10-1-2890 US producer questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

US Producer Questionnaire SRC

Seamless Refined Copper Pipe and Tube from China and Mexico (Final)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 10-1-2890; Expiration Date: 6/30/2011
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
SEAMLESS REFINED COPPER PIPE AND TUBE FROM CHINA AND MEXICO

This questionnaire must be received by the Commission by no later than August 9, 2010
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 antidumping investigations concerning seamless refined copper pipe and tube from China and Mexico
(Inv. Nos. 731-TA-1174-1175 (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 seamless refined copper pipe and tube (as defined in the instruction booklet) at any time
since January 1, 2007?

(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 these investigations 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 these investigations 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.

Name of Authorized Official

Title of Authorized Official
Phone: (

Date

)

Signature

E-mail address
Fax (

)

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U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

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 page 3 of 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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Page 3

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/exporter.--Does your firm have any related firms, either domestic or foreign,
which are engaged in importing seamless refined copper pipe and tube from China or Mexico into
the United States or which are engaged in exporting seamless refined copper pipe and tube from
China or Mexico 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 seamless refined copper pipe and tube?
No
Firm name

Yes--List the following information
Address

Affiliation

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U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 4

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Edward Petronzio (202-2053176, [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 seamless refined copper pipe and tube since January 1,
2007?
(check as many as appropriate)
plant openings ..........................

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

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

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

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

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

prolonged shutdowns or
production curtailments .................
revised labor agreements ..........

other (e.g., technology) ............

(please describe)

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U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 5

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

Same equipment, machinery, and workers.--Has your firm since 2007 produced, or does your
firm anticipate producing in the future, other products on the same equipment and machinery
used in the production of seamless refined copper pipe and tube and/or using the same production
and related workers employed to produce seamless refined copper pipe and tube?
No

Yes--List the following information and report your firm’s combined
production capacity and production of these products and seamless
refined copper pipe and tube in the periods indicated.

Product

Period

Basis for allocation of capacity and
employment data (indicate if different)

(Quantity in 1,000 pounds)
Calendar years
Item

2007

2008

January-June
2009

2009

2010

Overall Production Capacity
Production of:
Seamless Refined Copper Pipe
and Tube
Other product 1
_____________________
Other product 2
_____________________

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, 2007, has your firm been involved in a toll agreement (see definition
in the instruction booklet) regarding the production of seamless refined copper pipe and tube?
No

II-6.

Yes--Name firm(s):

Foreign trade zone.--Does your firm produce seamless refined copper pipe and tube in a foreign
trade zone (FTZ)?
No

Yes--Identify FTZ(s):

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U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 6

PART II.--TRADE AND RELATED INFORMATION--Continued
II-7.

Importer.--Since January 1, 2007, has your firm imported seamless refined copper pipe and
tube?
No
Yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

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U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 7

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

Trade data.--Report your firm’s production capacity, production, shipments, inventories, and
employment related to the production of seamless refined copper pipe and tube in your U.S.
establishment(s) during the specified periods. (See definitions in the instruction booklet.)

Please note: The data reported in the table below should include both industrial and plumbing seamless
refined copper pipe and tube. Questions V-2 and V-3 request that you report this data separately.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item

2007

2008

January-June
2009

2009

2010

Average production capacity1 (quantity)
Beginning-of-period inventories (quantity)
Production (quantity)
U.S. shipments:
Commercial shipments:
Quantity of commercial shipments
Value of commercial shipments
Internal consumption:
Quantity of internal consumption
Value2 of internal consumption
Transfers to related firms:
Quantity of transfers
Value2 of transfers
Export shipments:3
Quantity of export shipments
Value of export shipments
End-of-period inventories4 (quantity)
Channels of distribution:
U.S. shipments to distributors (quantity)
U.S. shipments to end users (quantity)
Employment data:
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs (value)
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 each of the periods noted above:
3

Identify your principal export markets:
.
Reconciliation of data.--Please note that the quantities reported above should reconcile as follows: beginning-of-period
inventories, plus production, less total shipments, equals end-of-period inventories. Do the data reported reconcile?
4

Yes

No--Please explain:

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Page 8

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

Related firms.--If you reported transfers to related firms in question II-8, 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-10.

Purchases.--Other than direct imports, has your firm otherwise purchased seamless refined
copper pipe and tube since January 1, 2007? (See definitions in the instruction booklet.)
Yes--Report such purchases below for the specified periods.1

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

2007

2008

January-June
2009

2009

2010

PURCHASES FROM U.S. IMPORTERS2 OF SEAMLESS REFINED COPPER PIPE AND TUBE FROM-China:
Quantity
Value
Mexico:
Quantity
Value
All other countries:
Quantity
Value
PURCHASES FROM DOMESTIC PRODUCERS:2
Quantity
Value
PURCHASES FROM OTHER SOURCES:2
Quantity
Value
1

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

Please list the name of the firm(s) from which you purchased this product. If your suppliers differ by source,
please identify the source for each listed supplier.

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Page 9

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, [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.

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,
10Qs,
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
seamless refined copper pipe and tube, 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 - Seamless Refined Copper Pipe and Tube

Page 10

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

Other products.--Please list any other products you produced in the facilities in which you
produced seamless refined copper pipe and tube, and provide the share of net sales accounted for
by these other products in your most recent fiscal year:
Products

III-6.

Does your firm receive inputs (raw materials, labor, energy, or any other services) used in the
production of seamless refined copper pipe and tube from any related firm?
Yes—Continue to question III-7 below.

III-7.

No--Continue to question III-10 below.

Inputs from related firms.--In the space provided below, identify the inputs used in the
production of seamless refined copper pipe and tube that your firm receives from related parties.
Input

III-8.

Share of sales

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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Page 11

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

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 seamless refined copper pipe and
tube operations.
Fiscal years ended-Item

January-June
2009

2010

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.

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Page 12

PART III.--FINANCIAL INFORMATION--Continued
III-11. Operations on seamless refined copper pipe and tube.--Report the revenue and related cost
information requested below on the seamless refined copper pipe and tube 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.
Note: The data reported in this table should include both industrial and plumbing seamless refined
copper pipe and tube. Questions V-2 and V-3 request that you report certain financial data separately.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended-Item

January-June
2009

2010

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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Page 13

PART III.--FINANCIAL INFORMATION--Continued
III-12. Asset values.--Report the total assets associated with the production, warehousing, and sale of
seamless refined copper pipe and tube. 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.
Note: The data reported in this table should include both industrial and plumbing seamless refined
copper pipe and tube. Questions V-2 and V-3 request that you report certain financial data separately.
Value (in $1,000)
Fiscal years ended-Item
Assets associated with the production, warehousing, and
sale of product:
1. Current assets:
A. Cash and equivalents
B. Accounts receivable, net
C. Inventories
D. Other (describe:

)

E. Total current assets (lines 1.A. through 1.D.)
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.E., 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 seamless refined copper pipe and tube.
Provide data for your three most recently completed fiscal years in chronological order from left
to right, and for the specified interim periods.
Note: The data reported in this table should include both industrial and plumbing seamless refined
copper pipe and tube. Questions V-2 and V-3 request that you report certain financial data separately.
Value (in $1,000)
Fiscal years ended-Item
Capital expenditures
Research and development expenses

January-June
2009

2010

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Page 14

PART III.--FINANCIAL INFORMATION--Continued
III-14. Effects of imports.--Since January 1, 2007, 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 seamless refined copper pipe
and tube from China or Mexico?
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
seamless refined copper pipe and tube from China or Mexico?

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U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 15

PART IV.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from James Fetzer (202-708-5403,
[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 2007–June 2010 of the following
products produced by your firm.
Product 1.-- Seamless refined copper pipe and tube, 1/2” Type L, hard temper, 20’ lengths
Product 2.-- Seamless refined copper pipe and tube, 3/4" Type M, hard temper, 20' lengths
Product 3.-- Seamless refined copper pipe and tube, 3/8” OD, ACR/RST coil, 50’-100’ lengths
Product 4.-- Seamless refined copper pipe and tube, 3/4” OD, ACR/RST coil, 50’-100’ lengths
Product 5.-- Seamless refined copper pipe and tube, 3/8" OD, inner-grooved LWC, 0.0110"0.0144" bottom wall thickness
Product 6.-- Seamless refined copper pipe and tube, 5/16" OD, inner grooved LWC, 0.011700.0125” bottom wall thickness
Product 7.-- Seamless refined copper pipe and tube, 3/8" OD, smooth bore LWC, 0.0249"0.0327" bottom wall thickness
Product 8.-- Seamless refined copper pipe and tube, 3/4" OD, smooth bore LWC, 0.0327"0.0430" bottom wall thickness
Please note that 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.
Please report data for products sold for plumbing applications on a separate page than data for
industrial applications.

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Page 16

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

Pricing data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Please report data for products sold for plumbing applications on a separate page than
data for industrial applications.
Plumbing applications

Period of shipment

Industrial applications

(Quantity in pounds, value in dollars)
Product 1
Quantity
Value

Product 2
Quantity
Value

2007:
January-March
April-June
July-September
October-December
2008:
January-March
April-June
July-September
October-December
2009:
January-March
April-June
July-September
October-December
2010:
January-March
April-June
1
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 Part IV.
Note.--If your product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your product:
Product 1:
Product 2:

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Page 17

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

Pricing data.—Continued. Please report data for products sold for plumbing applications on a
separate page than data for industrial applications.
Plumbing applications

Period of shipment

Industrial applications

(Quantity in pounds, value in dollars)
Product 3
Quantity
Value

Product 4
Quantity
Value

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Page 18

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

Pricing data.—Continued. Please report data for products sold for plumbing applications on a
separate page than data for industrial applications.
Plumbing applications

Period of shipment

Industrial applications

(Quantity in pounds, value in dollars)
Product 5
Quantity
Value

Product 6
Quantity
Value

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Page 19

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

Pricing data.—Continued. Please report data for products sold for plumbing applications on a
separate page than data for industrial applications.
Plumbing applications

Period of shipment

Industrial applications

(Quantity in pounds, value in dollars)
Product 7
Quantity
Value

Product 8
Quantity
Value

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Page 20

PART IV.--PRICING AND RELATED INFORMATION--Continued
When responding to questions in this section, please indicate when your response varies by
plumbing applications or industrial applications.
IV-3.

Price setting.—
(a)

How does your firm determine the prices that it charges for sales of seamless refined
copper pipe and tube (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.
Type of price setting

Plumbing
applications

Industrial
applications

Transaction by transaction
Contracts
Set price lists
Internet sales
Other--Please describe below

Other--Please describe:

(b)

Does the quotation period of copper purchases influence your selling prices of seamless
refined copper pipe and tube?
No

(c)

Yes-Please explain.

Does your firm offer hedging transactions that might lock the copper price for long
periods of time?
No

Yes-Please explain the nature of your hedging transactions.

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Page 21

PART IV.--PRICING AND RELATED INFORMATION--Continued
(d)

Do variations or changes in the COMEX, LME, or other copper benchmarks affect your
overall price lists?
No

IV-4.

Yes-Please explain.

Discount policy.—
(a)

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:

(b)

Does your company have a rebate program for any of your purchasers of seamless refined
copper pipe and tube?
No

IV-5.

Yes-How is the rebate program reflected in the net pricing
agreed to with each customer and in the price data reported in
this question IV-2? What is the approximate percentage of the
total delivered cost of seamless refined copper pipe and tube that is
accounted for by these rebates?
percent

Pricing terms for seamless refined copper pipe and tube.-(a)

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

(b)

On what basis are your prices of domestic seamless refined copper pipe and tube usually
quoted? (check one)
F.o.b.--Please specify point:
Delivered

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Page 22

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
seamless refined copper pipe and tube in 2009 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)?
Total share of sales for
industrial applications
(percent)

Type of sale

Total share of sales for
plumbing applications
(percent)

Total share of sales (percent)

Long-term contracts
Short-term contracts
Spot sales
IV-7.

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 metal costs that are based on a particular benchmark?
No benchmark

Plumbing applications

Yes

Quantity

No
Price

Both

Industrial applications

Both plumbing and industrial applications
(e)

Please specify metal cost benchmark(s):

(f)

Does the contract have a meet-or-release provision?

___________________________
Yes

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 23

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-8.

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 metal costs that are based on a particular benchmark?
No benchmark

Yes

Quantity

Plumbing applications

Price

Both

Industrial applications

Both plumbing and industrial applications

IV-9.

(e)

Please specify metal cost benchmark(s):

(f)

Does the contract have a meet-or-release provision?

___________________________
Yes

Lead times.--What is your share of sales both from inventory and produced to order and 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 seamless refined copper pipe and tube?
Source

Share of sales in 2009

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 seamless refined copper
pipe and tube 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 are delivered within 100 miles of your production facility?
percent. Within 101 to 1,000 miles?
percent. Over 1,000 miles?
percent.

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 24

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-11. Geographical shipments.-- What is the geographic market area in the United States served by
your firm’s shipments of seamless refined copper pipe and tube? (check all that apply)
Geographic area

√ if applicable

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.

IV-12. End uses.--List the top 3 end uses for which the seamless refined copper pipe and tube your firm
produces is used, the percentage of your production of seamless refined copper pipe and tube
accounted for by each end use, and the percentage of the total cost of the end use that is accounted
for by seamless refined copper pipe and tube.

End uses
1.
2.
3.

Share of your production of
seamless refined copper pipe
and tube that is used in this
end use (percent)

Share of cost of this
product accounted for by
seamless refined copper
pipe and tube (percent)

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 25

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-13. Substitutes.--Please list in order of importance any products that may be substituted for seamless
refined copper pipe and tube (ex. plastic tube (such as PEX or PVC), aluminum tube, and
stainless steel tube). For each possible substitute product, please describe the degree of
substitutability and indicate whether changes in the price of the substitute affect the price for
seamless refined copper pipe and tube, and to what degree, the length of any time lag of such an
effect.

Substitute

Application

Have changes in the prices of this
substitute affected the price for
seamless refined copper pipe and tube?

Yes--Please explain.

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 26

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-14. Demand trends.-(a)

How has the demand within the United States for seamless refined copper pipe and tube
changed since January 1, 2007? What principal factors (such as substitution to and from
other products, changes in regulations, etc.) affect changes in demand?
Increased

(b)

No Change

Decreased

Fluctuated

How has the demand outside the United States (if known) for seamless refined copper
pipe and tube changed since January 1, 2007? What principal factors (such as
substitution to and from other products, changes in regulations, etc.) affect changes in
demand?
Increased

No Change

Decreased

Fluctuated

IV-15. Product changes.--Have there been any significant changes in the product range, product mix, or
marketing (including sales over the internet) of seamless refined copper pipe and tube since
2007?
No

Yes--Please describe and quantify if possible.

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 27

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-16. Business cycles.-(a) Is seamless refined copper pipe and tube market subject to business cycles or conditions of
competition (including seasonal business) distinctive to seamless refined copper pipe and tube?
No (skip to question IV-17.)

Yes-- Please describe below and then answer part (b).

(b) If yes, have there been any changes in the business cycles or conditions of competition for
seamless refined copper pipe and tube since January 1, 2007?
No

Yes-- Please describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply seamless refined
copper pipe and tube since January 1, 2007 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, been unable to meet timely shipment commitments,
being unable to supply product due to patent constraints etc.)?
No

Yes-- Please describe.

IV-18. Raw materials.--Please describe any trends in the prices of raw materials used to produce
seamless refined copper pipe and tube and whether your firm expects these trends to continue.

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 28

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-19. Interchangeability.--Is seamless refined copper pipe and tube 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 countrypair.1
Country-pair

China

Mexico

Canada

Malaysia

Other countries

United States
China
Mexico
Canada
Malaysia

For any country-pair producing seamless refined copper pipe and tube which is sometimes or never
interchangeable, please explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 29

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-20. Factors other than price.--Are differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between seamless refined copper
pipe and tube 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

Country-pair

China

Mexico

Canada

Malaysia

Other countries

United States
China
Mexico
Canada
Malaysia
1

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

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 30

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-21. Customer Identification--Please identify below the names and addresses of your firm’s 10
largest customers for seamless refined copper pipe and tube during 2007-2009. 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 seamless refined copper pipe and tube that each of these customers
accounted for in 2009.

No.

Customer’s name

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

Contact person

Area
code and
telephone
number

Share of
2009
sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 31

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-22. 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.) PLEASE DO NOT RE-SUBMIT
ALLEGATIONS PROVIDED IN THE PRELIMINARY PHASE OF THIS
INVESTIGATION.
Since January 1, 2007: To avoid losing sales to competitors selling seamless refined copper pipe
and tube from China and Mexico, did your firm:
Reduce prices

Yes

Roll back announced price increases

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
(pounds)

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

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

Country of
origin

Competing
import price
(total
value—
dollars)

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 32

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-23. 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.) PLEASE DO NOT RE-SUBMIT
ALLEGATIONS PROVIDED IN THE PRELIMINARY PHASE OF THIS
INVESTIGATION.
Since January 1, 2007: Did your firm lose sales of seamless refined copper pipe and tube to
imports of these products from China and Mexico?
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
(pounds)

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

Country of
origin

Competing
import price
(total
value—
dollars)

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 33

PART IV.--PRICING AND RELATED INFORMATION
V-1.

COMPARABILITY OF INDUSTRIAL AND PLUMBING SEAMLESS REFINED
COPPER PIPE AND TUBE.
(a) Do industrial and plumbing seamless refined copper pipe and tube have the same
physical characteristics and end uses?
No

Yes

Please describe the similarities and/or differences between the physical characteristics or end uses.
_________________________________________________________________________
_____________________________________________________________________________
(b) Are industrial and plumbing seamless refined copper pipe and tube interchangeable?
No

Yes

Please describe what makes these two products interchangeable or not interchangeable.
_________________________________________________________________________
_____________________________________________________________________________
(b) Are the manufacturing processes to produce industrial seamless refined copper pipe
and tube similar to those to produce plumbing seamless refined copper pipe and tube?
No

Yes

Please describe the similarities and/or differences between the two manufacturing processes.
_________________________________________________________________________
_____________________________________________________________________________
(c) Do industrial and plumbing seamless refined copper pipe and tube share the same
channels of distribution?
No

Yes

Please describe the similarities and/or differences between the channels of distribution.
_________________________________________________________________________
_____________________________________________________________________________
(d) Do you or your customers perceive industrial seamless refined copper pipe and tube
and plumbing seamless refined copper pipe and tube to be similar products?
Yes

No, please describe the perceived differences between the two products:

__________________________________________________________________________
______________________________________________________________________________

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 34

PART V.-- ALTERNATIVE PRODUCTS--TRADE AND RELATED INFORMATION--Continued
(e) Are there generally differences in price between industrial and plumbing seamless
refined copper pipe and tube?
No
Yes, industrial seamless refined copper pipe and tube are generally higher in price than
plumbing seamless refined copper pipe and tube.
Yes, industrial seamless refined copper pipe and tube are generally higher in price than
plumbing seamless refined copper pipe and tube.
Please explain:
__________________________________________________________________________
______________________________________________________________________________

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 35

PART V.-- ALTERNATIVE PRODUCTS--TRADE AND RELATED INFORMATION--Continued
V-2. Industrial seamless refined copper pipe and tube.– For the industrial seamless refined copper
pipe and tube operations of your U.S. establishment(s), report the information requested below.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item

2007

2008

January-June
2009

2009

2010

AVERAGE PRODUCTION CAPACITY (quantity)
BEGINNING-OF-PERIOD INVENTORIES (quantity)
PRODUCTION (quantity)
U.S. SHIPMENTS
Commercial shipments:
Quantity of commercial shipments
Value of commercial shipments
Internal Consumption:
Quantity of internal consumption
1

Value of internal consumption
Transfers to related firms:
Quantity of transfers to related firms
1

Value of transfers to related firms
2

EXPORT SHIPMENTS:

Quantity of export shipments
Value of export shipments
3

END-OF-PERIOD INVENTORIES (quantity)
CHANNELS OF DISTRIBUTION:

U.S. shipments to distributors (quantity)
U.S. shipments to end users (quantity)
HOURS WORKED BY PRWs (1,000 hours)
WAGES PAID TO PRWs (value)
FINANCIAL INFORMATION:

Net sales:

Quantity
Value
Cost of goods sold (value)
Gross profit or (loss) (value)
Selling, general, and administrative expenses (value)
Operating income or (loss) (value)
Capital expenditures (value)
1
2

Sales to related firms (including internal consumption and transfers) must be valued at fair market value.
Identify your principal export markets:

Reconciliation of data.--Please note that the quantities reported above should reconcile as follows: beginning-of-period inventories, plus
production, less total shipments, equals end-of-period inventories. Do the data above reconcile?
Yes
No--Please explain:
4
5

Report financial information on a fiscal-year basis (year ending
Including internal consumption and transfer to related firms and net of discounts, returns, allowances, and prepaid freight.

Business Proprietary
U.S. Producers’ Questionnaire - Seamless Refined Copper Pipe and Tube

Page 36

PART V.-- ALTERNATIVE PRODUCTS--TRADE AND RELATED INFORMATION--Continued
V-3. Plumbing seamless refined copper pipe and tube.– For the plumbing seamless refined copper
pipe and tube operations of your U.S. establishment(s), report the information requested below.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item

2007

2008

January-June
2009

2009

2010

Value of internal consumption
Transfers to related firms:
Quantity of transfers to related firms
1

Value of transfers to related firms
2

EXPORT SHIPMENTS:

Quantity of export shipments
Value of export shipments
3

END-OF-PERIOD INVENTORIES (quantity)
CHANNELS OF DISTRIBUTION:

U.S. shipments to distributors (quantity)
U.S. shipments to end users (quantity)
HOURS WORKED BY PRWs (1,000 hours)
WAGES PAID TO PRWs (value)
FINANCIAL INFORMATION:

Net sales:

Quantity
Value
Cost of goods sold (value)
Gross profit or (loss) (value)
Selling, general, and administrative expenses (value)
Operating income or (loss) (value)
Capital expenditures (value)
1
2

Sales to related firms (including internal consumption and transfers) must be valued at fair market value.
Identify your principal export markets:

Report financial information on a fiscal-year basis (year ending
Including internal consumption and transfer to related firms and net of discounts, returns, allowances, and prepaid freight.

File Type	application/pdf
File Title	Microsoft Word - US Producer Questionnaire SRC.doc
Author	edward.petronzio
File Modified	2010-07-07
File Created	2010-07-07