In December 2014, Commerce released its new list of surrogate countries for China. Neither Indonesia nor the Philippines are on the new list, meaning that Commerce and parties in China NME cases will face increasing difficulties in finding usable surrogate countries on the official list, outside of Thailand. Perhaps reflecting these new difficulties, Commerce has begun to allow more countries not on the list to serve as surrogate countries.

On 23 September 2013, the World Bank released its latest per capita Gross National Income (GNI) rankings for calendar year 2012. Countries that are “close” to China in per capita GNI (i.e., in reasonable proximity to the band fixed by the current surrogate countries) include the Philippines, Costa Rica, and Mexico.