13-1-3187 U.S. Producer Questionnaire

OMB No. 3117-0016/USITC No. 14-1-3187; Expiration Date: 6/30/2014
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
DIFFUSION-ANNEALED, NICKEL-PLATED STEEL FROM JAPAN

This questionnaire must be received by the Commission by no later than January

31, 2014

See 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 antidumping investigation concerning diffusion-annealed, nickel-plated steel flat-rolled products
(“diffusion-annealed, nickel-plated steel”) from Japan (Inv. No. 731-TA-1206 (Final)). 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 firm’s
possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

World Wide Web address
Has your firm produced diffusion-annealed, nickel-plated steel (as defined in the instruction booklet) at any time
since January 1, 2011?

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)

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: DANP)
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 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
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

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
firm’s response or send them to the above address.

I-1c.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone number,
email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
No

Yes

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.

Petition support.--Does your firm support or oppose the petition?
Country
Japan

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 3

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

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

Firm name

I-5.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing diffusion-annealed, nickel-plated steel from Japan into the
United States or that are engaged in exporting diffusion-annealed, nickel-plated steel from Japan
to the United States?
No
Firm name

I-6.

Yes--List the following information.

Yes--List the following information.
Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of diffusion-annealed, nickel-plated steel?
No
Firm name

Yes--List the following information.
Address

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 4

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nathanael Comly
([email protected]; 202-205-3174). 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 diffusion-annealed, nickel-plated steel since January 1,
2011.
(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
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 5

PART II.--TRADE AND RELATED INFORMATION--Continued
II-3(a). Production and capacity.--Please report your firm’s production of diffusion-annealed, nickelplated steel, production of products made on the same equipment and machinery used to produce
diffusion-annealed, nickel-plated steel, and the combined production capacity on this shared
equipment and machinery in the periods indicated.
(Quantity in short tons)
Item

Calendar years
2011

2012

2013

Overall production capacity
1

Production of subject merchandise:
Diffusion-annealed, nickel-plated steel
Production of nonsubject
merchandise:
2
Other nickel-plated steel
Other

3

Nonsubject merchandise subtotal
Total
1

Subject merchandise should equal production data reported in II-7(a).
Not diffusion-annealed.
3
Please identify:
2

.

II-3(b). Operating parameters.--The production capacity (see definitions in instruction booklet) reported in
II-3a is based on operating
hours per week,
weeks per year.
II-3(c). Capacity calculation.--Please describe the methodology used to calculate overall production capacity
reported in II-3(a), and explain any changes in reported capacity.

II-3(d). Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-3(e). Product shifting.--Please describe the constraint(s) that set the limit(s) on your firm’s ability to shift
production capacity between products.

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 6

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

Tolling.--Since January 1, 2011, has your firm been involved in a toll agreement (see definition
in the instruction booklet) regarding the production of diffusion-annealed, nickel-plated steel?
No

II-5.

.

Foreign trade zone.--Does your firm produce diffusion-annealed, nickel-plated steel in a foreign
trade zone (FTZ)?
No

II-6.

Yes--Name firm(s):

Yes--Identify FTZ(s):

.

Importer.--Since January 1, 2011, has your firm imported diffusion-annealed, nickel-plated
steel?
No

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

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-7(a). Trade data.--Report your firm’s production capacity, production, shipments, inventories, and
employment related to the production of diffusion-annealed, nickel-plated steel in its U.S.
establishment(s) during the specified periods. (See definitions in the instruction booklet.)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2011

2012

2013

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
1

Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity of commercial shipments (D)
Value of commercial shipments (E)
Internal consumption:
Quantity of internal consumption (F)
2

Value of internal consumption (G)
Transfers to related firms:
Quantity of transfers (H)
2

Value of transfers (I)
3

Export shipments:
Quantity of export shipments (J)
Value of export shipments (K)
End-of-period inventories (quantity) (L)
Channels of distribution: (quantity)
U.S. shipments to distributors (M)
U.S. shipments to end users – Battery (N)
U.S. shipments to end users –Automotive (O)
U.S. shipments to end users –Other:

(P)

Employment data:
Average number of PRWs (number) (Q)
Hours worked by PRWs (1,000 hours) (R)
Wages paid to PRWs (value) (S)
1

Production data should equal subject merchandise production data reported in II-3(a).
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your
firm uses 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:
2

3

Identify your firm’s principal export markets:

.

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U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

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PART II.--TRADE AND RELATED INFORMATION--Continued
Note -- The calculations below will only appear if you have entered data on the previous page in the MS Word
form fields.
II-7(b). Reconciliation of trade data.—Please use the calculations provided in the tables below to check the
data reported in question II-7(a).
(i)

Shipments reconcile – Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each year equal the quantity reported for total U.S. shipments (i.e., lines
D, F, and H) in each period.
If the calculated fields below return values other than zero (i.e., “0”), the data in question II-7(a)
needs to be revised prior to submission to the Commission.
Calendar years
Reconcilation Item

U.S. shipments to distributors (M) + U.S.
shipments to end users (N +O+P) - total U.S.
shipments (D+ F+H) =

(ii)

2011

0

2012

0

2013

0

Inventory, Production and Shipment Reconcile. – Generally, the data reported for the end-ofperiod inventories (i.e., line L) in question II-7(a) should be equal to the beginning of period
inventories (i.e., line B), plus production (i.e., line C), less total shipments (i.e., lines D, F, H,
and J).
Please ensure that any differences are not due to data entry errors in completing this form, but
rather actually reflect your firm's records; and also provide any likely explanations for the
differences (e.g., theft, loss, damage, record systems issues, et cetera).
If the calculated fields below return values other than zero (i.e., “0”), please correct any data
errors in table II-7(a) or explain below.
Calendar years
Reconcilation Item

Beginning inventories + production – total
shipments – End-of-period inventories =

2011
0

2012
0

2013
0

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 9

PART II.--TRADE AND RELATED INFORMATION--Continued
II-7(c). U.S. shipments by type.—Please report quantity and value of U.S. shipments of diffusionannealed, nickel-plated steel provided in question II-7(a), for use in the production of the
sepecific types listed below.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2011

2012

2013

U.S. shipments for use in:
AA cans:
Quantity of commercial shipments
Value of commercial shipments
AAA cans:
Quantity of commercial shipments
Value of commercial shipments
9V/AAAA cans:
Quantity of commercial shipments
Value of commercial shipments
C cans:
Quantity of commercial shipments
Value of commercial shipments
D cans:
Quantity of commercial shipments
Value of commercial shipments
End Caps:
Quantity of commercial shipments
Value of commercial shipments
Automotive applications:
Quantity of commercial shipments
Value of commercial shipments
1

Other:
Quantity of commercial shipments
Value of commercial shipments
2

Total:

1

Quantity of commercial shipments

CALCULATED
FIELD

CALCULATED
FIELD

CALCULATED
FIELD

Value of commercial shipments

CALCULATED
FIELD

CALCULATED
FIELD

CALCULATED
FIELD

Please specify:

.

2

Total U.S. shipments should equal U.S. shipments (commercial, internal consumption, transfers) reported in
question II-7(a) (Total field (in grey) calculations below will only appear if you have entered data in the MS Word form
fields).

II-8.

Related firms.--If your firm reported transfers to related firms in question II-7, 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.

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 10

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

Purchases.--Other than direct imports, has your firm otherwise purchased diffusion-annealed,
nickel-plated steel since January 1, 2011? (See definitions in the instruction booklet.)
Yes--Report such purchases below for the specified periods.1

No

Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2011

2012

2013

2

PURCHASES FROM U.S. IMPORTERS OF
DIFFUSION-ANNEALED, NICKEL-PLATED
STEEL FROM—
Japan:
Quantity
Value
All other countries:
Quantity
Value
PURCHASES FROM DOMESTIC
2
PRODUCERS:
Quantity
Value
2

PURCHASES FROM OTHER SOURCES:
Quantity
Value
1

Please indicate your firm’s reasons for purchasing this product. If your firm’s reasons differ by source, please
elaborate.
2

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

II-10(a).Order book.—Does your firm maintain an “order book” of projected future shipments of
diffusion-annealed, nickel-plated steel?
No

Yes—Please describe when projected orders are entered into the order book,
whether such projections are subject to change at later dates, and how
far in advance customers typically provide projected order quantities.

II-10(b).Order book production.—Report your firm’s expected production of diffusion-annealed,
nickel-plated steel based on its “order books” for the specified periods.
Quantity (in short tons)
Item
Production

Jan-Mar 2014

Apr-Jun 2014

Jul-Sept 2014

Oct-Dec 2014

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 11

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202-708-4725,
[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 firm’s financial accounting system.
A.

When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include diffusion-annealed, nickelplated steel:

2.

3.

4.

Does your firm prepare profit/loss statements for the diffusion-annealed, nickelplated steel:
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)

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
diffusion-annealed, nickel-plated steel, 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 firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

______
III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

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U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 12

PART III.--FINANCIAL INFORMATION--Continued

III-5.

Other products.--Please list the products your firm produced in the facilities in which your firm
produced diffusion-annealed, nickel-plated steel, and provide the share of net sales accounted for
by these other products in your firm’s most recent fiscal year:
Products

Share of sales

Diffusion-annealed, nickel-plated steel

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any other services) used in the
production of diffusion-annealed, nickel-plated steel from any related firms?
Yes--Continue to question III-7 below.

III-7.

No--Continue to question III-9 below.

Inputs from related firms.--In the space provided below, identify the inputs used in the
production of diffusion-annealed, nickel-plated steel that your firm purchases from related firms.
Input

Related firm

III-8a. Inputs from related firms at cost.--All intercompany profit on inputs purchased from related
firms 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 firms are acceptable.
Has your firm complied with the Commission’s instructions regarding costs associated with
inputs purchased from related parties?

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

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PART III.--FINANCIAL INFORMATION--Continued
Yes

No--Please contact David Boyland (202-708-4725,
[email protected]).

III-8b. With respect to inputs purchased from related firms, please provide a narrative description of 1)
the procedures used to identify the relevant amount of inter-company profit and loss and 2) the
corresponding calculations to eliminate inter-company profit and losses to determine cost of
goods sold, specifically the hot-rolled steel component, as reported in table III-10.

III-8c. With respect to relevant inputs purchased from related firms and the hot-rolled steel cost reported
in table III-10, please report for each year the amount of inter-company profit or (loss) which was
eliminated from hot-rolled steel costs in order to determine the net amount reported in table III10.
Fiscal years ended-2011

2012

2013

Value (in $1,000)
Inter-company profit or (loss) eliminated from
total hot-rolled steel cost

III-8d. With regard to the amounts reported in table III-8C, please describe the primary factors which
explain variations in inter-company profit and intercompany loss.

III-8e. Please report the following information related to your purchases of hot-rolled steel used (or to be
used) in the production of diffusion-annealed, nickel-plated steel. (Note: In the space provided,
please identify the supplier.)
Fiscal years ended-2011

2012

2013

Purchases of hot-rolled steel used (or to be used) in the production of
diffusion-annealed, nickel-plated steel
Supplier 1:
Quantity (in short tons)
Value (in $1,000)
Supplier 2:
Quantity (in short tons)
Value (in $1,000)
Supplier 3:
Quantity (in short tons)
Value (in $1,000)

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U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

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PART III.--FINANCIAL INFORMATION--Continued
III-9. Nonrecurring items (charges and gains) included in reported in diffusion-annealed, nickelplated steel financial results.--For each annual 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 diffusion-annealed, nickel-plated steel financial results in table III-10.

Fiscal years ended-2011
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.

2012

2013

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 - Diffusion-Annealed, Nickel-Plated Steel

Page 15

PART III.--FINANCIAL INFORMATION--Continued
III-10a. Operations on diffusion-annealed, nickel-plated steel.--Report the revenue and related cost
information requested below on the diffusion-annealed, nickel-plated steel operations of your
firm’s U.S. establishment(s).1 Do not report resales of products. Note that commercial shipments
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 firm’s three most recently completed fiscal years. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact David
Boyland (202) 708-4725 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2011

2012

2013

3

Net sales quantities:
Commercial sales (“CS”)
Commercial shipments (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0
0

0
0

0
0

0
0

0
0

0
0

0

0

0

3

Net sales values:
Commercial sales
Commercial shipments
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Hot-rolled steel

4

Nickel
Other raw material costs
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 expenses and income:
Interest expense
All other expense items
All other income items
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-8.
2

3

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

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U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

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PART III.--FINANCIAL INFORMATION--Continued
III-10b. Financial data reconciliation.--The calculable line items from question III-10a (i.e., total net
sales quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or
loss)) have been calculated from the data submitted in the other line items. Do the calculated
fields return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No.--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are positive
and incomes or reversals are negative--instances of the latter should be rare
in those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 17

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 diffusion-annealed, nickel-plated steel. If your firm does
not maintain some or all of the specific asset information necessary to calculate total assets for
diffusion-annealed, nickel-plated steel 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
firm’s cost allocations in the previous question. Provide data as of the end of your firm’s three
most recently completed fiscal 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 years ended-Item

2011

2012

2013

Total assets (net)

III-12. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on diffusion-annealed, nickel-plated steel.
Provide data for your firm’s three most recently completed fiscal years.
Value (in $1,000)
Fiscal years ended-Item

2011

2012

2013

Capital expenditures
Research and development expenses

III-13. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-10, 11, and 12 are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify 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

If no, please explain.

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U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 18

PART III.--FINANCIAL INFORMATION--Continued
III-14. Effects of imports.--Since January 1, 2011, has your firm experienced any actual negative effects
on its return on investment or its growth, investment, ability to raise capital, existing development
and production efforts (including efforts to develop a derivative or more advanced version of the
product), or the scale of capital investments as a result of imports of diffusion-annealed, nickelplated steel from Japan?
No

Yes--My firm has experienced actual negative effects as follows:
Cancellation, postponement, or rejection of expansion projects
Denial or rejection of investment proposal
Reduction in the size of capital investments
Rejection of bank loans
Lowering of credit rating
Problem related to the issue of stocks or bonds
Other (specify)

III-15. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
diffusion-annealed, nickel-plated steel from Japan?
No

Yes

If yes, my firm anticipates negative effects as follows:

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 19

PART IV.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from John Benedetto (202-205-3270,
[email protected])
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax

PRICE DATA
IV-2.

This question requests quarterly quantity and value data, f.o.b. your firm’s U.S. point of
shipment, for your firm’s commercial shipments to unrelated U.S. customers since January 1,
2011 of the following products produced by your firm.
Product 1A. – Diffusion-annealed, nickel-plated steel, 0.010 inch, plus or minus
0.0004 in. (0.244 mm to 0.264 mm) thickness, maximum 326 mm width, with
nickel plate 1.25 micron minimum one side and .625 micron minimum opposite.
Product 1B.—Diffusion-annealed, nickel-plated steel, 0.010 inch, plus or minus 0.0004 in.
(0.244 mm to 0.264 mm) thickness, width of greater than 326 mm, with nickel
plate 1.25 micron minimum one side and .625 micron minimum opposite
Product 2.-- Diffusion-annealed, nickel-plated steel, 0.008 inch, plus or minus 0.0004 in.
(0.193 mm to 0.213 mm) thickness, with nickel plate 1.25 micron minimum one
side and .625 micron minimum opposite
Product 3.-- Diffusion-annealed, nickel-plated steel, 0.008 inch, plus or minus 0.0004 in.
(0.193 mm to 0.213 mm) thickness, with nickel plate 1.8 micron minimum one
side and .375 micron minimum, but less than .625 micron, opposite
Product 4.-- Diffusion-annealed, nickel-plated steel, 0.0135 inch, plus or minus 0.0005 in.
(0.330 mm to 0.356 mm) thickness, with nickel plate 1.0 micron minimum one
side and 1.0 micron minimum opposite
Product 5.-- Diffusion-annealed, nickel-plated steel, 0.0153 inch, plus or minus 0.0005 in.
(0.376 mm to 0.401 mm) thickness, with nickel plate 1.0 micron minimum one
side and 1.0 micron minimum opposite

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.

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 20

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-2.

Pricing data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.

(Quantity in short tons, value in $1,000)
Product 1A
Product 1B
Product 2
Period of
shipment
Quantity
Value
Quantity
Value
Quantity
Value
2011:
JanuaryMarch
April-June
JulySeptember
OctoberDecember
2012:
JanuaryMarch
April-June
JulySeptember
OctoberDecember
2013:
JanuaryMarch
April-June
JulySeptember
OctoberDecember
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 1A:
Product 1B:
Product 2:

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 21

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-2.

Pricing data.—Continued.

(Quantity in short tons, value in $1,000)
Product 3
Product 4
Product 5
Period of
shipment
Quantity
Value
Quantity
Value
Quantity
Value
2011:
JanuaryMarch
April-June
JulySeptember
OctoberDecember
2012:
JanuaryMarch
April-June
JulySeptember
OctoberDecember
2013:
JanuaryMarch
April-June
JulySeptember
OctoberDecember
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 3:
Product 4:
Product 5:

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 22

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-3.

Price setting.—
(a) How does your firm determine the prices that it charges for sales of diffusion-annealed,
nickel-plated steel (check all that apply)? If your firm issues price lists, please submit sample
pages of a recent list.
Transaction
by
transaction

Contracts

Set
price
lists

Other

If other, describe

(b) Please list each pricing formula (e.g., tying prices to raw material costs) in use by your firm
for its sales of diffusion-annealed, nickel-plated steel between 2011 and 2013, identifying the
customer and the time period during which the formula was in use.

(c) To the extent that your firm uses a pricing formula for its sales of diffusion-annealed, nickelplated steel, including a base price and adjustments for raw materials or other surcharges, please
provide the following information:
What is the duration of the contract?

How much time typically elapses between the award of a contract including a pricing formula and
the commencement of shipments under that contract?

For how long after shipments commence is the base price in effect?

How frequently may the price change due to the surcharge or price adjustment mechanism?

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 23

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-3.

Price setting.—continued.
(d) In bid negotiations for your firm’s sales of diffusion-annealed, nickel- plated steel, do any
customers require prices to be quoted based on specified or assumed values for raw materials
(such as for hot rolled steel)?
Yes

No

If yes, please identify the materials for which values are specified and describe the bidding
process

(e) Do price negotiations for your firm’s sales of diffusion-annealed, nickel-plated steel ever
conclude after shipments of the product have already begun (i.e., are prices renegotiated after
some shipments have already occurred, requiring post-shipment billing or price adjustments)?
Yes

No

If yes, please describe how such price adjustments are made and whether the quarterly pricing
data in section IV-2 above include such adjustments.

(f) Have you offered to supply or been invited to submit bids to customers with respect to
diffusion-annealed, nickel-plated steel specifications for which you were not qualified to supply
the customer at the time of the offer or bid?
Yes

No

If yes, please describe the circumstances, indicating whether you won any bid competition prior
to qualifying a particular customer specification and subsequently qualified to provide that
specification.

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 24

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-4.

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

Quantity
discounts

IV-5.

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms for diffusion-annealed, nickel-plated steel.-(a)

What are your firm’s typical sales terms for its U.S.-produced diffusion-annealed, nickelplated steel?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic diffusion-annealed, nickel-plated steel
usually quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 25

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
diffusion-annealed, nickel-plated steel in 2013 was on a (1) long-term contract basis, (2) shortterm contract basis, and (3) spot sales basis?
Share of
2013 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

IV-7.

100

%

Contract provisions.— Please fill out the table with respect to provisions of your firm’s typical
sales contracts for diffusion-annealed, nickel-plated steel (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
Price

Fixed quantity and/or price

Both
Yes

Meet or release provision

No

Not applicable

IV-8.

Lead times.--What is your firm’s share of sales both from inventory and produced to order and
what is the typical lead time between a customer’s order and the date of delivery for your firm’s
sales of its U.S.-produced diffusion-annealed, nickel-plated steel?
Source

Share of
2013 sales

From inventory

%

Produced to order

%

Total

100 %

Lead time (days)

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 26

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-9.

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of diffusion-annealed,
nickel-plated steel that is accounted for by U.S. inland transportation costs?
%

(b)

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

(c)

Indicate the approximate percentage of your firm’s sales of diffusion-annealed, nickelplated steel that are delivered the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%
Total

100

%

IV-10. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced diffusion-annealed, nickel-plated steel since January 1, 2011 (check all that apply)?
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.

√ if applicable

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U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 27

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-11. End uses.--List the end uses of the diffusion-annealed, nickel-plated steel that your firm
manufactures. For each end-use product, what percentage of the total cost is accounted for by
diffusion-annealed, nickel-plated steel and other inputs?
Share of total cost of end use product
accounted for by

End use product

Diffusion-annealed,
nickel-plated steel
(percent)

Other inputs (percent)

Total

%

%

100%

%

%

100%

%

%

100%

IV-12. Substitutes.-- Can other products be substituted for diffusion-annealed, nickel-plated steel?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the prices of this substitute
affected the price for diffusion-annealed,
nickel-plated steel?
No Yes

Explanation

1.
2.
3.

IV-13. Demand trends.-- Indicate how demand within the United States and outside of the United States
(if known) for diffusion-annealed, nickel-plated steel has changed since January 1, 2011. Explain
any trends and describe the principal factors that have affected these changes in demand.

Market
Within
the United
States
Outside
the United
States

Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 28

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-14. Product changes.--Have there been any significant changes in the product range, product mix, or
marketing of diffusion-annealed, nickel-plated steel since January 1, 2011?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Business cycles.-a) Is the diffusion-annealed, nickel-plated steel market subject to business cycles (other than
general economy-wide conditions) and/or other conditions of competition distinctive to diffusionannealed, nickel-plated steel?
No (skip to question IV-16).
Yes-Business cycles (e.g. seasonal business).
Yes-Other distinctive conditions of competition.
If yes, describe below.
Business cycles
Other conditions
of competition

(b) If yes, have there been any changes in the business cycles or conditions of competition for
diffusion-annealed, nickel-plated steel since January 1, 2011?
No

Yes

If yes, please describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply diffusionannealed, nickel-plated steel since January 1, 2011 (examples include placing customers on
allocation or “controlled order entry,” declining to accept new customers or renew existing
customers, delivering less than the quantity promised, been unable to meet timely shipment
commitments, etc.)?
No

Yes

If yes, please describe.

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 29

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-17. Raw materials.--Please describe any trends in the prices of raw materials used to produce
diffusion-annealed, nickel-plated steel and whether your firm expects these trends to continue.

IV-18. Interchangeability.--Is diffusion-annealed, nickel-plated steel 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

Japan

Germany

Korea

Other countries

United States
Japan
Germany
Korea

For any country-pair producing diffusion-annealed, nickel-plated steel that is sometimes or
never interchangeable, please explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 30

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-19. Factors other than price.--Are differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between diffusion-annealed,
nickel-plated steel 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

Japan

Germany

Korea

Other countries

United States
Japan
Germany
Korea

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

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 31

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-20. Customer Identification--Please identify the names and contact information for your firm’s
10 largest U.S. customers for diffusion-annealed, nickel-plated steel since January 1, 2011.
Indicate the share of the quantity of your firm’s total shipments of diffusion-annealed, nickelplated steel that each of these customers accounted for in 2013.

Customer’s name

1

Contact person

Email

Telephone

Street address (not P.O.
box), city, state, and zip
code

Street Address

,
City

2

State

Street Address

,
City

3

State

,
State

,
State

,
State

,
State

,
State

,
State

Zip Code

Street Address

,
City

10

Zip Code

Street Address
City

9

Zip Code

Street Address
City

8

Zip Code

Street Address
City

7

Zip Code

Street Address
City

6

Zip Code

Street Address
City

5

Zip Code

Street Address
City

4

Zip Code

State

Zip Code

Street Address

,
City

State

Zip Code

Share
of 2013
sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 32

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-21. Competition From Imports--Lost Revenue.-Since January 1, 2011: To avoid losing sales to competitors selling diffusion-annealed, nickelplated steel from Japan, did your firm:
No

Yes

Reduce prices
Roll back announced price increases
Please DO NOT RE-SUBMIT allegations provided in the preliminary phase of this
proceeding.
If you indicated “yes” above, please furnish the following information for each affected
transaction. If possible, provide documentation (e.g., copies of invoices, sales reports, or letters
from customers). Please note that the Commission may contact the firms named to verify the
allegations reported.
Customer name, contact person, phone and fax numbers
Specific product(s) involved
Date of your firm’s initial price quotation
Quantity involved
Your firm’s initial rejected price quotation (total delivered value)
Your firm’s accepted price quotation (total delivered value)
The country of origin of the competing imported product
The competing price quotation of the imported product (total delivered value)
Customer name,
contact person,
phone and fax
numbers

Firm
Contact
Phone

Fax

Firm
Contact
Phone

Fax

Firm
Contact
Phone

Fax

Firm
Contact
Phone

Fax

Product

Country
of origin

Date of
quote

Quantity
(short tons)

Initial
rejected U.S.
price (total
value-dollars)

Accepted
U.S. price
(total value-dollars)

Competing
import price
(total
value—
dollars)

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 33

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-22. Competition From Imports--Lost Sales.—
Since January 1, 2011: Did your firm lose sales of diffusion-annealed, nickel-plated steel to
imports of these products from Japan?
No
Yes
Please DO NOT RE-SUBMIT allegations provided in the preliminary phase of this
proceeding.
If you indicated “yes” above, please furnish the following information for each affected
transaction. If possible, provide documentation (e.g., copies of invoices, sales reports, or letters
from customers). Please note that the Commission may contact the firms named to verify the
allegations reported.
Customer name, contact person, phone and fax numbers
Specific product(s) involved
Date of your firm’s price quotation
Quantity involved
Your firm’s rejected price quotation (total delivered value)
The country of origin of the competing imported product
The accepted price quotation of the imported product (total delivered value)
Customer name,
contact person,
phone and fax
numbers

Firm
Contact
Phone

Fax

Firm
Contact
Phone

Fax

Firm
Contact
Phone

Fax

Firm
Contact
Phone

Fax

Product

Country
of
origin

Date of
quote

Quantity
(short tons)

Rejected
U.S. price
(total
value-dollars)

Competing
import price
(total
value—
dollars)

Business Proprietary
U.S. Producers’ Questionnaire - Diffusion-Annealed, Nickel-Plated Steel

Page 34

PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-23. Competition From Imports--Lost Sales and Lost Revenue—
For both any allegations listed above in IV-21 and IV-22 as well as for any allegations listed in
the preliminary phase of this investigation, please attach any additional documentation that your
firm has that would corroborate details in the allegation, e.g., pricing levels, volumes, dates, etc..
Did your firm attach any such corroboration?
No

Yes

Additional comments: