12-1-2973 U.S. ProducerQuestionnaire

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

Producer Q - Brass Sheet

Brass Sheet and Strip from France, Germany, Italy, and Japan, Inv. No. 731-313 (3rd Review)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 12-1-2973; Expiration Date: 6/30/2014
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U.S. PRODUCERS’ QUESTIONNAIRE
BRASS SHEET AND STRIP FROM FRANCE, GERMANY, ITALY, AND JAPAN

This questionnaire must be received by the Commission by no later than November 23, 2011
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 review of the antidumping duty orders concerning C20000-series brass sheet and strip from France,
Germany, Italy and Japan (Inv. No. 731-TA-313, 314, 317, 379 (Third Review)). 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
City

State

Zip Code

World Wide Web address
Has your firm produced C20000-series brass sheet and strip (as defined in the instruction booklet) at any time
since January 1, 2005?

(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 reviews in any other import-injury proceedings or reviews
conducted by the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout these reviews 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 these reviews or related proceedings for which this information is submitted, or in internal audits and
proceedings 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

Date

Phone:
Signature

E-mail address
Fax

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 2

PART II.--TRADE AND RELATED 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.

Position regarding continuation of order.--Do you support or oppose continuation of the
antidumping duty order currently in place for C20000-series brass sheet and strip from the
following countries?
France

Support

Oppose

Take no position

Germany

Support

Oppose

Take no position

Italy

Support

Oppose

Take no position

Japan

Support

Oppose

Take no position

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 3

PART II.--TRADE AND RELATED INFORMATION--Continued
I-4.

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

Yes--List the following information.

Firm name

I-5.

I-6.

Address

Extent of ownership

Related SUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing C20000-series brass sheet and strip from
France, Germany, Italy or Japan into the United States or that are engaged in exporting C20000series brass sheet and strip from France, Germany, Italy and/or Japan to the United States?
No

Yes--List the following information.

Firm name

Address

Affiliation

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing C20000-series brass sheet and strip from
countries other than France, Germany, Italy or Japan into the United States or that are engaged in
exporting C20000-series brass sheet and strip from countries other than France, Germany, Italy
and/or Japan to the United States?
No

Yes--List the following information.

Firm name and country

Address

Affiliation

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 4

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

I-8.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of C20000-series brass sheet and strip?
No

Yes--List the following information.

Firm name

Address

Business plan.--In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for C20000-series brass
sheet and strip?
No

I-9.

Affiliation

Yes--Please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Nature of production operations.--Please identify the nature of your U.S. production

operations and your production capabilities with respect to C20000-series brass sheet and
strip as follows:
integrated producer

reroller

both

We are an:

We perform the following production processes to produce C20000-series brass
sheet and strip (check all that apply):
casting
hot rolling
cold rolling of brass sheet and strip we produce
cold rolling of brass sheet and strip reroll material purchased from others

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 5

PART II.--TRADE AND RELATED INFORMATION--Continued
Further information on this part of the questionnaire can be obtained from Joanna Lo (202-2051888, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Please identify the individual to be contacted regarding the confidential information requested in
part II.
Name and title:
Please indicate the manner by which Commission staff may contact the individual responsible for
part II with questions regarding the submitted confidential information.
E-mail:

Telephone:

Fax:
II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of C20000-series brass sheet and strip since January 1, 2005.
(check as many as appropriate)
plant openings ..........................

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

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

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

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

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

restructurings ............................

company or significant assent
sales................................................
prolonged shutdowns or
production curtailments .................
revised labor agreements ..........

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

(please describe)

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 6

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

II-3.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
your operations or organization (as noted above) relating to the production of C20000-series brass
sheet and strip in the future?
No

Yes--Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce C20000-series brass sheet and strip (in 1,000
pounds) for 2011 and 2012.

For question II-4, if your response differs for particular orders, please indicate and explain the
particular effect of revocation of specific orders.
II-4.

Anticipated changes in operations in the event the orders are revoked.--Would your firm
anticipate any changes in the character of your operations or organization (as noted above)
relating to the production of C20000-series brass sheet and strip in the future if the antidumping
duty orders on C20000-series brass sheet and strip from France, Germany, Italy, and/or Japan
were to be revoked?
No

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 7

PART II.--TRADE AND RELATED INFORMATION--Continued
II-5.

Same equipment, machinery, and workers.--Has your firm since 2005 produced, or does your
firm anticipate producing in the future, other products on the same equipment and machinery
used in the production of C20000-series brass sheet and strip and/or using the same production
and related workers employed to produce C20000-series brass sheet and strip?
No

Yes--List the following information and report your firm’s combined
production capacity and production of these products and C20000series brass sheet and strip in the periods indicated.
(Quantity in 1,000 pounds)
Production stage

Casting (all copper and copper alloy):
Total production capacity
Production
Hot-rolling:
Total production capacity
Production:
C20000-series brass sheet and strip (subject)
Other copper-alloy and copper sheet and strip
Plate of any alloy
Foil of any alloy
Other flat-rolled products
Total production
Cold-rolling:
Total production capacity
Production:
C20000-series brass sheet and strip (subject)
Other copper-alloy and copper sheet and strip
Plate of any alloy
Foil of any alloy
Other flat-rolled products
Total production
Annealing:
Total production capacity
Production:
C20000-series brass sheet and strip (subject)
Other copper-alloy and copper sheet and strip
Plate of any alloy
Foil of any alloy
Other flat-rolled products
Total production

2005

2006

2007

2008

2009

2010

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 8

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

II-6.

Constraints on production.--Please describe the constraint(s) that set the limit(s) on your
production capacity.
Casting Stage:

Hot-rolling Stage:

Cold-rolling Stage:

Annealing Stage:

II-7.

Production shifting.--Is your firm able to switch production between C20000-series brass sheet
and strip and other products in response to a relative change in the price of C20000-series brass
sheet and strip vis-a-vis the price of other products, using the same equipment and/or labor?
No

Yes--Please identify the other products, the approximate time and cost
involved in switching, and the minimum relative price change required
for your firm to switch production to or from C20000-series brass sheet
and strip.

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 9

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 C20000-series brass sheet and strip in your U.S.
establishment(s) during the specified periods. (See definitions in the instruction booklet.)
Quantity (in 1,000 pounds) and value (in $1,000)
JanuarySeptember

Calendar year
Item

2005

2006

2007

2008

2009

2010

2011

Average production capacity1 (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial toll shipments:
quantity (D)
value (E)
Commercial nontoll shipments:
quantity (F)
value (G)
Internal consumption:2
quantity (H)
value (I)
Transfers to related firms:2
quantity (J)
value (K)
Export shipments:3
quantity (L)
value (M)
End-of-period inventories (quantity) (N)
Channels of distribution:
U.S. shipments to distributors (quantity) (O)
U.S. shipments to end users (quantity) (P)
Employment data:
Average number of PRWs (number) (Q)
Hours worked by PRWs (1,000 hours) (R)
Wages paid to PRWs (value) (S)
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 should 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:

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 10

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

Categories of U.S. shipments.--Report your firm’s shipments of C20000-series brass sheet and
strip produced in your U.S. establishments(s) by the categories of shipments during the specified
periods.

(Quantity in 1,000 pounds)
JanuarySeptember

Calendar year
Item
U.S. shipments to rerollers
U.S. shipments subject to “Buy
American” requirements or to
customers who otherwise will
buy only U.S. produced brass
sheet and strip
Internal consumption
Transfers to related firms
Other U.S. shipments
Total

2005

2006

2007

2008

2009

2010

2011

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 11

PART II.--TRADE AND RELATED INFORMATION--Continued
II-10.

Trade data.--Report your firm’s production capacity, production, shipments, inventories, and
employment related to the reroll of C20000-series brass sheet and strip in your U.S.
establishment(s) during the specified periods. (See definitions in the instruction booklet.)
Quantity (in 1,000 pounds) and value (in $1,000)
JanuarySeptember

Calendar year
Item

2005

2006

2007

2008

2009

2010

2011

Average production capacity1 (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:2
quantity (F)
value (G)
Transfers to related firms:2
quantity (H)
value (I)
Export shipments:3
quantity (J)
value (K)
End-of-period inventories (quantity) (L)
Channels of distribution:
U.S. shipments to distributors (quantity) (M)
U.S. shipments to end users (quantity) (N)
Employment data:
Average number of PRWs (number) (O)
Hours worked by PRWs (1,000 hours) (P)
Wages paid to PRWs (value) (Q)
1
The production capacity (see definitions in instruction booklet) reported is based on operating
hours per week,
weeks
per year. Please describe the methodology used to calculate production capacity, and explain any changes in reported capacity (use
additional pages as necessary).

Identify your principal export markets:

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 12

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

Reconciliation of trade data for producers.--

(a)

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

(b)

Yes

No--Please

Yes

No--Please

Please note that the quantities reported for end-of-period inventories should equal the
beginning-of-period inventories reported in the subsequent calendar year (i.e., line N of
year 2005 should equal line B of year 2006). Do these data reconcile for each adjacent
calendar year?
Yes.

II-12.

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

No--Please explain.

Reconciliation of trade data for rerollers.--

(a)

Please note that the quantities reported in question II-10 should reconcile as follows in
each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L
D+F+H=M+N

(b)

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

Yes

No--Please

Yes

No--Please

Please note that the quantities reported for end-of-period inventories should equal the
beginning-of-period inventories reported in the subsequent calendar year (i.e., line L of
year 2005 should equal line B of year 2006). Do these data reconcile for each adjacent
calendar year?
Yes.

No--Please explain.

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 13

PART II.--TRADE AND RELATED INFORMATION--Continued
II-13.

Transfers to 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.

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 14

PART II.--TRADE AND RELATED INFORMATION--Continued
II-14.

Purchases.--Other than direct imports, has your firm otherwise purchased C20000-series brass
sheet and strip since January 1, 2005? (See definitions in the instruction booklet.)
No

Yes-- Please indicate the reasons for your purchases (if your reasons differ by
source, please elaborate) and report the quantity and value of such
purchases below for the specified periods

Reasons:
(Quantity in 1,000 pounds, value in $1,000)
Item

2005

2006

2007

2008

2009

2010

PURCHASES FROM U.S.
IMPORTERS1 OF C20000-SERIES
BRASS SHEET AND STRIP FROM.-FRANCE:
quantity
value
GERMANY:
quantity
value
ITALY:
quantity
value
JAPAN:
quantity
value
All other countries:
quantity
value
PURCHASES FROM DOMESTIC
PRODUCERS:2
quantity
value
PURCHASES FROM OTHER
SOURCES:
quantity
Value
1

Please list the name of the importer(s) from which you purchased this product. If your suppliers differ by
source, please identify the source for each listed supplier.
2

Please list the name of the domestic producer(s) from which you purchased this product.

II-15.

Toll production.--Since January 1, 2005, has your firm been involved in a toll agreement (see
definition in the instruction booklet) regarding the production of C20000-series brass sheet and
strip?
No

Yes--Name firm(s):

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 15

PART II.--TRADE AND RELATED INFORMATION--Continued
II-16.

FTZ.--Does your firm produce C20000-series brass sheet and strip in a foreign trade zone (FTZ)?
No

II-17.

Yes--Identify FTZ(s):

Direct imports.--Since January 1, 2005, has your firm imported C20000-series brass sheet and
strip?
No

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

For questions II-18 and II-19, if your response differs for particular orders, please indicate and
explain the particular effect of imposition and/or revocation of specific orders.
II-18.

Effect of orders.--Describe the significance of the existing antidumping duty orders covering
imports of C20000-series brass sheet and strip from France, Germany, Italy, and Japan in terms of
its effect on your firm’s production capacity, production, U.S. shipments, inventories, purchases,
employment, revenues, costs, profits, cash flow, capital expenditures, research and development
expenditures, and asset values. You may wish to compare your firm’s operations before and after
the imposition of the order.

II-19.

Likely effect of revocation of orders.--Would your firm anticipate any changes in its production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, or asset values
relating to the production of C20000-series brass sheet and strip in the future if the antidumping
duty order on C20000-series brass sheet and strip from France, Germany, Italy, and Japan were to
be revoked?
No

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 16

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247,
[email protected]).
III-1.

Please identify the individual to be contacted regarding the confidential information requested in
part III?
Name and title:
Please indicate the manner by which Commission staff may contact the individual responsible for
part III with questions regarding the submitted confidential information.
E-mail:

Telephone:

Fax:
III-2.

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
C20000-series brass sheet and strip, 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 - Brass Sheet and Strip

Page 17

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

Other products.--Please list any other products you produced in the facilities in which you
produced C20000-series brass sheet and strip, and provide the share of net sales accounted for by
these other products in your most recent fiscal year:
Products

III-6.

Share of sales

Does your firm receive inputs (raw materials, labor, energy, or any other services) used in the
production of C20000-series brass sheet and strip from any related firms?
Yes—Continue to question III-7 below.

III-7.

Inputs from related firms.--In the space provided below, identify the inputs used in the
production of C20000-series brass sheet and strip that your firm receives from related parties.
Input

III-8.

No--Continue to question III-9 below.

Related party

Inputs from related firms at cost.--All intercompany profit on inputs purchased from related
parties should be eliminated from the costs reported to the Commission in question III-10 (i.e.,
costs reported in question III-10 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

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 18

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

Nonrecurring charges.--For each annual and interim period for which financial results are
reported in question III-10, please indicate in the schedule below the specific nonrecurring
charges, the particular expense/cost line items from question III-10 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 C20000-series brass sheet and
strip operations.
Fiscal years ended--

January-September

Item
Non-recurring charges: (In the far left 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-10.)
1.
2.
3.
4.
5.
6.
7.

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 19

PART III.--FINANCIAL INFORMATION--Continued
III-10. Operations on C20000-series brass sheet and strip.--Report the revenue and related cost
information requested below on the C20000-series brass sheet and strip 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 six most recently completed fiscal years in chronological
order from left to right, and for the specified interim periods.
Quantity (in 1,000 pounds) and value (in $1,000)
Item
Net sales quantities:3
Commercial sales (“CS”)
Tolling revenue (“TR”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
Net sales values:3
Commercial sales
Tolling revenue
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
Continued Dumping and Subsidy Offset Act
5
funds received

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 eliminate any profits or (losses) on inputs from related firms pursuant question III-8.
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 CS, TR, IC, and Transfers, as well as export shipments in question II-8.
5
Please report funds received under this act in the period(s) in which they were received. Do not report these funds as an offset to
operating expenses.
2

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 20

PART III.--FINANCIAL INFORMATION--Continued
III-10. Operations on C20000-series brass sheet and strip.--Continued
Quantity (in 1,000 pounds) and value (in $1,000)
Item

January-September 2010

January-September 2011

Net sales quantities:
Commercial sales
Tolling revenue

Internal consumption
Transfers to related firms
Total net sales quantities
Net sales values:3
Commercial sales
Tolling revenue
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
Continued Dumping and Subsidy Offset Act funds
5
received

All other income items
All other income or expenses, net
Net income or (loss) before income taxes
Depreciation/amortization included above
1

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 21

PART III.--FINANCIAL INFORMATION--Continued
III-11. Asset values.--Report the total assets associated with the production, warehousing, and sale of
C20000-series brass sheet and strip. If your firm does not maintain some or all of the specific
asset information necessary to calculate total assets for C20000-series brass sheet and strip in the
normal course of business, please estimate this information based upon some rational method
(such as production, sales, or costs) that is consistent with your cost allocations in the previous
question. Provide data as of the end of your six most recently completed fiscal years in
chronological order from left to right.
Note: Total assets should be net assets after any accumulated depreciation and allowances deducted.
Total assets should be allocated to the subject products if these assets are also related to other products.
Please provide a brief explanation if there are any substantial changes in total asset value during the
period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)

III-12. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on C20000-series brass sheet and strip.
Provide data for your six most recently completed fiscal years in chronological order from left to
right, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended-Item

January-September
2010

2011

Capital expenditures
Research and
development expenses

III-13. Data consistency and reconciliation.-Please indicate whether your financial data for questions III-10, 11, and 12 are based
on a calendar year or your fiscal year: Calendar year (
) or
Fiscal year (
Please note the quantities and values reported in question III-10 should reconcile with the data
reported in question II-8 (including export shipments) as long as they are reported on the same
calendar year basis.
Do these data in question III-10 reconcile with data in question II-8?
Yes

No--Please explain

________________________

)

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 22

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202205-3250, [email protected]).
IV-1.

Please identify the individual to be contacted regarding the confidential information requested in
part IV?
Name and title:
Please indicate the manner by which Commission staff may contact the individual responsible for
part IV with questions regarding the submitted confidential information.
E-mail:

Telephone:

Fax:
PRICE DATA
IV-2.

This question requests quarterly quantity and value data, f.o.b. your U.S. point of shipment, for
your commercial shipments to unrelated U.S. customers since 2005 of the following products
produced by your firm.

Product 1.— Distributors, CDA end-use classification 920, CDA alloy 260,0.020-inch to 0.025-inch
thick by maximum yield width, uncoated, without special surface finish, without special
annealing requirements, and without special tolerances
Product 2.-- Reroll, CDA end-use classification 910, alloy 260, 0.050-inch to 0.080-inch thick
by maximum yield width, uncoated, without special surface finish, without special annealing
requirements, and without special tolerances
Product 3.— Automotive electrical, CDA end-use classification 320, CDA alloy 230 and/or alloy
260, 0.0098 inch to 0.020 inch by 0.5 inch to 2 inches in width, not tin coated
Product 4.—Closures, CDA end-use classification 620, CDA alloy 260, 0.010-inch - 0.016-inch thick
by 1 inch to 4 inches in width
Product 5.— End users, CDA alloy 272, 0.015-inch to 0.020-inch thick, 0.75 – 2.00 inch wide,
without coating, without special tolerances, and without special surface finish
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.
Fabrication should include fabrication charges plus any surcharges/additions related to fabrication such
as energy surcharges.
Metal exchange price component should be the LME/COMEX settlement prices you used for zinc and
copper for the product on the date the metal price was fixed.
Metal premium should include any additions to the cost of metal reported in the “metal exchanged price
component” above, such as interest surcharges or other riders/surcharges.

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 23

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
(Quantity in pounds, value in dollars)
Product 1 nontolled sales
Value
Metal
exchange
price
Metal
Quantity Fabrication component premium
Total

Product 1 tolled sales

Fabrication
Period of shipment
Quantity
value
2005:
January-March
April-June
July-September
October-Dec.
2006:
January-March
April-June
July-September
October-Dec.
2007:
January-March
April-June
July-September
October-Dec.
2008:
January-March
April-June
July-September
October-Dec.
2009:
January-March
April-June
July-September
October-Dec.
2010:
January-March
April-June
July-September
October-Dec.
2011:
January-March
April-June
July-September
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:

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 24

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.—Continued
(Quantity in pounds, value in dollars)
Product 2 nontolled sales
Value
Metal
exchange
price
Metal
Quantity Fabrication component premium
Total

Product 2 tolled sales

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 25

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.—Continued
(Quantity in pounds, value in dollars)
Product 3 nontolled sales
Value
Metal
exchange
price
Metal
Quantity Fabrication component premium
Total

Product 3 tolled sales

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 26

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.—Continued
(Quantity in pounds, value in dollars)
Product 4 nontolled sales
Value
Metal
exchange
price
Metal
Quantity Fabrication component premium
Total

Product 4 tolled sales

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 27

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.—Continued
(Quantity in pounds, value in dollars)
Product 5 nontolled sales
Value
Metal
exchange
price
Metal
Quantity Fabrication component premium
Total

Product 5 tolled sales

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 28

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-3.

(a) Price setting.-- How does your firm determine the prices (including surcharges) that it
charges for fabrication in your sales of C20000-series brass sheet and strip (check all that apply)?
If your firm issues price lists, please include a copy of a recent price list with your submission. If
your price list is large, please only submit some sample pages.
Transaction by transaction

Contracts

Set price lists

Other--Please describe:

(b) How does your firm determine the prices that it charges for metal in your sales of C20000series brass sheet and strip? Include what specific reference prices for copper and zinc you use
and time lags between when the price of metal changes and when the price your charge changes.

(c) If you sell both tolled and nontolled C20000-series brass sheet and strip do the prices you
charge for fabrication of tolled and nontolled differ? Please explain why.
No

Yes

Do not sell both tolled and nontolled.

(d) Please include with your responses copies of all general price announcements between
January 1, 2005 and the date of the submission of your response to this questionnaire that
includes notice of a price change for C20000-series brass sheet and strip.
IV-4.

Surcharges.-(a)

Since 2005, has your firm included surcharges on its invoices for any of the following
(check all that apply)?
Raw materials

Fuel

Energy

Transportation

Other:

(b)

How did your firm determine the surcharge(s) (e.g., which indices were used)?

(c)

Please describe how the surcharges have changed since 2005.

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 29

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-5.

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

Annual total volume discounts

No discounts

Other--Please describe:

IV-6.

IV-7.

Pricing terms for C20000-series brass sheet and strip.-(a)

What are your firm’s typical sales terms for its U.S.-produced C20000-series brass sheet
and strip (e.g., 2/10 net 30 days)?
.

(b)

On what basis are your prices of domestic C20000-series brass sheet and strip usually
quoted? (check one)
F.o.b.--Please specify point:
Delivered

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
C20000-series brass sheet and strip in 2010 were on a (1) long-term contract basis (multiple
deliveries for more than 12 months), (2) short-term contract basis (multiple deliveries up to and
including 12 months), and (3) spot sales basis (for a single delivery)?
Type of sale

IV-8.

Share of sales (percent)

Long-term contracts

Short-term contracts

Spot sales

Long-term contract 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?

days

(b)

Can prices be renegotiated during the contract period?

(c)

Does the contract fix quantity, price, or both?

(d)

Does the contract have a meet or release provision?

Yes

Quantity

No
Price

Yes

Both
No

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 30

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-9.

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?

days

(b)

Can prices be renegotiated during the contract period?

(c)

Does the contract fix quantity, price, or both?

(d)

Does the contract have a meet or release provision?

Yes

Quantity

Price
Yes

Both
No

IV-10. Lead times.—
(a) 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 C20000-series brass sheet and strip?
Source

Share of sales in 2010

Lead time

From inventory

days

Produced to order

days

Total

100 %

(b) Did you provide lead time information for C20000-series brass sheet and strip to your
customers at any time since January 1, 2005?
No

Date
March 2005
June 2005
September 2005
December 2005
March 2006
June 2006
September 2006
December 2006
March 2007
June 2007
September 2007
December 2007
March 2008
June 2008
September 2008
December 2008

Yes--Please report the average lead time you reported to your customers at (or
as close as possible to) the end of the months in the table below.
Lead time (days)

Date
March 2009
June 2009
September 2009
December 2009
March 2010
June 2010
September 2010
December 2010
March 2011
June 2011
September 2011

Lead time (days)

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 31

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-11. Shipping information.-(a)

What is the approximate percentage of the total delivered cost of C20000-series brass
sheet and strip 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.

IV-12. Geographical shipments.-- What is the geographic market area in the United States served by
your firm’s C20000-series brass sheet and strip? (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-13. End uses.--List the end uses of the C20000-series brass sheet and strip that you manufacture. For
each end-use product, what percentage of the total cost is accounted for by C20000-series brass
sheet and strip and other inputs?
Share of total cost of end use product
accounted for by

End use product
1.

C20000-series brass
sheet and strip
(percent)
%

Other inputs (percent)
%

Total
100%

100%
100%

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U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 32

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-14. Changes in end uses.--Have there been any changes in the end uses of C20000-series brass sheet
and strip since 2005?
No

Yes--Please describe.

IV-15. Anticipated changes in end uses.--Do you anticipate any changes in terms of the end uses of
C20000-series brass sheet and strip in the future?
No

Yes--Please describe and identify the time period

IV-16. Substitutes.—Are there any nonsubject products that may be substituted for C20000-series brass
sheet and strip?
No

Yes—Please fill in the following table.

Substitute product
1.

Description of applications
and end uses in which this
substitute can be used

Have changes in the prices of this
substitute affected the price of C20000series brass sheet and strip since
January 1, 2005

Yes

Please explain--

Yes

Please explain--

Yes

Please explain--

Yes

Please explain--

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 33

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-17. Changes in substitutes.--Have there been any changes in the number or types of products that
can be substituted for C20000-series brass sheet and strip since 2005?
No

Yes--Please explain.

IV-18. Anticipated changes in substitutes.--Do you anticipate any changes in terms of the
substitutability of other products for C20000-series brass sheet and strip?
No

Yes--Please describe.

IV-19. Raw materials.—
(a)

To what extent have changes in the prices of raw materials affected your firm’s selling
prices for C20000-series brass sheet and strip since 2005?

(b)

Do you anticipated changes in your raw material costs in the foreseeable future?
No

Yes—Please explain.

IV-20. Changes in factors affecting supply.--Have any changes occurred in any other factors affecting
supply (e.g., changes in availability or prices of energy or labor; transportation conditions;
production capacity and/or methods of production; technology; export markets; or alternative
production opportunities) that affected the availability of U.S.-produced C20000-series brass
sheet and strip in the U.S. market since 2005?
No

Yes-- Please provide details.

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 34

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-21. Availability of supply (U.S.-produced).-(a)

Do you anticipate any changes in terms of the availability of U.S.-produced C20000series brass sheet and strip in the U.S. market in the future?
Increase

(b)

No change

Decrease

If you anticipate changes in supply, please explain.

IV-22. Availability of supply (nonsubject).--Has the availability of NONSUBJECT C20000-series
brass sheet and strip (i.e., C20000-series brass sheet and strip imported from countries other than
France, Germany, Italy and Japan) changed since 2005?
No

Yes--Please explain.

IV-23. Export constraints.--Describe how easily your firm can shift its sales of C20000-series brass
sheet and strip between the U.S. market and alternative country markets. In your discussion,
please describe any contracts, other sales arrangements, or other constraints that would prevent or
retard your firm from shifting C20000-series brass sheet and strip between the U.S. and
alternative country markets within a 12-month period.

IV-24. Product changes.--Have there been any significant changes in the product range, product mix, or
marketing of C20000-series brass sheet and strip since 2005?
No

Yes--Please describe and quantify if possible.

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 35

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-25. Anticipated product changes.--Do you anticipate any changes in terms of the product range,
product mix, or marketing of C20000-series brass sheet and strip in the future?
No

Yes--Please identify, including the time period.

IV-26. Demand trends.-(a)

How has the demand within the United States for C20000-series brass sheet and strip
changed since January 1, 2005? What principal factors affect changes in demand?
Increased

(b)

No Change

Decreased

Fluctuated

Don’t Know

How has the demand outside the United States for C20000-series brass sheet and strip
changed since January 1, 2005? What principal factors affect changes in demand?
Increased

No Change

Decreased

Fluctuated

Don’t Know

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 36

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-27. Anticipated demand trends.—
(a)

How do you anticipate demand will change within the United States for C20000-series
brass sheet and strip in the future? What principal factors will affect these changes in
demand?
Increase

(b)

No Change

Decrease

Fluctuate

How do you anticipate demand will change outside the United States for C20000-series
brass sheet and strip? What principal factors will affect these changes in demand?
Increase

No Change

Decrease

Fluctuate

IV-28. Conditions of competition.-(a)

Is the C20000-series brass sheet and strip market subject to any business cycles or is it
subject to special conditions of competition?
No

(b)

Yes--Please explain and estimate the duration of any such cycle.

Have the business cycles or conditions of competition for C20000-series brass sheet and
strip changed since 2005?
No

Yes--Please explain any such changes.

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 37

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-29. Price comparisons.—
(a)

Please compare market prices of C20000-series brass sheet and strip in U.S. and nonU.S. markets. Provide specific information as to time periods and regions for any price
comparisons.

(b)

Do other markets use fabrication and metal value to set prices? Please explain any
difference.
No

Yes

Do not know

IV-30. Market studies.--Please provide as a separate attachment to this request any studies, surveys, etc.
that you are aware of that quantify and/or otherwise discuss C20000-series brass sheet and strip
supply (including production capacity and capacity utilization) and demand in (1) the United
States, (2) each of the other major producing/consuming countries, including France, Germany,
Italy and Japan, and (3) the world as a whole. Of particular interest is such data from 2005 to the
present and forecasts for the future.
IV-31. Barriers to trade.--Are your exports of C20000-series brass sheet and strip subject to any tariff
or non-tariff barriers to trade in other countries?
No

Yes--Please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since 2005, or
that are expected to occur in the future.

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 38

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-32. Interchangeability.--Is C20000-series brass sheet and strip 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

France

Germany

Italy

Japan

Other countries

United States
France
Germany
Italy
Japan
1

For any country-pair producing C20000-series brass sheet and strip that is sometimes or never
interchangeable, please explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire - Brass Sheet and Strip

Page 39

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-33. Factors other than price.--Are differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between C20000-series brass sheet
and strip 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

France

Germany

Italy

Japan

Other countries

United States
France
Germany
Italy
Japan
1

For any country-pair for which differences other than price always or frequently are a significant factor
in your firm’s sales of C20000-series brass sheet and strip, identify the country-pair and report the
advantages or disadvantages imparted by such differences:

File Type	application/pdf
File Title	Microsoft Word - Producer Q - Brass Sheet.doc
Author	joanna.lo
File Modified	2011-10-18
File Created	2011-10-18