OPINION

RESTANI, Judge.

This matter is before the court on a motion for judgment on the agency record pursuant to USCIT Rule 56.2, brought by Kerr-McGee Chemical LLC and Chemetals, Inc. (collectively, "Plaintiffs"), the petitioner's in the underlying antidumpiug administrative review. At issue is Electrolytic Manganese Dioxide from Greece, 64 Fed.Reg. 62, 169 (Dep't comm. 1999) (final admin. rev.) [hereinafter "Final Results"]. Plaintiffs contest the selection of home market sales for price comparison purposes. Plaintiffs also contend that inventory carrying costs should not have been included in calculating constructed export price ("CEP").

JURISDICTION STANDARD OF REVIEW

The Court has jurisdiction pursuant to 28 U.S.C. § 1581 (c) (1994). In reviewing final determinations in antidumping duty investigations and reviews, the Court will hold unlawful those agency determinations that are unsupported by substantial evidence on the record, or otherwise riot in accordance with law. 19 U.S.C. § 1516a(b)(1)(B)(i).

FACTUAL PROCEDURAL BACKGROUND

In March of 1989, Commerce determined that EMD from Greece was being sold at less than fair value in the United States. Electrolytic Manganese Dioxide born Greece, 54 Fed.Reg. 8,771 (Dep't Cornm. 1989) (final determ.) ["EMD from Greece"]. In EMD from Greece, Commerce determined that zinc-chloride and alkaline grade EMD were "similar" merchandise because "the two [grades] of EMD are produced in the same production process and differ only in their final finishing"; there was minimal cost difference between the products; and both grades were used in the production of dry-cell batteries. Id. at 8773. Commerce also determined that "respondent's combined home market sales of alkaline and zinc-chloride grade EMD are adequate as a basis of comparison since these sales exceed five percent of sales of that merchandise to third countries." Id.

Plaintiffs sought judicial review of the determination in EMD from Greece regarding the issues of product comparability and home market viability. Kerr-McGee Chem. v. United States, 14 CIT 422, 741 F. Supp. 947 (1990). There, the court affirmed Commerce's viability analysis and its determination that the two grades of EMD were "similar" under the then-applicable like product provision of the statute. Id., 14 CIT at 426-31, 741 F. Supp. at 952-56.

On April 29, 1998, THA requested that Commerce initiate the administrative review of EMD from Greece. Initiation of Antidumping and Countervailing Duty Administrative Reviews and Requests for Revocations in Part, 63 Fed.Reg. 29,370 (Dep't Comm. 1998). Commerce found that the home market product qualified as a "foreign like product," that the home market was viable pursuant to the five percent viability test, and that a "particular market situation" did not exist to warrant departure therefrom. Final Results, 64 Fed.Reg. at 62, 170-73. Plaintiffs appealed the Final Results to this court.

On May 17, 2000, the United States International Trade Commission published the results of its five-year (sunset) review of the antidumping orders against EMD from Greece and Japan, finding that revocation of the antidumping duty orders "would not be likely to lead to continuation or recurrence of material injury to an industry in the United States within a reasonably foreseeable time." Electrolytic Manganese Dioxide from Greece and Japan, 65 Fed.Reg. 31,348, 31,348 (Int'l Trade Comm'n 2000) (sunset rev.). On May 31, 2000, Commerce revoked the antidumping order's against EMD from Greece and Japan, effective January 1, 2001. Electrolytic Manganese Dioxide from Greece and Japan, 65 Fed.Reg. 34,661 (Dep't Comm. 2000) (revocation). Notwithstanding the revocation, Plaintiffs maintain the appeal of the Final Results.

DISCUSSION

I. Foreign Like Product

In the Final Results, Commerce concluded that the EMD Tosoh sold in Greece is a "foreign like product" on which normal value can be based under 19 U.S.C. § 1677 (16)(B). 64 Fed.Reg. at 62,171. Plaintiffs argue that this conclusion is not supported by substantial evidence and is contrary to law because the EMD sold in Greece is (1) not "like [the exported product] in component material or materials and in the purposes for which used"; and (2) not "approximately equal in commercial value to [the exported product]," as required under 19 U.S.C. § 1677 (16)(B)(ii) and (iii).

A. Component Materials

In the Final Results Commerce determined that the EMD sold in Greece is "like [the exported product] in component material or materials" pursuant to 19 U.S.C. § 1677 (16)(B)(ii) based on several findings. Commerce found that "the most important component materials (i.e., manganese ore, heavy oil, sulfuric acid, etc.) of the U.S. and home market products are the same." Final Results; 64 Fed.Reg. at 62,170. Commerce recognized that the home market product is manufactured using a different subtype of a particular input than that used to manufacture the subject merchandise, but found that "the difference [between subtypes of the input] is not a difference in component materials but rather a difference in the equipment used in the manufacturing processes." IS Commerce also dismissed the fact that Tosoh itself had classified the subtype of input used in manufacturing the home market product as a "raw material," as "this designation was solely for accounting purposes because the useful life of the equipment is less than one year. Id.

Plaintiffs argue that Commerce's determination is not supported by substantial evidence for two reasons. First, Plaintiffs argue that contrary to Commerce's findings, the input at issue is also an "important" material because it is necessary for the manufacture of the home market EMD and constitutes a substantial percentage of total component material value. Second, Plaintiffs maintain that unlike the subject merchandise, the home market EMD is manufactured using an input subtype that, because it is consumed in the production process, is expensed as a variable cost and is therefore more properly characterized as a component raw material.

Plaintiffs do not establish that Commerce's determinations are not supported by substantial evidence. Substantial evidence "must be enough reasonably to support a conclusion." Ceramica Regiomontana, S.A. v. United States, 10 CIT 399, 405, 636 F. Supp. 961, 966 (1986) (citations omitted) aff'd, 810 F.2d 1137 (Fed. Cir. 1987). Under 19 U.S.C. § 1677 (16)(B), Commerce is not required to find that the products are identical as under 19 U.S.C. § 1677 (16)(A). Here, the record shows that (1) except for the input at issue, the materials used in producing the two grades of EMD are identical; (2) both EMD grades have the same physical structure; and (3) meet the same minimum chemical property specifications. Viability Comparability Mem. (Apr. 29, 1999), at 3, C.R. Doc. 33, Def.'s App., Tab 1, at 7; Questionaire Response (July 7, 1998, at A-17 to A-18, C.R. Doc. 1, Pl.'s App., Tab 4A, at 1-2. Plaintiffs do not dispute any of these facts. Plaintiffs concede that the input subtype that is used in manufacturing the subject merchandise also can be used to produce the home market EMD. Rather than deeming the input unnecessary or unimportant, Commerce reasonably determined that the difference in subtypes alone was not sufficient to outweigh the factual findings in favor of "foreign like product." See Sony Corp. v. United States, 13 CIT 353, 357-59, 712 F. Supp. 978, 981-83 (1989) (upholding International Trade Commission's determination that similarities in physical characteristics and production processes outweigh differences asserted by plaintiff). Therefore, even if the subtype of input at issue that was used in manufacturing the home market EMD were properly considered a "component," Commerce's determination of "like in component materials" is supported by substantial evidence.

Plaintiffs' second argument — that the designation of an item for accounting purposes should determine characterization under § 1677 (16)(B)(ii) — also lacks merit. Characterization of an item for accounting purposes does not dictate how the item should be classified for the purposes of finding "like in component materials" under 19 U.S.C. § 1677 (16)(B)(ii). Rather, the physical characteristics underlying the accounting designation are relevant to, but not dispositive of, Commerce's determination in this regard. For example, in Silicomanganese from the People's Republic of China, 65 Fed.Reg. 31,514 (Dep't Comm. 2000) (final admin. rev.), Commerce recognized that an item was not physically incorporated within the final product and, thus, would not normally be considered a direct material input (typically classified as "process materials" that are often included in factory overhead as "consumables"). See Issues Decision Mem., at Part IV, cmt. 1. Nevertheless, Commerce concluded there that for the purposes of determining "foreign like product," the item was more properly characterized as a cost element separate from factory overhead, and therefore a component part, because it represented a "significant portion of the cost of the finished product." Id. Similarly, in Sacchann from the People's Republic of China, 59 Fed.Reg. 58,818, 58,823-24 (Dept. Comm. 1994) (final determ.), though respondent characterized a particular item as "factory overhead." Commerce deemed it a direct material input, and therefore a component for the purposes of determining "foreign like product," because it was specially processed, packaged, and shipped to customers and because it was required for a particular segment of the production process for which a substitute was not available.

Commerce in this case properly looked at the physical properties underlying Tosoh's accounting designation and determined that such designation was not determinative. See Viability Comparability Mem., at 6, Def.'s App., Tab 1, at 6. As Tosoh explained to the Department, the is part of the finished product only insofar as "it cannot be totally eliminated in the washing process." See March 10, 1999 Submission, at 4, C.R. Doc. 29, Def.'s App., Tab 3, at 1. Based on these findings, Commerce concluded that the input at issue was not a component for the purpose of determining "foreign like product."

B. Purpose for which Used

Commerce concluded that the home market EMD and the subject merchandise did not differ in the purpose for which they are used. This conclusion was based on a finding that "Tosoh's customers use both types of EMD grades as a cathode material, which provides the electric charge needed for a battery to perform." Find Results; 64 Fed.Reg. at 62,171. Plaintiffs first argue that the batteries that contain the home market EMD cannot be used for the same purposes as the batteries that contain the subject merchandise. Plaintiffs further argue that the EMD sold in the home market was used primarily as an additive or an "enriching agent" to natural manganese dioxide (NMD) in inexpensive battery cells, while the subject merchandise is solely used in premium, high-drain AA batteries as the cathode material itself. To support their argument, Plaintiffs cite evidence that the EMD Tosoh sold in the home market is of a lower quality and sells for a lower price than the EMD exported by Tosoh to the United States.

First, under 19 U.S.C. § 1677 (16)(B)(ii), Commerce need only find that the home market product is like" the subject merchandise in the purpose for which it is used; it need not find exact identity of purpose, nor must it find like purpose for the device (here, batteries) into which the product is ultimately incorporated. Koyo Seiko Co. a United States; 66 F.3d 1204, 1210 (Fed. Cir. 1995) ("[I]t is not necessary to ensure that home market models are technically substitutable, purchased by the same type of customers, or applied to the same end use as the U.S. model.") (emphasis added). See also Sony Corp., 13 CIT at 359, 712 F. Supp. at 983 (rejecting plaintiffs contention that lack of interchangeability between products defeats a finding of "similar merchandise"); Certain Forged Steel Crankshafts from the United Kingdom, 56 Fed.Reg. 5975, 5977 (Dep't Comm. 1991) (final admin. rev.) ("Under [ 19 U.S.C. § 1677 (16)(B)] end-use is a factor only when the end-use pertains to the product under investigation itself, not to the product into which it is incorporated"), aff'd, United Eng. Forging v. United States, 15 CIT 561, 565-67, 779 F. Supp. 1375, 1380-82 (1991). Thus, that the batteries into which the respective grades of EMD were incorporated had different end-uses is not determinative of whether the grades of EMD themselves may properly be considered "like in purposes for which used." Second, that the home market EMD was used by some customers as an additive does not negate the fact that, as Plaintiffs concede, approximately 50% of the EMD sold in the home market was used as the cathode material itself, the same purpose for which the subject merchandise was used. Commerce's finding of "like" purpose is therefore supported by substantial evidence.

C. Commercial Value

Commerce concluded that the EMD sold in the home market is "approximately equal in commercial value to [the exported] merchandise" pursuant to 19 U.S.C. § 1677 (16)(B)(iii). Final Results, 64 Fed. Reg. at 62,171-72. Commerce based its conclusion on two findings: (1) the difference in merchandise ("difmer") fell within 20% of the total manufacturing cost of the subject merchandise, Electrolytic Manganese Dioxide from Greece, 64 Fed.Reg. 25,008, 25,009 (Dep't Comm 1999) (prelim.determ.); and (2) the sales data from a third country — the only country selling both grades of EMD at issue during the POR — revealed an extremely low price differential between the two grades. Plaintiffs contend that in this case the difmer test is unusable for the purposes of determining commercial comparability. Plaintiffs also dispute the use of third country sales data.

1. Application of the Difmer Test

Ordinarily, the difmer adjustment to normal value is used to account for the difference in cost attributable to the difference in physical characteristics between the home market product and the subject merchandise. See 19 U.S.C. § 1677b(a)(6)(C)(ii). See also import Administration Policy Bulletin, No. 92.2 (July 29, 1992) [hereinafter "Policy Bulletin"]; Bethlehem Steel Corp. v. United States, 2000 WL 726931 at *4 (CIT 2000). "[I]f the difmer adjustment . . . exceeds twenty percent, Commerce will not make a finding that the home-market product is reasonably comparable to the exported good, unless it can explain how the comparison is nevertheless reasonable." Mitsubishi Heavy Industries, Ltd. v. U.S., 112 F. Supp.2d 1170, 1171 (CIT 2000). In the instant case, Commerce found a difmer within this 20% guideline, as calculated on the basis of variable manufacturing costs. Final Results, 62 Fed.Reg. at 62,170. Commerce used the results of this calculation to support its conclusion that the home market product and the subject merchandise were "commercially comparable" for the purposes of determining "foreign like product" under 19 U.S.C. § 1677 (16)(B)(iii).

Plaintiffs first argue that the difmer test cannot be applied to support a finding of commercial comparability where the difmer is "distorted" by the difference in physical characteristics between the two grades of EMD. Plaintiffs contend that because the input at issue used in producing the home market product is wholly consumed, it is characterized as a variable cost, and thus factored into the difmer calculation. In contrast, because the disputed input used in producing the subject merchandise is not wholly consumed, it was not included in variable costs and was thus excluded from the difmer calculation. Consequently, Plaintiffs contend that the difmer is therefore necessarily unbalanced and unusable as support for a determination of commercial comparability. Plaintiffs also allege that Commerce was inconsistent in including as "variable costs" those costs associated with the home market input in calculating the difmer where this item had been excluded from consideration in the determination of "like in component materials" under 19 U.S.C. § 1677 (16)(B)(ii).

Commerce responds that it is within its discretion to use the difmer test to support its determination of commercial compatibility and the physical differences between the products are not such that the difmer test cannot be so used. Commerce also explains that it included variable costs associated with the disputed input in the home market EMD because the difmer accounts for not just component materials but also variable factory overhead. Find Results 64 Fed.Reg at 62,170. Although the court finds Commerce's calculation methodology for the difmer somewhat questionable, see note 10 infra, Commerce's determination of commercial comparability is supported by substantial evidence.

Commerce has been granted broad discretion to devise a methodology for determining what constitutes "similar" merchandise. See Koyo Seiko; 66 F.3d at 1209. Specifically, it is within Commerce's discretion to apply the 20% difmer test in informing its determination of commercial comparability under 19 U.S.C. § 1677 (16)(B)(iii). See SKF USA Inc. v. United States, 874 F. Supp. 1395, 1399-1400 (CIT 1995) (finding that Commerce acted within its discretion in using the 20% difmer adjustment cap as test for identifying similar merchandise).

Commerce is also correct that the difmer allowance normally relies on only variable and semi-variable manufacturing expenses in quantifying cost differences. Furthermore, Commerce did not reject Tosoh's accounting designation of costs associated with the home market input; Commerce merely determined that for the purpose of determining similarity in component materials, such designation was not controlling. In any event, nothing in the language of § 1677 (16)(B) compels Commerce to adhere to the characterization under its § 1677 (16)(B)(ii) analysis when determining commercial comparability under § 1677 (16)(B)(iii), or vice versa. Therefore, use of the difmer test in determining commercial comparability was proper.

2. The Use of Third Country Sales

To determine comparability of commercial value, Commerce also relied on data concerning the quantity and value of two EMD grade types sold in one third-country market, . Commerce relied on sales data from this third country because it was the only market in which Tosoh sold both grades during the POR. Final Results, 134 Fed.Reg. at 62,171-72. Based on this data, Commerce found that the two grades were priced closely enough to support a finding of commercial comparability.

Plaintiffs contend that Commerce erred in relying on data concerning third-country sales where such sales were not representative of the commercial value of the home market type EMD. Plaintiffs argue that the third-country sales cannot represent. the commercial value of the home market type EMD because the use of the EMD by the third-country customers differed substantially from the uses of the EMD in the U.S. and home markets. Plaintiffs concede that the EMD sold in the third-country market was used as the cathode material in battery manufacture, but maintain that it was not sold for use as the cathode in dry-cell batteries, nor as an additive for an NMD cathode, as in the U.S. and home market products, respectively. Plaintiffs contend that these different uses "may affect relevant supply/demand factors and thus its market value." Plaintiffs therefore urge that the commercial value be determined by comparing the average unit values based on worldwide sales of the two grades of EMD, in which case the difference in commercial value would preclude the home market EMD from being a "foreign like product."

Plaintiffs' assertion that the EMD sold in the third country was not used for the same purposes as the U.S. and home market EMD is not supported in the record. In the Commercial Value Memorandum, Commerce cited an affidavit from Tosoh's Director of Sales who stated that "during the review period, Tosoh's [third-country] customer purchased EMD from Tosoh for use as a cathode mixture in the manufacture of primary (i.e., non-rechargeable) dry-cell batteries." Pl.'s App., Tab 15-A, at 4. Furthermore, as stated above, the EMD sold in the home market was not sold exclusively as an enriching agent. but also as the cathode itself. Therefore, the court rejects Plaintiffs invitation to engage in speculation as to what effect any difference in use might have had on the demand and supply of the products sold in the third country. Commerce's use of third-country sales data was appropriate and its calculations derived therefrom appear accurate. Therefore, even though the exact difmer calculation is questionable. Commerce's determination of commercial comparability is supported by substantial evidence. In sum, Commerce's determination under the three-part test of § 1677 (16)(B) for determining like product is supported by substantial evidence.

II. Home Market Viability

In the Final Results, Commerce concluded that pursuant to 19 U.S.C. § 1677b(a)(1) the sales of EMD in the home market constituted a viable basis for calculating normal value. 64 Fed.Reg. at 62,172-73. Commerce's conclusion was supported by three findings. First, Commerce found that the aggregate quantity of foreign like product sold in the home market was greater than five percent of the aggregate quantity of sales of the subject merchandise to the United States. Id. at 62,173. Second, Commerce found that there was no "unusual situation" that would warrant a departure from the five percent viability test. Id. Third, Commerce found that there was no "particular market situation" within the meaning of 19 U.S.C. § 1677b(a)(1)(C)(iii) that would prevent a proper price comparison. Id. Plaintiffs contest only the second and third findings.

A. Unusual Situation

To determine whether there is a sufficient volume of sales in the home market to serve as a viable basis for calculating normal value (NV), Commerce compares the respondent's volume of homemarket sales of the foreign like product to the volume of U.S. sales of the subject merchandise in accordance with 19 U.S.C. § 1677b(a)(1)(C)(ii). Under normal circumstances, if the respondent's aggregate volume of home-market sales of the foreign like product is greater than five percent of its aggregate volume of U.S. sales for the subject merchandise, the home market is deemed viable and NV may be based on home-market sales. 19 U.S.C. § 1677b(a)(1)(C). The Statement of Administrative Action ("SAA") recognizes, however, that "in unusual situations . . . home market sales constituting more than five-percent of sales to the United States could be considered not viable." H.R. Rep. No. 103-826, at 821, reprinted in 1994 U.S.C.C.A.N. 4040, at 4162. When a home market is deemed not viable, Commerce normally calculates NV based on sales to a viable third-country market rather than on constructed value (CV). See Certain Forged Stainless Steel Flanges from India, 61 Fed.Reg. 14,073, 14,074 (prelim.results) (Dep't Comm. 1996).

Plaintiffs argue that there is an "unusual situation" warranting rejection of home market sales as a basis for calculating NV because the sales in the United States were "negligible," such that "virtually any volume of home market sales" would satisfy the five percent viability test. Pl.'s Br. at 38-39. Plaintiffs urge that NV be based instead on EMD sales to Switzerland because sales to that country were of sufficient volume "to subsidize Tosoh Greece's penetration of the United States market." Id.

Plaintiffs' argument is without merit Under the pre-Uruguay Round Agreements Act statute, viability was determined by comparing the quantity of goods sold in the home market to those sold in countries other than the United States. Under the current statute, the five percent viability test is determined by comparing home market sales directly to U.S. sales. The SAA clarifies that the use of third country sales data comparator was eliminated from the five percent home market viability test to "prevent the use of "thin home markets as the basis for identifying dumping." H.R. Rep. No. 103-826, at 821, reprinted in 1994 U.S.C.C.A.N. 4040, at 4162. The term "thin" markets refers to situations whereby the volume of home market sales is high in relation to third country sales such that the 5% test would be satisfied even though the quantity of home market sales might be extremely low in relation to U.S. sales such that a price-to-price comparison would be unreasonable. Thus, the amendment eliminated the use of the third country sales data comparator to account for the possibility of "false positive" results in the application of the five percent viability test that might arise therefrom. To use Switzerland sales data because the home market sales are somehow "thin" in comparison to US. sales, as plaintiffs urge, would turn the SAA on its head. Furthermore, the statute sets no minimum quantity of U.S. sales that may be used in making the direct comparison to home market sales. Indeed, even a single entry of subject merchandise is sufficient where such an entry is indicative of the respondent's regular pricing practices. See Silicon Metal from Brazil, 59 Fed. Beg. 42,806, 42,813 (Dep't Comm. 1994) (final admin. rev.) (review based on finding that single sale "constitutes the most accurate reflection of [respondent's] pricing practices during the review period). See also Fresh and Chilled Atlantic Salmon from Norway, 62 Fed.Reg. 1430, 1432 (Dept.Comm.1997) (final results) (review based on single sale so long as sale based on born fide arm's length transaction). Plaintiffs have made no showing that the U.S. sales are somehow anomalous in terms of pricing, nor any other circumstances of sale that would render U.S. sales an invalid basis for comparison. Therefore, Plaintiffs have not shown on this basis that Commerce's direct comparison of U.S. sales to home market sales is not supported by substantial evidence or otherwise not in accordance with law.

B. Particular Market Situation

Even if the five percent home market viability test may be met under 19 U.S.C. § 1677b(a)(1)(C)(ii), the use of third country sales as a basis for calculating NV may be justified where Commerce, acting in its discretion, finds a "particular market situation" in the exporting country that would preclude a proper comparison with the export price pursuant to § 1677b(a)(1)(C)(iii). Although the statute does not specify what constitutes such a "particular market situation," examples given in the SAA include the following (1) a single sale in the home market constitutes five percent of sales to the United States; (2) government controls over prices "to such extent that home market prices cannot be considered competitively set," and (3) differing patterns of demand experienced in the United States and in the exporting country. Plaintiffs do not contend that any of these scenarios apply to the instant case. Rather, Plaintiffs argue a "particular market situation" exists where (1) the physical characteristics of the home and U.S. market products are so dissimilar that a proper difmer adjustment cannot be made, and, alternatively, (2) home market sales are "incidental" to Tosoh and therefore are insufficient to permit a proper comparison with sales to the United States.

Plaintiffs' first argument lacks merit. Where Commerce finds that a proper difmer adjustment cannot be made, it may choose not to use home market sales as a basis for calculating NV. For example, in Large Newspaper Printing Presses and Components thereof whether Assembled or Unassembled, from Japan, 61 Fed.Reg. 38,139, 38,146-47 (Dept. Comm. 1996) (final determ.), Commerce found that use of home market sales as a basis for calculating NV was inappropriate and instead opted to use constructed value (CV) where "the degree of unique customization for customers made the difference-in-merchandise adjustment for product price matching potentially . . . complex." Thus, Commerce's finding in Large Newspaper Printing Presses was based on the impracticability of comparing prices set according to the specifications of individual customers. In contrast, EMD is a commodity, the grades of which are established according to industry specifications and the prices of which are not determined according to customer specifications or requested modifications. Because there is nothing in the record to suggest that the sales of the home market EMD did not reflect prevailing market prices for the commodity, Plaintiffs' argument that home market sales are not viable pursuant to 19 U.S.C. § 1677b(a)(1)(C)(iii) must fail.

Plaintiffs' second argument also lacks merit. Plaintiffs contend that the home market sales are "incidental" because they were for a "low value use" and therefore "hav[e] no material effect on a company's profitability." Pl.'s Br. at 44. The term "incidental" for the purposes of determining whether a "particular market situation" exists, however, refers not to the value of the sales or the quality of the goods sold, but to whether the sales were made under normal market circumstances. For example, in Fresh Atlantic Salmon from Chile, 63 Fed.Reg. 31,411, 31,418 (Dep't Comm. 1998) (final determ.), Commerce found home market sales to be incidental where the respondent sold substandard (i.e., "reject" or "industrial") grade sales on an "as available" basis and without standard quality guarantees to offset losses that would have been sustained by disposal of the off-market merchandise. The sales in Salmon from Chile, therefore, can hardly be said to have been made under conditions that would reflect normal market prices.

Here, in contrast, the home market EMD was sold for use in batteries that were of a lower quality than those into which the subject merchandise was incorporated. It does not follow, however, that the home market EMD sales did not reflect prevailing market prices. In fact, the record reveals evidence that the home market EMD was sold under normal market circumstances: the home market EMD was sold to a regular customer at prices set in arm's-length transactions and under a standard guarantee. Questionnaire Response at Exhs. A-3, B-1, Tosoh's App., Tab B-1, at 7, 9, 17; Quantity and Value Reconcilation Letter at Exh. 4. Tosoh's App., Tab C. In addition, the home market EMD met basic minimum technical standards. Questionnaire Response. at A-21, Exhs. A-3, A-19, A-20, Pl.'s App., Tab 4A. at 5, Tosoh's App., Tab B-1, at 7, 9, 12-16. Therefore, plaintiffs contention that the home market sales were incidental and thus not indicative of market prices fails.

III. Inventory Carrying Costs

Plaintiffs contend that Commerce erred in including Tosoh's inventory carrying costs in calculating normal value as a constructed export price offset adjustment while disregarding them in calculating CEP. See Pl.'s Br., at 47; Final Results, 64 Fed.Reg. at 62,174. Specifically, Plaintiffs claim that although the inventory carrying costs were incurred outside the United States. they were incurred in connection with sales to an unaffiliated purchaser in the United States. Because such sales were for the benefit of the unaffiliated purchaser, Plaintiffs argue, they are therefore "associated with" commercial activity in the United States and deductible from CEP under 19 C.F.R. § 851.402 (b). Pl.'s Br. at 47-48. Plaintiffs concede, however, that disposition of this issue in their favor would have a de minumis effect on the dumping margin. Therefore, the court need not resolve whether Commerce erred in the assumptions underlying its calculations as the issue is moot given the court's other holdings.

CONCLUSION

Because the court finds that Commerce's determinations with respect to foreign like product and home market viability are supported by substantial evidence and are in accordance with law, the Final Results determination is AFFIRMED.