OPINION
On November 14, 1996, this court remanded the Department of Commerce, International Trade Administration’s two letter rulings in Stainless Steel Plate from Sweden.1 Bohler-Uddeholm Corp. v. United States, 946 F.Supp. 1003, 1004 (Ct. Int’l Trade 1996). The letter rulings reversed the Treasury Department’s 1976 post-finding scope ruling and held that two grades of stainless steel plate sold by plaintiff Bóhler-Uddeholm Corporation under the trade names UHB Stavax (“Stavax”) and UHB Ramax (“Ramax”) were within the scope of the 1973 antidumping finding issued in Stainless Steel Plate from Sweden, 38 Fed.Reg. 15,079, 15,079 (Treasury Dep’t 1973).
The court noted in its decision ordering remand that while Commerce may amend a detérmination when it has “ ‘utilized a legally improper method in making a determination or when the original determination contains an error of inadvertence or mistake,’ ” Commerce could not determine that Treasury erred in its 1976 post-finding ruling or correct that error by applying the current standard used in scope determinations.2 Bóhler- *1178 Uddeholm Corp., 946 F.Supp. at 1007, 1009-10. Rather, the court held that Commerce must apply the scope determination standard in effect in 1976,3 which was the totality of the circumstances test applied in the classification case United States v. Carborundum Company, 63 C.C.P.A. 98, 536 F.2d 373, 377 (1976). Id. at 1008.4 Moreover, “the current threshold test of finding ambiguity in the documentary description of the merchandise as set forth under 19 C.F.R. § 353.29(i)(l) before resorting to Diversified Products or Carborundum type factors is not applicable under the 1976 standards.” Id. at 1009.
On remand, the court instructed Commerce to:
apply the 1976 standards to determine whether Treasury erred in its post-finding ruling. In reviewing Treasury’s actions Commerce must interpret ambiguous actions in accordance with the presumption of administrative legality and regularity. Moreover, at this stage, Commerce may not reweigh the evidence. If a court would find sufficient evidence to sustain Treasury’s decision, so must Commerce. Second, if Treasury erred, Commerce may correct the antidumping scope determination by applying the law in effect in 1976.
Id. at 1009-10. In its remand determination, Commerce concluded that Treasury erred in its 1976 post-finding ruling. Final Results of Redetermination Pursuant to Court Remand, Bohler-Uddeholm Corp. v. United, States, Slip Op. 96-184 (Nov. 14, 1996) at 3 (hereinafter “Remand Results ”). In addition, Commerce determined that Treasury applied the standard articulated in Acrylic Sheet from Japan5 and not the Carborundum standard in making scope determinations. Id. at 5. Applying the Acrylic Sheet standard, Commerce found that Stavax and Ramax, whether flat-rolled or forged, are within the scope of the 1973 antidumping finding on stainless steel plate from Sweden. Id. at 2-3. This matter is now before the court following Commerce’s remand determination.
Discussion
I. Remand Determination that Treasury Erred in its 1976 PostFinding Ruling
Commerce’s remand determination concluded that Treasury’s post-finding ruling was unlawful on a number of bases.
First, the Department has determined that, at least with respect to flat-rolled Stavax and Ramax, Treasury could have reached a determination by applying a plain reading of the scope language under the finding on stainless steel plate from Sweden. Second, the Department has determined that if Treasury could not resolve, with a plain reading, whether flat-*?rolled' or forged Stavax and Ramax were within the scope of the finding, the appropriate test which Treasury should have applied is the test set forth in its unpublished scope determination on the 1976 finding of dumping of Acrylic Sheet from Japan. The Department has also determined that, in reaching its 1976 scope ruling, Treasury used an impermissible bright line test and also failed to correctly apply the factors in that test. Our analyses reveal that, regardless of whether its bright line test was permissible, Treasury unlawfully altered the scope of the finding. In addition, the Department has determined that if Treasury had applied a plain reading of the scope language or used the Acrylic Sheet test, its determination that Stavax and Ramax fall outside the scope of the finding on stainless steel plate would not have been supported by substantial evidence on the record. Finally, our analyses have revealed that, however one characterizes the analysis employed by Treasury in its 1976 determination, the test applied in that ruling was neither an appropriate application of a plain reading of the description, the Acrylic Sheet analysis, the Diversified analysis, nor even the Carborundum analysis. Therefore, it was plainly incorrect.
Remand Results, at 8. Moreover, Commerce found that the 1976 ruling itself indicates that Treasury:
(1) did not include a complete reference to the scope of the antidumping finding; (2) ignored the fact that Stavax and Ramax clearly fall within the physical characteristics contained in the description of stainless steel plate in the petition ..., failing to even mention this important fact; (3) relied heavily on the fact that the petition failed to include a price .comparison of the specific grades of steel in question; (4) emphasized its conclusion that the uses for which the merchandise was imported did not fall within the illustrative (not exhaustive) list contained in the petition and; (5) erroneously determined that' Stavax and Ramax were not covered by the finding simply because such products were not part of the fair value price-to-price comparisons.
Id. at 9-10 (internal citation omitted). The court need, not discuss all of the reasons relied upon by Commerce to sustain this section of the remand results as even one finding of error supported by substantial evidence would make Treasury’s ruling unlawful.
In its remand determination, Commerce concluded that under either the Acrylic Sheet test or the Carborundum test, Treasury’s ruling was unlawful because Treasury did not consider all of the required factors. See id. at 8, 16. In reaching this determination, Commerce relied solely on the language of the 1976 ruling. See id. at 16. The post-finding ruling is implicitly divided into three sections. See Treasury’s Mem. on Stainless Steel Plate from Sweden (Oct. 29,1976); Pl.’s App., Tab 5, at 66-67 (hereinafter “Post-Finding Ruling Letter”). The first section details the materials appended to Bohler-Uddeholm’s memoranda. Id. at 66. Here, Bóhler-Üddeholm described Stavax and Ra-max as tool steel with a specific chemical composition. Id. The second section contains Treasury’s .description of stainless steel'plate, defined by physical dimension and ability to resist corrosion and abrasion.6 Id. The third section contains Treasury’s analysis and conclusion. Id. at 66-67. In this section, Treasury stated:
*1180[N]one of .the aforementioned grades of steel were enumerated in. the complainant’s price, comparison. Inasmuch as the complaint failed to address itself to those varieties of steel, and based on the materials appended to your memorandum, it is our opinion that UHB 904L plate, UHB Stavax and UHB Ramax, manufactured by [Bohler-]Uddeholm Steel Company, Sweden, do not come within the purview of T.D. 73-157. We note that UHB 904L plate does not fall within the stainless steel family given the industry standards. We also note that UHB Ramax and UHB Stavax are stainless plastic mold steels rather than stainless steel plate. In addition, Custom^ did not consider these varieties of steel during the course of the fair value investigation.
Id.
Commerce’s conclusion in this regard is supported by substantial evidence and thus is affirmed. Treasury’s 1976- post-finding ruling mentioned facts relevant to a proper scope determination, but did not integrate these facts into its analysis section. The analysis section does not address the factors of either Acrylic Sheet or Carborundum such as physical characteristics, expectations of purchasers, or channels of trade of stainless steel plate. See PosMF’inding Ruling Letter; Pl.’s App., Tab 5, at 66-67. Instead, “every sentence in the paragraph relates to Treasury’s analysis of the use requirement it added or the requirement added by Treasury that Stavax or Ramax fall under one of the listed grades.” Remand Results, at 16; see also PostFinding Ruling Letter; Pl.’s App., Tab 5, at 66-67. Plaintiff counters Commerce’s findings by suggesting that Commerce cannot determine twenty years later the degree of weight given to each factor and speculates that those factors not explicitly mentioned may have been implicitly considered by Treasury. As plaintiff has not directed the court to any record evidence to support its argument or to contradict Commerce’s finding, this argument is unpersuasive.
Moreover, Commerce further supported its remand determination that Treasury did not consider all of the relevant factors by concluding that Treasury’s post-finding scope ruling was based, in significant part, on the fact that Stavax and Ramax were not listed in the petition as examples of price comparisons for stainless steel plate and that this reliance constituted an impermissible “bright line test.”7 Remand results, at 15-16 (quoting Bohler-Uddeholm Corp., 946 F.Supp. at 1008).
The court agrees with Bohler-Uddeholm that the evidence does not indicate the relative weight Treasury assigned to this factor and thus does not indicate its use as a “bright line test.” The court, however, sustains this aspect of the remand results as the finding that Treasury based its ruling, at least in part, on the omission of Stavax and Ramax’s grades of steel from the petition’s list of price comparisons is supported by substantial evidence. ' In fact, Treasury’s ruling included only one expressly articulated reason for excluding Stavax and Ramax— that the grades of steel in question were not enumerated in the petition. See Post-Finding Ruling Letter; Pl.’s App., Tab 5, at 66-67. Treasury’s consideration of the list as complete in determining the scope of the class or kind of merchandise was thus unlawful.8
*?In addition to contesting each finding of error, plaintiff also argues that Commerce disregarded the court’s instructions to
interpret ambiguous actions in accordance with the presumption of administrative legality and regularity. Moreover, at this stage, Commerce may not reweigh the evidence. If a court would find sufficient evidence to sustain Treasury’s decision, so must Commerce.
Bohler-Uddeholm Corp., 946 F.Supp. at 1009-10. The court notes the significance of these instructions because not just legally, but practically, a decision three years after the original determination should be presumed correct. More than twenty years after the fact, Commerce should find error reluctantly.9 In its remand determination, however, Commerce stated that while it dis-' agrees with the court’s instruction to apply the presumption, it
[njonetheless, in accordance with the Court’s statement ... we have examined the record to determine whether Treasury’s 1976 detérmination was supported by substantial evidence on the record at that time, rather than impose our own judgement or examine Treasury’s ruling under standards currently in effect which were not in effect in 1976.
Remand Results, at 2. In addition, plaintiff has not directéd the court’s attention to any evidence indicating that Commerce did not interpret Treasury’s actions in accordance with the presumption of administrative regularity. Rather, plaintiff argues merely that if the presumption had been applied the result would have been different. This is not a sufficient basis to reject Commerce’s remand determination.
II. Commerce’s Application of the 1976 Scope Determination Standard
The court’s remand opinion stated that if Treasury erred, Commerce may correct the antidumping scope determination by applying the law in effect in 1976. Bohler-Uddeholm Corp., 946 F.Supp. at 1010. The court further instructed Commerce that in 1976, Treasury applied a totality of the circumstances test which included, but was not limited, to the seven factors listed in Carborundum when making scope determinations.10 Id. at 1008. On remand, Commerce *1182determined that Treasury did not apply the test articulated by the court, but instead applied the standard articulated in Acrylic Sheet. Remand Results, at 4. Applying the Acrylic Sheet standard, Commerce determined that Stavax and Ramax, both forged and flat:rolled, are within the scope of the antidumping finding on stainless steel plate from Sweden. Id. at 19. Plaintiff argues that Commerce’s remand results are not in accordance with law and are unsupported by substantial evidence because: (1) Commerce applied the Acrylic Sheet factors instead of the Carborundum factors as directed by the court; (2) Commerce’s Acrylic Sheet analysis relied on its November 2, 1995 Diversified Products analysis; and (3) the remand results are not supported by substantial evidence. For the reasons that follow, we remand this issue to Commerce.
First, Commerce did not apply the scope determination standard articulated by the court in its remand opinion. The court clearly stated in Bohler-Uddeholm, that in 1976 Treasury applied the totality of the circumstances test articulated in Carborundum when making scope determinations. 946 F.Supp. at 1008. In the remand results, however, Commerce determined that in 1976, Treasury applied the four factor standard articulated in Acrylic Sheet which included only five of the seven Carborundum factors: “1) [t]he physical characteristics of the merchandise; 2) [t]he uses for which the merchandise is imported and the economic practicality of so using the import; 3) [t]he expectation of the ultimate purchasers; and 4) [t]he channels of trade in which the merchandise moves.” Remand Results, at 5. Moreover, Commerce explicitly noted that “Treasury clearly did not purport to consider either the environment of the sale or the recognition in the trade of the use for the merchandise in its analysis in Acrylic Sheet,” both factors included in the Carborundum test. Id.
The determination in Acrylic Sheet does not conclusively establish that the restricted approach of Acrylic Sheet was applied in all scope determinations in 1976. In fact, the court is not aware of another Treasury decision applying that standard. Instead, the evidence suggests .that Treasury could consider additional Carborundum factors as appropriate in each case. The language of the. Acrylic Sheet determination itself describes the four factors as “essential factors” to be used as “guidelines”, but does not explicitly limit Treasury to considering only these factors. See Acrylic Sheet; Def.’s App. at 46-47. Moreover, in Kyowa Gas Chemical Industry Co. v. United States, 7 CIT 138, 140, 582 F.Supp. 887, 889 (1984), the court considered the Acrylic Sheet finding and noted that the factors listed in the determination are “[a]mong the factors considered” by the agency making the scope determination. Id. (emphasis added)(citing Parts for Self-Propelled Bituminous Paving Equipment from Canada, 46 Fed.Reg. 47, 806, 47,807 (Dep’t Commerce 1981)(clarification of scope)(apply~ ing same factors in 1981 scope determination)).11 Thus, in 1976 Treasury looked at as many of the Carborundum factors as were appropriate to a particular case. By re*?strieting its analysis to only the four factors listed in Acrylic Sheet, and not considering whether the additional factors listed in Carborundum were appropriate in this case; Commerce did not comply with the court’s remand instructions.12
Moreover, the court must reject the remand results because they relied on the Diversified Products analysis of forged Stavax and Ramax conducted by Commerce in November 1995. On remand, Commerce explained its methodology for correcting the scope determination by stating that
[it] ha[s] re-examined the scope issue under the Acrylic Sheet standard. We note that this standard is very similar to the Diversified Products standard codified at 19 C.F.R. Sec. 353.29(i)[ (2) ], which we applied in our November 2, 1995 determination that Stavax and Ramax, when forged, are properly included within the scope of the finding. Because the Diversified and Acrylic Sheet analyses are so similar and we have already analyzed Stavax and Ramax under [Diversified Products ], it is appropriate, for these [] remand results, to provide a brief explanation of our Acrylic Sheet analysis herein.13
Remand Results, at 16-17. While Commerce explicitly relied in part on its 1995 determination for only two Acrylic Sheet factors, use and expectations of the purchasers, it is unclear if it conducted a new analysis or merely reworded the Diversified Products analysis for the other factors. See id. at 17-18.
The extent of Commerce’s reliance on the 1995 determination, however, need not be decided as any reliance would be unlawful. A proper Diversified Products analysis would compare the product in question to the entire class or kind of merchandise subject to the antidumping finding. Here, Commerce primarily relied on a comparison of forged Stavax and Ramax to flat-rolled Stavax and Ramax, instead of to the class or kind of merchandise, stainless steel plate. Passages from Commerce’s November 1995 Determination for each Diversified Product factor demonstrate the unlawful comparison. See November 1995 Determination; Pl.’s App., Tab 2, at 32-41. In its analysis of use, for example, Commerce stated:
Based on an analysis of the ultimate use of Stavax and Ramax, the Department concludes that Stavax and Ramax, when forged, have the same ultimate use as merchandise within the scope of the antidumping finding on stainless steel plate from Sweden, suck as flat[-] rolled Stavax and Ramax.
November 1995 Determination; Pl.’s App., Tab 2, at 39 (emphasis added).14
*1184Moreover, Commerce’s articulated reasoning for including Stavax and Ramax under the Diversified Products test further supports the conclusion that Commerce primarily compared forged Stavax and Ramax to flat-rolled Stavax and Ramax. First, Commerce implicitly relied on its original determination that flat-rolled Stavax and Ramax were within the- scope of the antidumping finding under the threshold dispositiveness test of 19 C.F.R. § 353.29(i)(l). See November 1995 Determination; Pl.’s App., Tab 2, at 30. Second, Commerce found that for many factors of the Diversified Products test, Bohler-Uddeholm could not distinguish between’ flat-rolled and forged Stavax and Ramax. See generally, id. at 33-41. Thus, as flat-rolled Stavax and Ramax were already within the scope of the antidumping finding and forged Stavax and Ramax were not distinguishable, Commerce concluded forged Stavax and Ramax must also be within the class or kind of merchandise.15 See id. Commerce’s reasoning suggests a comparison only to flat-rolled Stavax and Ramax and not to stainless steel plate.
Even if Commerce did not limit its comparison of forged Stavax and Ramax solely to flat-rolled Stavax and Ramax, its reasoning in the November 1995 Determination is flawed under the 1976 standards. Under the' 1976 standards, Treasury did not apply the current threshold dispositiveness test codified at 19 C.F.R. § 353.29(i). Bohler-Uddeholm Corp., 946 F.Supp. at 1009. Thus, Commerce’s reliance on the inclusion of flat-rolled Stavax and Ramax under the threshold test as a means of concluding that forged Stavax and Ramax are also inclüded, is not valid under the 1976 standards.
In addition, the November 1995 Determination relied on evidence not on the agency record in 1976. As this case concerns an error correction as to a twenty-year old scope ruling, permitting a new scope ruling based on new evidence and new policies would allow a fundamental change in the original definition of the class or kind of merchandise.16 This is not permitted. In its November 1995 Determination, Commerce relied on new evidence in its analysis of the expectations of purchasers by referring to evidence discussed in the physical characteristics factor. November 1995 Determination; Pl.’s App., Tab 2, at 38. As support for its findings on the physical characteristics of Stavax and Ramax, Commerce relied in part on letters from the domestic industry written in 1994 and 1995, affidavits from 1995, and technical sources from 1985 and 1990. Id. at 34-37. Commerce was instructed to apply the 1976 standards using the evidence before Treasury in 1976; it was not instructed simply to provide the same analysis the court *1185previously rejected.17
Thus, the court remands this ease to Commerce to apply the totality of the circumstances test as articulated in Carborundum by considering as many of the seven factors as are appropriate. Commerce is limited to the record before Treasury in 1976. Moreover, Commerce may not rely on (1) its prior determination that flat-rolled Stavax and Ra-max are within the scope of the antidumping finding based on the Diversified Products threshold test, (2) the November 1995 Diversified Products analysis for forged Stavax and Ramax, or (3) the Acrylic Sheet analysis provided in the first remand results.
Remand results are due within 30 days. Any objections shall be filed 11 days thereafter. Response, if any, is due within 5 days thereafter.