Certain Tow Behind Lawn Groomers

INSTRUCTION BOOKLET
GENERAL INFORMATION, INSTRUCTIONS, AND
DEFINITIONS FOR COMMISSION QUESTIONNAIRES

TOW-BEHIND LAWN GROOMERS FROM CHINA
INV. NOS. 701-TA-457 AND 731-TA-1153 (FINAL)

Further information.--If you have any questions concerning the enclosed
questionnaire(s) or other matters related to these investigations, you may contact
the following members of the Commission=s staff:
Jennifer Merrill, Investigator (202-205-3188; E-mail [email protected])
regarding general questions and trade and related information.
Charles Yost, Auditor (202-205-3432; E-mail [email protected])
regarding financial information
Nancy Bryan, Economist (202-205-2088; E-mail [email protected])
regarding pricing, market, and related information

GENERAL INFORMATION
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

Background.--These investigations were instituted in response to a petition filed on June 24, 2008 by Agri-Fab,
Inc., Sullivan, IL, 61951. Countervailing and/or antidumping duties may be assessed on imports of
tow-behind lawn groomers (“TBLG”) from China as a result of these investigations if the U.S. International
Trade Commission (“Commission”) makes an affirmative determination of injury, threat, or material
retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative determination
of subsidization and/or dumping.
Questionnaires and other information pertinent to these investigations are available on the Commission’s
website (www.usitc.gov), by selecting the link to “antidumping and countervailing duty investigations” (on
the left-hand side of the home page) and then the link to “active investigations” (on the right-hand side of
the second page). Address all correspondence to the United States International Trade Commission, 500
E Street, SW, Washington, DC 20436. Hearing-impaired individuals can obtain information regarding
these investigations via the Commission=s TDD terminal (202-205-1810).
Due date of questionnaire(s).--Return the completed questionnaire(s) to the United States International Trade
Commission by no later than:

APRIL 16, 2009
Please make sure the completed questionnaire(s) is sent to the attention of Jennifer Merrill. Return only
one copy of the completed questionnaire(s), but please keep a copy for your records so that you can refer to
it if the Commission staff contacts you with any questions during the course of the investigations.
Service of questionnaire response(s).--In the event that your firm is a party to these investigations, you are
required to serve a copy of the questionnaire(s), once completed, on other parties to the proceeding that are
subject to administrative protective order (see 19 CFR ' 207.7). A list of such parties is maintained by the
Commission’s Secretary and may be obtained by calling 202-205-2000. A certificate of service must
accompany the copy of the completed questionnaire(s) you submit (see 19 CFR ' 207.7).
Confidentiality.--The commercial and financial data furnished in response to the enclosed questionnaire(s) that
reveal the individual operations of your firm will be treated as confidential by the Commission to the extent
that such data are not otherwise available to the public and will not be disclosed except as may be required
by law (see 19 U.S.C. ' 1677f). Such confidential information will not be published in a manner that will
reveal the individual operations of your firm; however, nonnumerical characterizations of numerical
business proprietary information (such as discussion of trends) will be treated as confidential business
information only at the request of the submitter for good cause shown.
Verification.--The information submitted in the enclosed questionnaire(s) is subject to audit and verification by
the Commission. To facilitate possible verification of data, please keep all your workpapers and supporting
documents used in the preparation of the questionnaire response(s).

DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

Release of information.--The information provided by your firm in response to the questionnaire(s), as well as
any other business proprietary information submitted by your firm to the Commission in connection with
the investigations, may become subject to, and released under, the administrative protective order
provisions of the Tariff Act of 1930 (19 U.S.C. ' 1677f) and section 207.7 of the Commission’s Rules of
Practice and Procedure (19 CFR ' 207.7). This means that certain lawyers and other authorized individuals
may temporarily be given access to the information for use in connection with these investigations or other
import-injury investigations conducted by the Commission on the same or similar merchandise; those
individuals would be subject to severe penalties if the information were divulged to unauthorized
individuals. In addition, if your firm is a U.S. producer, the information you provide on your production and
imports of TBLGs and your responses to the questions in Part I of the producer questionnaire will be
provided to the U.S. Department of Commerce, upon its request, for use in connection with (and only in
connection with) its requirement pursuant to section 702(c)(4)/732(c)(4) of the Act (19 U.S.C. '
1671a(c)(4)/1673a(c)(4)) to make a determination concerning the extent of industry support for the petition
requesting these investigations. Any information provided to Commerce will be transmitted under the
confidentiality and release guidelines set forth above. Your response to these questions constitutes your
consent that such information be provided to Commerce under the conditions described above.

INSTRUCTIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

Answer all questions.--Do not leave any question or section blank unless a questionnaire expressly directs you
to skip over certain questions or sections. If the answer to any question is “none,” write “none.” If
information is not readily available from your records in exactly the form requested, furnish
carefully prepared estimates--and indicate in the footnotes of the table(s) in which line items
estimates were used. Answers to questions and any necessary comments or explanations should be
supplied in the space provided or on separate sheets attached to the appropriate page of the questionnaire(s).
Consolidate all U.S. establishments.--Report the requested data for your establishment(s) located in the
United States. Firms operating more than one establishment should combine the data for all establishments
into a single report.
Electronic completion.--Your firm is encouraged to complete the questionnaire electronically in MS Word
format, although hand-written responses will be accepted. The MS Word version of the questionnaire(s) is
available online at the ITC web page for these investigations or directly from the Commission’s Investigator,
Jennifer Merrill (202-205-3188, [email protected]).

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

Tow-Behind Lawn Goomers (“TBLGs”).— This investigation covers certain non-motorized TBLGs
manufactured from any material, and certain parts thereof. TBLGs are defined as sweepers, aerators,
dethatchers, and spreaders. Unless specifically excluded, TBLGs that are designed to perform at least one
of the functions listed above are included in the scope of these investigations, even if the TBLG is designed
to perform additional non-subject functions (e.g., mowing). All TBLGs are designed to incorporate a hitch,
of any configuration, which allows the product to be towed behind a vehicle. TBLGs that are designed to
incorporate both a hitch and a push handle, of any type, are also covered by the scope of these investigations.
The hitch and handle may be permanently attached or removable, and they may be attached on opposite
sides or on the same side of the TBLG. TBLGs designed to incorporate a hitch, but where the hitch is not
attached to the TBLG, are also included in the scope of the investigations.
Tow-Behind Lawn Sweepers (“Sweepers”) consist of a frame, as well as a series of brushes attached
to an axle of shaft which allows the brushing component to rotate. Sweepers also include a container
(which is a receptacle into which debris swept from the lawn of turf is deposited) supported by the
frame.
Tow-Behind Lawn Aerators (“Aerators”) consist of a frame, as well as an aerating component that
is attached to an axle or shaft which allows the aerating component to rotate. The aerating component
is made up of a set of knives fixed to a plate (known as a “plug aerator”), a series of discs with
protruding spikes (a “spike aerator”), or any other configuration, that are designed to create holes or
cavities in a lawn or turf surface.
Tow-Behind Lawn Dethatchers (“Dethatchers”) consist of a frame, as well as a series of tines
designed to remove material (e.g., dead grass or leaves) or other debris from the lawn of turf. The
dethatcher tines are attached to and suspended from the frame.
Tow-Behind Lawn Spreaders (“Spreaders”) consist of a frame, as well as a hopper (i.e., a container
of any size, shape, or material) that holds a media to be spread on the lawn or turf. The media can be
distributed by means of a rotating spreader plate that broadcasts the media (“broadcast spreader”), a
rotating agitator that allows the media to be released at a constant rate (“drop spreader”) or any other
configuration.
Lawn dethatchers with a net fully– assembled weight (i.e., without packing, additional weights, or
accessories) of 100 pounds or less are covered by the scope of the investigations. Other lawn
groomers–sweepers, aerators, and spreaders–with a net fully–assembled weight (i.e., without packing,
additional weights, or accessories) of 200 pounds or less are covered by the scope of the investigations.
Also included in the scope of the merchandise subject to these investigations are any modular units,
consisting of a chassis that is designed to incorporate a hitch, where the hitch may or may not be
included, which allow modules that perform dethatching, aerating, sweeping, or spreading operations
to be interchanged. Modular units – when imported with one or more lawn grooming modules – with
a net fully-assembled weight (i.e. without packing, additional weights, or accessories) of 200 pounds
or less are covered by the scope of the investigations. Modular unit chasses, imported without a lawn
grooming module and with a fully assembled net weight (i.e. without packing, additional weights, or
accessories) of 125 pounds or less are covered by the scope of the investigations. When imported
separately, modules that are designed to perform subject lawn grooming functions (i.e., sweeping,
aerating, dethatching, or spreading), with a fully assembled net weight (i.e., without packing, additional
weights, or accessories) of 75 pounds or less, and that are imported with or without a hitch, are also

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

covered by the scope.
TBLGs, assembled or unassembled, are covered by these investigations. For purposes of these
investigations, “unassembled TBLGs” consist of either (1) all parts necessary to make a fully
assembled TBLG, or (2) any combination of parts, constituting a less than complete, unassembled lawn
groomer, with a minimum of two of the following “major components”:
1) an assembled or unassembled brush housing designed to be used in a lawn sweeper, where
a
brush housing is defined as a component housing the brush assembly, and consisting of a
wrapper which covers the brush assembly and two end plates attached to the wrapper;
2) a sweeper brush;
3) an aerator or dethatcher weight tray, or similar component designed to allow weights of any
sort to be added to the unit;
4) a spreader hopper;
5) a rotating spreader plate or agitator, or other component designed for distributing media in
a
lawn spreader;
6) dethatcher tines;
7) aerator spikes, plugs, or other aerating component; or
8) a hitch.
The major components or parts of TBLGs that are individually covered by these investigations
under the term ‘‘certain parts thereof’’ are: (1) brush housings, where the wrapper and end plates
incorporating the brush assembly may be individual pieces or a single piece; and (2) weight trays, or
similar components designed to allow weights of any sort to be added to a dethatcher or an aerator unit.
The products for which relief is sought specifically exclude the following: (1) agricultural
implements designed to work (e.g., churn, burrow, till, etc.) soil, such as cultivators, harrows, and
plows; (2) lawn or farm carts and wagons that do not groom lawns; (3) grooming products incorporating
a motor or an engine for the purpose of operating and/or propelling the lawn groomer; (4) lawn
groomers that are designed to be hand held or are designed to be attached directly to the frame of a
vehicle, rather than towed; (5) “push” lawn grooming products that incorporate a push handle rather
than a hitch, and which are designed solely to be manually operated; (6) dethatchers with a net
assembled weight (i.e., without packing, additional weights, or accessories) of more than 100 pounds,
or lawn groomers–sweepers, aerators, and spreaders–with a net fully–assembled weight (i.e., without
packing, additional weights, or accessories) of more than 200 pounds; and (7) lawn rollers designed to
flatten grass and turf, including lawn rollers which incorporate an aerator component (e.g.,
“drum–style” spike aerators).
The TBLGs that are the subject of these investigations are currently classifiable in the Harmonized
Tariff Schedule of the United States (‘‘HTSUS’’) statistical reporting numbers 8432.40.0000,
8432.80.0000, 8432.80.0010, 8432.90.0030, 8432.90.0080, 8479.89.9896, 8479.89.9899,
8479.90.9496, and 9603.50.0000. These HTSUS provisions are given for reference and customs
purposes only, and the description of merchandise is dispositive for determining the scope of the
product included in these investigations. If your firm is an importer of the subject merchandise as
defined and imports these products under provisions of the HTSUS other than the HTS numbers

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

previously noted, please indicate in your questionnaire response the applicable additional or separate
statistical reporting numbers of the HTSUS.

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

Tow-Behind Carts.-- Tow-behind carts are designed to haul items that are placed into them. Such items cover
a variety of materials including mulch, fertilizer, wood, and debris picked up from the yard. Unlike TBLGs,
carts do not perform a lawn grooming function. For example, materials hauled in a cart are physically
placed into the cart by individuals whereas TBLG sweepers are designed to sweep up debris when passed
over the lawn. Tow-behind carts are generally used as necessary throughout the year, depending on the
required utility. Tow-behind carts have the appearance of a wagon but with an apparatus for towing behind
a lawn tractor, all terrain vehicle, utility type vehicle, riding lawn mower, or similar vehicle. The carts may
be two- or four-wheelers and designed for manual unloading or with a dumping mechanism to make
unloading and cleaning easier. Tow-behind carts come in a variety of bed (hauling area) sizes, generally
ranging from 30"wide x 45" long x12" high to 34" wide x 60" long x 15" high.
Firm.--An individual proprietorship, partnership, joint venture, association, corporation (including any
subsidiary corporation), business trust, cooperative, trustee in bankruptcy, or receiver under decree of any
court.
Related firm.--A firm that your firm solely or jointly owned, managed, or otherwise controlled; a firm that
solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm that was solely or jointly
owned, managed, or otherwise controlled by a firm that also solely or jointly owned, managed, or otherwise
controlled your firm.
Establishment.--Each facility of a firm in the United States involved in the production, importation, and/or
purchase of TBLGs (as defined above), including auxiliary facilities operated in conjunction with (whether
or not physically separate from) such facilities.
United States.--For purposes of this investigation, the 50 States, Puerto Rico, the U.S. Virgin Islands, and the
District of Columbia.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in importing
TBLGs (as defined above) into the United States from a foreign manufacturer or through its selling agent.
Imports.--Those products identified for Customs purposes as imports for consumption for which your firm was
the importer of record (i.e., was responsible for paying any import duty) or consignee (i.e., to which the
merchandise was first delivered).
Import quantities.--Quantities reported should be net of returns.
Import values.--Values reported should be landed, duty-paid values at the U.S. port of entry, including
ocean freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland
freight in the United States).
Purchaser.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
purchasing TBLGs (as defined above) from another firm that produces, imports, or otherwise distributes
TBLGs. A retail firm that is the importer of record may be considered a purchaser.
Purchases.--Purchases from all sources, not including direct imports from foreign producers (which should be
reported as imports in a U.S. importers’ questionnaire).
Purchase quantities.--Quantities reported should be net of returns.

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

Purchase values.--Values reported should be net values (i.e., gross purchase values less all discounts,
allowances, rebates, and the value of returned goods), delivered to your U.S. receiving point.

Shipments.--Shipments of products produced in or imported by your U.S. establishment(s). Include shipments
to the contracting firm of product produced by your firm under a toll agreement.
Shipment quantities.--Quantities reported should be net of returns.
Shipment values.--Values reported should be net values (i.e., gross sales values less all discounts,
allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your U.S. point of shipment.
The value of domestic shipments to the contracting firm under a toll agreement is the conversion fee
(including profit).
Types of shipments:
U.S. shipments.--Commercial shipments, internal consumption, and transfers to related firms within the
United States.
Commercial shipments.--Shipments, other than internal consumption and transfers to related firms, within
the United States.
Internal consumption.--Product consumed internally by your firm.
Transfers to related firms.--Shipments made to related domestic firms.
Export shipments.--Shipments to destinations outside the United States, including shipments to related
firms.
Inventories.--Finished goods inventory, not raw materials or work-in-progress.
The following definitions apply only to the U.S. PRODUCERS’ QUESTIONNAIRE:
Average production capacity.--The level of production that your establishment(s) could reasonably have
expected to attain during the specified periods. Assume normal operating conditions (i.e., using equipment
and machinery in place and ready to operate; normal operating levels (hours per week/weeks per year) and
time for downtime, maintenance, repair, and cleanup; and a typical or representative product mix).
Toll agreement.--Agreement between two firms whereby the first firm furnishes the raw materials and the
second firm uses the raw materials to produce a product that it then returns to the first firm with a charge for
processing costs, overhead, etc.
Production.--All production in your U.S. establishment(s), including production consumed internally within
your firm and production for another firm under a toll agreement.
PRWs.--Production and related workers (“PRWs”), including working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling, inspecting,
receiving, storage, handling, packing, warehousing, shipping, trucking, hauling, maintenance, repair,
janitorial and guard services, product development, auxiliary production for plant=s own use (e.g., power

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-457 and 731-TA-1153, TBLGs from China (Final))

plant), recordkeeping, and other services closely associated with the above production operations.
Average number employed.--Add the number of employees, both full-time and part-time, for the 12 pay
periods ending closest to the 15th of the month and divide that total by 12. For the January-March periods,
calculate similarly and divide by 3.
Hours worked.--Include time paid for sick leave, holidays, and vacation time. Include overtime hours actually
worked; do not convert overtime pay to its equivalent in straight-time hours.
Wages paid.--Total wages paid before deductions of any kind (e.g., withholding taxes, old-age and
unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid directly by your
firm for overtime, holidays, vacations, and sick leave.
Fiscal year.--The 12-month period between settlement of your firm=s financial accounts.
Purchases other than direct imports.--Purchases from U.S. producers, U.S. importers, and other U.S. sources,
excluding direct imports (which should be reported as imports in a U.S. importers’ questionnaire).

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