0.0004 - - 1 0.001

Myanmar - - 1 0.001 1 0.0004 - - - - - -

New Zealand 1 0.001 - - 1 0.0004 - - - - - -

Cameroon - - - - 1 0.0004 - - - - - -

Greece - - - - - - - - 1 0.0005 - -

Jordan - - 1 0.001 - - - - - - 2 0.002

Korea, Democratic Peoples Republic of - - 1 0.001 - - - - - - - -

Norfolk Island - - 1 0.001 - - - - - - - -

Slovakia - - - - - - 1 0.0004 - - - -

Croatia - - - - - - - - - - 11 0.01

Cambodia - - - - - - - - - - 1 0.001

Total: Other Sources 6,639 4.32 8,354 4.62 9,899 4.16 10,391 4.27 10,591 5.11 3,840 3.07

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2.b.3. Share of Imports (by Country) – AHTN Code 87.04 (Light Commercial

Vehicles)

Table 5: Share of Imports By Country of AHTN Code 87.04- Light Commercial Vehicles (2014 – September 2019 ) in units

Source: BOC-IEIRD

Thailand and Indonesia are the major sources of imported motor vehicles (for the transport of goods), classified under AHTN Code 87.04 during the POI. Indonesia exported only in 2014, with merely less than 1% of the said product. On the other hand, Thailand dominated and supplied 100% of the Philippine market during the POI, with approximately 17,000 units in 2014 to 52,000 units in 2018. In 2019 (Jan- Sep), Indonesian exported about 50,000 units of motor vehicles. C.3. Relative Terms Table 5: Comparison of Volume of Imports to Domestic Production of Motor Vehicles AHTN 87.03 – Passengers Vehicles (2014 to 2018) in units

Sources: Bureau of Customs (BOC-SAD-IERD) – Import Volume DTI Research – Domestic Production *Figures indexed due to confidentiality

For the first 3-years (2014 to 2016), the share of imported motor vehicles to domestic production continuously increase from xxx (2014) to xxx (2016). However, it declined to xxx in 2017. In 2018, the share of imports vis-à-vis domestic production set a record high at xxx.

Country 2014 %

Share 2015

% Share

2016 % Share 2017 %

Share 2018

% Share

2019 (Jan-Sep)

% Share

Thailand 17,276 99.98 17,898 100 24,413 100 37,571 100 51,969 100 49,524 100

Total: Major Source

17,276 99.98 17,898 100 24,413 100 37,571 100 51,969 100 49,524 100

Other Sources:

Indonesia 4 0.02 - - - - - - - - - -

Total: Other Sources

4 0.02 - - - - - - - - - -

Total: 17,280 100.00 17,898 100 24,413 100 37,571 100 51,969 100 49,524 100

Year Imports

(in units)

Domestic Production (in units)*

Share of Imports to Domestic Production

(%)

2014 153,531 100 xxx

2015 180,939 113 xxx

2016 237,995 131 xxx

2017 243,129 148 xxx

2018 207,248 93 xxx

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Table 6: Comparison of Volume of Imports to Domestic Production of Motor Vehicles AHTN 87.04 - Light Commercial Vehicles (2014 to 2018) in units

Year Imports (in units)

Domestic

Production (in units)*

Share of Imports to

Domestic Production

(%) 2014 17,280 100 xxx

2015 17,898 139 xxx

2016 24,413 143 xxx

2017 37,571 266 xxx

2018 (Jan to Oct) 38,183 159 xxx Sources: Bureau of Customs (BOC-SAD-IERD) – Import Volume DTI Research – Domestic Production *Figures indexed due to confidentiality

In 2014, the share of imports of motor vehicles was recorded at xxx relative to domestic production. Share of imports relative to domestic production for the period 2015 to 2017 showed a fluctuating trend. In 2018, (Jan to Oct), imports recorded its highest share to domestic production at xxx.

IV. THE EVIDENCE PRESENTED BY THE INDUSTRY

A. The Product Subject to the Petition

Section 4 (h) of RA 8800 defines like product as "a domestic product which is identical, i.e. alike in all respects to the imported product under consideration, or in the absence of such a product, another domestic product which, although not alike in all respects, has characteristics closely resembling those of the imported product under consideration".

Section 4 (e) of RA 8800 further provides, "directly competitive product shall mean domestically produced substitutable products".

A comparison of the imported motor vehicles with the locally produced vehicles is required to determine if these are like or directly competitive products.

A.1 Domestic Product

Passenger cars refer to any four-wheeled motor vehicle, which is propelled by gasoline, diesel, electricity or any other motive power such as hatchbacks, sedans, CUV and SUV, which are designed to transport persons and not primarily to transport goods.

Light commercial vehicles refer to vehicles whether four-wheeled drive or not, which may be classified under but not limited to the following: utility vehicles, sports utility vehicles, Asian utility vehicles, commuter vans, pick-ups, which are designed to carry both passenger and goods/cargoes.

A.2. Uses and Applications

Passenger cars principally designed to transport persons (less than 10 persons) and not primarily to transport goods.

Light commercial vehicles are principally designed to carry both passengers and goods/cargoes.

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B. Imported Product

1. Product Description under the Tariff and Customs Code 8703 (Passenger

Vehicles/Cars)

AHTN

Description

MFN AKFTA AJCEP AIFTA AANZFTA ACFTA PJEPA

ATIGA

2017- 2019 2015 2016

2014- 2018

2015 2016 2017 2018 2019 2020 2004-

2020 2017 2018

2011- 2018

8703

Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 87.02), including station wagons and racing cars.

30

87032110 - - - 18 15 12 9 0 0 - - - - 0

87032129 - - - - Other 20 5 - - - - - - - - 20 5 - 0

87032129B - - - - - New 20 5 - - - - - - - - 20 5 - 0

87032190C - - - - Other, New 20 5 - - - - - - - - 20 5 - 0

87032219B - - - - - New 20 5 - - - - - - - - 20 5 - 0

87032345

- - - - - - - - - - - 0

87032351B - - - - - New 20 5 20 - - - - - - 0 - - - 0

87032352B - - - - - New 20 5 20 - - - - - - 0 - - - 0

87032353B - - - - - New 20 5 20 - - - - - - 0 - - - 0

87032354B - - - - - New 20 5 20 - - - - - -

- - - 0

87032450B - - - - New 20 5 30 - - - - - - 0 - - 0 0

87033120

- - - Motor cars (including station wagons, SUVs and sports cars, but not including vans), other:

- - - - - - - - - - 20 5 - 0

87033120B - - - - New 20 5 - - - - - - - 0 20 5 - 0

87033241 - - - - - - - - -

20 5 - 0

87033249 - - - - - - - - -

20 5 - 0

87033251B - - - - - - - - - 0 20 5 - 0

87033259B - - - - - - - - - 0 20 5 - 0

87033291B - - - - - - - - -

20 5 - 0

87033291D - - - - - - - - - 0 20 5 - 0

87033291E - - - - - - - - - - 20 5 - 0

87033299C - - - - - - - - - - 20 5 - 0

87033341 - - - - - - - - - - 20 5 - 0

87033342 - - - - - - - - - - 20 5 - 0

87033351A - - - - - - - - - - 20 5 - 0

87033351B - - 30 - - - - - - 0 20 5 - 0

87033352B - - 30 - - - - - - - - - 0 0

87033390C - - - - - - - - - - - - 0 0

87039051 - - - - - - - - - - - - 0 0

Source: Classification based on The Philippine Tariff Finder (PTF) of the Tariff Commission. Retrieved from

http://tariffcommission.gov.ph/finder

AHTN ASEAN Harmonized Tariff Nomenclature

MFN Most Favoured Nation AANZFTA ASEAN-Australia/New Zealand Free Trade Agreement ACFTA ASEAN-China Free Trade Agreement AIFTA ASEAN-India Free Trade Agreement AJCEPA ASEAN-Japan Comprehensive Economic Partnership Agreement AKFTA ASEAN-Korea Free Trade Agreement ATIGA ASEAN Trade in Goods Agreement PJEPA Philippines-Japan Economic Partnership Agreement


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2. Product Description under the Tariff and Customs Code 8704 (Light

Commercial Vehicles)

AHTN Description MFN AANZFTA ACFTA AJCEPA AKFTA PJEPA ATIGA

2017-2020 2012-2020 2012-2017 2018 2015-2018 2012-2015 2016 2011-2018

8704 Motor vehicles for the transport of goods

8704.21.29 ----Other. 30 0 20 5 30 20 5 0 0

8704.21.19 ----Other. 30

Source: Classification based on The Philippine Tariff Finder (PTF) of the Tariff Commission. Retrieved from http://tariffcommission.gov.ph/finder

AHTN ASEAN Harmonized Tariff Nomenclature

MFN Most Favoured Nation AANZFTA ASEAN-Australia/New Zealand Free Trade Agreement ACFTA ASEAN-China Free Trade Agreement AJCEPA ASEAN-Japan Comprehensive Economic Partnership Agreement AKFTA ASEAN-Korea Free Trade Agreement PJEPA Philippines-Japan Economic Partnership Agreement

C. Comparison between Imported and Domestic Product

Locally produced motor vehicles and imported motor vehicles are like products as follows:

1. classified under same tariff codes 2. Same uses and application

V. EVIDENCE OF SERIOUS INJURY Rule 3.1 of the IRRs of RA 8800 provides that “a general safeguard measure under Chapter II of these IRRs shall apply where there is an increase in the quantity of a product being imported, whether absolute or relative to the domestic production, which is determined to be a substantial cause of serious injury or threat thereof to the domestic industry”.

Section 4 (o) of RA 8800 also provides that “a serious injury shall mean a significant impairment in the position of the domestic industry after evaluation by competent authorities of all relevant factors of an objective and quantifiable nature having a bearing on the situation of the industry concerned. In particular, the rate and amount of the increase in imports of the product concerned in absolute and relative terms, the share of the domestic market taken by increased imports, changes in levels of sales, production, productivity, capacity utilization, profit and losses, and employment”.

Section 12 of RA 8800 further provides that “in reaching a positive determination that the increase in the importation of the product under consideration is causing serious injury or threat thereof to a domestic industry producing like products or directly competitive products, all relevant factors having a bearing on the situation of the domestic industry shall be evaluated. These shall include, in particular, the rate and amount of the increase in imports of the products concerned in absolute and relative terms, the share of the domestic market taken by the increased imports, and changes in the level of sales, production, productivity, capacity utilization, profits and losses, and employment.

Such positive determination shall not be made unless the investigation demonstrates on the basis of objective evidence, the existence of the causal link between the increased imports of the product under consideration and serious injury or threat thereof to the domestic industry. When factors other than increased imports are causing injury, such injury shall not be attributed to increased imports.”


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A. Share of the Domestic Industry 1) Market Size

1.a Passenger Vehicles/Cars

Table 7: Total Apparent Philippine Market (in units) - 2014 to 2018

Year Imports (in units)

Domestic Industry

Sales Volume (in units)*

Total Apparent Philippine

Market (in units)*

% Increase/ (Decrease)

2014 153,531 100 100 -

2015 180,939 116 117 17%

2016 237,995 130 149 27%

2017 243,129 148 156 5%

2018 207,248 77 120 (23%) Source: Volume - Bureau of Customs, (SAD-IEIRD) Domestic Sales – DTI Research *Figures indexed due to confidentiality

In 2015, the apparent Philippine market increased by 17% over the 2014 level. It continued to increase by 27% in 2016 and further by 5% in 2017. In 2018, the total apparent consumption fell by 23%, as imports and domestic sales went down by 14% and 48%, respectively. This can be attributed to the TRAIN law implemented in the same year.

1.b Light Commercial Vehicles

Table 8: Total Apparent Philippine Market (in units) - 2014 to 2018

Year Imports

(unit)

Domestic Industry

Sales Volume (unit)*

Total Apparent Philippine

Market (unit)*

% Increase/ (Decrease)

2014 17,280 100 100 -

2015 17,898 82 100 (0.33%)

2016 24,413 104 135 35%

2017 37,571 123 200 49%

2018 (Jan to Oct) 38,183 81 196 (2%) Sources: Volume - Bureau of Customs, (SAD-IEIRD) Domestic Sales – DTI Research *Figures indexed due to confidentiality

The apparent Philippine market of light commercial vehicles showed an increasing trend from 2016 to 2018 (i.e. xxx units in 2016 to xxx units in 2018).

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2) Market Share

2.a Passenger Vehicles/Cars Table 9: Volume of Imports of Motor Vehicles vis-à-vis Domestic Sales (in units) -

2014 to 2018

Year 2014 2015 2016 2017 2018

Imports 153,531 180,939 237,995 243,129 207,248

Domestic Sales* 100 116 130 148 77

Total to Philippine Market*

100 117 149 156 120

% Share to Philippine Market

Imports xxx xxx xxx xxx xxx

Domestic Sales xxx xxx xxx xxx xxx

Sources: BOC-IEIRD – Volume of Imports DTI Research – Domestic Sales *Figures indexed due to confidentiality

The domestic sales relative to the Philippine market ranges from xxx to xxx for the period 2014 to 2017 and fell to its lowest in 2018 as imports ate up xxx of the market. On the other hand, the share of imports to the total Philippine market captured xxx to xxx of the market during the POI.

2.b Light Commercial Vehicles Table 10: Volume of Imports of Light Commercial Vehicles vis-à-vis Domestic Sales (in

units) - 2014 to 2018

Year 2014 2015 2016 2017 2018 (Jan to Oct)

Imports 17,280 17,898 24,413 37,571 38,183

Domestic Sales* 100 82 104 123 81

Total Philippine Market* 100 100 135 200 196

% Share to Philippine Market

Imports xxx xxx xxx xxx xxx

Domestic Sales xxx xxx xxx xxx xxx

Sources: Volume - Bureau of Customs, (SAD-IEIRD) Domestic Sales – DTI Research *Figures indexed due to confidentiality

Share of total imports to the total Philippine market showed a steady increase during the POI. It increased to xxx in 2015, xxx in 2016, xxx in 2017 and xxx in 2018 (Jan-Oct). Share of domestic sales of the said product to the Philippine market exhibited a downward trend from 2014 to 2018 (Jan. to Oct), from a high of xxx to a low of xxx.

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B.1 Domestic Sales

1.a Passenger Vehicles/Cars Table 11: Domestic Sales Volume and Value of Passenger Vehicles

Year Sales Volume

(in units)* % Increase (Decrease)

Sales Value (in Million

Php)* % Increase (Decrease)

2014 100

100

2015 116 15.51 114 14.50

2016 130 12.71 134 16.76

2017 148 13.47 158 18.38

2018 92 - 102 -

Source: DTI Research *Figures indexed due to confidentiality

The domestic sales volume steadily increased in 2015 by 16% and in 2016 and 2017 by 13%. In the same way, sales value increased from 2014 to 2017 at 15%, 17%, and 18%, respectively. One of the manufacturers' data covers only until September 2018.

1.b Light Commercial Vehicles Table 12: Domestic Sales Volume and Value of Light Commercial Vehicles

Year

Sales Volume

(in units)* % Increase (Decrease)

Sales Value (in Million

Php)* % Increase (Decrease)

2014 100

100 2015 82 (18.06) 83 (17.38)

2016 104 27.28 105 27.28

2017 123 17.88 133 26.09

2018 Jan-Oct 81 - 92 -


The domestic sales volume and value declined in 2015 by 18% and 17%, respectively. From 2015 to 2017, sales volume steadily increased by 27% and 18% with an increase in sales value at 27% in 2016 and 26% in 2017. However, as of October 2018, sales volume and value are only 66% and 69% compared to the 2017 level, respectively.

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B.2 Share of Sales of Domestically Assembled Passenger Vehicles vs. Share of Sales of Imported Passenger Vehicles

Table 13: Share of Sales of Domestically Assembled Cars vs. Share of Sales of

Imported Passenger Cars by the Domestic Industry

Year

Domestically Assembled Car Sales Volume

(a)*

Imported Vehicles or

CBU's Sales

Volume (b)*

Total Sales in

Units (a + b=c)*

Share of Domestically Assembled

Cars to Total Sales (a/c)

Share of Imported

Vehicles or CBU's Sales Volume to Total Sales

(b/c)

2014 100 100 100 42.64 57.36

2015 108 128 120 38.56 61.44

2016 121 184 157 32.84 67.16

2017 137 218 184 31.85 68.15

2018 86 178 138 26.43 73.57 Source: DTI Research *Figures indexed due to confidentiality

There was a declining trend of share of domestically assembled passenger vehicle sales volume to the total sales by the domestic industry from 43% in 2014 to 32% in 2017. On the other hand, there was an increasing share of sales of imported vehicles or CBUs to the total sales of the motor vehicle industry from 58% in 2014 to 68% in 2017. Notwithstanding the last quarter data in 2018 of one motor vehicle company, the share of sales of domestically assembled motor vehicle to total unit sales of the motor vehicle industry further shrank to 26% while the share of sales of imported CBUs to total unit sales increased to 74%, posting a 1:3 ratio of sales volume of domestically assembled CBU to sales volume of imported CBU by the domestic motor vehicle industry. C. Production

C.1 Passenger Vehicles/Cars Table 14: Total Production of Passenger Vehicles/Cars

Year 2014 2015 2016 2017 2018

Production (in units)* 100 113 131 148 93

% Increase (Decrease) - 13.37 15.36 13.04

(37.06)


As sales exhibited an increasing trend, production volume also increased from 2014 to 2017 at 14%, 15%, and 13%, respectively, and one of the manufacturers' data covers only until September 2018.

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C.2 Light Commercial Vehicles

Table 15: Total Production of Light Commercial Vehicles

Year 2014 2015 2016 2017 Jan-Oct 2018

Production (in units)* 100 139 143 266 159 % Increase (Decrease)

-

39.15

2.67

86.25

-


Production volume exhibited an increasing trend from 2014 to 2017 by 39%, 3%, and 86%, respectively. Production in ten (10) months of 2018 is only 60% of the 2017 level.

However, PMA provided data relevant to the production volume of two (2) major manufacturers of commercial vehicles. It exhibited a downward trend from 2017 to 2018, as shown in the table below.6

Table 16: Total Production of Commercial Vehicles

Year

Company A Company B

2017 2018 Jan-June

2019 April 2017 to March 2018

April 2018 to March 2019

Production (in units) 12,035 9,349 2,050 36,972 21,022

% Increase (Decrease)

-

(12.32)

-

-

(43.14)

Source: PMA

D. Capacity Utilization

D.1 Passenger Vehicles/Cars

Table 17: Total Production of Passenger Vehicles/Cars

Year

Installed/Rated Capacity (in

units)*

Actual Production (in

units)*

Capacity Utilization Rate (%)


2014 100 100 50.55 -

2015 102 113 56.33 11.43

2016 124 131 53.11 (5.72)

2017 128 148 58.40 9.97

2018 152 93 31.01 (46.91) Source: DTI Research *Figures indexed due to confidentiality

Capacity utilization exhibited a fluctuating trend from 2014 to 2017. In 2015, capacity utilization increased by 11%, while in 2016, it declined by 6%. This can be attributed to the increase of rated capacity by 22% while production only increased by 13%. In 2017, it increased by 10%.

Based on data gathered, the installed capacity may process production in two batches (2) batches, depending on the number of requirements/ assembled cars to be produced in a day. 6 PMA submitted data on production from two (2) major manufacturers in the Philippine Automotive Industry.

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D.2 Light Commercial Vehicles Table 18: Total Production of Light Commercial Vehicles

Year Maximum Line

Capacity*

Actual Production (in

units)*

Capacity Utilization Rate (%)


2014 100 100 23.09 -

2015 100 139 32.13 39.15

2016 100 143 32.99 2.67

2017 117 266 52.66 59.64

2018 Jan-Oct 117 159 31.50 -


The capacity utilization is increasing from 2015 to 2017 by 39%, 3%, and 60%, respectively. It can be noted that the industry has increased its capacity in 2017. During the ten (10) months of 2018, the capacity utilization is 32% compared to 53% in 2017. E. Finished Goods Inventory

E.1 Passenger Vehicles/Cars Table 19: Finished Goods Inventory

Year Volume (in

units)* % Increase (Decrease)

Value (in Million Php)*

% Increase

(Decrease)

2014 100

100 2015 91 (8.91) 79 (20.52)

2016 241 164.25 229 188.42

2017 332 37.95 291 27.12

2018 457 - 467 - Source: DTI Research *Figures indexed due to confidentiality

Finished goods inventory volume declined by 9% in 2015 but soared to 164% in 2016. It further increased to 38% in 2017, registering the highest finished goods inventory at xxx units. Finished goods inventory value also declined by 21% in 2015 and increased by 188% and 27% in 2016 and 2017, respectively. Since CBUs are a high-value item, the value of finished goods inventory increased from a recorded amount of xxx in 2014 to xxx in 2017. Notwithstanding the last quarter data of one car company, the finished goods inventory registered at the highest level in 2018 at xxx units of CBUs or xxx.

E.2 Light Commercial Vehicles Based on data gathered, the accumulated inventory from 2013 to October 2018 is xxx units at xxx based on average price.

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F. Cost to Produce

F.1 Passenger Vehicles/Cars

Table 20: Cost to Produce

Particulars 2014 2015 2016 2017 2018

Raw Materials* 89 88 87 89 88

Direct Labor* 2 2 2 2 3 Manufacturing

Overhead* 9 10 11 9 9

Variable* 6 7 7 7 6

Fixed* 3 3 3 2 3 Total Mfg cost

(Php/unit)* 100 100 100 100 100

% Increase (Decrease)**

(4.54)

7.88

4.52

8.54

Source: DTI Research *Figures in percentage of the cost to produce per unit **Computed based on the absolute figures of cost to produce per unit

The cost to produce per unit declined by 5% in 2015 while it steadily increased from 2016 to 2018 by 8%, 5%, and 9%, respectively.

F.2 Light Commercial Vehicles

Table 21: Cost to Produce

Particulars 2014 2015 2016 2017 2018

Jan-Oct

Raw Materials* 92 92 93 94 94

Direct Labor* 2 2 2 2 2 Manufacturing

Overhead* 6 6 5 4 4

Variable* 4 4 4 3 3

Fixed* 2 2 1 1 1 Total Mfg cost

(Php/unit)* 100 100 100 100 100

% Increase (Decrease)**

(2.33) (1.97) 11.89 13.36

Source: DTI Research *Figures in percentage of the cost to produce per unit **Computed based on the absolute figures of cost to produce per unit

The cost to produce per unit decline from 2014 to 2016 by 2% each year. However, it increased in 2017 by 12% and further increased by 13% as of October 2018.

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G. Earnings Before Interest and Taxes

G.1 Passenger Vehicles/Cars

Table 22: Earnings Before Interest and Taxes

Particulars 2014* 2015* 2016* 2017* 2018*

% Increase

(Decrease) (2014

vs.2015)

% Increase

(Decrease) (2015

vs.2016)

% Increase

(Decrease) (2016

vs.2017)

% Increase

(Decrease) (2017

vs.2018)

Sales 100 114 134 158 101 14.50 17.41 17.36 (35.74)

Cost of Goods Sold 100 113 134 160 110 12.92 18.70 19.52 (31.41)

Gross Profit 100 125 137 141 43 25.38 9.42 2.79 (69.80)

Selling, General and Administrative Expenses 100 93 91 94 73 (7.13) (2.24) 3.80 (23.00)

Earnings Before Interest and Tax 100 148 170 174 21 48.28 14.56 2.41 (87.66)


The aggregate earnings before interest and taxes (EBIT) increased during the POI 2014 to 2017. However, individual EBIT showed that one company already exhibited losses in 2017 and further to 2018. xxx. Another company declined its EBIT by 88% in 2017 and exhibited a loss in 2018 at xxx or a decrease of 691% as compared to the increase of profit in 2015 and 2016 at 112% and 88%, respectively. The other company increased its EBIT from 2013 to 2017 at 81%, 54%, 6%, and 19%, respectively. Its EBIT registered highest in 2013 when import competition is low. While the aggregate EBIT showed an increasing trend from 2014 to 2017 at 48%, 15%, and 2%, respectively, the individual companies were affected resulting in losses and a decline in profit. Also, the rate of increase in EBIT was declining since 2014. Notwithstanding the last quarter data of one company in 2018, the aggregate EBIT declined by 88%.

G.2 Light Commercial Vehicles Table 23: Earnings Before Interest and Taxes

Particulars 2014* 2015* 2016* 2017*


(2014 vs.2015)


(2015 vs.2016)


(2016 vs.2017)

Sales 100 151 157 307 51.12 3.62 96.17

Cost of Goods Sold 100 150 158 300 49.71 5.24 90.61

Gross Profit 100 202 121 557 102.42

(40.15) 359.66

Selling, General and Administrative

Expenses 100 168 241 388 68.48 43.32 60.73

Earnings Before Interest and Tax 100 152 298 308 (52.44) (95.67) (3.39)


Despite the increasing sales from 2014 to 2017, the industry sustained increasing losses during the period by 52%, 96%, and 4%, respectively. The highest loss was recorded in 2017 at xxx.

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H. Return on Sales

H.1 Passenger Vehicles/Cars

Table 24: Return on Sales

Particulars (in Million Php) 2014 2015 2016 2017

2018

Sales* 100 114 134 158 101

EBIT* 100 148 170 174 21

Return on Sales xxx xxx xxx xxx xxx

% Increase (Decrease) -

26.01

(5.85)

(13.37)

(79.53)


Return on sales (ROS) ranges from xxx to xxx from 2014 to 2017, the highest of which was recorded in 2015 at xxx. In 2018, ROS was recorded at xxx.

H.2 Light Commercial Vehicles

Table 25: Return on Sales

Particulars 2014 2015 2016 2017

Sales* 100 151 157 307

EBIT* (100) (152) (298) (308)

Return on Sales xxx xxx xxx xxx

% Increase (Decrease) -

(0.88)

(88.84)

47.30 Source: DTI Research *Figures indexed due to confidentiality

Loss on sales was recorded from 2014 to 2017 ranging from 5.65% to 10.77%.

I. Employment PMA provided data relevant to employment of major manufacturers of motor vehicles.

Table 28: Employment

Year Employees % Increase (Decrease)

2013 1,084 -

2014 1,186 9.41

2015 1,242 4.72

2016 1,915 54.19

2017 2,309 20.57

2018 1,901 (17.67)

2019 1,112 (41.50) Source: PMA

The table above showed that data on employment indicated an increasing trend from 2013 to 2017 but started to decline from 2018 to 2019.

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K. Price Undercutting Price undercutting reflects the extent to which the imported product is consistently sold at a price below the domestic selling price of the like product.

K.1 Passenger Vehicles/Cars

Table 31: Average Selling Price of Domestic Product vs. Landed Cost of Imports for

2018 (P in unit)

Country Wtd. Ave. Landed Cost

(P in unit) (a)

% Share to Total

Imports

Ave. Domestic

Selling Price (P in unit)

(b)

% Undercutting

(b-a)/b*100

Major Sources:

Thailand xxx 36

xxx

18.09

Indonesia xxx 41 23.85

South Korea xxx 8 24.12

Other Sources xxx 15 18.80

Wtd. Average xxx 100 21.75

Sources: Wtd. Ave. Landed Cost- BOC-SAD-IERD Domestic Selling Price - DTI Research

Based on BOC-IEDs in 2018, the top three (3) major source countries of motor vehicles to the Philippines are Thailand, Indonesia, and South Korea. Weighted average landed cost of imports from all sources is lower by 21.75% than the domestic selling price of the domestic product, thus, imported motor vehicles undercut the domestic passenger vehicle.

K.2 Light Commercial Vehicles

Table 32: Average Selling Price of Domestic Product vs. Landed Cost of Imports for 2018 (P in unit)

Country Wtd. Ave. Landed Cost

(P in unit) (a)

% Share to Total Imports

Ave. Domestic Selling Price (P

in unit) (b)

% Undercutting (b-a)/b*100

Major Source:

Thailand xxx 100 xxx 30.19

Sources: Wtd. Ave. Landed Cost- BOC-SAD-IERD Domestic Selling Price - DTI Research

Based on the BOC-IEDs for 2018, the only source country of pick-up trucks to the Philippines is from Thailand.

Weighted average landed cost of imports from Thailand is lower by 30% than the domestic selling price of the domestic product, imported commercial vehicles undercut the domestic product.

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L. Price Suppression Price suppression refers to the extent by which the imported product prevents the domestic producer from increasing its selling price to a level that will allow full recovery of its cost of production.

L.1 Passenger Vehicles/Cars Table 33: Average Selling Price of Domestic Product vs. Cost of Production for 2018 (P

in unit)

Year Ave. Selling Price of Domestic

Product (Php in unit)*

(A)

Cost of Production (Php in unit)

(B)*

Difference (Php in

unit) (A-B)*

% Price Suppression (A-B)/B*100

2014 100 100 100 xxx

2015 98 95 110 xxx

2016 98 103 77 xxx

2017 101 108 69 xxx

2018 108 117 66 xxx


There was no indication of price suppression during the POI.

L.2 Light Commercial Vehicles Table 34: Average Selling Price of Domestic Product vs. Cost of Production for 2018 (P

in unit)

Year Ave. Selling Price of Domestic

Product (Php in unit)*

(A)

Cost of Production

(Php in unit)*

(B)

Difference (Php in unit)* (A-B)

% Price Suppression (A-B)/B*100

2014 100 100 100 xxx

2015 107 98 133 xxx

2016 116 96 172 xxx

2017 110 107 119 xxx

Jan-Oct 2018 121 121 122 xxx


There was no indication of price suppression during the POI.

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M. Price Depression Price depression reflects the extent at which the domestic producer decreases its selling price in order to compete with the imported product.

M.1 Passenger Vehicles/Cars Table 35: Domestic Selling Price of Locally Manufactured Cars (P in unit)

Year Average Selling Price per unit*


2014 100 58.29

2015 98 (1.99)

2016 98 0.44

2017 101 2.56

2018* 108 6.97 Source: DTI Research *Figures indexed due to confidentiality

Price depression was recorded in 2015 at (1.99%).

M.2 Light Commercial Vehicles Table 36: Average Domestic Selling Price

Year Average Selling Price per unit*


2014 100 -

2015 107 6.94

2016 116 8.25

2017 110 (4.75)

Jan-Oct 2018 121 10.16 Source: DTI Research *Figures indexed due to confidentiality

Price depression was recorded in 2017at (4.75%). VI.1 FINDINGS AND CONCLUSIONS A. Passenger Vehicles/Cars

1. Volume of Imports

1.a. In Absolute Terms

Imports increased from 2014 to 2015. In 2016, imported motor vehicles increased by 32% over the 2015 level and continued to increase by 2% in 2017. In 2018, imports experienced a decline of 15% over the 2017 level due to TRAIN law.

In 2019 (Jan. to Sept.), imports were 74% of the 2018 level.

Top three (3) source countries for Philippine motor vehicle imports are Thailand, Indonesia, and South Korea during the POI.

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1.b. In Relative Terms

The share of imported motor vehicles to domestic production continuously increase from 295% (2014) to 349% (2016).

Declined by 316% in 2017. In 2018, the share of imports vis-à-vis domestic production set a record high at 428%.

2. Serious Injury

2.a. Market Size

In 2015, the apparent Philippine market increased by 17% over the 2014 level. It continued to increase by 27% in 2016 and further by 5% in 2017.

In 2018, the total apparent consumption fell by 23%, as imports and domestic sales went down by 14% and 48%, respectively.

2.b. Market Share

Domestic sales relative to the Philippine market recorded a range of 22% to 25% from 2014 to 2017 and fell to its lowest in 2018 as imports ate up 84% of the market.

Share of imports to total Philippine market captured 75% to 84% of the market during the POI

3. Domestic Sales

Domestic sales volume steadily increased by 16% in 2015 and by 13% in 2016 and 2017. Sales value increased from 2014 to 2017 at 15%, 17%, and 18%, respectively. The motor vehicle industry could have sold more units but increased imports eaten up the market.

4. Production

4.a. Total Production

Increased from 2014 to 2017 at 15% to 13%, respectively. 4.b. Capacity Utilization

Exhibited a fluctuating trend from 2014 to 2017. In 2015, capacity utilization increased by 11% but declined in 2016 by 6%. In 2017, it increased by 10%.

4.c. Inventories

Inventories exhibited an increasing trend from 2015 to 2017.

The highest level of inventory was recorded at xxx units in 2018.

4.d Cost of Production

The cost to produce per unit declined by 5% in 2015 and steadily increased from 2016 to 2018 by 8%, 5%, and 9%, respectively.

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5. Profitability

5.a. Profits and Losses

EBIT showed an increasing trend from 2014 to 2017 at 48%, 15%, and 2%, respectively. The motor vehicle industry could have earned more profit, but due to increased imports resulted in a decline in profit.

5.b. Return on Sales

Return on sales (ROS) ranges from xxx to xxx from 2014 to 2017, the highest was recorded in 2015.

ROS is at xxx in 2018. 6. Employment

Employment showed an increasing trend from 2013 to 2017 but started to decline from 2018 to 2019.

7. Prices

7.a. Price Undercutting

The weighted average landed cost of imports from all sources is lower by 21.75% than the domestic selling price of the domestic product.

7.b. Price Suppression

The domestic industry average domestic selling price managed to cover its

costs of production during the POI.

7.c. Price Depression

Price depression was recorded at (1.99%) in 2015.

VI.2 FINDINGS AND CONCLUSIONS

B. Commercial and Light Vehicles 1. Volume of Imports

1.a. In Absolute Terms

Imports increased from 2014 to 2018. In 2016, imported motor vehicles increased by 32% over the 2015 level and continued to increase by 2% in 2017. In 2018, imports experienced a decline of 15% over the 2017 level.

In 2019 (Jan. to Sept.), imports were 95% of the 2018 level.

Thailand is the source country for commercial and light vehicles during the POI.

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1.b. In Relative Terms

The share of imported motor vehicles to domestic production continuously increase from 645% (2015) to 1,203% (2018- (Jan-Oct)).

2. Serious Injury

2.a. Market Size

Apparent Philippine market for commercial vehicles showed an increasing trend from 2016 to 2018 (i.e. x x x units in 2016 to x x x units in 2018).

2.b. Market Share

Domestic sales relative to the Philippine market exhibited a downward trend from 2014 to 2018 (Jan. to Oct), from a high of 18% to a low of 7%.

Share of imports to total Philippine showed a steady increase during the POI, i.e. 85% in 2015, 86% in 2016, 89% in 2017 and 93% in 2018 (Jan-Oct).

3. Domestic Sales

Domestic sales volume declined by 16% in 2015 but increased by 27% in 2016 and 18% in 2017. Sales value decreased by 17% in 2017 but increased by 27% in 2016 and 26% in 2017. For 2018 (Jan-Oct), sales volume and value are only 66% and 69% compared to the 2017 level, respectively.

4. Production

4.a. Total Production

Production volume increased from 2014 to 2017, i.e. 39% (2015), 3% (2016) and 86% (2017).

4.b. Capacity Utilization

Exhibited increasing trend from 2014 to 2017, i.e. 39% (2015), 3% (2016) and 60% (2017). For 2018 (Jan-Oct) it is recorded at 32%.

4.c. Inventories

Accumulated inventory from 2013 to October 2018 is xxx.

4.d Cost of Production

The cost to produce per unit declined from 2014 to 2016 by 2% each year.

It increased in 2017 by 12% and further increased by 13% as of October 2018.

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5. Profitability

5.a. Profits and Losses

Industry sustained increasing losses during the POI by 52%, 96%, and 4%, respectively. The highest loss was recorded in 2017 at xxx.

5.b. Return on Sales

Loss on sales was recorded from 2014 to 2017 ranging from xxx to xxx. 6. Employment

Employment showed an increasing trend from 2013 to 2017 but started to decline from 2018 to 2019.

7. Prices

7.a. Price Undercutting

The weighted average landed cost of imports from Thailand is lower by 30% than the domestic selling price of the domestic product.

7.b. Price Suppression

There was no price suppression during the POI.

7.c. Price Depression

Price depression was recorded at (4.75%) in 2017.

VII.1 CAUSATION (Passenger Vehicles) The above evidence shows that serious injury to the domestic motor vehicle industry was caused by the increased imports based on the following:

Significant increases in the volume of the imported passenger vehicles from 2014 to 2018;

The conditions of competition showed that the market share of the domestic motor vehicle industry significantly decreased during the POI from a high of 25% in 2014 to 16% in 2018, as imports displaced locally produced passenger vehicles.

The domestic motor vehicle industry could have sold a higher number of units, but due to loss of market share, companies were affected resulting to losses and decline in profit.

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VII.2 CAUSATION (Light Commercial Vehicles) The above evidence shows that serious injury to the domestic industry was caused by increased imports based on the following:

Significant increase in the volume of the imported commercial or light vehicles from 2014 to 2017; declined by 15% in 2018 over the 2017 level.

The conditions of competition showed that the market share of the Philippine motor vehicle industry significantly declined during the POI from 18% in 2014 and to 7% in 2018 (Jan-Oct.), as imports displaced locally produced light commercial vehicles in the domestic market.

The motor vehicle industry sustained increasing losses that can be attributed to increased imports.

VIII. THE WORLD TRADE ORGANIZATION AGREEMENT ON SAFEGUARDS Article XIX (Emergency Action on Imports of Particular Products) of the General Agreement on Tariffs and Trade (GATT) 1994 provides that: “If, as a result of unforeseen developments and of the effect of the obligations incurred by a contracting party under this Agreement, including tariff concessions, any product is being imported into the territory of that contracting party in such increased quantities and under such conditions as to cause or threaten serious injury to domestic producers in that territory of like or directly competitive products the contracting party shall be free, in respect of such product, and to the extent and for such time as may be necessary to prevent or remedy such injury, to suspend the obligation in whole or in part or to withdraw or modify the concession.” The WTO Appellate Body in Argentina – Footwear and Korea – Certain Dairy Products established that safeguard measures may be applied only when the prerequisites of Article XIX of GATT 1994 and the conditions of the Agreement on Safeguards (both Multilateral Trade Agreements and as such are integral parts of the WTO Agreement) are clearly demonstrated.

Motor vehicles are not the subject of any tariff concession under the WTO Agreement. The investigation is also governed by RA 8800, the Safeguard Measures Act, and the terms and conditions of the Agreement on Safeguards.

VIII.a. Unforeseen Development

As a WTO Member, the Philippines is bound by Article XIX GATT 1994 and the Safeguards Agreement. The applicant domestic industry must, therefore, allege and prove that unforeseen developments and the effect of the obligations of the Philippines under the WTO Agreement, including tariff concessions, have led to the increase in importation as well as the presence of the resulting serious injury or threat thereof.

Southeast Asia is a powerhouse for the motor vehicle industry in Asia and beyond with a very attractive perspective for the coming years. The region presents the double interest of having large markets with important sales growth potential and important automotive manufacturing hubs to produce for Asia and the world7. 7 https://aseanup.com/southeast-asia-automotive-industry-overview/

https://aseanup.com/southeast-asia-automotive-industry-overview/

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There are opportunities in the industry for investors in assembly operation. On the export market, though not yet quantified, there is a huge demand in the export market especially ASEAN. The current ASEAN AFTA provides for a zero-tariff regime which started in 2007, provided the 40% ASEAN content requirement is met. The Philippines can be one of the centers for motor vehicle assembly for export to ASEAN being ideally situated geographically. The country likewise provides some incentives and policies which could give a competitive advantage to would-be assemblers, not to mention the inherent strength of the industry as mentioned earlier.

On a regional level, Thailand is the largest car manufacturer in Southeast Asia, with 23 car assembly plants, eight motorcycle plants, 386 tier-one auto parts makers and 1,700 tier-two and tier-three auto parts makers. The Federation of Thai Industries (FTI) estimates exports of automotive products at 950 billion baht in 2018, up from 941 billion the year before.8 Since with ASEAN integration, there are no more customs duties and taxes moving goods within the ASEAN. These manufacturing facilities in Thailand would rather focus on economies of scale and just export to their free-trade markets. This is exactly what has happened in the case of Thailand. In spite of the recent political unrest and natural calamities in Thailand, these companies stayed put and plan to increase their production capacity to 3 million vehicles in 2015. The Philippines, on the other hand, has a declining percentage of locally assembled vehicles sold in the domestic market. Clearly, a case where the Asean integration has not worked in favor of the Philippines. https://businessmirror.com.ph/2015/04/14/is-there-hope-for-the-philippine-auto-industry/

Indonesia is the second-largest car manufacturing nation in Southeast Asia and the ASEAN region (trailing rather far behind Thailand that controls about half of total car production in the ASEAN region). However, due to robust growth in recent years, Indonesia is expected to somewhat limit the gap with Thailand's dominant position over the next decade. To overtake Thailand as the biggest car manufacturer in the ASEAN region will, however, require major efforts and breakthroughs. Currently, Indonesia is primarily dependent on foreign direct investment, particularly from Japan, for the establishment of onshore car manufacturing facilities. The country also needs to develop car component industries that support the car manufacturing industry. https://www.indonesia-investments.com/business/industries-sectors/automotive-industry/item6047

Indonesia benefits from a huge domestic automobile market driven by an emerging middle-class. The automobile consumer base is expected to grow rapidly, with most purchases occurring in Indonesia’s cities, mainly in Jakarta. Car sales grew by six percent by the end of 2018 – at just over 1.3 million units, with 346,000 exported to markets such as the Philippines, Saudi Arabia, and Vietnam. Indonesia has an ambitious target to export 400,000 units in 2019. And with zero tariff rates for imported motor vehicles, exporters can easily penetrate the ASEAN market including the Philippines.

8 https://www.bangkokpost.com/auto/1606570/automotive-industry-at-a-turning-point

https://www.indonesia-investments.com/business/industries-sectors/automotive-industry/item6047

https://www.indonesia-investments.com/business/industries-sectors/automotive-industry/item6047

https://www.bangkokpost.com/auto/1606570/automotive-industry-at-a-turning-point

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IX.b. Notification Requirement Article 12.1 of the WTO Agreement on safeguards states that a Member shall immediately notify the Committee on Safeguards upon:

(a) initiating an investigatory process relating to serious injury or threat thereof and the reasons for it;

X. RECOMMENDATIONS Based on the above findings, there are indications that increased imports of motor vehicles are the substantial cause of serious injury to the domestic industry in terms of declining market share, production, sales, capacity utilization, incurred losses, employment, price depression and price undercutting. Wherefore, premises considered, the Department, finds prima facie evidence to initiate and conduct a preliminary safeguards investigation to determine whether motor vehicles (i.e. passenger and light commercial vehicles) are being imported into the Philippines in increased quantities and is causing serious injury to the domestic industry. Let the notice of initiation of a preliminary safeguards investigation be published in two (2) newspapers of general circulation and individual notices be sent to all interested parties including the country members concerned. SO ORDERED.

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LIST OF IMPORTERS OF 87.03 (Passenger Vehicles)

I. Sourced from the Bureau of Customs (BOC-SAD-IERD)

No. Company Name No. Company Name

1 A.M. LEYCO AUTO TRADING 56 MALDEPENA AUTO TRADING

2 AB WEE ENTERPRISE 57 MASV TRADING

3 ADVENTURE CYCLE PHILIPPINES INC. 58 MITSUBISHI MOTORS PHILIPPINES CORPORATION

4 AFP FINANCE CENTER 59 MOPEN TRADING CORPORATION

5 ALLTOP TRADING CORP. 60 MOTOR IMAGE PILIPINAS INC.

6 AMEST TRADING 61 NEUTEQ TRUCKS AND TRAILERS CO INC

7 ANGEL&LUIS STAR TRADE INC. 62 NISSAN PHILIPPINES INC.

8 ANONUEVO AUTO TRADING 63 PAD AUTO MATRIX CENTER

9 ARDN AUTO CENTER 64 PAMALICAN RESORT INC.

10 ASIAN CARMAKERS CORPORATION 65 PGA AUTOMOBILE INC.

11 AUTO NATION GROUP INC 66 PGA CARS INC.

12 AUTOCHINA INC 67 PHILCOX (PHILIPPINES) INC.

13 AUTOEXTREME PERFORMANCE INC. 68 PILIPINAS TAJ AUTOGROUP INC.

14 AUTOMOBILE CENTRAL ENTERPRISE INC. 69 POLARISTAR TRADING

15 AUTOSTRADA MOTORE INC. 70 PORO EXIM CORP

16 AYUMI ROSE MARKETING 71 PUREFEEDS CORPORATION

17 BERMAZ AUTO PHILIPPINES INC. 72 PVM MOTORS & AUTO PARTS

18 BONO DE LUXE PHILIPPINES INC 73 QSJ MOTORS PHILS. INC.

19 BORLA ENTERPRISES 74 RICH CARS TRADING

20 BRITISH UNITED AUTOMOBILES INC. 75 RISING CARS CORPORATION

21 CAMAMA AUTO HUB 76 SCANDINAVIAN MOTORS CORPORATION

22 CAPE OF HOPE ENTERPRISES 77 SCUDERIA ENTERPRISES

23 CAVITE NAGANO SEIKO INC 78 SEVEN SHORES IMPORTS

24 CHERY MOTORS PHILIPPINES INC 79 SHOGUN INTERNATIONAL CORP

25 COLUMBIAN AUTOCAR CORPORATION 80 SKY GREEN IMPORTS

26 COVENTRY MOTORS CORPORATION 81 SMC ASIA CAR DISTRIBUTORS CORP.

27 CROSS OCEAN ENTERPRISE 82 SOJITZ G AUTO PHILIPPINES CORP

28 DBPHILS MOTORSPORTS INCORPORATED 83 SOLAR TRANSPORT AND AUTOMOTIVE

29 EUROBRANDS DISTRIBUTOR INC. 84 SPHIRO AUTO TRADING

30 EZWED TRADING 86 SSANGYONG BERJAYA MOTOR PHILIPPINES

31 FOCUS VENTURES INC 87 STREAMSEVEN MARKETING

32 FORD GROUP PHILIPPINES INC. 88 SUMMIT PACIFIC PHILIPPINES INC.

33 FORMULA SPORTS INC 89 SUZUKI PHILIPPINES INCORPORATED

34 FOTON MOTOR PHILIPPINES INC. 90 TERRYS AUTOWORLD

35 FREBEL ENTERPRISES 91 THE COVENANT CAR COMPANY INC.

36 GAMMA GRAY MARKETING 92 TOMRAVEN TRADING

37 GOLDTEB TRADING 93 TOYOTA AUTOPARTS PHILS. INC.

38 HANDYWARE PHILIPPINES INCORPORATED

94 TOYOTA MOTOR PHILIPPINES CORP

39 HONDA CARS PHILIPPINES INC 95 TPN TRADING

40 HYUNDAI ASIA RESOURCES INC 96 TRADERS AUTOCENTER INC

41 IFUND CREDIT AND TRADING INC. 97 TRANSPORT AUTOMOTIVE SALES CORP.

Annex A

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42 ISIDORE FERTIAGRO CORPORATION 98 TRIESENBURG AUTO CORPORATION

43 ISUZU PHILIPPINES CORPORATION 99 UNIVERSAL MOTORS CORPORATION

44 JABMAN ENTERPRISES 100 VIN ENTERPRISES

45 JAGUAR PHILIPPINES INCORPORATED 101 VIPR AUTOMOBILE TRADING

46 JOAQUIN CAR CHECK CENTER 102 WHITE KNIGHT AUTOMOBILES INC.

47 JOROM TRADING 103 YURESHA TRADING

48 JO-WER INTERNATIONAL TRADING 104 MASV TRADING

49 KENKEV TRADING 105 MITSUBISHI MOTORS PHILIPPINES CORPORATION

50 KILTON MOTOR CORPORATION 106 MOPEN TRADING CORPORATION

51 LEGADO MOTORS INC. 107 MOTOR IMAGE PILIPINAS INC.

52 LLORIN TRADING 108

LIST OF IMPORTERS OF 87.04 (Light Commercial Vehicles

II. Sourced from the Bureau of Customs (BOC-SAD-IERD)

No. Company Name No. Company Name

1 FORD GROUP PHILIPPINES INC. 4 THE COVENANT CAR COMPANY INC.

2 MITSUBISHI MOTORS PHILIPPINES CORP 5 TOYOTA MOTOR PHILIPPINES CORP

3 NISSAN PHILIPPINES INC.

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LIST OF EXPORTERS OF 87.03 (Passenger Vehicles)

I. Sourced from the Bureau of Customs (BOC-SAD-IERD)

No. Company Name Country No. Company Name Country

1 2000007 ONTARIO INC. Cameroon 25 AUTOLIV (THAILAND) LTD. Thailand

2 2000007 ONTARIO INC. USA 26 AUTOMOBILES PEUGEOT France

3 2000007 ONTARIO INC. United Arab Emirates

27 AUTOMOBILI LAMBORGHINI SPA

Italy

4 2000007 ONTARIO INC. Canada 28 AUTOMOBILI LAMBORGHINI SPA

Singapore

5 2016 TOYOTA ALPHARD WAGON 3.5 GAS (A)

Japan 29 AUTRANS (THAILAND) CO LTD

Thailand

6 2016 TOYOTA LAND CRUISER SUV 4.5 DSL (A)

Japan 30 BAIC INTERNATIONAL DEVELOPMENT CO.,

PROC

7 2422315 ONTARIO INC. Canada 31 BAYERISCHE MOTOREN WERKE AG

United Kingdom

8 ACE INTERNATIONAL FZE United Arab Emirates

32 BAYERISCHE MOTOREN WERKE AG

Belgium

9 AG AUTO TRADING LLC United Arab Emirates

33 BAYERISCHE MOTOREN WERKE AG

Germany

10 AL BORAQ AUOMOBILES CO.WLL

Qatar 34 BAYERISCHE MOTOREN WERKE AG

USA

11 AM ZEHNHOFF-SOENS GMBH

Germany 35 BAYERISCHE MOTOREN WERKE AG

Netherlands

12 AMERICAN EXPORT LINES USA 36 BAYERISCHE MOTOREN WERKE AG

Malaysa

13 AMERICAN HONDA MOTOR CO., INC.

USA 37 BENTLEY MOTORS LTD United Kingdom

14 AMI MIDDLE EAST LLC United Arab Emirates

38 BENTLEY MOTORS LTD Germany

15 ANHUI JIANGHUAI AUTOMOBILE GROUP CO

PROC 39 BMW (UK) MFG.LTD. Germany

16 ASIAN AUTOSPORT AUCTION (AAA)

Malaysia 40 BMW (UK) MFG.LTD. United Kingdom

17 ASIAN HONDA MOTOR CO., LTD.

Thailand 41 BMW AG USA

18 ASTON MARTIN LAGONDA LTD

United Kingdom

42 BMW AG Germany

19 ATI CONSULTING AND TRADE OY

Russia 43 BMW ASIA PTE LTD Singapore

20 AUDI AG Mexico 44 BMW MANUFACTURING (THAILAND) CO. LT

Thailand

21 AUDI AG Germany 45 BMW MANUFACTURING CORP.

Germany

22 AUDI VOLKSWAGEN TAIWAN CO LTD

Poland 46 BMW MANUFACTURING CORP.

USA

23 AUTO ALLIANCE (THAILAND)CO. LTD

Thailand 47 BMW MANUFACTURING CORP.

Belgium

24 AUTO VISION GENERAL TRADING LLC

United Arab Emirates

48 BMW MFG LTD United Kingdom

Annex B

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49 BORAM CO., LTD South Korean 76 FAW HAIMA AUTOMOBILE CO., LTD

PROC

50 BRITPART UK United Kingdom

77 FCA INTERNATIONAL OPERATIONS LLC

USA

51 BRITPART UK United Arab Emirates


Canada

52 BYD AUTO CO LTD PROC 79 FCA INTERNATIONAL OPERATIONS LLC

Japan

53 BYD AUTO INDUSTRY CO. LTD

PROC 80 FCA INTERNATIONAL OPERATIONS LLC

Italy

54 CAM AUTO TRADING LLC United Arab Emirates


South Korea

55 CANADIAN RED CROSS SOCIETY

Canada 82 FCA ITALY S.P.A. Italy

56 CAROTRANS INTERNATIONAL INC

USA 83 FERRARI S.P.A. Italy

57 CHANGAN INTERNATIONAL PROC 84 FIRSTLINK FREIGHT INTERNATIONAL

USA

58 CHANGSHA BYD AUTO CO LTD

PROC 85 FIRSTLINK FREIGHT INTERNATIONAL

Canada

59 CHERY AUTOMOBILE HONGKONG

PROC 86 FLO LOGISTICS LLC USA

60 CHINA MOTOR CORPORATION

Taiwan 87 FORD MOTOR COMPANY (THAILAND) LTD.

Thailand

61 CHONGQING SOKON MOTORS (GROUP) IMP.

PROC 88 FORD TRADING COMPANY USA

62 CHRYSLER GROUP LLC South Korea 89 FOTON INTERNATIONAL TRADE CO., LTD.

PROC

63 CHRYSLER GROUP LLC USA 90 FUJI HEAVY IND. LTD. Japan

64 DAEWOO INTERNATIONAL CORPORATION

South Korea 91 FUJIAN NEW LONGMA MOTOR CO., LTD.

PROC

65 DAIMLER AG Germany 92 GEELY AUTOMOBILE INTERNATIONAL CORP

PROC

66 DANIMEX Germany 93 GENERAL MOTORS (THAILAND) LIMITED

Thailand

67 DESERT MOTORS USA 94 GENERAL MOTORS OVERSEAS DISTRIBUTION

USA

68 DESERT MOTORS United States Virgin Islands

95 GM KOREA COMPANY South Korea

69 DR ING HCF PORSCHE AG Germany 96 GM KOREA COMPANY PROC

70 EAST WEST ALLIANCE INC USA 97 GREATWALL MOTOR COMPANY LIMITED

PROC

71 EAST WEST ALLIANCE INC United Arab Emirates

98 GREEN VALLEY AUTO MOBILES LLC


72 EMARAT SHIPPING INC USA 99 GUANGZHOU AUTOMOBILE GROUP

PROC

73 EMIRATES NATIONAL GENERAL


100 GUANGZHOU FU DE LU TRADING

PROC

74 ETERNAL GRACE (HONGKONG) LTD.

Hong Kong 101 GULF AUTO TRADING FZE United Arab Emirates

75 ETERNAL GRACE (HONGKONG) LTD.


102 HAESUNG INTERNATIONAL CO., LTD

South Korea

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103 HAIMA AUTOMOBILE INTERNATIONAL CORP

PROC 125 LOTUS CARS LTD United Kingdom

104 HAIMA CARS CO., LTD PROC 126 M/S MAHINDRA AND MAHINDRA LIMITED

India

105 HAIMA COMMERCIAL VEHICLE CO., LTD

PROC 127 MAGYAR SUZUKI CORPORATION LTD.

Belgium

106 HARFORDS 4X4 LTD United Kingdom

128 MARUBENI CORPORATION South Korea

107 HERITAGE EQUIPMENT SERVICES

USA 129 MARUTI SUZUKI INDIA LIMITED

India

108 HONDA AUTOMOBILE(THAILAND)CO., LTD

Thailand 130 MASERATI SPA Italy

109 HONDA AUTOPARTS MANUFACTURING

Malaysia 131 MAZDA MOTOR CORP. Japan

110 HONDA MOTOR CO., LTD TOKYO JAPAN

Japan 132 MERCEDES BENZ (PTY) LTD South Africa

107 HONDA MOTOR EUROPE United Kingdom

133 MERCEDES BENZ (PTY) LTD Germany

108 HYUNDAI CORPORATION South Korea 134 MERCEDES BENZ ESPANA S.A

Spain

109 HYUNDAI CORPORATION PROC 135 MERCEDES BENZ ESPANA S.A

Germany

110 HYUNDAI GLOVIS CO., LTD. South Korea 136 MERCEDES BENZ S.A LIMITED

South Africa

111 HYUNDAI MOTOR COMPANY PROC 137 MERCEDES BENZ US INTERNATIONAL

USA

112 HYUNDAI MOTOR COMPANY South Korea 138 MERCEDES BENZ US INTERNATIONAL

Germany

113 HYUNDAI MOTOR INDIA LIMITED

India 139 MERCEDES BENZ US INTERNATIONAL

Malaysia

114 INTERNATIONAL HUMANITARIAN


140 MERCURY GLOBAL FZE United Arab Emirates

115 ISUZU MOTORS THAILAND CO LTD

Thailand 141 MITSUBISHI MOTORS (THAILAND)CO., LTD

Thailand

116 JAGUAR LAND ROVER LIMITED

United Kingdom

142 MITSUBISHI MOTORS CORPORATION

Indonesia

117 JAGUAR LAND ROVER LIMITED

Italy 143 MITSUBISHI MOTORS CORPORATION

Japan

118 JETTHOL VISION TRADING PTE LTD

Taiwan 144 NANJING AUTOMOBILE (GROUP) CORP.

PROC

119 JINGDEZHEN BAIC CHANGHE IMP.&EXP, CO

PROC 145 NAZA AUTOMOTIVE MANUFACTURING

Malaysia

120 KIA MOTORS CORPORATION PROC 146 NISSAN MOTOR (THAILAND) CO., LTD

Thailand

121 KIA MOTORS CORPORATION South Korea 147 NISSAN MOTOR ASIA PACIFIC CO

Thailand

122 KLAUS ACKERMANN AUTOMOBILE

Germany 148 NISSAN MOTOR CO., LTD Japan

123 KLAUS ACKERMANN AUTOMOBILE

United Kingdom

149 NISSAN MOTOR INDIA PVT LTD

India

124 KRF CO., LTD Japan 150 NISSAN MOTOR INDIA PVT LTD

Japan

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152 NISSAN NORTH AMERICA USA 178 SOJITZ CORPORATION Japan

153 NISSAN NORTH AMERICA Japan 179 SOUTHPOINT ALLIANCE Hong Kong

154 NISSAN SHANGHAI CO., LTD. PROC 180 SPEED LOGISTICS LIMITED Japan

155 P.T. TOYOTA MOTOR MANUFACTURING

Indonesia 181 SSANGYONG MOTOR COMPANY

South Korea

156 PACASIATIC INTERNATIONAL USA 182 SUBARU CORPORATION Japan

157 PERFECT EXPRESS CORP USA 183 SUZUKI MOTOR (THAILAND) CO., LTD.

Thailand

158 PISTOP KOREA CO., LTD South Korea

184 SUZUKI MOTOR CORPORATION

Japan

159 POSCO DAEWOO CORPORATION South Korea

185 SUZUKI MOTOR CORPORATION

Indonesia

160 PT ASTRA DAIHATSU MOTOR Indonesia 186 TAI HING MOTORS (INTERNATIONAL) LTD

Oman

161 PT Honda Precision Parts Mfg., Indonesia 187 TAI HING MOTORS INTERNATIONAL


162 PT HONDA PROSPECT MOTOR Indonesia 188 TAIHING MOTORS (INT'L) LTD Hong Kong

163 PT TOYOTA ASTRA DAIHATSU MOTOR

Indonesia 189 TAIWAN HONDA TRADING CO., LTD

PROC

164 PT TOYOTA ASTRA MOTOR MANUFACTURING

Indonesia 190 TATA MOTORS LIMITED India

165 PT. GENERAL MOTOR INDONESIA Indonesia 191 TECHLANTIC LTD Canada

166 PT. Honda Precision Parts Mfg. Indonesia 192 THE LONDON TAXI COMPANY PROC

167 PT. MITSUBISHI MOTORS KRAMA YUDHA

Indonesia 193 TOYOTA MOTOR ASIA PACIFIC ENGINEERING

Thailand

168 PT. SUZUKI INDOMOBIL MOTOR Thailand 194 TOYOTA MOTOR ASIA PACIFIC PTE.

Japan

169 RENAULT TAN/YEUNG KONG MING USA 195 TOYOTA MOTOR CORPORATION

Japan

170 SAHARA MOTORS United Arab Emirates

196 TOYOTA MOTOR EUROPE VEHICLE

Belgium

171 SAIC GM DONG YUE MOTORS CO., LTD

PROC 197 TOYOTA MOTOR MFG. INDONESIA

Indonesia

172 SAIC MOTOR INTERNATIONAL CO., LTD.

PROC 198 TOYOTA MOTOR THAILAND CO. LTD.

Thailand

173 SAIC GM WULING AUTOMOBILE PROC 199 TOYOTA TSUSHO CORPORATION

Japan

174 SDDC USA 200 TRANSWORLD GENERAL TRADING FZC

Turkey

175 SEKYUNG AUTO TRADING CO LTD South Korea

201 TRANSWORLD GENERAL TRADING FZC


176 SHENZHEN LEQUEUE IMPORT AND EX

PROC 202 TRIPP HD EQUIPMENT USA

177 SIME DARBY AUTO BAVARIA SDN BHD

Malaysia 203 VARGAS THOMAS ABAS Hungary

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204 VOLKSWAGEN AG Germany 215 WESTERN AUTO LLC South Korea

205 VOLKSWAGEN AG Slovakia 216 WESTERN AUTO LLC PROC

206 VOLKSWAGEN GROUP IMPORT COMPANY LIM

PROC 217 WESTERN AUTO LLC Germany

207 VOLKSWAGEN INDIA PVT LTD India 218 WESTERN AUTO LLC Qatar

208 VOLKSWAGEN KONZERNLOGISTIK GMB

Germany 219 WESTERN AUTO LLC. US

209 VOLKSWAGEN MEXICO PUEBLA KM 116

Mexico 220 XIAMEN DALLE NEW ENERGY AUTOMOBILE

PROC

210 VOLVO CAR CORP Sweden 221 XIAMEN KING LONG UNITED AUTOMOTIVE

PROC

211 VOLVO CAR CORP Belgium 222 YE CHUI METAL RECYCLING(CHINA)

PROC

212 VOLVO CAR MANUFACTURING MALAYSIA SD

Malaysia 223 YELLOWMONT VENTURES LIMITED

Canada

213 WEBTRANS LOGISTICS INC USA 224 ZF STEERING (MALAYSIA) SDN BHD

Malaysia

214 WESTERN AUTO LLC United Arab Emirates

225 ZHEJIANG RENLI VEHICLE CO LTD

PROC

LIST OF EXPORTERS OF 87.04 (Light Commercial Vehicles)

I. Sourced from the Bureau of Customs (BOC-SAD-IERD


1 AUTO ALLIANCE (THAILAND) CO. LTD

Thailand 6 T.R.K. BANGKOK INDUSTRY & EXPORTER

Thailand

2 FORD MOTOR COMPANY (THAILAND) LTD

Thailand 7 TOYOTA MOTOR ASIA PACIFIC PTE., LTD

Thailand

3 GENERAL MOTORS (THAILAND) LIMITED

Thailand 8 TOYOTA MOTOR THAILAND CO., LTD.

Thailand

4 MITSUBISHI MOTORS (THAILAND) CO.

Thailand 9 TOYOTA MOTOR THAILAND CO., LTD.

Indonesia

5 NISSAN MOTOR (THAILAND) CO., LTD

Thailand