14-1-3275 U.S. Producer Questionnaire

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

LWTP (R) - US Producer Questionnaire

Lightweight Thermal Paper from China and Germany, Inv. No. 701-TA-451 and 731-TA-1126-1127 (Review)

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

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OMB No. 3117-0016/USITC No. 14-1-3275; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN LIGHTWEIGHT THERMAL PAPER FROM CHINA AND GERMANY

This questionnaire must be received by the Commission by no later than SEPTEMBER 5, 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 review of the countervailing duty and antidumping duty orders concerning certain lightweight thermal
paper from China and Germany (Inv. Nos. 701-TA-451 and 731-TA-1126-1127 (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 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 certain lightweight thermal paper (“certain LW thermal paper”) (as defined in the
instruction booklet) at any time since January 1, 2008? For purposes of this questionnaire, you should consider
your firm a "producer" if your firm makes and coats base paper, just coats base paper, or performs conversion
operations (i.e., slitting and/or printing operations).

(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: LWTP)
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:

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U.S. Producers’ Questionnaire – Certain LW Thermal Paper

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-2.

Establishments covered.-- Provide the city, state, zip code, and brief description of each
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
in the footnote to the table.
Establishments
1
Covered

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

I-3.

Additional discussion on establishments consolidated in this questionnaire:

Position regarding continuation of order.--Does your firm support or oppose continuation of
the antidumping and/or countervailing duty order currently in place for certain LW thermal paper
from the following countries?
Country
China
Germany

Support

Oppose

Take no position

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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.

Address

Related SUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing certain LW thermal paper from China or
Germany into the United States or that are engaged in exporting certain LW thermal paper from
China or Germany to the United States?
No

Yes--List the following information.

Firm name

I-6.

Extent of
ownership
(percent)

Address

Affiliation

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing certain LW thermal paper from countries other
than China or Germany into the United States or that are engaged in exporting certain LW
thermal paper from countries other than China or Germany to the United States?
No

Yes--List the following information.

Firm name and country

Address

Affiliation

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PART I.--GENERAL INFORMATION--Continued
I-7.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of certain LW thermal paper?
No

Yes--List the following information.

Firm name

I-8.

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 certain LW thermal
paper?

Yes

If yes, please provide the requested documents. If you are not providing
the requested documents, please explain why not.

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Page 5

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 certain LW thermal paper since January 1, 2008.
(check as many as appropriate)
plant openings

plant closings

relocations

expansions

acquisitions

consolidations

prolonged shutdowns or
production curtailments
revised labor agreements

New products (e.g. BPA-free
paper)
other (e.g., technology,
modernization or upgrade of
equipment)

(please describe)

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

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
firm’s operations or organization (as noted above) relating to the production of certain LW thermal
paper 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
certain LW thermal paper (in short tons) for 2014 and 2015.

For question II-4, if your firm’s 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 firm’s operations or organization (as noted above) relating to the
production of certain LW thermal paper in the future if the countervailing duty or antidumping duty
orders on certain LW thermal paper from China and/or Germany were to be revoked?
No

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 7

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

Production and capacity.-- Please report your firm’s production of certain LW thermal paper,
production of products made on the same equipment and machinery used to produce certain LW
thermal paper, and the combined production capacity on this shared equipment and machinery in the
periods indicated.

Coating/jumbo roll machinery
(Quantity in short tons)
Item

2008

2009

2010

2011

2012

2013

Jan-Jun
2014

Overall production capacity on
coating/jumbo roll machinery
Production of:
Certain LW thermal paper
2

Other thermal paper
3

Other products
1

Certain LW thermal paper production should equal production data reported in II-7.
Please identify:
3
Please identify:
2

Conversion (cutting, slitting) machinery
(Quantity in short tons)
Item

2008

2009

2010

2011

2012

2013

Jan-Jun
2014

Overall production capacity on
conversion (cutting, slitting)
machinery
Production of:
Certain LW thermal paper
2

Other thermal paper
3

Other products
1

Certain LW thermal paper production should equal production data reported in II-8.
Please identify:
3
Please identify:
2

II-5b.

Operating parameters.--The production capacity (see definitions in instruction booklet) reported in
II-5a is based on operating
hours per week,
weeks per year.

II-5c.

Capacity calculation.--Please describe the methodology used to calculate overall production capacity
reported in II-5a, and explain any changes in reported capacity.

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 8

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

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

II-6.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between certain LW thermal paper and other
products using the same equipment and/or labor?
No

(ii)

Yes-- (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:

Please describe the factors that affect your firm’s ability to shift production capacity between
products (e.g., time, cost, relative price change required, etc.), and the degree to which these
factors enhance or constrain such shifts.

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Page 9

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

Trade data – U.S. producers of jumbo rolls.--Report your firm’s production capacity, production,
shipments, inventories, and employment related to the production of jumbo rolls of certain LW
thermal paper in your firm’s U.S. establishment(s) during the specified periods. U.S. producers of
jumbo rolls are producers who conduct coating operations in the United States. Coaters that
also perform conversion operations, such as slitting and packaging, on the jumbo rolls that they
produce in the United States should report data for all operations (both coating and conversion)
in this table, and should not complete table II-8. Table II-8 is reserved for those firms who
exclusively slit and package jumbo rolls that are purchased or imported.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item

2008
1

Average production capacity
(quantity) (A)

Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
2

Internal consumption:
quantity (F)
value (G)

Transfers to related firms:
quantity (H)
value (I)
3

Export shipments:
quantity (J)
value (K)

End-of-period inventories
(quantity) (L)
Channels of distribution:
U.S. commercial shipments to
distributors (quantity) (M)
U.S. commercial 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)
Table notes next page.

2009

2010

2011

January-June
2012

2013

2014

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 10

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

Trade data – U.S. producers of jumbo rolls.—Continued

The production capacity (see definitions in instruction booklet) reported is based on operating
hours per week,
weeks per year. Please describe the methodology used to calculate production capacity, and explain any changes in
reported capacity (use additional pages as necessary).
2

Internal consumption and transfers to related firms should be valued at fair market value. In the event that 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:
3

Identify your firm’s principal export markets:

RECONCILIATION OF CHANNEL DATA
Please ensure that the quantities reported for channels of distribution (i.e., lines M and N) in each time period equal the
quantities reported for commercial U.S. shipments (i.e., line D) in each time period. If the calculated fields below return
values other than zero (i.e., “0”), the data in question II-7 needs to be revised prior to submission to the Commission.
Calendar years
Reconciliation item

2008

Reconciliation should = 0 (if not
revise)

2009

2010

January-June

2011

2012

2013

2014

RECONCILIATION OF SHIPMENT, INVENTORY AND PRODUCTION DATA
Generally, the data reported for the end-of-period inventories (i.e., line L) 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, etc.).
Calendar years
Reconciliation item

2008

Reconciliation should = 0 (if not,
either revise data or explain the
reason for the discrepancy
below)

2009

2010

January-June

2011

2012

2013

2014

Explanation for reconciliation not holding:
.

Also please note that the quantities reported for end-of-period inventories should equal the beginningof-period inventories reported in the subsequent calendar year (i.e., line L of year 2008 should equal
line B of year 2009). Do these data reconcile for each adjacent calendar year?
Yes

No--Please explain.

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 11

PART II.--TRADE AND RELATED INFORMATION--Continued
II-8.

Trade data – U.S. converters.--Report your firm’s production capacity, production, shipments,
inventories, and employment related to the conversion of jumbo rolls into certain LW thermal
paper products in your firm’s U.S. establishment(s) during the specified periods. This table is for
those firms who exclusively slit and package jumbo rolls that are purchased or imported.
Coaters that also perform slitting and packaging operations on jumbo rolls they produce in the
United States should use table II-7.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item

2008

2009

2010

January-June

2011

2012

2013

2014

Purchases of jumbo rolls
quantity (A)
value (B)
1

Average conversion capacity
(quantity) (C)

Beginning-of-period inventories
(quantity) (D)
Production from (quantity)-U.S. produced jumbo rolls (E)
Foreign-sourced jumbo rolls:
Imported from subject
sources (F)
Imported from nonsubject
sources (G)

Total production
U.S. shipments:
Commercial shipments:
quantity (H)
value (I)
2

Internal consumption:
quantity (J)
value (K)

Transfers to related firms:
quantity (L)
value (M)
3

Export shipments:
quantity (N)
value (O)

End-of-period inventories
(quantity) (P)
Channels of distribution:
U.S. commercial shipments to
distributors (quantity) (Q)
U.S. commercial shipments to
end users (quantity) (R)
Employment data:
Average number of PRWs
(number) (S)
Hours worked by PRWs
(1,000 hours) (T)
Wages paid to PRWs (value)
(U)
Table notes next page.

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 12

PART II.--TRADE AND RELATED INFORMATION--Continued
1

Identify your firm’s principal export markets:

RECONCILIATION OF CHANNEL DATA
Please ensure that the quantities reported for channels of distribution (i.e., lines Q and R) in each time period equal the
quantities reported for commercial U.S. shipments (i.e., line H) in each time period. If the calculated fields below return
values other than zero (i.e., “0”), the data in question II-8 needs to be revised prior to submission to the Commission.
Calendar years
Reconciliation item

2008

Reconciliation should = 0 (if not
revise)

2009

2010

January-June

2011

2012

2013

2014

RECONCILIATION OF SHIPMENT, INVENTORY AND PRODUCTION DATA
Generally, the data reported for the end-of-period inventories (i.e., line P) should be equal to the beginning-of-period
inventories (i.e., line D), plus production (i.e., lines E, F and G), less total shipments (i.e., lines H, J, L, and N). 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, etc.).
Calendar years
Reconciliation item

2008

Reconciliation should = 0 (if not,
either revise data or explain the
reason for the discrepancy
below)

2009

2010

January-June

2011

2012

2013

2014

Explanation for reconciliation not holding:
.

Please note that the quantities reported for end-of-period inventories should equal the beginning-ofperiod inventories reported in the subsequent calendar year (i.e., line P of year 2008 should equal line
D of year 2009). Do these data reconcile for each adjacent calendar year?
Yes

No--Please explain.

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 13

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

Transfers to related firms.--If your firm reported transfers to related firms in question II-8, please
indicate the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a non-market
formula, whether your firm retained marketing rights to all transfers, and whether the related firms
also processed inputs from sources other than your firm.

II-10.

Coating.—
(i)
What share, by weight, of the paper your firm coated in 2013 was produced from base paper
that your firm or an affiliated firm produced?
Item

Share
(percent)

All weights
2

48 g/m

55 g/m

(ii)

Has this percent changed since January 1, 2008?
No

Yes-- Please describe (including reasons for change).

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 14

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

U.S. shipments by basis weight.—Report your firm’s U.S. commercial shipments of certain LW
thermal paper by specified basis weights during the specified periods.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item

2008

2009

2010

2011

January-June
2012

2013

2014

Jumbo rolls
U.S. shipments of LW thermal
paper of:
2

Less than 49.9 g/m
quantity
value
2

49.9 g/m to 60 g/m
quantity
value
2

Over 60 g/m to 70 g/m
quantity
value
1

Total shipments
quantity
value

Slit rolls
U.S. shipments of LW thermal
paper of:
2

Less than 49.9 g/m
quantity
value
2

49.9 g/m to 60 g/m
quantity
value
2

Over 60 g/m to 70 g/m
quantity
value
1

Total U.S. shipments
quantity
value
1

Total U.S. shipments should equal those reported in questions II-7 or II-8 (i.e. line D). If they do not, please explain:

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Page 15

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

U.S. shipments - BPA.—Report your firm’s U.S. commercial shipments of certain LW thermal paper
for the specified Bisphenol A (“BPA”) content during the specified periods.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item

2008

2009

2010

2011

January-June
2012

2013

2014

Jumbo rolls
U.S. shipments of LW thermal
paper of:
BPA-containing
quantity
value
BPA-free
quantity
value
1

Total shipments
quantity
value

Slit rolls
U.S. shipments of LW thermal
paper of:
BPA-containing
quantity
value
BPA-free
quantity
value
1

Total U.S. shipments
quantity
value
1

Total U.S. shipments should equal those reported in questions II-7 or II-8 (i.e. line D). If they do not, please explain:

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 16

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

Purchases.--Other than direct imports, has your firm otherwise purchased jumbo rolls and/or slit rolls
of certain LW thermal paper since January 1, 2008? (See definitions in the instruction booklet.)
No

Yes-- Please indicate the reasons for your firm’s purchases (if your firms’ 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)
Item

2008

2009

2010

2011

2012

2013

Jumbo rolls
PURCHASES FROM U.S.
1
IMPORTERS OF CERTAIN LW
THERMAL PAPER FROM.—
China
Germany
All other countries
PURCHASES FROM DOMESTIC
2
PRODUCERS:
PURCHASES FROM OTHER
SOURCES:
Slit rolls
PURCHASES FROM U.S.
1
IMPORTERS OF CERTAIN LW
THERMAL PAPER FROM.—
China
Germany
All other countries
PURCHASES FROM DOMESTIC
2
PRODUCERS:
PURCHASES FROM OTHER
SOURCES:
1

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

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

II-14.

Toll production.--Since January 1, 2008, has your firm been involved in a toll agreement (see
definition in the instruction booklet) regarding the production of certain LW thermal paper?
No

II-15.

FTZ.--Does your firm produce certain LW thermal paper in a foreign trade zone (FTZ)?
No

II-16.

Yes--Name firm(s):

Yes--Identify FTZ(s):

Direct imports.--Since January 1, 2008, has your firm imported certain LW thermal paper?
No

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

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Page 17

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 orders.--Describe the significance of the existing countervailing duty and/or antidumping
duty orders covering imports of certain LW thermal paper from China and/or Germany 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 orders.--Would your firm anticipate any changes in its production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs, profits,
cash flow, capital expenditures, research and development expenditures, or asset values relating to the
production of certain LW thermal paper in the future if the countervailing duty and/or antidumping
duty orders on certain LW thermal paper from China and/or Germany were to be revoked?
No

II-19.

Other explanations--If your firm would like to further explain a response to a question in Part II that
did not provide a narrative response box, please note the question number and the explanation in the
space provided below. Please also use this space to highlight any issues your firm had in providing
the data in this section, including but not limited to technical issues with the MS Word questionnaire.

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Page 18

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

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 certain LW thermal paper:

Does your firm prepare profit/loss statements for certain LW thermal paper:
Yes
No
How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive 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
certain LW thermal paper, 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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Page 19

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

Other products.--Please list the products your firm produces in the facilities in which it produces
certain LW thermal paper, 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

Certain LW thermal paper

%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any other services) used in the
production of certain LW thermal paper from any related firms?
Yes--Continue to question III-7.

III-7.

Inputs from related firms.--In the space provided below, identify the inputs used in the
production of certain LW thermal paper that your firm purchases from related parties.
Input

III-8.

No--Continue to question III-9.

Related party

Inputs from related firms at cost.--All intercompany profit on inputs purchased from related
parties should be eliminated from the costs reported to the Commission in question III-10 (i.e.,
costs reported in question III-10 should only reflect the related party’s cost and not include an
associated profit component). Reasonable methods for determining and eliminating the
associated profit on inputs purchased from related parties are acceptable.
Has your firm complied with the Commission’s instructions regarding costs associated with
inputs purchased from related parties?
Yes

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Page 20

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

Nonrecurring items (charges and gains) included in certain LW thermal paper 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 certain LW thermal paper financial results in
tables III-10.
Fiscal years ended-2008

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.

2009

2010

2011

January-June
2012

2013

2014

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 - Certain LW Thermal Paper

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PART III.--FINANCIAL INFORMATION--Continued
III-10(a)U.S. operations relating to certain LW thermal paper.--Report the revenue and related cost
information requested below on the certain LW thermal paper operations of your firm’s U.S.
establishment(s) during the specified periods.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
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2008

2009

2010

2011

2012

2013

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

0
0

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
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 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-7.
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-7/II-8.
2

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PART III.--FINANCIAL INFORMATION--Continued
III-10(a)U.S. operations relating to certain LW thermal paper.—Continued
Quantity (in short tons) and value (in $1,000)
Item

January-June 2013

January-June 2014

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

0
0

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
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 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

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 - Certain LW Thermal Paper

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PART III.--FINANCIAL INFORMATION--Continued
III-10(b)U.S. operations relating to certain LW thermal paper.--Continued
Financial data reconciliation.--The calculable line items from question III-10 (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.

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Page 24

PART III.--FINANCIAL INFORMATION--Continued

III-11. For U.S. converters – value added.—For the reported raw material costs in III-10(a), please
provide the percentage of total raw material costs that reflect U.S. content (raw material inputs
purchased from U.S. producers) and the percentage of total raw material costs that reflect foreign
content (directly imported or purchased imports of raw material inputs) for your firm’s most
recently completed fiscal year.
Item

Value added (percent)

Raw material costs:
U.S. content – jumbo rolls
1

U.S. content – other than jumbo rolls
2

Foreign content

Total (should sum to 100.0%)
1
2

Please identify the other raw materials sourced in the United States:
Please identify the raw materials and the country source(s):

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with the
production, warehousing, and sale of certain LW thermal paper. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for certain LW
thermal paper 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 six 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
Total assets (net)

2008

2009

2010

2011

2012

2013

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 25

PART III.--FINANCIAL INFORMATION--Continued
III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on certain LW thermal paper. Provide data
for your firm’s six most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended-Item

2008

2009

2010

2011

January-June
2012

2013

2014

Capital expenditures
Research and development
expenses

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-10 through III-13 are based on a calendar year or 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 questions II-7/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 questions II-7/II-8?
Yes

If no, please explain.

III-15. Other explanations--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with the
MS Word questionnaire.

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Page 26

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

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Page 27

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

This question requests quarterly quantity and value data for your firm’s commercial shipments to
unrelated U.S. customers since January 1, 2008 of the following products produced by your firm.
Product 1.--Thermal paper in jumbo rolls, made with Bisphenol A (BPA), with a target caliper of 2.2
to 2.5 mils (55.9 to 63.5 microns), with a target basis weight of at least 49.9 g/m2 and up to 60 g/m2,
not top-coated, white/non-colored paper, black image color, not printed on the non-thermal coated
side, standard sensitivity.
Product 2.--Thermal paper in jumbo rolls, made free of BPA, with a target caliper of 2.2 to 2.5 mils
(55.9 to 63.5 microns), with a target basis weight of at least 49.9 g/m2 and up to 60 g/m2, not topcoated, white/non-colored paper, black image color, not printed on the non-thermal coated side,
standard sensitivity.
Product 3.-- Thermal paper in jumbo rolls, made with PBA, with a target caliper of less than 2.2 (less
than 55.9 microns), with a target basis weight of less than 49.9 g/m2, not top-coated, white/noncolored paper, black image color, not printed on the non-thermal coated side, standard sensitivity.
Product 4.-- Thermal paper in jumbo rolls, made free of BPA, with a target caliper of less than 2.2
(less than 55.9 microns), with a target basis weight of less than 49.9 g/m2, not top-coated, white/noncolored paper, black image color, not printed on the non-thermal coated side, standard sensitivity.
Product 5. --Thermal paper in slit rolls, made with PBA, with a target caliper of 2.2 to 2.5 mils (55.9
to 63.5 microns), with a target basis weight of at least 49.9 g/m2 and up to 60 g/m2, not top-coated,
white/non-colored paper, black image color, standard sensitivity, measuring 3-1/8 (+/- 1/16) inch by
230 (+/- 10) feet, without printing on the non-thermal coated side.
Product 6. --Thermal paper in slit rolls, made free of BPA, with a target caliper of 2.2 to 2.5 mils
(55.9 to 63.5 microns), with a target basis weight of at least 49.9 g/m2 and up to 60 g/m2, not topcoated, white/non-colored paper, black image color, standard sensitivity, measuring 3-1/8 (+/- 1/16)
inch by 230 (+/- 10) feet, without printing on the non-thermal coated side.
Product 7. --Thermal paper in slit rolls, made with PBA, with a target caliper of less than 2.2 (less
than 55.9 microns), with a target basis weight of less than 49.9 g/m2, not top-coated, white/noncolored paper, black image color, standard sensitivity, measuring 3-1/8 (+/- 1/16) inch by 230 (+/- 10)
feet, without printing on the non-thermal coated side.
Product 8. --Thermal paper in slit rolls, made free of BPA, with a target caliper of less than 2.2 (less
than 55.9 microns), with a target basis weight of less than 49.9 g/m2, not top-coated, white/noncolored paper, black image color, standard sensitivity, measuring 3-1/8 (+/- 1/16) inch by 230 (+/- 10)
feet, without printing on the non-thermal coated side.

Please note that values should be delivered and should include U.S.-inland transportation costs.
Values should reflect the final net amount paid to your firm (i.e., should be net of all deductions for
discounts or rebates). See instruction booklet.
During January 2008-June 2014, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question IV-3.

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Page 28

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

Pricing data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report quantity in thousands of square feet (msf). Report value in actual dollars (not 1,000s).
Product 1
Quantity
Value

Product 2
Quantity
Value

Product 3
Quantity
Value

Product 4
Quantity
Value

Period of shipment
(msf)
(dollars)
(msf)
(dollars)
(msf)
(dollars)
(msf)
(dollars)
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
April-June
July-September
October-December
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
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 firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified
product, provide a description of the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 29

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

Pricing data.--Continued.
Report quantity in thousands of square feet (msf). Report value in actual dollars (not 1,000s).
Product 5
Quantity
Value

Product 6
Quantity
Value

Product 7
Quantity
Value

Product 8
Quantity
Value

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Page 30

PART IV.--PRICING AND MARKET FACTORS--Continued
If your response to any question in this section differs for slit rolls versus jumbo rolls, please explain.
IV-3.

Price setting.-- How does your firm determine the prices that it charges for sales of certain LW
thermal paper (check all that apply)? If your firm issues price lists, please submit sample pages
of a recent list.
Transaction
by
transaction

IV-4.

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe typical range of values of such
discounts and, if “other,” describe type of
discount

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced certain LW thermal paper?
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 certain LW thermal paper usually
quoted (check one)?
Delivered

IV-6.

Other

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

Quantity
discounts

IV-5.

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
certain LW thermal paper in 2012 and 2013 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
Share of your
2013 sales

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

Spot sales
(for a single
delivery)

Total
(should sum
to 100.0%)

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Page 31

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-7.

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
certain LW thermal paper (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

Meet or release provision

Yes
No

Not applicable

IV-8.

Lead times.--What is the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of your firm’s U.S.-produced certain LW thermal paper?

Source

Share of 2013
sales

From inventory

Produced to order

Total (should sum to 100.0%)

Lead time
(average number
of days)

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Page 32

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

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of certain LW thermal
paper 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 certain LW thermal paper that
are delivered the following distances from your firm’s production facility.
Distance from production facility

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

IV-10. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced certain LW thermal paper since January 1, 2008 (check all that apply)?
√ 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-11. End uses.--List the end uses of the certain LW thermal paper that your firm manufactures. For
each end-use product, what percentage of the total cost is accounted for by certain LW thermal
paper and other inputs?
Share of total cost of end use product
accounted for by

End use product

Certain LW thermal
paper

Total
(should sum to
100.0% across)l

Other inputs

%
%

0
0

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Page 33

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-12. Changes in end uses.--Have there been any changes in the end uses of certain LW thermal paper
since January 1, 2008? Do you anticipate any future changes?
Changes in end
uses

Yes

Explain

Changes since
January 1, 2008
Anticipated
changes

IV-13. Substitutes.-- Can other products be substituted for certain LW thermal paper?
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 certain LW thermal
paper?
No Yes

Explanation

1.
2.
3.

IV-14. Changes in substitutes.-- Have there been any changes in the number or types of products that
can be substituted for certain LW thermal paper since January 1, 2008? Do you anticipate any
future changes?
Changes in
substitutes
Changes since
January 1, 2008
Anticipated
changes

No Yes

Explain and report if they have affected the price of LW
thermal paper.

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Page 34

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-15. Raw materials.-- Indicate how certain LW thermal paper raw materials prices have changed
since January 1, 2008, and how you expect they will change in the future.

Raw
materials
prices

Fluctuate
with no
Overall
No
Overall
clear
increase change decrease
trend

Explain, noting how raw material
price changes have affected your
firm’s selling prices for certain LW
thermal paper.

Changes
since
January 1,
2008
Anticipated
changes

IV-16. Product offerings. – Please fill in the following table for the products you sell.
Ranges of
widths in
inches

Percent
standard
print
sensitivity
%

Ranges of
calipers

Ranges of
basis weights

Percent
with
advertising
on back
%

Percent
BPA free
%

IV-17. Printer approval certification. – Please list the five largest thermal printer manufacturers (e.g.,
IBM, Epson) that have approved your LW thermal paper for use in their machines.
Name of printer manufacturer
1
2
3
4
5

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Page 35

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-18. Availability of supply.--Has the availability of certain LW thermal paper in the U.S. market
changed since January 1, 2008? Do you anticipate any future changes in availability?
Availability in the U.S.
market

Please explain, noting the countries and reasons for
No Yes the changes.

Changes since January 1 2008:
U.S.-produced product
Imports from China
Imports from Germany
Nonsubject imports
Anticipated changes:
U.S.-produced product
Imports from China
Imports from Germany
Nonsubject imports

IV-19. Supply constraints.--Has your firm refused, declined, or been unable to supply certain LW
thermal paper since January 1, 2008 (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 and report the types of customers affected.

IV-20. Export constraints.--Describe how easily your firm can shift its sales of certain LW thermal
paper 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 certain LW thermal paper between the U.S. and alternative country
markets within a 12-month period.

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 36

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-21. Product changes.-- Have there been any significant changes in the product range, product mix,
or marketing of certain LW thermal paper since January 1, 2008? Do you anticipate any future
changes?
Changes in
product range,
product mix, or
marketing
No Yes

Explain

Changes since
January 1, 2008
Anticipated
changes

IV-22. Demand trends.-- Indicate how demand within the United States and outside of the United States
(if known) for certain LW thermal paper has changed since January 1, 2008, 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.

Market

Overall
No
increase change

Fluctuate
Overall
with no
decrease clear trend

Demand since January 1, 2008
Within
the United
States
Outside
the United
States
Anticipated future demand
Within
the United
States
Outside
the United
States

Explanation and factors

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Page 37

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-23. Conditions of competition.-(a) Is the certain LW thermal paper market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to certain LW
thermal paper?

Check all that apply.

Please describe.

Skip to question IV-24.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition

(b) If yes, have there been any changes in the business cycles or conditions of competition for
certain LW thermal paper since January 1, 2008?
No

Yes

If yes, describe.

(c) Are there unique attributes of competition at different levels of trade in the U.S. market
(coaters to converters and converters to end users)?
No

Yes

If yes, describe.

(d) Has the competition at different levels of trade in the U.S. market changed since 2008?
No

Yes

If yes, describe.

IV-24. Price comparisons.--Please compare market prices of certain LW thermal paper in U.S. and nonU.S. markets, if known. Provide specific information as to time periods and regions for any price
comparisons.
Jumbo
rolls
Split rolls

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Page 38

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-25. 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 certain LW thermal paper 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 Germany, and (3)
the world as a whole. Of particular interest is such data from 2008 to the present and forecasts for
the future.
IV-26. Barriers to trade.--Are your firm’s exports of certain LW thermal paper subject to any tariff or
non-tariff barriers to trade in other countries?

Yes

If yes, please list the countries and describe any such barriers and
any significant changes in such barriers that have occurred since
January 1, 2008, or that are expected to occur in the future.

IV-27. Interchangeability.--Is certain LW thermal paper 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

China

Germany

Other countries

United States
China
Germany

For any country-pair producing certain LW thermal paper which is sometimes or never
interchangeable, please identify the country-pair and explain the factors that limit or preclude
interchangeable use:

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U.S. Producers’ Questionnaire - Certain LW Thermal Paper

Page 39

PART IV.--PRICING AND MARKET FACTORS--Continued
IV-28. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between certain LW thermal paper
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

China

Germany

Other countries

United States
China
Germany

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

IV-29. Other explanations--If your firm would like to further explain a response to a question in Part IV
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with the
MS Word questionnaire.

File Type	application/pdf
File Title	US Producer questionnaire - sunst
Author	USITC
File Modified	2014-08-01
File Created	2014-08-01