Aluminum Extrusions from China

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

Aluminum Extrusions from China
Inv. Nos. 701-TA-475 and 731-TA-1177 (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:
Ed Petronzio, investigator (202-205-3176; E-mail [email protected])
regarding general questions and trade and related information;
David Boyland, auditor (202-708-5403; 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
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

Background.--The final phase of these investigations is being conducted as a result of affirmative preliminary
determinations by the Department of Commerce (“Commerce”) under section 703 of the Tariff Act of 1930
(19 U.S.C. § 1671b) (“the Act”) that certain benefits which constitute subsidies are being provided to
manufacturers, producers, or exporters in China of aluminum extrusions,1 and under section 733 of the Act
(19 U.S.C. § 1673b) that such products are being sold in the United States at less than fair value (“LTFV”).2
As of result of Commerce’s preliminary subsidy and LTFV determinations, the U.S. Department of
Homeland Security, Customs and Border Protection Agency (“Customs”) has been instructed to suspend
liquidation of all imports of aluminum extrusions from China and require a cash deposit or bond on these
imports. Definitive countervailing duty (“CVD”) and/or antidumping duties (“AD”) may be assessed on
imports of aluminum extrusions from China as a result of these investigations if the U.S. International Trade
Commission (“Commission”) makes an affirmative determination of injury, threat, or material retardation,
and if the Commerce makes an affirmative determination of subsidization and/or dumping.
Petition.--The investigations were requested in a petition filed on March 31, 2010, by the Aluminum Extrusions
Fair Trade Committee and the United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied
Industrial and Service Workers International Union.
Correspondence.--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:

FEBRUARY 8, 2011
Please make sure the completed questionnaire(s) is sent to the attention of Ed Petronzio
([email protected]). Return only one copy of the completed questionnaire(s), but please keep a
copy for your records so that you can refer to it if the Commission staff contacts you with any questions
during the course of the investigations.
Service of questionnaire response(s).--In the event that your firm is a party to these investigations, you are
required to serve a copy of the questionnaire(s), once completed, on other parties to the proceeding that are
subject to administrative protective order (see 19 CFR ' 207.7). A certificate of service must accompany
the copy of the completed questionnaire(s) you submit (see 19 CFR ' 207.7) and a list of such parties is
maintained by the Commission’s Secretary online at web address:
http://www.usitc.gov/secretary/fed_reg_notices/service_lists/serv_lists_antidump.htm

1

See Aluminum Extrusions From the People’s Republic of China: Preliminary Affirmative Countervailing Duty
Determination, 75 FR 54302, September 7, 2010, and Aluminum Extrusions From the People’s Republic of China: Alignment of
Final Countervailing Duty Determination With Final Antidumping Duty Determination, 75 FR 57441, September 21, 2010.
2
See Aluminum Extrusions From the People’s Republic of China: Notice of Preliminary Determination of Sales at Less Than
Fair Value, and Preliminary Determination of Targeted Dumping, 75 FR 69403, November 12, 2010, and Aluminum Extrusions
From the People’s Republic of China: Postponement of Final Determination of Sales at Less Than Fair Value, 75 FR 73041,
November 29, 2010.

Page 2 of 10

GENERAL INFORMATION--Continued
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

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

INSTRUCTIONS
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

Answer all questions.--Do not leave any question or section blank unless a questionnaire expressly directs you
to skip over certain questions or sections. If the answer to any question is “none,” write “none.” If
information is not readily available from your records in exactly the form requested, furnish
carefully prepared estimates--and indicate in the appropriate question in section I of the
questionnaire a discussion of those responses which include estimates. Answers to questions and any
necessary comments or explanations should be supplied in the space provided or on separate sheets
included with your questionnaire submission.
Consolidate all U.S. establishments.--Report the requested data for your establishment(s) located in the
United States (including Puerto Rico). Firms operating more than one establishment should combine the
data for all establishments into a single report.

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INSTRUCTIONS--Continued
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

Electronic completion.--Your firm is encouraged (but not required) to complete the questionnaire
electronically in MS Word format. The MS Word versions of all the questionnaires in these investigations
are available online at the ITC web page or may be obtained directly from the Commission’s Investigator,
Ed Petronzio (202-205-3176, [email protected]).
Electronic submission.--To the degree that it is possible and not overly burdensome, the Commission requests
that responding firms submit their questionnaire responses electronically in MS Word format. The
completion and receipt of questionnaire responses in the MS Word format allows the Commission to easily
compile and analyze submitted data. There are three electronic submissions options detailed below. Paper
and hardcopy submissions are also accepted.
SUBMISSION OPTIONS
1) Upload via Secure Drop Box.--Upload the completed questionnaire in MS Word format along with a
scanned copy of the signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: OINV
2) E-mail.--E-mail the completed questionnaire to Ed Petronzio ([email protected]) in MS
Word format and include a scanned copy of the signed certification page (page 1).3
3) Compact disc (CD).--Copy or burn the completed questionnaires in MS Word format along with a
scanned copy of the signed certification page (page 1), and mail the CD to the address below via
overnight mail service (regular U.S. mail undergoes security treatments that often damage CDs).
4) U.S. mail or 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 (overnight)
Washington, DC 20436 (U.S. mail)
5) Fax.--Fax to 202.205.3205.
Note to parties.--If you are a party to the investigations, and service of the questionnaire(s) is required, such
service should be made in paper form pursuant to the applicable Commission rules for the purposes of
service. However, all parties are instructed to encourage their clients to complete the questionnaires
electronically and to forward any electronically completed questionnaires in the underlying MS Word
format to the Commission’s Investigator (e-mail or upload) at the time of service.

3

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.

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DEFINITIONS
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

Definition of “Aluminum Extrusions” (based on Commerce’s Scope).--4
The merchandise covered by this investigation is aluminum extrusions which are shapes
and forms, produced by an extrusion process, made from aluminum alloys having metallic elements
corresponding to the alloy series designations published by The Aluminum Association
commencing with the numbers 1, 3, and 6 (or proprietary equivalents or other certifying body
equivalents). Specifically, the subject merchandise made from aluminum alloy with an Aluminum
Association series designation commencing with the number 1 contains not less than 99 percent
aluminum by weight. The subject merchandise made from aluminum alloy with an Aluminum
Association series designation commencing with the number 3 contains manganese as the major
alloying element, with manganese accounting for not more than 3.0 percent of total materials by
weight. The subject merchandise made from an aluminum alloy with an Aluminum Association
series designation commencing with the number 6 contains magnesium and silicon as the major
alloying elements, with magnesium accounting for at least 0.1 percent but not more than 2.0 percent
of total materials by weight, and silicon accounting for at least 0.1 percent but not more than 3.0
percent of total materials by weight. The subject aluminum extrusions are properly identified by a
four-digit alloy series without either a decimal point or leading letter. Illustrative examples from
among the approximately 160 registered alloys that may characterize the subject merchandise are as
follows: 1350, 3003, and 6060.
Aluminum extrusions are produced and imported in a wide variety of shapes and forms,
including, but not limited to, hollow profiles, other solid profiles, pipes, tubes, bars, and rods.
Aluminum extrusions that are drawn subsequent to extrusion (“drawn aluminum”) are also included
in the scope.
Aluminum extrusions are produced and imported with a variety of finishes (both coatings
and surface treatments), and types of fabrication. The types of coatings and treatments applied to
subject aluminum extrusions include, but are not limited to, extrusions that are mill finished (i.e.,
without any coating or further finishing), brushed, buffed, polished, anodized (including bright-dip
anodized), liquid painted, or powder coated. Aluminum extrusions may also be fabricated, i.e.,
prepared for assembly. Such operations would include, but are not limited to, extrusions that are
cut-to-length, machined, drilled, punched, notched, bent, stretched, knurled, swedged, mitered,
chamfered, threaded, and spun. The subject merchandise includes aluminum extrusions that are
finished (coated, painted, etc.), fabricated, or any combination thereof.
Subject aluminum extrusions may be described at the time of importation as parts for final
finished products that are assembled after importation, including, but not limited to, window frames,
door frames, solar panels, curtain walls, or furniture. Such parts that otherwise meet the definition
of aluminum extrusions are included in the scope. The scope includes aluminum extrusions that are
attached (e.g., by welding or fasteners) to form subassemblies, i.e., partially assembled merchandise.
Subject extrusions may be identified with reference to their end use, such as heat sinks,
door thresholds, or carpet trim. Such goods are subject merchandise if they otherwise meet the scope
definition, regardless of whether they are finished products and ready for use at the time of
importation.
The following aluminum extrusion products are excluded: Aluminum extrusions made
from aluminum alloy with an Aluminum Association series designations commencing with the
number 2 and containing in excess of 1.5 percent copper by weight; aluminum extrusions made from
aluminum alloy with an Aluminum Association series designation commencing with the number 5
4

Taken from Aluminum Extrusions From the People’s Republic of China: Notice of Preliminary Determination of Sales at
Less Than Fair Value, and Preliminary Determination of Targeted Dumping, 75 FR 69403, November 12, 2010.

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DEFINITIONS--Continued
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

and containing in excess of 1.0 percent magnesium by weight; and aluminum extrusions made from
aluminum alloy with an Aluminum Association series designation commencing with the number 7
and containing in excess of 2.0 percent zinc by weight.
The scope also excludes finished merchandise containing aluminum extrusions as parts
that are fully and permanently assembled and completed at the time of entry, such as finished
windows with glass, doors, picture frames, and solar panels. The scope also excludes finished goods
containing aluminum extrusions that are entered unassembled in a “kit.” A kit is understood to mean
a packaged combination of parts that contains, at the time of importation, all of the necessary parts
to fully assemble a final finished good.
The scope also excludes aluminum alloy sheet or plates produced by other than the
extrusion process, such as aluminum products produced by a method of casting. Cast aluminum
products are properly identified by four digits with a decimal point between the third and fourth digit.
A letter may also precede the four digits. The following Aluminum Association designations are
representative of aluminum alloys for casting: 208.0, 295.0, 308.0, 355.0, C355.0, 356.0, A356.0,
A357.0, 360.0, 366.0, 380.0, A380.0, 413.0, 443.0, 514.0, 518.1, and 712.0. The scope also excludes
pure, unwrought aluminum in any form.
The scope also excludes collapsible tubular containers composed of metallic elements
corresponding to alloy code 1080A as designated by the Aluminum Association where the tubular
container (excluding the nozzle) meets each of the following dimensional characteristics: (1) Length
of 37 mm or 62 mm, (2) outer diameter of 11.0 mm or 12.7 mm, and (3) wall thickness not exceeding
0.13 mm.
Imports of the subject merchandise are provided for under the following categories of the
Harmonized Tariff Schedule of the United States (“HTS”): 7604.21.0000, 7604.29.1000,
7604.29.3010, 7604.29.3050, 7604.29.5030, 7604.29.5060, 7608.20.0030, and 7608.20.0090. The
subject merchandise entered as parts of other aluminum products may be classifiable under the
following additional Chapter 76 subheadings: 7610.10, 7610.90, 7615.19, 7615.20, and 7616.99 as
well as under other HTS chapters. While HTS subheadings are provided for convenience and
customs purposes, the written description of the scope in this proceeding is dispositive.

Heat Sinks.--Heat sinks (at all levels of production) are a subset of aluminum extrusions typically used in
electronic equipment as a thermal controlling tool and should be reported as part of all data reported in
section II of the Commission questionnaires. The following definitions should be used to assist in reported
data on the alternative product section of the questionnaires (part V of the U.S. producers’ questionnaire or
part IV of the U.S. importers’ questionnaire).
Heat Sink Blanks.--Heat sink blanks are the full length aluminum extrusions used to produce finished heat
sinks. In other words, these are the pre-fabricated, pre-tested inputs in the production of heat sinks (post
any stretching or aging processes applied). (Note.--The industry often just refers to heat sink blanks as
“heat sinks”, but here for the purposes of these questionnaires we are making the distinction between
the final product and this intermediate product)
Fabricated Heat Sinks.--Fabricated heat sinks should be understood to be any heat sink blank that has
been cut-to-length, precision machined, and or otherwise fabricated to the end product specifications,
but not yet tested, assembled onto other materials, or packaged.
Finished Heat Sinks.--Finished heat sinks should be understood to be the final product ready to be sold to
electronic manufacturers. Finished heat sinks differ from fabricated heat sinks in that they have been

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DEFINITIONS--Continued
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

fully test and assured to comply with the required end-use specifications.
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 certain aluminum extrusions (as defined above), including auxiliary facilities operated in
conjunction with (whether or not physically separate from) such facilities.
United States.--For purposes of this investigation, the 50 States, Puerto Rico, the U.S. Virgin Islands, and the
District of Columbia.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in importing
certain aluminum extrusions (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
Imports.--Those products identified for Customs purposes as imports for consumption for which your firm was
the importer of record (i.e., was responsible for paying any import duty) or consignee (i.e., to which the
merchandise was first delivered).
Import quantities.--Quantities reported should be net of returns in short tons.
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 aluminum extrusions from another firm that produces, imports, or otherwise distributes
aluminum extrusions.
Purchases.--Purchases from all sources, not including direct imports from foreign producers (which should be
reported as imports in a U.S. importers’ questionnaire).
Purchase quantities.--Quantities reported should be net of returns in short tons.
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 are to be reported in short tons and 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
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

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.
Toll shipments.--Shipments of extrusions produced on your extrusions presses and drawing machines
(but not necessarily finishing or fabrication machinery) under a toll agreement whereby the
shipment values reflects only conversion costs. Shipments of another firm’s aluminum extrusions
that your firm has only finished under a tolling arrangement (e.g., painted, anodized) should not be
reported as part of your firms’ U.S. shipments.
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. Inventories may represent
aluminum extrusions at different levels of finishing (i.e., some inventory may be painted extrusions, some
may be anodized extrusions, and some may be mill finish extrusions) or fabrication, based on the intended
end use.
Market Sectors.--Major end-use applications for aluminum extrusions as defined by the Aluminum Extruders
Council.
Building and Construction.--Windows, doors, carpet framing, shower doors, tub enclosures, railings,
high-rise curtain wall, highway and bridge construction, framing members, other various structures
Transportation.--Automotive (cars, buses, trucks, trailer/van/container vehicles), heavy rail, light rail
and other mass transit vehicles, recreational vehicles, aircraft, aerospace, and marine machinery;
Engineered Products.--Consumer and commercial products - air conditioners, appliances, furniture,
lighting, sports equipment, personal watercraft; electrical power units, heat sinks, coaxial cables,
bus bars; machinery & equipment, food displays, refrigeration; medical equipment, display
structures, laboratory equipment and apparatus.
Finishing capabilities.--A description of the types of finishes given to aluminum extrusions. These are
understood to relate to coats given to aluminum extrusions, such as a layer of anodized material, or paint,
and not other fabrication services. For the purposes of reporting a break-out of U.S. shipments, the
mill-finished, anodized, and painted categories should be understood to be mutual exclusive categories that
represent the universe of aluminum extrusions. Bright-dipped extrusions should be reported as anodized
extrusions, except where requested otherwise.
Mill finished.--A type of finish to aluminum extrusions that does not involve any further processing
after the extrusion/drawing, stretching, cutting, and aging processes.

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DEFINITIONS--Continued
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

Anodized.–This process involves the use of electrolysis to encourage oxygen ions to combine with
aluminum to form a hard aluminum oxide film or seal, thus enhancing the durability and beauty of
the profile. Pretreatment steps to the anodizing process may include alkaline cleaning to remove
organic contaminants and acid cleaning to remove inorganic contaminants. The extrusion profile
is immersed in a tank containing an acid-based electrolyte solution. Electric current is passed
through the solution while the temperature is carefully controlled. The electric current causes
oxygen ions to be released from the electrolyte solution and to be drawn to the surface of the
aluminum profile, which serves as an anode.
Painted.–Both specialty liquid paints and powder coatings may be applied to the aluminum profile.
Thermoplastic or thermoset polymer powder coatings are applied using an electrostatic gun to
impart a positive electric charge to the powder. The powder is accelerated toward and adheres to
the negatively charged aluminum profile. After the powder is applied, the profile is baked in an
oven where the powder particles are melted to a liquid state which then fuses with the profile to
form a homogeneous surface finish. The surface is then cooled to form a hard coating.
Other finishes.--For the purpose of responding to Commission questionnaires, please report any
extrusion without anodized or painted finishes as mill finished. Other finishes such as metallic
brushing, buffing, polishing, et cetera should be reported under one of the primary three categories
provided above. For example, brushed nickel will likely be reported as an anodized product as it is
eventually anodized, and non-painted, non-anodized extrusions that have been buffed and polished
would be reported as mill finish, et cetera.
Bright Dipped.–This is a type of anodizing process. The aluminum extrusion is first polished to
remove fine scratches and then submerged typically in a phosphoric acid and nitric acid bath and
heated to an elevated temperature. It is then anodized to protect the surface finish and to apply color
to the profile.
Type of extrusion.--The following categories should be considered mutually exclusive and representative of
the the universe of aluminum extrusions together.
Custom.--Any aluminum extrusion that was designed specifically to the customer’s specification and
is not a standard shape.
Standardized.--Any aluminum extrusion that is produced to a standard shape and is not customer
specific.
The following definitions apply only to the U.S. PRODUCERS’ QUESTIONNAIRE:
Production capability.--A description of the types of extrusion presses or drawing machines used by your firm
in the production of aluminum extrusions.
Extrusion press.--Any machinery that extrudes heated aluminum into shapes, thus producing
aluminum extrusions.
Drawing machine.--Any machinery that draws heated aluminum into shapes, thus producing
aluminum extrusions (as defined by Commerce’s scope to include drawn product).
Fabrication capabilities.-- A description of the types of fabrication services by your firm in the production of

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DEFINITIONS--Continued
(Instruction Booklet, in Inv. Nos. 701-TA-475 and 731-TA-1177, Aluminum Extrusions from China (Final))

aluminum extrusions. For example, drilling holes, crimping, notching, et cetera.
Average production capacity.--The level of production that your establishment(s) could reasonably have
expected to attain during the specified periods. Assume normal operating conditions (i.e., using equipment
and machinery in place and ready to operate; normal operating levels (hours per week/weeks per year) and
time for downtime, maintenance, repair, and cleanup; and a typical or representative product mix).
Toll agreement.--Agreement between two firms whereby the first firm furnishes the raw materials and the
second firm uses the raw materials to produce a product that it then returns to the first firm with a charge for
processing costs, overhead, etc.
Production.--All production in your U.S. establishment(s), including production consumed internally within
your firm and production for another firm under a toll agreement.
PRWs.--Production and related workers (“PRWs”), including working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling, inspecting,
receiving, storage, handling, packing, warehousing, shipping, trucking, hauling, maintenance, repair,
janitorial and guard services, product development, auxiliary production for plant=s own use (e.g., power
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.
Hours worked.--Include time paid for sick leave, holidays, and vacation time. Include overtime hours actually
worked; do not convert overtime pay to its equivalent in straight-time hours.
Wages paid.--Total wages paid before deductions of any kind (e.g., withholding taxes, old-age and
unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid directly by your
firm for overtime, holidays, vacations, and sick leave.
Fiscal year.--The 12-month period between settlement of your firm=s financial accounts.
Purchases other than direct imports.--Purchases from U.S. producers, U.S. importers, and other U.S. sources,
excluding direct imports (which should be reported as imports in a U.S. importers’ questionnaire).

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