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U.S. Trade Remedy Law: The Canadian Experience
III United States Safeguard Law
- 2.1 Petitions
- 2.2 Investigations and Determinations
- 2.3 Domestic Industry and Like or Directly Competitive Articles
- 2.4 Increased Imports
- 2.5 Serious Injury
- 2.6 Substantial Cause
- 2.7 Public Hearings
- 2.8 ITC Report
- 2.9 Critical Circumstances and Provisional Relief
- 2.10 Referrals for Related Agency Action
- 2.11 Facilitation of Positive Adjustment
- 2.12 Presidential Action
- 2.13 Forms of Relief
- 2.14 Congressional Veto Power
- 2.15 Monitoring, Modification, and Termination of Action
- 2.16 North American Free Trade Agreement
- 2.17 Compensation and Compliance
- 2.18 Uruguay Round Special Agricultural Safeguards
- 2.19 Miscellaneous Provisions
U.S. trade legislation contains “escape clause” or “safeguard” provisions, which permit the President to temporarily suspend, withdraw or modify trade concessions (usually by means of import quotas or additional duties), and/or offer adjustment assistance to domestic industries, firms and workers injured by import competition. The intent of these provisions is not to provide permanent protection from foreign imports, but to offer affected industries, firms and workers an opportunity to adjust to import competition. Safeguard actions are available whether the imports are priced “fairly” or “unfairly,” although they are generally used in response to increases in fairly traded imports. Remedies used to respond to unfair trade, i.e. dumped or subsidized imports, are invariably exhausted before safeguard action is requested. Despite the fact that safeguard‑type actions may be found in several statutes,1 the primary measure is found in Chapter 1 of Title II (sections 201–203) of the Trade Act of 1974 and is generally known as section 201.
The President determines whether or not to grant import relief after an investigation by the U.S. International Trade Commission and upon receiving a recommendation from it. In its investigation, the ITC determines whether an article is being imported in such increased quantities as to be a substantial cause of serious injury, or the threat thereof, to the domestic industry producing an article like or directly competitive with the imported article. The Secretaries of Labour and Commerce determine whether to provide adjustment assistance to affected workers and firms/industries respectively.
Import relief granted under Title II largely receded during the mid‑1980s to mid‑1990s as a declining number of petitions were filed by U.S. industries seeking such relief. However, as exemplified by the 1998 increase in U.S. imports of steel in particular, there was a re‑emergence of consideration by U.S. industries of safeguard actions in the late 1990s.
The import relief authorized in Title II of the Trade Act of 1974 is circumscribed by the WTO and NAFTA obligations and requirements. Article XIX of the GATT 1947 and NAFTA Article 802 both permit signatories to temporarily suspend, withdraw or modify trade concessions to give domestic industries injured by import competition an opportunity to take measures necessary to become more competitive with foreign firms. International concern about the use of import and export restraint agreements outside the scope of Article XIX was perceived to be the primary reason for the establishment of the WTO Agreement on Safeguards in the Uruguay Round of multilateral trade negotiations. This agreement specifically prohibits the use of certain unilateral and bilateral negotiated measures affording import relief, such as voluntary restraint agreements, orderly marketing agreements or export restraint agreements. In such agreements, one country undertakes to limit its exports of a particular product to another importing nation. Like many countries, the United States has concluded such agreements in the past to respond to import competition.
An entity “representative of an industry,” including trade associations, unions or groups of workers, may file a petition with the ITC under section 202 of the Trade Act of 1974. The petition must include a statement describing the purpose of the petition—in other words, the means of adjustment sought—which is invariably protection from allegedly injurious imports. With the petition, or within 120 days of filing it, the petitioner may submit a plan to facilitate positive adjustment to import competition.2 An ITC investigation may also be initiated upon the request of the President or the U.S. Trade Representative, or upon a resolution of the House Committee on Ways and Means or the Senate Committee on Finance. In addition, it may be self‑initiated.
Unless the ITC determines good cause, no investigation may be initiated with respect to the same subject matter as a previous investigation, unless one year has elapsed since the ITC report to the President. If import relief was provided further to a safeguard investigation, no new action may be initiated with respect to the same product for a period of time equivalent to the period of import relief previously granted or for two years, whichever is greater.3
Once the ITC initiates proceedings, it must determine which producers constitute the domestic industry and what products are like or directly competitive with the imported articles. Unlike other trade remedy provisions, there is no statutory deadline between the submission of a petition and the initiation of an investigation. Once such terms are established, the ITC must determine whether “an article is being imported into the United States in such increased quantities as to be a substantial cause of serious injury, or the threat thereof, to the domestic industry producing an article like or directly competitive with the imported article.”4 For a positive finding to be made, three conditions must be satisfied:
- imports have increased;
- the domestic industry is seriously injured or is threatened with serious injury; and
- such increased imports are a substantial cause of serious injury or threat thereof to the domestic industry.
If the ITC finds that all three conditions are met, it must then recommend to the President “the action that would address the serious injury, or threat thereof, to the domestic industry and be the most effective in facilitating the efforts of the domestic industry to make a positive adjustment to import competition.”5
Unlike anti‑dumping and countervailing duty law, there is no mathematical threshold for determining the standing of a domestic industry to request a safeguard investigation. The Trade Act of 1974 defines “domestic industry” as those producers whose collective production of the like or directly competitive article constitutes all or a major portion of the total domestic production of such article.6 The following factors are generally considered in defining the relevant domestic industry: productive facilities; manufacturing processes; and the markets for the product at issue. In the case of a domestic producer who also imports, the ITC may treat as the domestic industry only the domestic production. The ITC may also define an industry as production in one major geographic area in which the imports at issue are concentrated, when producers in that area constitute a substantial portion of the entire domestic industry and primarily serve markets in that area.
The terms “like article” and “directly competitive article” are defined in the legislative history of the Trade Act of 1974: “‘Like’ articles are those which are substantially identical in inherent or intrinsic characteristics (i.e. materials from which the article is made, its appearance, quality, texture, etc.), and ‘directly competitive’ articles are those which, although not substantially identical in their inherent or intrinsic characteristics, are substantially equivalent for commercial purposes, that is, are adapted to the same uses and are essentially interchangeable.”7
The ITC has identified several additional factors to be considered in identifying the like or directly competitive product. Using a “product line” approach, the ITC takes into account such factors as the physical properties of the article, customs treatment, where and how it is made (e.g., in a separate facility), uses and marketing channels. Clear dividing lines are sought between possible products, and minor variations are disregarded.
The increased imports requirement provides that the increase must have been either actual or relative to domestic production. The requirement is thus satisfied if imports have increased in actual terms, or if they have remained steady or even declined in actual terms but have increased relative to domestic production (that is, domestic production is falling at a faster rate than imports). In making this determination, the ITC generally examines import trends over the most recent five‑year period.
The ITC must then find whether the domestic industry is seriously injured or threatened with serious injury. “Serious injury” is defined as a significant impairment in the position of the domestic industry. “Threat of injury” is defined as serious injury that is clearly imminent and not based on conjecture. The ITC is instructed to take into account various economic factors in its determination of injury.
In the case of serious injury, these are: significant idling of productive facilities in the industry; the inability of a significant number of firms to conduct domestic production operations at a reasonable profit; and significant unemployment or underemployment within the industry.
In the case of threat of serious injury, the economic factors to be taken into account are: a decline in sales or market share; a higher and growing inventory; a downward trend in production, profits, wages, productivity or employment in the domestic industry concerned; the extent to which domestic producers are unable to generate adequate capital to modernize equipment and facilities, or are unable to maintain existing levels of expenditure on research and development; and the extent to which foreign exports are being diverted to the U.S. market by reason of trade restraints on the part of other countries.8
These statutory factors are not all‑inclusive or singly decisive. The ITC must make an injury determination within 120 days of receipt of the petition—unless it determines that the case is extraordinarily complicated, in which circumstances there may be an extension of 30 days.
The third condition requires a finding that the increase in imports be a substantial cause of serious injury or threat thereof to the domestic industry. Substantial cause is defined as “a cause which is important and not less than any other cause.”9 The following economic factors guide the ITC in its determination: whether there is an increase in imports (either actual or relative to domestic production) and a decline in the proportion of the domestic industry supplied by domestic producers.
Furthermore, the ITC is directed to consider the condition of the domestic industry over the course of the relevant business cycle. It may not aggregate the causes of declining demand associated with a recession or economic downturn in the economy into a single cause of serious injury or threat of injury.
The ITC also examines factors other than imports that may be a cause of serious injury or the threat thereof to the domestic industry, and it includes such findings in its report. The legislative history of the Trade Act of 1974 includes examples of other causes, such as changes in technology or consumer tastes, domestic competition from substitute products, plant obsolescence or poor management. If such developments are found to be more important causes of injury than increased imports, a negative finding is required.
The third condition of a finding would therefore require a weighing of causes. The increase in imports must be both an important cause and a cause that is equal to or greater than any other cause of serious injury or threat thereof. The legislative history states that the ITC must assure itself that imports are a substantial cause and not simply one of a multitude of equal causes.10
The ITC is required to hold a public hearing within a reasonable time after the commencement of proceedings. In addition to submissions by the domestic producer(s) and the foreign exporter(s), other interested parties and consumers may present evidence, comment on the adjustment plan if any, respond to presentations of other parties, and otherwise be heard. A separate hearing on the issue of remedy is required if the ITC reaches an affirmative determination.11
The ITC must submit a report to the President, including its findings, remedy recommendations (if any) and reasons for its determination no later than six months from the date of the filing of the petition. The report must also be made available to the public and a summary published in the Federal Register.
If the ITC determines that increased quantities of imports of an article are or threaten to be a substantial cause of serious injury to the domestic industry, the Commission is required to make recommendations as to relief, including its type, amount and duration.12 The report must include the short- and long‑term effects of both the implementation and non‑implementation of the recommended action on the petitioning domestic industry, its workers, consumers, the communities where production facilities are located, and other domestic industries. If the ITC finds that increased imports are not a substantial cause of serious injury or threat thereof to the domestic industry, the proceedings are terminated.
The ITC may not release information that it considers to be confidential business information unless the party submitting the confidential business information had notice, at the time of submission, that such information would be released by the ITC, or such party subsequently consents to the release of the information. Regulations provide for access to confidential information under protective orders to authorized representatives of interested parties to the ITC investigation.13
Critical circumstances exist where there is clear evidence that increased imports are a substantial cause of serious injury or threat thereof to the affected domestic industry, and delay in taking action would cause damage to the domestic industry that would be difficult to repair. If the ITC and the President agree that critical circumstances exist, provisional relief may be granted prior to any final determination. The allegation of critical circumstances must appear in the original petition and be supported with relevant evidence. If provisional relief is warranted, the President may proclaim such relief as is necessary, for a period not to exceed 200 days. The President is also directed to give preference to duties over other forms of provisional relief. Where a petition alleges critical circumstances and requests provisional relief, the ITC must determine not later than 60 days after filing whether critical circumstances exist, and the President has 30 days from receipt of the ITC report to decide what provisional action to take, if any. After completing its 60‑day critical‑circumstances phase, the ITC proceeds to conduct a regular 180‑day investigation.14
Amendments introduced in 1988 authorize the President to provide emergency import relief for perishable agricultural products. For emergency relief, these products must have been monitored by the ITC for a period of at least 90 days before the filing of a petition.15 The ITC has 21 days from the filing of a petition to make and report its determination and findings to the President, and the President has seven days to decide what action to take.
When the ITC commences an investigation, it must notify the Secretary of Labour, who immediately initiates a study of the number of affected workers likely to be certified as eligible for adjustment assistance, and the extent to which the adjustment of such workers to the import competition may be facilitated through the use of existing programs. The ITC must also notify the Secretary of Commerce, who must undertake a study of the number of domestic firms likely to be certified as eligible for adjustment assistance, and the extent to which adjustment may be facilitated by existing programs. Both Secretaries must submit a report to the President not more than 15 days after the date on which the ITC report is due. If during the investigation the ITC has reason to believe that increased imports are attributable in part to unfair trade practices (e.g., dumping or subsidization), it must promptly notify the agency administering the appropriate trade law.
Title II of the Trade Act of 1974 also provides for the possibility of government adjustment assistance for workers, firms and industries determined to be adversely affected by import competition. Adjustment assistance may be requested in petitions filed specifically for that purpose and not connected to a safeguard measure, or as part of a section 201 petition filed to facilitate positive adjustment to import competition. Petitions for adjustment assistance for workers, including recognized unions, are filed with the Secretary of Labour, who then initiates an investigation. Workers deemed eligible for adjustment assistance may apply for a trade adjustment allowance of cash benefits or re‑employment services, including job training and job search, and relocation allowances.
Prior to 1986, firms certified to be eligible for adjustment assistance by the Secretary of Commerce could apply for direct financial assistance. Since 1986, however, eligible firms may receive only technical assistance for the development and implementation of an economic adjustment proposal. The Secretary of Commerce may also provide technical assistance for industry‑wide programs “for new product development, new process development or other uses consistent with the purposes” of Title II.
The law provides that a positive adjustment occurs, and assistance is no longer warranted, when: (1) the domestic industry is able to compete successfully with imports after actions taken under section 204 terminate, or the domestic industry experiences an orderly transfer of resources to other productive pursuits; and (2) dislocated workers in the industry experience an orderly transition to productive pursuits.
The domestic industry may be considered to have made a positive adjustment to import competition even though the industry is not of the same size and composition as it was at the time the investigation was initiated.
The Trade Act of 1974 requires the President to take all appropriate and feasible action within his power within 60 days of receiving a report from the ITC containing an affirmative finding. The President, however, retains discretion as to the extent and duration of the action he deems appropriate and feasible, and may choose to entirely disregard the ITC recommendation and take no action at all. In making his decision, the President is advised by the Trade Policy Committee (chaired by a Deputy Trade Representative, this Committee is the U.S. government agency designated to hold hearings pertaining to any matters relevant to trade agreements).
In determining what action is appropriate, the President is required to consider a number of factors, including:
- the ITC recommendations and report;
- the extent to which workers and firms are benefiting from adjustment assistance and similar programs, and are engaged in worker retraining efforts;
- the efforts being made or planned by the domestic industry to make a positive adjustment to import competition;
- the probable effectiveness of action he might take to achieve positive adjustment;
- the economic and social costs and benefits of actions;
- the extent to which there is a diversion of foreign exports to the United States as a result of foreign restraints;
- the potential for circumvention of action taken;
- the national security interests of the United States;
- the factors that the ITC is required to take into account in making its recommendation; and
- factors relating to the economic interest of the United States, including: the economic and social costs that would be incurred by taxpayers, communities and workers if relief were not provided; the effect of action on consumers and on competition in domestic markets; and the impact on domestic industry as a result of international obligations regarding compensation.16
Section 203 authorizes the President to provide one or more of the following types of relief:
- increases in, or imposition of, duties;
- tariff‑rate quotas;
- quantitative restrictions—i.e. quotas allocated among importers by auctioned licences;
- adjustment measures, including trade adjustment assistance;
- agreements limiting exports from foreign countries into the United States;
- initiation of international negotiations to address the cause or otherwise alleviate the injury;
- submission of legislative proposals to facilitate positive adjustment by industry;
- any other action within his power; or
- any combination of the above.17
If the remedy provided is tariff adjustment, the increased tariff is generally applied on a Most Favoured Nation (MFN) basis, meaning that there would be one tariff for imports from all WTO members. The President may not increase a rate of duty to more than 50% ad valorem above the existing rate.18
If quantitative restrictions are used, the concept of MFN application becomes more difficult. Global quotas are the least discriminatory form of quantitative restriction, but they often create problems as importers rush to fill them early in a prescribed time period. One solution is to distribute quotas on a quarterly basis, thereby ensuring that imports are not disproportionately entered. In practice, quotas are usually granted on a country‑by‑country basis (country reserves). Such quota systems generally establish the amount of the quota for each country, and are usually based on the amount or proportion of trade that each country had during a historical period. If quantitative restrictions are placed on imports, they must permit importations at least equal to the average amount imported in the most recent three‑year representative period for which data are available—unless the President finds that the importation of a different quantity or value is clearly justified to prevent or remedy the serious injury.19
As a general matter, simple tariff increases are preferred to tariff‑rate quotas and quantitative restriction quotas because a tariff tends to be least distortive of trade and easiest to administer. The cumulative impact of any relief afforded must not exceed the amount of relief necessary to prevent or remedy the serious injury caused by imports. Imposition of duties or quotas in effect for more than one year must be phased down at regular intervals during the course of the period for which action is taken.20
The Uruguay Round amendments shortened the maximum period for initial relief to four years. The President may extend the relief to eight years upon the recommendation of the ITC if he determines that the relief continues to be necessary to prevent or remedy serious injury, and there is evidence that the domestic industry is making a positive adjustment to import competition.21
On the day the President takes action, he must submit to Congress a document describing the reasons for his action. If the action taken by the President differs from the action recommended by the ITC, the President shall state in detail the reasons for the difference. Congress may override Presidential action differing from the action recommended by the ITC by passing a joint resolution of both Houses within 90 days of the transmission of the President’s report.
If Presidential action is taken, the ITC is required to monitor developments in the industry, including its efforts to adjust, and must report to the President at specified intervals.22 If the initial period of relief exceeds three years, the ITC must conduct a hearing and submit a report on the results of the monitoring to the President and Congress no later than the mid‑point of the initial period of relief.23 Upon receiving such a report from the ITC, the President may reduce, modify or terminate action if he determines that changed circumstances so warrant.24 The changed circumstances that warrant reduction, modification or termination include any of the following:
- The domestic industry has not undertaken adequate efforts to make a positive adjustment.
- A change in economic circumstances has impaired the effectiveness of the action.
- The domestic industry has submitted a petition indicating that it has already achieved a positive adjustment to import competition.
- The WTO Dispute Settlement Body finds that an action under Title II is inconsistent with the Agreement on Safeguards. In such a case the U.S. Trade Representative may ask the ITC to issue an advisory opinion on whether the United States may take steps to make its action consistent with the Agreement. The ITC then advises the President as to whether Title II permits steps to render U.S. action consistent with the Agreement.
Upon request of the President, the ITC must advise him as to the probable economic effects on the domestic industry of any proposed reduction, modification or termination of action.
After any action taken under this title has terminated, the ITC must evaluate the effectiveness of the action in facilitating positive adjustment by the domestic industry to import competition, and must submit a report to the President and Congress within six months of termination.
Chapter Eight of the North American Free Trade Agreement affects the scope of relief that may be granted by a safeguard action as it relates to imports from NAFTA parties. That is, when global safeguards are imposed as the result of a section 201 investigation, the relief against NAFTA imports may be constrained by the Agreement. Section 311 (a) of the NAFTA Implementation Act provides that if the ITC makes an affirmative injury determination in an investigation under section 202 of the Trade Act of 1974, the ITC must also determine whether:
- imports of the article from a NAFTA country, considered individually, account for a substantial share of total imports; and
- imports of the article from a NAFTA country considered individually or (in exceptional circumstances) imports from NAFTA countries considered collectively contribute importantly to the serious injury, or threat thereof, caused by imports.
Thus, in order to make an affirmative finding with respect to imports from Canada or Mexico, the ITC must make an affirmative finding on both conditions. If the ITC finds that either condition is not satisfied, it must recommend to the President that NAFTA‑origin goods be excluded. The President may subsequently include such imports in the action if he determines that a surge in imports from a NAFTA country or countries is undermining the effectiveness of the action. Section 311 (b) (1) states that imports from a NAFTA country “normally” will not be considered to account for a substantial share of total imports if that country is not among “the top five suppliers of the article subject to the investigation, measured in terms of import share during the most recent three‑year period.”
Section 311 (c) defines “contribute importantly” as to be “an important cause, but not necessarily the most important cause.” In determining whether imports have contributed importantly to the serious injury or the threat thereof, the ITC is directed to consider such factors as the change in the import share of the NAFTA country or countries, and the level and change in the level of imports from a NAFTA country or countries. Imports from a NAFTA country or countries “normally” will not be considered to contribute importantly to the serious injury or the threat thereof “if the growth rate of imports from such country or countries during the period in which an injurious increase in imports occurred is appreciably lower than the growth rate of total imports from all sources over the same period.”
In exceptional circumstances, imports from NAFTA countries may be considered collectively in determining whether NAFTA imports have contributed importantly to the serious injury or threat. The NAFTA Implementation Act Statement of Administrative Action states, “The ITC is likely to consider imports from NAFTA countries collectively when imports from individual NAFTA countries are each small in terms of import penetration, but collectively are found to contribute importantly to the serious injury or threat of serious injury.”
One of the reasons safeguards have been used infrequently is that the importing country must generally offer affected countries some form of compensation in order to avoid being subjected to retaliatory measures brought by the exporting countries. The WTO does not use the terms “sanction” or “retaliation,” but it has a structure for requiring “payment” from a country that departs from its scheduled obligations in the context of the escape clause of Article XIX. Article XIX of the GATT 1947 and Article 8 of the Agreement on Safeguards require the member proposing the safeguard to grant a substantially equivalent level of concessions and other obligations to the exporting members that would be affected by such a measure.
To achieve this objective, the parties hold consultations in an attempt to arrive at an agreement. Generally, the importing country offers interested exporting countries concessions on other products by way of compensation. One of the problems in recent years, as the general average of tariffs has declined to low levels, is that it has become increasingly difficult for countries invoking safeguard measures to be able to effectively compensate affected countries by way of granting tariff concessions. Usually the amount of requested compensation is sufficiently large that it becomes difficult to find any products with a high enough tariff to make concession meaningful, except for products that are already very sensitive and therefore subject to higher tariffs.
If no agreement is reached within 30 days of consultations, then the affected exporting members shall be free, not later than 90 days after the measure is applied, to suspend, 30 days from the day on which written notice of such suspension is received by the WTO Council for Trade in Goods, the application of substantially equivalent concessions or other obligations to the trade of the member applying the safeguard measure. This right of suspension cannot be exercised for the first three years that a safeguard measure is in effect, provided that the safeguard measure has been taken as a result of an absolute increase in imports and that such a measure conforms to the provisions of the Agreement on Safeguards. Furthermore, Article XIX gives exporting countries having a substantial interest in the product concerned an opportunity to consult on the matter. NAFTA Article 802:6 also contains a “compensation” or “retaliation” provision very similar to that found in the WTO agreements.
U.S. law makes no explicit reference to compensation in the context of safeguards but section 123 of the Trade Act of 1974 gives the President a certain amount of compensation authority. That provision allows that whenever import relief has been provided by increasing or imposing any duty or other import restriction, the President may enter into trade agreements with foreign countries to grant concessions as compensation in order to maintain the general level of reciprocal and mutually advantageous concessions. To carry out such an agreement, the President may proclaim modification or continuance of any existing duty or treatment, as appropriate.
The Uruguay Round Agreement on Agriculture contains provisions permitting the designation of import‑sensitive agricultural goods as “special safeguard agricultural goods.” Imports of such goods may be subject to an imposition of safeguards in the form of additional duties when their import level reaches a designated trigger point. Either price‑based or volume‑based trigger points may be used. The President is required to publish a list of the designated goods, determine the appropriate volume and price trigger levels, and reset the volume‑based trigger levels on an annual basis. Finally, the President may exempt from any special safeguards goods that originate in any NAFTA country.
No safeguard investigation may be initiated with respect to an article that is the subject of the WTO Agreement on Textiles and Clothing unless and until the United States has integrated the specific product or article into GATT 1994. Thus, such articles are no longer subject to import or export restraints concluded under the WTO Agreement on Textiles and Clothing.
Section 406 of the Trade Act of 1974 establishes separate safeguard procedures for non‑market economies. These apply to any non‑market country regardless of whether Most Favoured Nation treatment has been accorded. The provisions are very similar to the safeguard provisions outlined in sections 201–203, but section 406 provides for a lower standard of injury determination and faster import relief procedures, and the investigation focuses on imports from a specific country as opposed to all imports.
1There are safeguards in the Uruguay Round Agreement on Textiles and Clothing to be used during the phase‑out of the Multi‑Fibre Arrangement.There are also special agricultural safeguards discussed below.
2Sec. 202 (a) (4).
3Sec. 203 (e) (7).
4Sec. 201 (b) (1) (A).
5Sec. 202 (e) (1).
6Sec. 202 (c) (6) (A) (I).
7Trade Act of 1974: Report of the Committee on Finance, United States Senate, on H.R. 10710, S. Rept.No. 93‑1298, 93d Cong., 2d Sess. (1974), at 21‑22.
8Sec. 202 (c) (1).
9Sec. 202 (b) (1) (B).
10Trade Act of 1974: Report of the Committee on Finance, United States Senate, on H.R. 10710, S. Rept.No. 93‑1298, 93d Cong., 2d Sess. (1974), at 121.
11Sec. 202 (e) (5) (A).
12Sec. 2202 (e) (3).
13Sec. 202 (f ).
14Sec. 202 (d) (1) (C).
15Sec. 202 (d) (1) (C).
16Sec. 203 (a) (2).
17Sec. 203 (a) (3).
18Sec. 203 (e) (3).
19Sec. 203 (e) (4).
20Sec. 203 (e) (5).
21Sec. 203 (e) (1)‑(2).
22Sec. 204 (a) (1).
23Sec. 204 (a) (2)‑(3).
24Sec. 204 (c).
- Date Modified: