12-1-3043 U.S. Producer Questionnaire

OMB No. 3117-0016/USITC No. 12-1-3043; Expiration Date: 6/30/2014
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
SILICOMANGANESE FROM BRAZIL, CHINA, AND UKRAINE

This questionnaire must be received by the Commission by no later than July 2, 2012
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 silicomanganese from Brazil, China, and Ukraine
(Inv. Nos. 731-TA-671-673 (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
State

City

Zip Code

World Wide Web address
Has your firm produced silicomanganese (as defined in the instruction booklet) at any time since January 1, 2006?

NO

(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 this proceeding 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 this proceeding may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of this proceeding 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:

Business Proprietary
U.S. Producers’ Questionnaire -- Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 2

PART I.—GENERAL INFORMATION
The questions in this questionnaire have been reviewed with market participants to ensure that issues of
concern are adequately addressed and that data requests are sufficient, meaningful, and as limited as
possible. Public reporting burden for this questionnaire is estimated to average 50 hours per response,
including the time for reviewing instructions, searching existing data sources, gathering the data needed,
and completing and reviewing the questionnaire. Send comments regarding the accuracy of this burden
estimate or any other aspect of this collection of information, including suggestions for reducing the
burden, to the Office of Investigations, U.S. International Trade Commission, 500 E Street, SW,
Washington, DC 20436.
I-1a.

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of preparing the reply to this questionnaire and completing the form.
hours

dollars

I-1b.

OMB feedback.--We are interested in any comments you may have for improving this
questionnaire in general or the clarity of specific questions. Please attach such comments to your
response or send them to the above address.

I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire (see page 3 of the instruction booklet for reporting guidelines). If your firm is
publicly traded, please specify the stock exchange and trading symbol.

I-3.

Position regarding continuation of order.--Do you support or oppose continuation of the
antidumping duty orders currently in place for silicomanganese from the following countries?
Brazil

Support

Oppose

Take no position

China

Support

Oppose

Take no position

Ukraine

Support

Oppose

Take no position

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 3

PART I.--GENERAL 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 silicomanganese from Brazil, China, and
Ukraine into the United States or that are engaged in exporting silicomanganese from Brazil,
China, and Ukraine 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 silicomanganese from countries other than
Brazil, China, and Ukraine into the United States or that are engaged in exporting
silicomanganese from countries other than Brazil, China, and Ukraine to the United States?
No

Yes--List the following information.

Firm name and country

Address

Affiliation

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

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PART I.--GENERAL 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 silicomanganese?
No

Yes--List the following information.

Firm name

Address

Affiliation

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 silicomanganese?
No

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

Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Russell Duncan (202-7084727, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted in
part II.
Name:
Title:
Email:
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 silicomanganese since January 1, 2006.
(check as many as appropriate)
plant openings ..............................

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

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

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

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

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

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

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

(please describe)

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

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 silicomanganese 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 silicomanganese (in short tons) for 2012 and 2013.

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 order is revoked.--Would your firm
anticipate any changes in the character of your operations or organization (as noted above)
relating to the production of silicomanganese in the future if the antidumping duty orders on
silicomanganese from Brazil, China, and Ukraine were to be revoked?
No

II-5.

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 silicomanganese (in short tons) for 2012 and 2013.

Technology changes.--Have there been any significant changes in the technologies available for
the production of silicomanganese since the initial imposition of the antidumping duty orders?
No

Yes--Please describe.

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 7

PART II.--TRADE AND RELATED INFORMATION--Continued
II-6.

Furnace count and specs.--Please detail your firms’ furnaces and their specifications used in
production of silicomanganese in the United States.
Short description of furnace specifications
(and if not operated thoroughout the period
Location
of review a discussion of the periods
(City, State)
operated)

Dedicated to
SiMag
production
(check = yes)

Year purchased,
installed, or
acquired (year)

1.

2.

3.

4.

5.

6.

7.

8.

More than eight.--Check here if your firm operated more than eight furnaces in the production of
silicomanganese in the United States since January 1, 2006, and please provide the same
information as requested in the above grid for those additional furnaces as an attachment to your
firm’s response to this questionnaire.

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 8

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

Product shifting.--Please provide answers to each of the following questions relating to your
firm’s ability to shift production between silicomanganese and other products.
(a)

In relation to those furnaces (reported in question II-6 above) not dedicated 100 percent
to the production of silicomanganese, please provide the following information on the
other products produced in those furnaces (if more than four products, list the largest).

Costs and timeframes involved in switching
production to/from SiMag

Product(s)

Est. share of furnace
fleet’s production time
dedicated to product1
(share)

1. Ferromanganese

2. Ferrosilicon

3.

4.

1

Provide an estimated share here that represents how much of the annual average total production
hours of the all the furnaces reported in question II-6 (a.k.a., furnace fleet) relates to the production of the
listed product in a given year. For example, report 25 percent of ferromanganese if in a year 500 hours
are dedicated to ferromanganese and 1500 dedicated to silicomanganese.

Additional discussion:

(b)

In relation to those furnaces (reported in question II-6 above) dedicated 100 percent to the
production of silicomanganese since January 1, 2006, could these furnaces be converted
to the production of products other than silicomanganese?
No

Yes.--And at what cost/time constraint?

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

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

Product shifting.--Continued
(c)

Does your firms own or operate furnaces not reported in question II-6 at all (i.e., not
involved in silicomanganese production during the period) that could be converted to the
production of silicomanganese?
No

II-8

Yes.--And at what cost/time constraint?

Overall capacity.--Based on your firm’s typical silicomanganese operations (i.e., typical hours
per week and weeks per year) and in relation to only those furnaces actually used to produce
silicomanganese at any time since January 1, 2006 (i.e., reported in question II-6 and not those
discussed in II-7c), please report the following information.
Item

2006

2007

2008
2009
Quantity (short tons)

2010

2011

Overall production capacity1
Production of:
Silicomanganese
Ferromanganese
Ferrosilicon
Other product 3 (from Q II-7a)
Other product 4 (from Q II-7a)
All other products2
1
The overall production capacity reported here relates to operating your firm’s furnaces used in the production
hours per week and
weeks per year, and indicate how
of silicomanganese (as reported in question II-6)
the overall production capacity quantity figure was arrived at:

II-9.

Constraints on production.--Please describe the constraint(s) that set the limit(s) on your
production capacity for silicomanganese.

Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 10

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 production of silicomanganese in your U.S. establishment(s) during the
specified periods. (See definitions in the instruction booklet.)
Quantity (short tons) and value (in $1,000)
Calendar year
Item

2006

2007

2008

2009

2010

2011

Average production capacity1
(quantity) (A)
BOP 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)
EOP 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

If your firm produces more than just silicomanganese on its furnaces (i.e., production of silicomanganese does not
equal the totality of all production as reported in question II-8), on what basis did your firm allocate overall capacity (reported
in question II-7) to the average production capacity reported here (e.g., share of production, hours dedicated, other…)?

2

Are values of internal consumption shipments (line G) and transfer shipments (line I) reported at fair market value
pursuant to Commission instruction?
Yes
No 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 the specific formula or methodology for arriving
at the value data reported in those lines.

3

Identify your principal export markets and a percentage approximation of their share of your firm’s total export
shipments reported (i.e., Canada approx. 60 percent, Mexico approx. 25 percent, rest UK, Germany and Italy):
.

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

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

Trade data.--Continued
Quantity (short tons) and value (in $1,000)
January-March
Item

2011

2012

Average production capacity1 (quantity) (A)
BOP 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)
EOP 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)

II-11.

Reconciliation of trade data.-(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

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

Yes

No--Please

Yes

No--Please

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

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

Reconciliation of trade data.--Continued
(b)

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 2006 should equal line B of year 2007). Do these data reconcile for each adjacent
calendar year?
Yes

No--Please explain.

II-12.

Transfers to related firms.--If you reported transfers to related firms in question II-10, please
indicate the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a non-market
formula, whether your firm retained marketing rights to all transfers, and whether the related
firms also processed inputs from sources other than your firm.

II-13.

Toll production.--Since January 1, 2006, has your firm been involved in a toll agreement (see
definition in the instruction booklet) regarding the production of silicomanganese ?
No

II-14.

.

FTZ.--Does your firm produce silicomanganese in a foreign trade zone (FTZ)?
No

II-15.

Yes--Name firm(s):

Yes--Identify FTZ(s):

Direct imports.--Since January 1, 2006, has your firm imported silicomanganese from any
source (i.e., when your firms is the importer of record for Customs purposes)?
No

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

.

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 13

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

Purchases.--Other than direct imports (i.e., when your firms is the importer of record for
Customs purposes), has your firm otherwise purchased silicomanganese since January 1, 2006?
(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 short tons, value in $1,000)
Calendar year
Item

2006

2007

2008

2009

January-March
2010

2011

2011

2012

PURCHASES FROM U.S.
1
SUPPLIER OF IMPORTED
SILICOMANGANESE
FROM:—
Brazil
quantity
value
China
quantity
value
Ukraine:
quantity
value
All other countries:
quantity
value
PURCHASES FROM U.S.
SUPPLIER2 OF
DOMESTICALLY PRODUCED
SILICOMANGANESE:
Quantity
Value
PURCHASES FROM U.S.
SUPPLIER3 FOR WHICH
COUNTRY OF ORIGIN IS
NOT KNOWN:
quantity
value
1

Please list the name of the importer(s) or supplier(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) or supplier(s) from which you purchased this product.

3

Please list the name the supplier(s) from which you purchased this product.

Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 14

PART II.--TRADE AND RELATED INFORMATION--Continued
For questions II-17 and II-18, if your response differs for particular orders, please indicate and
explain the particular effect of imposition and/or revocation of specific orders.
II-17.

Effect of order.--Describe the significance of the existing antidumping duty orders covering
imports of silicomanganese from Brazil, China, and Ukraine 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-18.

Likely effect of revocation of order.--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 silicomanganese in the future if the antidumping duty orders
covering imports of silicomanganese from Brazil, China, and Ukraine were to be revoked?
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 for any trends or
projections you may provide.

Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 15

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Justin Jee (202-205-3186, [email protected]).
III-1.

Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted in
part III.
Name:
Title:
Email:
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 silicomanganese:

2.

Does your firm prepare profit/loss statements for the silicomanganese:
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,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive basis
of accounting (specify)

3.

4.

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
silicomanganese, 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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Page 16

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

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

Share of sales
%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any other services) used in the
production of silicomanganese 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 silicomanganese that your firm purchases 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

No--Please contact Justin Jee (202-205-3186, [email protected]).

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 17

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

Nonrecurring items (charges and gains) included in silicomanganese financial results.--For
each annual and interim period for which financial results are reported in question III-10, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-10 line item where the nonrecurring items are included, a brief description of
the relevant nonrecurring items, and the associated values (in $1,000), as reflected in table III-10;
i.e., if an aggregate nonrecurring item has been allocated to table III-10, only the allocated value
amount included in table III-10 should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported silicomanganese financial results in table III-10.
Fiscal year (ended) or calendar year
2006

Nonrecurring item: In this column
please provide a brief description of each
nonrecurring item and indicate the
specific table III-10 line item where the
nonrecurring item is included.
1.
2.
3.
4.
5.
6.
7.

2007

2008

2009

2010

January-March
2011

2011

2012

Nonrecurring item: In these columns please report the amount (in $1,000) of the relevant
nonrecurring item reported in table III-10.

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U.S. Producers’ Questionnaire - Silicomanganese from Brazil, China, and Ukraine (3rd Review)

Page 18

PART III.--FINANCIAL INFORMATION--Continued
III-10. Operations on silicomanganese.--Report the revenue and related cost information requested
below on the silicomanganese 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 or calendar years, and for the specified interim periods. If your firm
was involved in tolling operations (either as the toller or as the tollee), please contact Justin Jee
(202-205-3186, [email protected]) before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal year (ended) or calendar year
Item

2006

2007

2008

2009

2010

2011

Net sales quantities:3
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):4
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other income and expenses:
Interest expense
All other expense items
All other income items
All other income or expenses, net
Net income or (loss) before income taxes
Depreciation/amortization included above
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Please eliminate any profits or (losses) on inputs from related firms pursuant question III-8.
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, IC, and Transfers, as well as export shipments in question II-9.
2

3

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PART III.--FINANCIAL INFORMATION--Continued
III-10. Operations on silicomanganese.--Continued
Quantity (in short tons) and value (in $1,000)
Item

January-March 2011

January-March 2012

3

Net sales quantities:
Commercial sales

Internal consumption
Transfers to related firms
Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):4
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other income and expenses:
Interest expense
All other expense items
All other income items
All other income or expenses, net
Net income or (loss) before income taxes
Depreciation/amortization included above
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Please 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, IC, and Transfers, as well as export shipments in question II-8.
2

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PART III.--FINANCIAL INFORMATION--Continued
III-11. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with the
production, warehousing, and sale of silicomanganese. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for silicomanganese in the
normal course of business, please estimate this information based upon a 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 or calendar years.
Note: Total assets should reflect 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 year (ended) or calendar year
Item

2006

2007

2008

2009

2010

2011

Total assets (net)

Additional explanations (if applicable):

III-12. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on silicomanganese. Provide data for your
six most recently completed fiscal or calendar years, and for the specified interim periods.
Value (in $1,000)
Fiscal year (ended) or calendar year
Item
Capital expenditures
Research and development
expenses

2006

2007

2008

2009

2010

January-March
2011

2011

2012

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PART III.--FINANCIAL INFORMATION--Continued
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
Fiscal year (specify:

)

Please note the quantities and values reported in question III-10 should reconcile with the data
reported in question II-10 (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-10?
Yes

No--Please explain:

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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-205-3250,
[email protected]).
Contact information.-- Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in part IV.
Name:
Title:
Email:
Telephone:
Fax:
PRICE DATA
IV-1.

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 2006 of the following products
produced by your firm.
Product 1.--ASTM grade B bulk silicomanganese sold to steel producers under quarterly
requirement contracts
Product 2.-- ASTM grade B bulk silicomanganese sold as spot sales

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.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-1.

Pricing data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
(Quantity in short tons, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity

Period of shipment
Value
2006:
January-March
April-June
July-September
October-December
2007:
January-March
April-June
July-September
October-December
2008:
January-March
April-June
July-September
October-December
2009:
January-March
April-June
July-September
October-December
2010:
January-March
April-June
July-September
October-December
2011:
January-March
April-June
July-September
October-December
2012:
January-March
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. Also, please explain any anomalies in your reported pricing data.
Product 1:
Product 2:

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2. Price setting.-- How does your firm determine the prices that it charges for sales of
silicomanganese (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction

IV-3.

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms for silicomanganese.-(a)

What are your firm’s typical sales terms for its U.S.-produced silicomanganese?
Net 30 days

(b)

Net 60 days

2/10 net 30 days

Other (specify)

On what basis are your prices of domestic silicomanganese usually quoted (check one)?
Delivered

IV-5.

Other

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

Quantity
discounts

IV-4.

Contracts

Set
price
lists

F.o.b.

If f.o.b., specify point

Contract versus spot.-- Approximately what share of your firm’s sales of its U.S.-produced
silicomanganese in 2011 was on a (1) long-term contract basis, (2) short-term contract basis, and
(3) spot sales basis?
Share of
2011 sales

Type of sale
Long-term contracts (multiple deliveries for more
than 12 months)

%

Short-term contracts (multiple deliveries up to and
including 12 months)

%

Spot sales (for a single delivery)

%

Total

100

%

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-6.

Contract provisions.— Please fill out the table with respect to provisions of your typical sales
contracts for silicomanganese (or check “not applicable” if your firm does not sell on a long term
and/or short term contract basis).

Typical sales contract
provisions

Item

Average contract duration

Number of days

Price renegotiation (during the
contract period)

Yes

Short term contracts

Long term contracts

(multiple deliveries up to
and including 12 months)

(multiple deliveries for more
than 12 months)

No
Quantity

Fixed quantity and/or price

Price
Both
Yes

Meet or release provision

No

Not applicable

IV-7.

Lead times.--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 silicomanganese?
Source
From inventory

%

Produced to order

%

Total

IV-8.

Share of
2011 sales

Lead time (days)

100 %

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of silicomanganese that is
accounted for by U.S. inland transportation costs?
%

(b)

Who generally arranges the transportation to your customers’ locations?
your firm
purchaser (check one)

(c)

Indicate the approximate percentage of your sales of silicomanganese that are delivered
the following distances from your production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%
Total

100

%

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-9. Geographical shipments.-- What is the geographic market area in the United States served by
your firm’s silicomanganese? (check all that apply)
(Check if
applicable)

Geographic area
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, and VI, among others.

IV-10. End uses.--List the end uses of the silicomanganese that you manufacture. For each end-use
product, what percentage of the total cost is accounted for by silicomanganese and other inputs?
Share of total cost of end use product
accounted for by

End use product

silicomanganese
(percent)

Other inputs (percent)

Total

Steel (integrated mill)

%

%

100%

Steel (electric arc
furnace)

%

%

100%

%

%

100%

Other (specify):

IV-11. Changes in end uses.--Have there been any changes in the end uses of silicomanganese since
2006? Do you anticipate any future changes?
Changes in end
uses
Changes since
2006
Anticipated
changes

No

Yes

Explain

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-12. Substitutes.-- Can other products be substituted for silicomanganese?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

Have changes in the prices of this substitute
affected the price for silicomanganese?
No Yes

Explanation

1.
2.
3.

IV-13. Changes in substitutes.-- Have there been any changes in the number or types of products that
can be substituted for silicomanganese since 2006? Do you anticipate any future changes?
Changes in
substitutes

No Yes

Explain

Changes since
2006
Anticipated
changes

IV-14. Raw materials.-(a)

To what extent have changes in the prices of raw materials affected your firm’s selling
prices for silicomanganese since 2006?

(b)

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

Yes—Please explain.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-15. 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 silicomanganese in the
U.S. market since 2006?
No

Yes--Please note the time period(s) of any such changes, the factors(s)
involved, and the impact such changes had on your shipment volumes
and prices.

IV-16. Availability of supply (U.S.-produced).-(a)

Do you anticipate any changes in terms of the availability of U.S.-produced
silicomanganese in the U.S. market in the future?
Increase

(b)

No change

Decrease

If you anticipate changes in supply, please explain.

IV-17. Availability of supply (nonsubject).--Has the availability of NONSUBJECT silicomanganese
(i.e., silicomanganese imported from countries other than Brazil, China and Ukraine) changed
since 2006?
No

Yes--Please explain.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-18. Export constraints.--Describe how easily your firm can shift its sales of silicomanganese
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 silicomanganese between the U.S. and alternative country markets within a 12month period.

IV-19. Product changes.-- Have there been any significant changes in the product range, product mix,
or marketing of silicomanganese since 2006? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes

Explain

Changes since
2006
Anticipated
changes

IV-20. Demand trends.-- Indicate how demand within the United States and outside of the United States
(if known) for silicomanganese has changed since January 1, 2006, and how you anticipate
demand will change in the future. Describe the principal factors that have affected, and that you
anticipate will affect, these changes in demand.

Market

No
Increase change Decrease Fluctuate
Demand since 2006

Within
the United
States
Outside
the United
States
Anticipated future demand
Within
the United
States
Outside
the United
States

Factors

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-21. Conditions of competition.-(a)

Is the silicomanganese market subject to business cycles or conditions of competition
(including seasonal business) distinctive to silicomanganese?
No (skip to question IV-22).

(b)

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

If yes, have there been any changes in the business cycles or conditions of competition
for silicomanganese since January 1, 2006?
No

Yes-- Please describe.

IV-22. Price comparisons.--Please compare market prices of silicomanganese in U.S. and non-U.S.
markets, if known. Provide specific information as to time periods and regions for any price
comparisons.

IV-23. 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 silicomanganese supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of the
other major producing/consuming countries, including Brazil, China and Ukraine, and (3) the
world as a whole. Of particular interest is such data from 2006 to the present and forecasts for the
future.
IV-24. Barriers to trade.--Are your exports of silicomanganese 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 2006, or
that are expected to occur in the future.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-25. Interchangeability.--Is silicomanganese produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

Brazil

China

Ukraine

Other countries

United States
Brazil
China
Ukraine

For any country-pair producing silicomanganese that is sometimes or never interchangeable,
please explain the factors that limit or preclude interchangeable use:

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-26. Factors other than price.--Are differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between silicomanganese produced
in the United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

Brazil

China

Ukraine

Other countries

United States
Brazil
China
Ukraine

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