HEDP from China and India

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

1-HYDROXYETHYLIDENE-1,1-DIPHOSPHONIC ACID (HEDP)
FROM CHINA AND INDIA
Investigations Nos. 731-TA-1146 and 1147 (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 (Fax 202-205-3205):
Nathanael Comly, Investigator (202-205-3174; E-mail: [email protected])
regarding general questions and trade and related information;
David Boyland, Auditor (202- 708-4725; E-mail: [email protected])
regarding financial information; and
James Fetzer, Economist (202-708-5403; E-mail: [email protected].)
regarding pricing, market, and related information.

GENERAL INFORMATION
Background.—These investigations were instituted in response to a petition filed on March 19,
2008, by Compass Chemical International LLC, Huntsville, TX. Antidumping duties may be
assessed on the subject imports as a result of these investigations if the Commission makes an
affirmative determination of injury, threat, or material retardation, and if the U.S. Department of
Commerce makes an affirmative determination of dumping.
Questionnaires and other information pertinent to these investigations are available at
http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2008/hedp_from_china_and
_india/finalphase.htm. Address all correspondence to the United States International Trade
Commission, 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 December 17, 2008. Although the enclosed
postpaid envelope may be used to return the completed questionnaire, use of an overnight mail
service may be necessary to ensure that your response actually reaches the Commission by
December 17, 2008. If you do not use the enclosed envelope, please make sure the completed
questionnaire is sent to the attention of Nathanael Comly. 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 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
202-205-1803. 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).

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GENERAL INFORMATION--Continued
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 these 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. Your response to these questions constitutes your consent that such information be
provided to Commerce under the conditions described above.

INSTRUCTIONS
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
Anone,@ write Anone.@ If information is not readily available from your records in exactly the
form requested, furnish carefully prepared estimates--designated as such by the letter
AE@--and explain the basis of your estimates. 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). If your firm is completing more than one
questionnaire in connection with these investigations (i.e., a producer, importer, and/or purchaser
questionnaire), you need not respond to duplicated questions in the questionnaires.
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.

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INSTRUCTIONS--Continued
Filing instructions.—Questionnaires may be filed either in paper form or electronically.
OPTIONS FOR FILING IN PAPER FORM
• Overnight mail service.—Mail to the following address:
United States International Trade Commission
Office of Investigations, Room 615
500 E Street SW
Washington, DC 20024
• Fax.—Fax to 202.205.3205.
• U.S. mail.—Mail to the address above, but use zip code 20436. This option is not recommended.
U.S. mail sent to government offices undergoes additional processing to screen for hazardous
materials; this additional processing results in substantial delays in delivery.
OPTIONS FOR FILING ELECTRONICALLY
This questionnaire is available as a “fillable” form in MS Word format on the Commission’s
website at
http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2008/hedp_from_china_and
_india/finalphase.htm. Please do not attempt to modify the format or permissions of the
questionnaire document. You may complete the questionnaire electronically, print it out, and
submit it in paper form as described above, or you may submit it electronically through one of the
following means:
• By means of the Commission’s Electronic Document Information System (EDIS).—Follow
the step-by-step instructions on the next page.
• Compact disc (CD).—Copy your questionnaire onto a CD, include a signed certification page
(page 1) (either in paper form or scanned PDF copied onto CD), and mail to the address above. It
is strongly recommended that you use an overnight mail service. U.S. mail sent to government
offices undergoes additional processing which not only results in substantial delays in delivery but
may also damage CDs.
• E-mail.—E-mail your questionnaire to the investigator identified on page 1 of the Instruction
Booklet; include a scanned PDF of the signed certification page (page 1). Type the following in
the e-mail subject line: BPI Questionnaire, INV. NOS. 731-1146-1147. Please note that
submitting your questionnaire by e-mail may subject your firm’s business proprietary information
to transmission over an unsecure environment and to possible disclosure. If you choose this
option, the Commission warns you that any risk involving possible disclosure of such information
is assumed by the submitter and not by the Commission.
Note: If you are a party to the investigations, and service of the questionnaire is
required, such service should be made in paper form.
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INSTRUCTIONS--Continued
INSTRUCTIONS FOR FILING VIA EDIS
STEP 1: REGISTER AS A NEW USER IN EDIS (current registered users may skip this step)
• The authorized official whose name appears under the Certification at the bottom of page
1 of the questionnaire should be the person who completes the registration in EDIS
• Go to https://eofpub.usitc.gov/edis-efile/app
• Click on Register
• Read and accept the Terms of Use Agreement
• Complete the EDIS Online User Registration form
o In the Firm/Organization field, select Questionnaire Respondent
• Click Submit Registration
STEP 2: ELECTRONICALLY SUBMIT YOUR QUESTIONNAIRE(S) IN EDIS
• Click on E-File Documents
• Under Submitter Information, type the name of your firm in the Filed On Behalf Of
field
• Under Investigations Information, click on Find Investigation
o For Investigations Phase, select “Final” and for Investigations Number, type
“731-1146”; Click on Find Investigation
o Click in the circle to the left of the investigations number that appears, then click
on Select and confirm by clicking OK
• Under Document Filing Information—
o For Document Type, select Questionnaire – Foreign Producer, Questionnaire
– Importer, Questionnaire – Purchaser, or Questionnaire – U.S. Producer, as
appropriate
o Leave Document Title field blank
• Under Add Document Attachments for Electronic Submission—
o In the Attach File field, click on Browse, locate your MS Word questionnaire file,
and double-click the file
o The Attachment Title field is optional
o Click on Attach Files (note that your file will be listed below under Attachments)
o You must attach a scanned PDF of the signed certification page (page 1). If you
wish to attach any other files, i.e., supporting documents, do so at this time (unlike
the questionnaire itself, these additional documents must be PDFs). Only one
questionnaire may be filed at a time.
o When you have attached all relevant files, click on Submit Document
w/attachments. An EDIS Document Submission Confirmation screen will
appear. Confirm the information and click on Accept Information. An EDIS
Notice of Receipt of Electronic Documents will appear, which completes the
process. If you wish to electronically file another questionnaire, repeat Step 2.

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DEFINITIONS
HEDP.–All grades of aqueous, acidic (non-neutralized) concentrations of 1-hydroxyethylidene-1,
1-diphosphonic acid,1 also referred to as hydroxyethylidenediphosphonic acid,
hydroxyethanediphosphonic acid, acetodiphosphonic acid, or etidronic acid. The CAS registry
number for HEDP is 2809-21-4. HEDP is properly provided for in statistical reporting number
2931.00.9043 of the HTSUS.2 Although the CAS and HTSUS numbers are provided for
convenience, the written description of the HEDP subject to these investigations is dispositive.
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 HEDP (as defined above), including auxiliary facilities operated
in conjunction with (whether or not physically separate from) such facilities.
United States.--For purposes of these investigations, 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 HEDP (as defined above) into the United States from a foreign manufacturer or
through its selling agent.

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C2H8O7P2 or C(CH3)(OH)(PO3H2)2.
U.S. imports of HEDP that have been entered under other HTS statistical reporting numbers (e.g. 2811.19.6090)
are included in this definition and should be included in the data submitted in Part II of the importers’ questionnaire.
2

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DEFINITIONS—Continued
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 HEDP (as defined above) from another firm that produces, imports, or
otherwise distributes HEDP. 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 in an importer questionnaire).
Purchase quantities.--Quantities reported should be net of returns.
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).

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DEFINITIONS—Continued
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 PRODUCER 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, 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 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-September periods, calculate similarly and divide by 9.

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DEFINITIONS—Continued
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.

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