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Between 2007 and 2009, Italy and Libya (then under the rule of Colonel Muammar el-Qaddafi) concluded several agreements to combat clandestine immigration. Pursuant to these agreements, Italy instated a policy of sending undocumented migrants and asylum seekers who had crossed the Mediterranean Sea from Africa back to Libya. In a number of cases, boats were intercepted on the high seas, and those on board were taken back to Libya without a prior individualized assessment of their situation and protection needs.

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Threatened by trade retaliation against U.S. exports by the European Union ("EU") and Japan, on February 14, 2012, the U.S. Department of Commerce ("DOC") announced a policy change to generally end the practice of "zeroing" in antidumping cases. The DOC had earlier ended zeroing in antidumping investigations; the February 14 policy change covers future administrative reviews of existing antidumping orders, including new shipper reviews, expedited antidumping reviews, and sunset reviews.

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