14-4-3172 Foreign Producer Questionnaire

OMB No. 3117-0016/USITC No. 14-4-3172; Expiration Date: 6/30/2014
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
PERSULFATES FROM CHINA

This questionnaire must be received by the Commission by no later than October 21, 2013
See page 5 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 order concerning persulfates from China (Inv. No. 731-TA-749 (Third
Review)). The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title
VII.

Name of firm
Address
World Wide Web address
Has your firm produced or exported persulfates (as defined in the instruction booklet) at any time since January 1,
2007?

NO
YES

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
(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)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking
on the following link: https://dropbox.usitc.gov/oinv/. (use the following PIN: PERSR3)
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

Email address
Fax:

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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 30 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
firm’s 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 6 of the instruction booklet for reporting guidelines). If your firm is
publicly traded, please specify the stock exchange and trading symbol.

I-3.

U.S. importers.--Please provide the names, contacts, email addresses, and telephone numbers of
the FIVE largest U.S. importers of your firm’s persulfates in 2012.

No.

1
2
3
4
5

Importer’s name

Contact person

Email address

Area
code and
telephone
number

Share of
your firm’s
2012
exports
(%)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART I.--GENERAL INFORMATION--Continued
I-4.

U.S. production.--Does your firm or any related firm produce, have the capability to produce, or
have any plans to produce persulfates in the United States or other countries?
No

I-5.

U.S. importation.--Does your firm or any related firm import or have any plans to import
persulfates into the United States?
No

I-6.

Yes--Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire
(contact Angela Newell ([email protected]) for copies of that
questionnaire).

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire (contact Angela Newell
([email protected]) for copies of that questionnaire).

Business plan.--In Parts II and III 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 future market conditions for persulfates?
No

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

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Angela Newell
([email protected], 202-708-5409). 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 persulfates since January 1, 2007.
(check as many as appropriate)
plant openings ..............................

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

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

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

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

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

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

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

(please describe)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of persulfates in the
future?
No

II-4.

Anticipated changes in operations in the event the order is revoked.--Would your firm
anticipate any changes in the character of its operations or organization (as noted above) relating
to the production of persulfates in the future if the antidumping duty order on persulfates from
China 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 persulfates (in 1,000 pounds) for 2013 and
2014.

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 persulfates (in 1,000 pounds) for 2013 and
2014.

Same equipment, machinery, and workers.--Has your firm since 2007 produced, or does your
firm anticipate producing in the future, other products on the same equipment and machinery
used in the production of persulfates?
No

Product
Persulfates

Yes--List the following information and report your firm’s combined
production capacity and production of these products and persulfates in
the periods indicated.
Period

Basis for allocation of capacity data

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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

Same equipment, machinery, and workers.--Continued
(Quantity in 1,000 pounds)
JanuarySeptember

Calendar year

Item
2007

2008

2009

2010

2011

2012

2012

2013

Overall Production Capacity
Production of:
Persulfates
Other product 1:
Other product 2:

II-6.

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

II-7.

Production shifting.--Is your firm able to switch production between persulfates and other
products in response to a relative change in the price of persulfates vis-à-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 persulfates.

II-8.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of persulfates?
percent

II-9.

Inventories in the United States.--Has your firm, since 2007, maintained any inventories of
persulfates in the United States (not including inventories held by firms identified in question
I-3)?
No

Yes--Report the quantity of such end-of-period inventories below.
(Quantity in 1,000 pounds)

2007
Inventory

JanuarySeptember

Calendar year

Item
2008

2009

2010

2011

2012

2012

2013

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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

Barriers.-(a)

Are your firm’s exports of persulfates subject to tariff or non-tariff barriers to trade (for
example, antidumping or countervailing duty findings or remedies, tariffs, quotas, or
regulatory barriers) in any countries other than the United States?
No

Yes--List the products(s), country(ies), the year each such barrier was
imposed, and the type of barrier.

Product

(b)

Year
imposed

Barrier
(if tariff, give rate)

Are your firm’s exports of persulfates subject to current proceedings in any countries
other than the United States that might result in tariff or non-tariff barriers to trade?
No

Yes--List the products(s), country(ies), and type of proceeding.
Product

II-11.

Country

Country

Type of proceeding

Other export markets.--Identify export markets (other than the United States) that your firm has
developed or where it has increased its sales of persulfates since 2007. Please identify and
discuss below.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-12.

Significance of antidumping duty order.--Describe the significance of the existing antidumping
duty order covering imports of persulfates from China in terms of its effect on your firm’s
production capacity, production, home market shipments, exports to the United States and other
markets, and inventories. You may wish to compare your firm’s operations before and after the
imposition of the order.

II-13.

Anticipated changes if order revoked.--Would your firm anticipate any changes in its
production capacity, production, home market shipments, exports to the United States and other
markets, or inventories relating to the production of persulfates in the future if the antidumping
duty order on persulfates from China 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
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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

Trade data (China).-- Report production capacity, production, shipments, and inventories of
persulfates produced by your firm in China during the specified periods. (See definitions in the
instruction booklet.)
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
JanuarySeptember

Calendar year
Item

2007

2008

2009

2010

2011

2012

2012

2013

Average production capacity1 (A)
Beginning-of-period inventories (B)
Production2 (C)
Home market shipments:
Internal consumption/transfers
quantity (D)
Commercial shipments
quantity (E)
value (F)
Export shipments:
to the United States:3
quantity (G)
value (H)
to the European Union:4
quantity (I)
value (J)
to Asia:5
quantity (K)
value (L)
to all other markets:6
quantity (M)
value (N)
Total exports (quantity) (O)
Total shipments (quantity) (P)
End-of-period inventories (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.
2

Please estimate the percentage of total production of persulfates in China accounted for by your firm’s production in
2012:
percent
3
Please estimate the percentage of total exports to the United States of persulfates in China accounted for by your firm’s
exports in 2012:
percent
4
Identify your firm’s principal European Union export markets:
.
5
Identify your firm’s principal Asian export markets:
.
6
Identify your firm’s principal other export markets:
.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-15.

Reconciliation of trade data.—
(a)

The quantities reported in question II-14 should reconcile as follows in each period (i.e.,
in each column):
Reconciliation
B+C–D–E–G–I–K–M=Q

(b)

Yes

No--Please

Further, the quantities reported for end-of-period inventories should equal the beginningof-period inventories reported in the subsequent calendar year (i.e., line Q of year 2007
should equal line B of year 2008). Do these data reconcile for each adjacent calendar
year?
Yes

II-16.

Do these data reconcile?
explain:

No--Please explain.

What share of your firm’s commercial shipments of persulfates was used in each of the following
end use applications in 2012?

End use applications
Cosmetics and pharmaceuticals
Electronics (e.g. printed circuit board etchants)
Environmental remediation
Oil and gas recovery
Polymerization applications (plastics, synthetic rubber, adhesives)
Pool and spa supply
Pulp and paper
Textiles
Other:
Total

Share of
quantity of 2012
commercial
shipments
%
%
%
%
%
%
%
%
%
100 %

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART III.--MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Aimee Larsen (202-205-3179,
[email protected]).
III-1.

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

III-2.

Contract versus spot.--Approximately what share of your firm’s sales of persulfates to U.S.
customers in 2012 was on a (1) long-term contract basis, (2) short-term contract basis, and
(3) spot sales basis?

Long-term contracts
(multiple deliveries for
more than 12 months)
Share of your
2012 sales

III-3.

%

Type of sale
Short-term contracts
(multiple deliveries up
to and including 12
months)
%

Spot sales
(for a single
delivery)
%

Total

=100%

Please fill out the table with respect to provisions of your firm’s typical sales contracts with U.S.
customers for persulfates (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
No
Quantity

Fixed quantity and/or price

Price
Both

Meet or release provision
Not applicable

Yes
No

Short term contracts

Long term contracts

(multiple deliveries up to
and including 12 months)

(multiple deliveries for more
than 12 months)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART III.--MARKET FACTORS--Continued
III-4.

Lead times.--What is the average lead time to U.S. customers between a customer’s order and the
date of delivery for your firm’s sales of persulfates?
Share of
2012 sales

Source
From inventory

%

Produced to order

%

Total

Lead time (days)

100 %

III-5.

Raw materials.--To what extent have changes in the prices of raw materials affected your firm’s
selling prices for persulfates since 2007? Also discuss any anticipated changes in your firm’s raw
material costs.

III-6.

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 Chinese-produced persulfates in the
U.S. market since 2007?
No

III-7.

Yes

If yes, please describe.

Availability of SUBJECT import supply.-- Do you anticipate any changes in terms of the
availability of Chinese-produced persulfates in the U.S. market in the future?
If you anticipate changes in supply, please identify the
No
changes, including the time period and the impact of such
Increase change Decrease changes on shipment volumes and prices.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART III.--MARKET FACTORS--Continued
III-8.

Product shifting.--Describe how easily your firm can shift its sales of persulfates between the
U.S. market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints (including any third-country trade barriers such as
tariffs, quotas, or other non-tariff barriers) that would prevent or retard your firm from shifting
persulfates between the U.S. and alternative country markets within a 12-month period.

III-9.

Product range.--Is the product range, product mix, or marketing of persulfates in your firm’s
home market different from that of persulfates for export to the United States or to third-country
markets?
No

Yes

If yes, please explain.

III-10. Product changes.--Have there been any significant changes in the product range, product mix, or
marketing of persulfates in your firm’s home market, for export to the United States, or for export
to third-country markets since 2007? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
2007
Anticipated
changes

Explain

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART III.--MARKET FACTORS--Continued
III-11. Substitutes.— Can other products be substituted for persulfates?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

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

Explanation

1.
2.
3.

III-12. Changes in substitutes.-- Have there been any changes in the number or types of products that
can be substituted for persulfates since 2007? Do you anticipate any future changes?
Changes in
substitutes

No Yes

Explain

Changes since
2007
Anticipated
changes

III-13. Interchangeability.--Are the persulfates produced by your firm and sold in its home market
interchangeable (i.e., can be used in the same applications) with your firm’s persulfates sold to
the United States and/or to third-country markets?
Yes

No

If no, identify the market(s) and any differences in the products.

III-14. End uses.--Describe the end uses of the persulfates that your firm manufactures and sells to your
firm’s home market. If these end uses differ from those of the persulfates your firm sells to the
U.S. market or to third-country markets, explain.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART III.--MARKET FACTORS--Continued
III-15. Changes in end uses.-- Have there been any changes in the end uses of persulfates since 2007?
Do you anticipate any future changes?
Changes in end
uses

No

Yes

Explain

Changes since
2007
Anticipated
changes

III-16. Demand trends.-- Indicate how demand in the following markets for persulfates has changed
since January 1, 2007, and how you anticipate demand will change in the future. Explain any
trends and describe the principal factors that have affected, and that you anticipate will affect,
these changes in demand.
Your
firm’s
market

Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explanation and factors

Demand since 2007
Home
market
United
States
Other
markets
Anticipated future demand
Home
market
United
States
Other
markets

III-17. Price differences.--Please compare market prices of persulfates in your firm’s home market, the
United States, and third-country markets.

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Foreign Producers’/Exporters’ Questionnaire – Persulfates from China

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PART III.--MARKET FACTORS--Continued
III-18. Description of home market.--Describe briefly your firm’s home market for persulfates,
including the number of, and competition between, producers.

III-19. Import competition.--Does your firm face competition from imports of persulfates in your
firm’s home market?

No

Yes

If yes, please identify the country sources of any imports of persulfates
into your firm’s home market.

III-20. 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 persulfates supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of the
other major producing/consuming countries, including China, and (3) the world as a whole. Of
particular interest is such data from 2007 to the present and forecasts for the future.