Preliminary Investigations - April

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

CERTAIN STEEL NAILS FROM THE UNITED ARAB EMIRATES
Investigation No. 731-TA-1185 (Preliminary)

Further information.--If you have any questions concerning the enclosed
questionnaire(s) or other matters related to this proceeding, you may contact
the following members of the Commission=s staff (Fax 202-205-3205):
Fred Ruggles, investigator (202-205-3187; E-mail [email protected])
regarding general questions and trade and related information;
Mary Klir, auditor (202-205-3247; E-mail [email protected])
regarding financial information; and
Clark Workman, economist (202-205-3248; E-mail [email protected])
regarding pricing, market, and related information.

GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on March 31, 2011,
by Mid Continent Nail Corporation, Poplar Bluff, Missouri. Antidumping duties may be assessed
on the subject imports as a result of this proceeding 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 this proceeding are available at
http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2011/steel_nails/prelimphase.htm.

Address all correspondence to the United States International Trade Commission, Washington,
DC 20436. Hearing-impaired individuals can obtain information regarding this proceeding via
the Commission=s TDD terminal (202-205-1810).
Due date of questionnaire(s).--Return the completed questionnaire(s) to the United States
International Trade Commission by no later than April 14, 2011. 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 April 14, 2011. If
you do not use the enclosed envelope, please make sure the completed questionnaire is sent to the
attention of Fred Ruggles. 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 this proceeding.
Service of questionnaire response(s).--In the event that your firm is a party to this proceeding,
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 this proceeding, 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 this proceeding or other import-injury proceedings
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 steel nails 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 732(c)(4) of the
Act (19 U.S.C. ' 1673a(c)(4)) to make a determination concerning the extent of industry support
for the petition requesting this proceeding. 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
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 this proceeding (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.
Filing instructions.—Questionnaires may be filed either electronically or in paper form.

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INSTRUCTIONS--Continued
OPTIONS FOR FILING
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/2011/steel_nails/prelimphase.htm.

Please do not attempt to modify the format or permissions of the questionnaire document. You
may complete the questionnaire and submit it, electronically, or you may print it out and submit it
in paper form, as described below:
• 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.
• 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

• 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. NO. 731-TA-1185. 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.
• Fax.—Fax to 202.205.3205.
• Overnight mail service.—Mail to the following address:
United States International Trade Commission
Office of Investigations, Room 615-B
500 E Street SW
Washington, DC 20024
• 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.
Note: If you are a party to the proceeding, and service of the questionnaire is required,
such service should be made in paper form.
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DEFINITIONS
Product.-- The merchandise covered by this proceeding includes certain steel nails having a shaft
length up to 12 inches. Certain steel nails include, but are not limited to, nails made of round wire
and nails that are cut. Certain steel nails may be of one piece construction or constructed of two or
more pieces. Certain steel nails may be produced from any type of steel, and have a variety of
finishes, heads, shanks, point types, shaft lengths and shaft diameters. Finishes include, but are not
limited to, coating in vinyl, zinc (galvanized, whether by electroplating or hot-dipping one or more
times), phosphate cement, and paint. Head styles include, but are not limited to, flat, projection,
cupped, oval, brad, headless, double, countersunk, and sinker. Shank styles include, but are not
limited to, smooth, barbed, screw threaded, ring shank and fluted shank styles. Screw-threaded
nails subject to this proceeding are driven using direct force and not by turning the fastener using
a tool that engages with the head. Point styles include, but are not limited to, diamond, blunt,
needle, chisel and no point. Certain steel nails may be sold in bulk, or they may be collated into
strips or coils using materials such as plastic, paper, or wire.
If properly classified, certain steel nails subject to this proceeding are currently classified under
the Harmonized Tariff Schedule of the United States (“HTSUS”) subheadings 7317.00.55,
7317.00.65, and 7317.00.75.
Excluded from the scope of this proceeding are steel nails specifically enumerated and identified
in ASTM Standard F 1667 (2005 revision) as Type I, Style 20 nails, whether collated or in bulk,
and whether or not galvanized.
Also excluded from the scope of this proceeding are non-collated (i.e., hand-drive or bulk),
two-piece steel nails having plastic or steel washers (“caps”) already assembled to the nail, having
a bright or galvanized finish, a ring, fluted or spiral shank, an actual length of 0.500” to 8”,
inclusive; an actual shank diameter of 0.1015” to 0.166”, inclusive; and an actual washer or cap
diameter of 0.900” to 1.10”, inclusive.
Also excluded from the scope of this proceeding are non-collated (i.e., hand-drive or bulk), steel
nails having a bright or galvanized finish, a smooth, barbed or ringed shank, an actual length of
0.500” to 4”, inclusive; an actual shank diameter of 0.1015” to 0.166”, inclusive; and an actual
head diameter of 0.3375” to 0.500”, inclusive, and whose packaging and packaging marking are
clearly and prominently labeled “Roofing” or “Roof” nails.
Also excluded from the scope of this proceeding are wire collated steel nails, in coils, having a
galvanized finish, a smooth, barbed or ringed shank, an actual length of 0.500” to 1.75”, inclusive;
an actual shank diameter of 0.116” to 0.166”, inclusive; and an actual head diameter of 0.3375” to
0.500”, inclusive, and whose packaging and packaging marking are clearly and prominently
labeled “Roofing” or “Roof” nails.

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DEFINITIONS--Continued
Product.—Continued
Also excluded from the scope of this proceeding are non-collated (i.e., hand-drive or bulk), steel
nails having a convex head (commonly known as an umbrella head), a smooth or spiral shank, a
galvanized finish, an actual length of 1.75” to 3”, inclusive; an actual shank diameter of 0.131” to
0.152”, inclusive; and an actual head diameter of 0.450” to 0.813”, inclusive, and whose
packaging and packaging marking are clearly and prominently labeled “Roofing” or “Roof” nails.
Also excluded from the scope of this proceeding are corrugated nails. A corrugated nail is made
of a small strip of corrugated steel with sharp points on one side.
Also excluded from the scope of this proceeding are thumb tacks, which, if properly classified, are
currently classified under HTSUS 7317.00.10.00.
Also excluded from the scope of this proceeding are fasteners suitable for use in powder-actuated
hand tools, not threaded and threaded, which, if properly classified, are currently classified under
HTSUS 7317.00.20 and 7317.00.30.
Also excluded from the scope of this proceeding are certain steel nails that are equal to or less than
0.0720 inches in shank diameter, round or rectangular in cross section, between 0.375 inches and
2.5 inches in length, and that are collated with adhesive or polyester film tape backed with a heat
seal adhesive. Also excluded from the scope of this proceeding are fasteners having a case
hardness greater than or equal to 50 HRC, a carbon content greater than or equal to 0.5 percent, a
round head, a secondary reduced-diameter raised head section, a centered shank, and a smooth
symmetrical point, suitable for use in gas-actuated hand tools.
While the HTSUS subheadings are provided for convenience and customs purposes, the written
description of the scope of this investigation 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 involved in the production, importation, and/or purchase
of certain steel nails (as defined above), including auxiliary facilities operated in conjunction with
(whether or not physically separate from) such facilities.

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DEFINITIONS--Continued
United States.--For purposes of this proceeding, 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 steel nails (as defined above) into the United States from a foreign
manufacturer or through its selling agent.
Imports.--Those products identified for Customs purposes as imports for consumption for which
your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
Import quantities.--Quantities reported should be net of returns.
Import values.--Values reported should be landed, duty-paid values at the U.S. port of
entry, including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
Purchaser.--Any person or firm engaged, either directly or through a parent company or
subsidiary, in purchasing certain steel nails (as defined above) from another firm that produces,
imports, or otherwise distributes certain steel nails.
Purchases.--Purchases from all sources, NOT including direct imports from foreign sources
located outside of the United States (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 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.
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 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.

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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.

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