09-1-2738 U.S. Producer questionnaire

OMB No. 3117-0016/USITC No. 09-1-2738; Expiration Date: 6/30/11
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN TOW BEHIND LAWN GROOMERS (“TBLGs”) FROM CHINA

Please return the completed questionnaire to the Commission by April

16, 2008

See page 4 of the Instruction Booklet for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty investigation and its antidumping investigation concerning certain tow behind
lawn groomers and parts thereof (“TBLGs”) from China (Inv. Nos. 701-TA-457 and 731-TA-1153 (Final)). The
information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This report
is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of records or
information in your possession (19 U.S.C. § 1333(a)).

Name of firm
Address
State

City

Zip Code

World Wide Web address
Has your firm produced at least one of the four types of TBLGs (as defined in the instruction booklet) at any time
since January 1, 2006?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Read the instruction booklet carefully, complete all parts of the questionnaire, and return the entire
questionnaire to the Commission so as to be received by the date indicated above)

CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my knowledge and
belief and understand that the information submitted is subject to audit and verification by the Commission.
By means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the information
provided in this questionnaire and throughout this investigation in any other import-injury investigations conducted by the Commission
on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout this investigation may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of this investigation or related proceedings for which this information is submitted, or in internal audits and
investigations relating to the programs and operations of the Commission pursuant to 5 U.S.C. Appendix 3. I understand that all contract
personnel will sign non-disclosure agreements.

I AGREE TO THE ABOVE CERTIFICATION

Name of Authorized Official

Title of Authorized Official

Date

Signature

Phone: (
Fax ( )

E-mail address

)

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

Page 2

PART I.—GENERAL INFORMATION
The questions in this questionnaire have been reviewed with market participants to ensure that issues of
concern are adequately addressed and that data requests are sufficient, meaningful, and as limited as
possible. Public reporting burden for this questionnaire is estimated to average 50 hours per response,
including the time for reviewing instructions, searching existing data sources, gathering the data needed,
and completing and reviewing the questionnaire. Send comments regarding the accuracy of this burden
estimate or any other aspect of this collection of information, including suggestions for reducing the
burden, to the Office of Investigations, U.S. International Trade Commission, 500 E Street, SW,
Washington, DC 20436.
I-1a.

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of preparing the reply to this questionnaire and completing the form.
hours

dollars

I-1b.

OMB feedback.--We are interested in any comments you may have for improving this
questionnaire in general or the clarity of specific questions. Please attach such comments to your
response or send them to the above address.

I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire (see the instruction booklet for reporting guidelines). If your firm is publicly
traded, please specify the stock exchange and trading symbol.

I-3.

Petition support.--Do you support or oppose the petition?
Support

Oppose

Take no position

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART I.--GENERAL INFORMATION--Continued
I-4.

Ownership.--Is your firm owned, in whole or in part, by any other firm?
No

Firm name

I-5.

Address

Extent of
ownership

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, which are engaged in importing TBLGs from China into the United States or which are
engaged in exporting TBLGs from China to the United States?
No
Firm name

I-6.

Yes--List the following information

Yes--List the following information
Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, which
are engaged in the production of TBLGs?
No
Firm name

Yes--List the following information
Address

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

Page 4

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jennifer Merrill (202-2053188, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information (Trade).--Who should be contacted regarding the requested trade and
related information?
Company contact:
Name and title
(
)
Phone number

II-2.

E-mail address

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of TBLGs since January 1, 2006?
(check as many as appropriate)
plant openings ..........................

plant closings............................

relocations ................................

expansions ................................

acquisitions...............................

consolidations...........................

prolonged shutdowns or
production curtailments .................
other..........................................

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

Page 5

PART II.--TRADE AND RELATED INFORMATION--Continued
II-3.

Shared production equipment and workers.--Does your firm produce other products on the
same equipment and machinery used in the production of TBLGs and/or does your firms produce
other products using the same production and related workers (“PRWs”) employed to produce
TBLG?
No, neither

Yes--List the following information.

Products

Share of total
production on same
equipment in 20081
(percent)

Share of total
production using
same PRWs in 20081
(percent)

TBLGs
Tow-behind carts
Other:
Other:
Other:
1

Please indicate the basis for allocation (e.g., sales):

II-4.

Production constraints and product shifting.--Please describe the constraint(s) that set the
limit(s) on your production capacity and your ability to shift production capacity between
products.

II-5.

Tolling.--Since January 1, 2006, has your firm been involved in a toll agreement (see definition
in the instruction booklet) regarding the production of TBLGs?
No

II-6.

.

FTZs.--Does your firm produce TBLGs in a foreign trade zone (FTZ)?
No

II-7.

Yes--Name firm(s):

.

Yes--Identify FTZ(s):

Importer.--Since January 1, 2006, has your firm imported TBLGs?
No

Yes--COMPLETE AND RETURN A U.S. IMPORTERS’
QUESTIONNAIRE

.

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

Page 6

PART II.--TRADE AND RELATED INFORMATION--Continued
II-8.

Comparability of TBLGs and tow behind carts and/or push lawn groomers.–Please describe
the differences and similarities between TBLGs and tow behind carts and/or push lawn
groomers with respect to the following factors: (a) characteristics and uses--describe the
differences and similarities in the physical characteristics and end uses; (b) interchangeability-discuss the extent to which the products are interchangeable in the same end uses; (c)
manufacturing processes--describe the processes and include a discussion of the
interchangeability of production inputs, machinery and equipment, and skilled labor used to
produce the different products; (d) channels of distribution--describe the specific end
use/customer requirements and channels of distribution/market situation in which the products are
sold; (e) customer and producer perceptions--describe any perceived differences in the
products (e.g., sales/marketing practices); and (f) price--provide a discussion and specific
examples of prices for the products. Use additional pages as necessary.
(a) Characteristics and uses:

(b) Interchangeability:

(c) Manufacturing processes:

(d) Channels of distribution:

(e) Customer and producer perceptions:

(f) Price:

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-9.

Trade Data.--Report your firm’s production capacity, production, shipments, inventories, and
employment related to the production of TBLGs in your U.S. establishment(s) during the
specified periods. (See definitions in the instruction booklet.)
Quantity (in units) and value (in $1,000)
Calendar years
Item

2006

2007

January-March
2008

2008

2009

1

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value2 (G)
Transfers to related firms:
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Channels of distribution:
U.S. shipments to distributors (quantity) (M)
U.S. shipments to end users (quantity) (N)
Employment data:
Average number of PRWs (number) (O)
Hours worked by PRWs (1,000 hours) (P)
Wages paid to PRWs (value) (Q)
1

The production capacity (see definitions in instruction booklet) reported is based on operating
hours per week,
weeks per year. Please describe the methodology used to calculate production capacity, and explain any changes in
reported capacity (use additional pages as necessary).
2

Internal consumption and transfers to related firms must be valued at fair market value. In the event that you use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data
using that basis for 2006, 2007, and 2008 below:
3

Identify your principal export markets:

II-10.

.

Reconciliation of trade data.--Please note that the quantities reported in question II-8 should
reconcile as follows in each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L
D+F+H=M+N

Do these data reconcile?
explain
Do these data reconcile?
explain

Yes

No--Please

Yes

No--Please

.
.

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-11.

Related firms.--If you reported transfers to related firms in question II-9, please indicate the
nature of the relationship between your firm and the related firms (e.g., joint venture, wholly
owned subsidiary), whether the transfers were priced at market value or by a non-market formula,
whether your firm retained marketing rights to all transfers, and whether the related firms also
processed inputs from sources other than your firm.

II-12.

Purchases.--Other than direct imports where your firm served as the importer of record, has your
firm otherwise purchased domestic or imported TBLGs since January 1, 2006? (See definitions
in the instruction booklet.)
Yes--Report such purchases below for the specified periods.1

No

(Quantity in units, value in $1,000)
Calendar years
Item

2006

2007

January-March
2008

2008

2009

PURCHASES OF IMPORTED2 TBLGs
FROM-China:
Quantity
Value
All other countries:
Quantity
Value
PURCHASES OF DOMESTICALLY
3
PRODUCED TBLGs:
Quantity
Value
PURCHASES OF TBLGs ORIGIN
UNKNOWN:4
Quantity
Value
1

Please indicate your reasons for purchasing this product. If your reasons differ by source, please elaborate.

2

Imported product.--Please list the name of the firm(s) from which you purchased the imported product.

3

Domestic product.--Please list the name of the firm(s) from which you purchased this product and the U.S.
producers who produced the product if different.
4

Unknown origin.--Please list the name of the firm(s) from which you purchased this product.

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

Page 9

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202-205-3432,
[email protected]).
III-1.

Contact information (Financial).--Who should be contacted regarding the requested financial
information?
Company contact:
Name and title
(
)
Phone number

III-2.

E-mail address

Accounting system.--Briefly describe your financial accounting system.
A.

When does your fiscal year end (month and day)?
If your fiscal year changed during the period examined, explain below:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include subject merchandise:

2.
3.

4.

Does your firm prepare profit/loss statements for the subject merchandise:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
(specify)

Note.-- The Commission may request that your company submit copies of its financial statements,
including internal profit-and-loss statements for the division or product group that includes
TBLGs, as well as those statements and worksheets used to compile data for your firm’s
questionnaire response.

III-3.

Cost accounting system.--Briefly describe your cost accounting system (e.g., standard cost, job
order cost, etc.).

III-4.

Allocation basis.--Briefly describe your allocation basis, if any, for COGS, SG&A, and interest
expense and other income and expenses.

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART III.--FINANCIAL INFORMATION--Continued
III-5.

Other products.--Please list any other products you produced in the facilities in which you
produced TBLGs, and provide the share of net sales accounted for by these other products in your
most recent fiscal year:
Share of net sales
value in 20081
(percent)

Products
TBLGs
Carts
Other:
Other:
Other:

III-6.

Raw materials from related firms.--Does your firm receive inputs (raw materials, labor, energy,
or any other services) used in the production of TBLGs from any related firm?
Yes--Continue to question III-7 below.

III-7.

Inputs from related firms.--In the space provided below, identify the inputs related to the
production of TBLGs that your firm receives from related parties.
Input

III-8.

No--Continue to question III-10 below.

Related party

Related firms’ financials.--With respect to the related companies identified in response to
question III-7 above, are their financial statements consolidated with your firm’s financial
statements? (In other words, are profits or losses arising from intercompany transactions
eliminated?
Yes--Continue to question III-9 below.

No--Continue to question III-10 below.

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART III.--FINANCIAL INFORMATION--Continued
III-9.

Inputs from related firms at cost.--All intercompany profit on inputs purchased from related
parties that is eliminated pursuant to formal financial statement consolidation should also be
eliminated from the costs reported to the Commission in question III-11 (i.e., costs reported in
question III-11, to the extent that they reflect inputs purchased from related parties, should only
reflect the related party’s cost and not include an associated profit component). Reasonable
methods for determining and eliminating the associated profit on inputs purchased from related
parties are acceptable.
Has your firm complied with the Commission’s instructions regarding costs associated with
inputs purchased from related parties?
Yes

No.

III-10. Nonrecurring charges.--For each annual and interim period for which financial results are
reported in question III-11, please indicate in the schedule below the specific nonrecurring
charges, the particular expense/cost line items from question III-11 where the associated charges
are included, a brief description of the charges, and the associated values (in $1,000).
Nonrecurring charges would include, but are not limited to, items such as asset write-offs and
accelerated depreciation due to restructuring of the company’s TBLG operations.
Fiscal years ended-Item
Non-recurring charges: (In this column please
provide a brief description of each nonrecurring
charge and indicate the particular expense/cost line
items where the associated charges are included in
question III-11.)
1.
2.
3.
4.
5.
6.
7.

January-March
2008

2009

Business Proprietary
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PART III.--FINANCIAL INFORMATION--Continued
III-11. Operations on TBLGs.--Report the revenue and related cost information requested below on the
TBLG operations of your U.S. establishment(s).1 Do not report resales of products. Note that
internal consumption and transfers to related firms must be valued at fair market value and
purchases from related firms must be at cost.2 Provide data for your three most recently
completed fiscal years in chronological order from left to right, and for the specified interim
periods. If your firm was involved in tolling operations (either as the toller or as the tollee) please
contact Charles Yost at (202-205-3432, [email protected]) before completing this section
of the questionnaire.
Quantity (in units) and value (in $1,000)
Fiscal year ending
Item

January-March
2008

2009

Net sales quantities:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):4
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other income and expenses:
Interest expense
All other expense items
All other income items
All other income or expenses, net
Net income or (loss) before income taxes
Depreciation/amortization included above
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Please list the expense categories and amounts of any profits on internal inputs or inputs from related firms that are reflected on
your books but which are eliminated from the costs reported below.
3
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
4
COGS should include costs associated with internal consumption and transfers to related firms.
2

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART III.--FINANCIAL INFORMATION--Continued
III-12. Asset values.--Report the total assets associated with the production, warehousing, and sale of
TBLGs. If your firm does not maintain some or all of the specific asset data in the normal course
of business, please estimate it based upon some rational method (such as production, sales, or
costs) that is consistent with your cost allocations in the previous question. Your finished goods
inventory value should reconcile with the inventory quantity data reported in Part II. Provide data
as of the end of your three most recently completed fiscal years in chronological order from left
to right.
Fiscal year ending
Item
Assets associated with the production,
warehousing, and sale of product:
1. Current assets:
A. Cash and equivalents
B. Accounts receivable, net
C. Inventories (finished goods)
D. Inventories (raw materials and work in process)
E. Other (describe:

)

F. Total current assets (lines 1.A. through 1.E.)
2. Property, plant, and equipment
A. Original cost of property, plant, and equipment
B. Less: Accumulated depreciation
C. Equals: Book value of property, plant, and
equipment
3. Other (describe:

)

4. Total assets (lines 1.F., 2.C. and 3)

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on TBLGs. Provide data for your three
most recently completed fiscal years in chronological order from left to right, and for the
specified interim periods.
Value (in $1,000)
Fiscal year ending
Item
Capital expenditures
Research and development expenses

January-March
2008

2009

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Page 14

PART III.--FINANCIAL INFORMATION--Continued
III-14. Effects of imports.--Since January 1, 2006, has your firm experienced any actual negative effects
on its return on investment or its growth, investment, ability to raise capital, existing development
and production efforts (including efforts to develop a derivative or more advanced version of the
product), or the scale of capital investments as a result of imports of TBLGs from China?
No

Yes--My firm has experienced actual negative effects as follows:
Cancellation, postponement, or rejection of expansion projects
Denial or rejection of investment proposal
Reduction in the size of capital investments
Rejection of bank loans
Lowering of credit rating
Problem related to the issue of stocks or bonds
Other (specify)

III-15. Anticipated effects of imports.--Does your firm anticipate any negative impact of imports of
TBLGs from China?

Business Proprietary
U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

Page 15

PART IV.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nancy Bryan (202-205-2088,
[email protected])
IV-1.

Contact information (Price).--Who should be contacted regarding the requested pricing and
related information?
Company contact:
Name and title
(
)
Phone number

E-mail address

PRICE DATA
This section requests quarterly quantity and value data, f.o.b. your U.S. point of shipment, for your
commercial shipments to unrelated U.S. customers during January 2006 – March 2009 of the following
products produced by your firm.
Product 1.--Lawn Sweeper: 38 inch (nominal housing width) "standard" sweeper; or a lawn
sweeper with the following characteristics: cantilever bag, steel frame, and brush width of 37
inches or less.
Product 2.--Lawn sweeper: 42 inch (nominal housing width) "standard" sweeper; or a lawn
sweeper with the following characteristics: cantilever bag, steel frame, brush width 41 inches or
less.
Product 3.--Lawn Sweeper: 42 inch (nominal housing width) "heavy duty" sweeper; or a lawn
sweeper with the following characteristics: cantilever bag, steel frame, brush width 41 inches or
less.
Product 4.--Aerator: 40 inch (nominal tray width) plug type; or a lawn aerator with the following
characteristics: steel frame tray width of 39 to 41 inches, plug width of approximately 39 inches.
Product 5.--Aerator: 48 inch (nominal tray width) plug type; or a lawn aerator with the following
characteristics: steel frame tray width of 47 to 49 inches, plug width of approximately 47 inches.
Product 6.--Spreader: Broadcast type, plastic hopper, 125 pound capacity (14 gallon dry)
(nominal hopper capacity).
Product 7.--Dethatcher: 40 inch (nominal tray width) tine dethatcher; or a lawn dethatcher with
the following characteristics: steel frame, tray width of 39 to 43 inches, tine assembly width of
38.5 to 42.5 inches.
Note.--Total dollar values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Total dollar values should reflect the final net amount paid to you (i.e., should be net
of all deductions for discounts or rebates). See instruction booklet.

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PART IV.--PRICING AND RELATED INFORMATION--Continued
Pricing data.--Report quarterly price data1 for pricing products2 produced and sold by your firm.

IV-2.

Period of
shipment
2006:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2007:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2008:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2009:
Jan-Mar
Period of
shipment
2006:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2007:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2008:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2009:
Jan-Mar
1

Quantity (in units) and value (in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

Product 4
Quantity
Value

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.
2
Pricing product definitions are provided on the first page of section IV.

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-2.

Pricing data.--Continued.

Period of
shipment
2006:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2007:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2008:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2009:
Jan-Mar
Period of
shipment
2006:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2007:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2008:
Jan-Mar
Apr-Jun
Jul-Sep
Oct-Dec
2009:
Jan-Mar
1

Quantity (in units) and value (in dollars)
Product 5
Product 6
Quantity
Value
Quantity
Value

Product 7
Quantity
Value

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.
2
Pricing product definitions are provided on the first page of section IV.

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U.S. Producers’ Questionnaire - TBLGs from China (701-TA-457 and 731-TA-1153 (Final))

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-3.

Price setting.-- How does your firm determine the prices that it charges for sales of TBLGs
(check all that apply)? If your firm issues price lists, please include a copy of a recent price list
with your submission. If your price list is large, please only submit some sample pages.
Transaction by transaction

Contracts

Set price lists

Other--Please describe:

IV-4.

Discount policy.-- Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity discounts

Annual total volume discounts

No discount policy

Other--Please describe:

IV-5.

IV-6.

Pricing terms for TBLGs.-(a)

What are your firm’s typical sales terms for its U.S.-produced TBLGs (e.g., 2/10 net 30
days)?
.

(b)

On what basis are your prices of domestic TBLGs usually quoted? (check one)
F.o.b.--Please specify point:
Delivered

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
TBLGs in 2008 were on a (1) long-term contract basis (multiple deliveries for more than 12
months), (2) short-term contract basis (multiple deliveries up to and including 12 months), and (3)
spot sales basis (for a single delivery)?
Type of sale
Long-term contracts
Short-term contracts
Spot sales

Share of sales (percent)

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-7.

IV-8.

IV-9.

Long-term contact provisions.--If you sell on a long-term contract basis, please answer the
following questions with respect to provisions of a typical long-term contract.
(a)

What is the average duration of a contract?

(b)

Can prices be renegotiated during the contract period?

(c)

Does the contract fix quantity, price, or both?

(d)

Does the contract have a meet or release provision?

Yes

Quantity

No
Price

Yes

Both
No

Short-term contract provisions.--If you sell on a short-term contract basis, please answer the
following questions with respect to provisions of a typical short-term contract.
(a)

What is the average duration of a contract?

(b)

Can prices be renegotiated during the contract period?

(c)

Does the contract fix quantity, price, or both?

(d)

Does the contract have a meet or release provision?

Yes

Quantity

No
Price

Yes

Both
Not

Lead times.--What is the average lead time between a customer’s order and the date of delivery
for your firm’s sales of your U.S.-produced TBLGs?

Source

Share of sales,
2008

Lead time

From inventory
Produced to order
Total

100 %

IV-10. Shipping information.-(a)

What is the approximate percentage of the total delivered cost of TBLGs that is
accounted for by U.S. inland transportation costs?
percent.

(b)

Who generally arranges the transportation to your customers’ locations? (check one)
Your firm
or purchaser

(c)

What proportion of your sales occur within 100 miles of your production facility?
percent. Within 101 to 1,000 miles?
percent. Over 1,000 miles?
percent.

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Page 20

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-11. Substitutes.--Please list in order of importance any products that may be substituted for TBLGs.
For each possible substitute product, please give examples of applications and end uses for which
they are substitutes (including whether the substitute applies specifically to a type of TBLG) and
indicate whether changes in the price of the substitute affect the price for TBLGs, and to what
degree, the length of any time lag of such an effect.

Substitute

Description / End use

Have changes in the prices of this
substitute affected the price for TBLGs?

1.

No

Yes--Please explain.

2.

No

Yes--Please explain.

3.

No

Yes--Please explain.

4.

No

Yes--Please explain.

5.

No

Yes--Please explain.

IV-12. Demand trends.-(a)

How has the demand within the United States for TBLGs changed since January 1, 2006?
What principal factors affect changes in demand?
Increase

(b)

No Change

Decrease

Fluctuated

How has the demand outside the United States (if known) for TBLGs changed since
January 1, 2006? What principal factors affect changes in demand?
Increase

No Change

Decrease

Fluctuated

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-13. Product/marketing changes.--Have there been any significant changes in the product range or
marketing of TBLGs since January 1, 2006?
No

Yes--Please describe.

IV-14. Are different types of TBLGs (i.e., aerators, lawn sweepers, spreaders, and dethatchers) marketed
and/or sold together in the U.S. market?
No

Yes-- Please explain, noting which types of TBLGs have been marketed or
sold together and how prices are determined (i.e., each type of TBLG
priced separately, or different types of TBLGs priced in combination or as
sets).

IV-15. Raw materials.--Please identify the major raw materials used in your firm’s production of
TBLGs, the approximate percentage change in the cost of each raw material since January 1,
2006, and the share of your firm’s total raw material costs for TBLG production in 2008
accounted for by each raw material. If raw materials differ between type of TBLG, please
indicate as much.

Raw material
1.
2.
3.
4.
5.
6.

Change in
cost since
2006
(percent)

Estimated share of
total raw material
cost for TBLG
production in 2008
(percent)

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Page 22

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-16. Geographical shipments.—Please indicate the percentage share of your firm’s U.S. shipments in
2008, as reported in response to question II-8 above. Please indicate the percentage share that
was shipped to each of the following geographic markets. Please base your responses to this
question on the ultimate delivery destinations for sales to customers in the United States.

Geographic area

Share of U.S.
shipments in 2008
(in percent)

Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed, including AK, HI,
PR, VI, among others.
Note.--These shares should be calculated from all reported U.S. shipments in 2008 (lines D, F, and H) from question II8.

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Page 23

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-17. Interchangeability.--Are TBLGs produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)? Please indicate
below, using “A” to indicate that the products from a specified country-pair are always
interchangeable, “F” to indicate that the products are frequently interchangeable, “S” to indicate
that the products are sometimes interchangeable, “N” to indicate that the products are never
interchangeable, and “0” to indicate no familiarity with products from a specified country-pair.1
Other countries (specify)-Country-pair

China

United States
China
1

For any country-pair producing TBLGs which are sometimes or never interchangeable, please explain
the factors that limit or preclude interchangeable use:

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Page 24

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-18. Differences other than price.--Are differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between TBLGs produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate below, using “A” to indicate that such differences are always significant, “F” to
indicate that such differences are frequently significant, “S” to indicate that such differences are
sometimes significant, “N” to indicate that such differences are never significant, and “0” to
indicate no familiarity with products from a specified country-pair.1
Other countries (specify)-Country-pair

China

United States
China
1

For any country-pair for which factors other than price are always or frequently a significant factor in
your firm’s sales of TBLGs, identify the country-pair and report the advantages or disadvantages imparted
by such factors:

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Page 25

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-19. Major Customers.-- Please provide the names and addresses of your firm’s ten (10) largest
customers of TBLGs during January 2006-March 2009. Please also provide the name and
telephone number of a contact person and the share of the quantity of your firm’s total shipments
of TBLGs that each of these suppliers accounted for in 2008.

No.

1

2

3

4

5

6

7

8

9

10

Customer’s name

Street address (not P.O.
box), city, state, and zip
code

Contact person (name and
e-mail address)

Share of
2008
sales
(percent)

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Page 26

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-20. COMPETITION FROM IMPORTS--LOST REVENUES.--THIS SECTION IS TO BE
COMPLETED ONLY BY NON-PETITIONERS. (Note: petitioners may provide allegations
involving quotes made after the filing of the petition.)
Since January 1, 2006: To avoid losing sales to competitors selling TBLGs from China, did your
firm:
Reduce prices

No

Yes

Roll back announced price increases

No

Yes

If yes, please furnish as much of the following information as possible for each affected
transaction. Document such allegations of lost revenues whenever possible (documentation could
include copies of invoices, sales reports, or letters from customers). Please note that the
Commission may contact the firms named to verify the allegations reported.
Customer name, contact person, phone and fax numbers
Specific product(s) involved
Date of your initial price quotation
Quantity involved
Your initial rejected price quotation (total delivered value)
Your accepted price quotation (total delivered value)
The country of origin of the competing imported product
The competing price quotation of the imported product (total delivered value)
Customer name,
contact person,
phone and fax
numbers

Product

Date of
quote

Quantity
(units)

Initial
rejected U.S.
price (total
value-dollars)

Accepted
U.S. price
(total value-dollars)

Country of
origin

Competing
import price
(total
value—
dollars)

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-21. COMPETITION FROM IMPORTS--LOST SALES.--THIS SECTION IS TO BE
COMPLETED ONLY BY NON-PETITIONERS. (Note: petitioners may provide allegations
involving quotes made after the filing of the petition.)
Since January 1, 2006: Did your firm lose sales of TBLGs to imports of these products from
China?
No

Yes

If yes, please furnish as much of the following information as possible for each affected
transaction. Document such allegations of lost sales whenever possible (documentation could
include copies of invoices, sales reports, or letters from customers). Please note that the
Commission may contact the firms named to verify the allegations reported.
Customer name, contact person, phone and fax numbers
Specific product(s) involved
Date of your price quotation
Quantity involved
Your rejected price quotation (total delivered value)
The country of origin of the competing imported product
The accepted price quotation of the imported product (total delivered value)
Customer name,
contact person,
phone and fax
numbers

Product

Date of
quote

Quantity
(units)

Rejected
U.S. price
(total value-dollars)

Country of
origin

Competing
import price
(total
value—
dollars)

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Page 28

PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jennifer Merrill (202-2053188, [email protected]). Supply all data requested on a calendar-year basis (except
financial data may be reported on a fiscal year basis).
V-1.

Contact information (Alternative Products).--Who should be contacted regarding the requested
trade and related information?
Company contact:
Name and title
(
)
Phone number

V-2.

E-mail address

Effects of imports.--Since January 1, 2006, has your firm experienced any actual negative effects
on its return on investment or its growth, investment, ability to raise capital, existing development
and production efforts (including efforts to develop a derivative or more advanced version of the
four types of TBLGs), or the scale of capital investments as a result of imports of any of the four
types of TBLGs from China?
Aerators

Cancellation, postponement, or
rejection of expansion projects
Denial or rejection of investment
proposal
Reduction in the size of capital
investments
Rejection of bank loans
Lowering of credit rating
Problem related to the issue of
stocks or bonds
Other, specify:

.

Dethatchers

Spreaders

Sweepers

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Page 29

PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-3a.

Alternative Product Data.--Report the information on your firm’s operations relating to
Aerators in your U.S. establishment(s) during the specified periods. (See definitions in the
instruction booklet.)

Tow-Behind Aerators
Quantity (in units) and value (in $1,000)
Calendar years
Item

2006

2007

January-March
2008

2008

2009

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value1 (G)
Transfers to related firms:
Quantity (H)
Value1 (I)
Export shipments:
Quantity of export shipments (J)
Value of export shipments (K)
End-of-period inventories (quantity) (L)
Employment data:
Average number of PRWs (number) (M)
Hours worked by PRWs (1,000 hours) (N)
Wages paid to PRWs (value) (O)
Financial Data2
Net Sales:
3
Quantity (P)
Value (Q)
Cost of goods sold (value) (R)
Gross profit or (loss) (value) (S)
Selling, general, and administrative
expenses (value) (T)
Operating income or (loss) (value) (U)
Capital expenditures (value) (V)
1

Internal consumption and transfers to related firms must be valued at fair market value.
If reporting financial data for fiscal year not ending on December 31, please indicated (year ending:
3
Including internal consumption and transfers to related firms and net of discounts, returns, allowances, and prepaid freight.
2

).

Reconciliation of alternative product data.--Please note that the quantities reported in this
question should reconcile as follows in each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L

Do these data reconcile?
explain

Yes

No--Please
.

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PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-3b. Alternative Product Data.--Report the information on your firm’s operations relating to
Dethatchers in your U.S. establishment(s) during the specified periods. (See definitions in the
instruction booklet.)

Tow-Behind Dethatchers
Quantity (in units) and value (in $1,000)
Calendar years
Item

2006

2007

January-March
2008

2008

2009

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value1 (G)
Transfers to related firms:
Quantity (H)
Value1 (I)
Export shipments:
Quantity of export shipments (J)
Value of export shipments (K)
End-of-period inventories (quantity) (L)
Employment data:
Average number of PRWs (number) (M)
Hours worked by PRWs (1,000 hours) (N)
Wages paid to PRWs (value) (O)
Financial Data2
Net Sales:
3
Quantity (P)
Value (Q)
Cost of goods sold (value) (R)
Gross profit or (loss) (value) (S)
Selling, general, and administrative
expenses (value) (T)
Operating income or (loss) (value) (U)
Capital expenditures (value) (V)
1

Internal consumption and transfers to related firms must be valued at fair market value.
If reporting financial data for fiscal year not ending on December 31, please indicated (year ending:
3
Including internal consumption and transfers to related firms and net of discounts, returns, allowances, and prepaid freight.
2

).

Reconciliation of alternative product data.--Please note that the quantities reported in this
question should reconcile as follows in each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L

Do these data reconcile?
explain

Yes

No--Please
.

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PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-3c.

Alternative Product Data.--Report the information on your firm’s operations relating to
Spreaders in your U.S. establishment(s) during the specified periods. (See definitions in the
instruction booklet.)

Tow-Behind Spreaders
Quantity (in units) and value (in $1,000)
Calendar years
Item

2006

2007

January-March
2008

2008

2009

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value1 (G)
Transfers to related firms:
Quantity (H)
Value1 (I)
Export shipments:
Quantity of export shipments (J)
Value of export shipments (K)
End-of-period inventories (quantity) (L)
Employment data:
Average number of PRWs (number) (M)
Hours worked by PRWs (1,000 hours) (N)
Wages paid to PRWs (value) (O)
Financial Data2
Net Sales:
3
Quantity (P)
Value (Q)
Cost of goods sold (value) (R)
Gross profit or (loss) (value) (S)
Selling, general, and administrative
expenses (value) (T)
Operating income or (loss) (value) (U)
Capital expenditures (value) (V)
1

Internal consumption and transfers to related firms must be valued at fair market value.
If reporting financial data for fiscal year not ending on December 31, please indicated (year ending:
3
Including internal consumption and transfers to related firms and net of discounts, returns, allowances, and prepaid freight.
2

).

Reconciliation of alternative product data.--Please note that the quantities reported in this
question should reconcile as follows in each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L

Do these data reconcile?
explain

Yes

No--Please
.

Business Proprietary
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PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-3d. Alternative Product Data.--Report the information on your firm’s operations relating to
Sweepers in your U.S. establishment(s) during the specified periods. (See definitions in the
instruction booklet.)

Tow-Behind Sweepers
Quantity (in units) and value (in $1,000)
Calendar years
Item

2006

2007

January-March
2008

2008

2009

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value1 (G)
Transfers to related firms:
Quantity (H)
Value1 (I)
Export shipments:
Quantity of export shipments (J)
Value of export shipments (K)
End-of-period inventories (quantity) (L)
Employment data:
Average number of PRWs (number) (M)
Hours worked by PRWs (1,000 hours) (N)
Wages paid to PRWs (value) (O)
Financial Data2
Net Sales:
3
Quantity (P)
Value (Q)
Cost of goods sold (value) (R)
Gross profit or (loss) (value) (S)
Selling, general, and administrative
expenses (value) (T)
Operating income or (loss) (value) (U)
Capital expenditures (value) (V)
1

Internal consumption and transfers to related firms must be valued at fair market value.
If reporting financial data for fiscal year not ending on December 31, please indicated (year ending:
3
Including internal consumption and transfers to related firms and net of discounts, returns, allowances, and prepaid freight.
2

).

Reconciliation of alternative product data.--Please note that the quantities reported in this
question should reconcile as follows in each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L

Do these data reconcile?
explain

Yes

No--Please
.

Business Proprietary
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PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-4

Comparability of types of TBLGs.--For each of the following indicate whether the product
comparisons are: fully (“F”) comparable or the same, i.e., have no differentiation between them;
mostly (“M”) comparable or similar; somewhat (“S”) comparable or similar; never or not-at-all
(“N”) comparable or similar; or no familiarity (“0”) with products. 1 Leave blank if you do not
have any familiarity with a specific product comparison.
(a)

Characteristics and Uses.-- The differences and
similarities in the physical characteristics and end uses
Productcomparison

Aerators

Dethatchers

Legend:
F = Fully comparable; M = Mostly comparable; S =
Somewhat comparable; N = Not at all comparable;
0 = No familiarity

Spreaders

Sweepers

Aerators
Dethatchers
Spreaders
Sweepers
1

Please provide a narrative discussion for the comparability ratings you provided for each product
comparison in terms of their characteristics and uses:

(b)

Interchangeability.--The ability to substitute one
product for another in the same application.
Productcomparison

Aerators

Dethatchers

Legend:
F = Fully interchangeable; M = Mostly
interchangeable; S = Somewhat interchangeable; N
= Not at all interchangeable; 0 = No familiarity

Spreaders

Sweepers

Aerators
Dethatchers
Spreaders
Sweepers
1
Please provide a narrative discussion for the comparability ratings you provided for each product
comparison in terms of their interchangeability:

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PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-4

Comparability of types of TBLGs.--Continued
(c)

Manufacturing facilities, production processes, and
production employees.-- Whether products are
manufactured in the same facilities, from the same
inputs, on the same machinery and equipment, and using
the same employees.
Productcomparison

Aerators

Dethatchers

Legend:
F = Fully the same; M = Mostly the same; S =
Somewhat the same; N = Not at all the same; 0 =
No familiarity

Spreaders

Sweepers

Aerators
Dethatchers
Spreaders
Sweepers
1

Please provide a narrative discussion for the comparability ratings you provided for each product
comparison in terms of their manufacturing processes:

(d)

Channels of distribution.-- Channels of
distribution/market situation through which the products
are sold (i.e., sold direct to end users, through
distributors, etc.)
Productcomparison

Aerators

Dethatchers

Legend:
F = Fully the same; M = Mostly the same; S =
Somewhat the same; N = Not at all the same; 0 =
No familiarity

Spreaders

Sweepers

Aerators
Dethatchers
Spreaders
Sweepers
1

Please provide a narrative discussion for the comparability ratings you provided for each product
comparison in terms of their channels of distribution:

Business Proprietary
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PART V.--ALTERNATIVE PRODUCTS—TRADE AND RELATED INFORMATION--Continued
V-4

Comparability of types of TBLGs.--Continued
(e)

Customer and producer perceptions.--Perceived
differences and/or similarities in the two products (e.g.,
sales/marketing practices)
Productcomparison

Aerators

Dethatchers

Legend:
F = Fully the same; M = Mostly the same; S =
Somewhat the same; N = Not at all the same; 0 =
No familiarity

Spreaders

Sweepers

Aerators
Dethatchers
Spreaders
Sweepers
1

Please provide a narrative discussion for the comparability ratings you provided for each product
comparison in terms of their customer and producer perceptions:

(f)

Price.--Whether prices are comparable or differ
between the product types.
Productcomparison

Aerators

Dethatchers

Legend:
F = Fully comparable; M = Mostly comparable; S =
Somewhat comparable; N = Not at all comparable;
0 = No familiarity

Spreaders

Sweepers

Aerators
Dethatchers
Spreaders
Sweepers
1

Please provide a narrative discussion for the comparability ratings you provided for each product
comparison in terms of their prices: