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pdfOMB No. 3117-0016/USITC No.15-1-3408; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
SILICOMANGANESE FROM AUSTRALIA
This questionnaire must be received by the Commission by December 11, 2015
See last page 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 silicomanganese from Australia (Inv. No. 731-TA-1269 (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
Website
Has your firm produced silicomanganese (as defined on next page) at any time since January 1, 2012?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: SIMN)
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
Fax:
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Silicomanganese
Page 2
PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to a petition filed on February 19, 2015, by
Felman Production LLC, Letart, West Virginia. Antidumping duties may be assessed on the subject
imports as a result of this proceeding if the Commission makes an affirmative determination of injury,
threat, or material retardation, and if the U.S. Department of Commerce makes an affirmative
determination of dumping. Questionnaires and other information pertinent to this proceeding are
available at http://www.usitc.gov/investigations/701731/2015/silicomanganese_australia/final.htm.
Silicomanganese. The scope of this investigation covers all forms, sizes and compositions of
silicomanganese, except low-carbon silicomanganese, including silicomanganese briquettes, fines, and
slag. Silicomanganese is a ferroalloy composed principally of manganese, silicon, and iron, and normally
contains much smaller proportions of minor elements, such as carbon, phosphorus, and sulfur.
Silicomanganese is sometimes referred to as ferrosilicon manganese. Silicomanganese generally
contains by weight not less than 4 percent iron, more than 30 percent manganese, more than 8 percent
silicon and not more than 0.2 percent phosphorus. Silicomanganese is properly classifiable under
subheading 7202.30.0000 of the Harmonized Tariff Schedule of the United States (“HTSUS”).
Low-carbon silicomanganese is excluded from the scope of this investigation. It is sometimes referred to
as ferromanganese-silicon. The low-carbon silicomanganese excluded from this investigation is a
ferroalloy with the following chemical specifications by weight: minimum 55 percent manganese,
minimum 27 percent silicon, minimum 4 percent iron, maximum 0.10 percent phosphorus, maximum
0.10 percent carbon, and maximum 0.05 percent sulfur. Low-carbon silicomanganese is classifiable
under HTSUS subheading 7202.30.0000. The HTSUS subheadings are provided for convenience and
customs purposes. The written description of the scope is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. '1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 3
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. '1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR '207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of silicomanganese and your responses to the questions in Part
I of the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request,
for use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
I-1a.
Page 4
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
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, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.
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?
Yes
I-2.
No
Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of silicomanganese, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
City, State
Zip (5 digit)
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
Description
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
I-3.
Page 5
Petition support.--Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
Australia
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 silicomanganese from Australia into the United States or
that are engaged in exporting silicomanganese from Australia 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 silicomanganese?
No
Firm name
Yes--List the following information.
Address
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 6
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Michael Szustakowski (202205-3169, [email protected]). Supply all data requested on a calendar-year basis.
II-1.
Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax
II-2.
Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of silicomanganese since January 1, 2012. Please include
as an attachment to this questionnaire any contemporary business records (e.g., marketing
plans, business plans, management reports, presentations) documenting the reasons for any of
the following changes in operations.
(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 - Silicomanganese
Page 7
Product shifting.—Please provide answers to each of the following questions relating to your firm’s
ability to shift production between silicomanganese and other products.
II-3.
(a)
In relation to furnaces not dedicated 100 percent to the production of silicomanganese,
please provide the following information on the other products produced in those
furnaces (if more than four products, list the largest).
Costs and timeframes involved in switching production
to/from Silicomanganese
Product(s)
Est. share of furnace fleet’s
production time dedicated
1
to product
(share)
1. Ferromanganese
2.
3.
4.
1
Provide an estimated share here that represents how much of the annual average total production hours of
all of your firm’s furnaces relates to the production of the listed product in a given year. For example, report 25
percent of ferromanganese if in a year 500 hours are dedicated to ferromanganese and 1500 dedicated to
silicomanganese.
Additional discussion:
(b)
In relation to those furnaces dedicated 100 percent to the production of
silicomanganese since January 1, 2012, could these furnaces be converted to the
production of products other than silicomanganese?
No
Yes.--And at what cost/time constraint?
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-3.
Product shifting.—Continued
(c)
Does your firm own or operate furnaces not reported in question II-3(a) at all (i.e., not
involved in silicomanganese production during the period) that could be converted to
the production of silicomanganese?
No
II-4a.
Page 8
Yes.--And at what cost/time constraint?
Production capacity using same machinery.-- Please report your firm’s production capacity of
products made on the same equipment and machinery used to produce silicomanganese, and
the combined production capacity on this shared equipment and machinery in the periods
indicated.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix). In other words,
capacity dedicated to specific products.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup). In other words, capacity for the overall furance's productive
operations in a period. Overall prodcution capacity is the sum of the average production
capacities reported for the individual products produced on the same machinery as
silicomaganese.
First define each of the individual furances your firm used to produce silicomanganese since
January 2012. Then reporte the average production capacity for those those furances in the
specified periods for the specified products.
Label
Furance A
Furance B
Furance C
Furance D
Short name
Description
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 9
II-4a. Production capacity using same machinery.--Continued
(Quantity in short tons)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
CAPACITY DATA ONLY
Average silicomanganese
(SiMn) production capacity
Furnace A
Furnace B
Furnace C
Furnace D
Average production
1
capacity for "SiMn"
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Furnace B
0
0
0
0
0
Furnace C
0
0
0
0
0
Furnace D
0
0
0
0
0
0
0
0
0
0
Average other products
1
production capacity
Furnace A
Furnace B
Furnace C
Furnace D
Average production
capacity for "other
products"
Overall production capacity
Furnace A
Overall production
capacity 3
1
Data reported here on a furnace by furnace basis will populate into total silicomanganese capacity
reported in question II-8.
2
Please identify these products:
3
Aggregated data for all reported furnace capacity in this line will populate into total overall
production capacity reported in question II-4b.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 10
Production capacity using same machinery.--Continued
II-4b.
“Production” – All production in your U.S. establishment(s) of products made on the same
equipment and machinery used to produce silicomanganese, including production consumed
internally within your firm and production for another firm under a toll agreement.
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Capacity (in short tons)
Overall production
capacity1
0
0
0
0
0
Production (in short tons)
Production of:
Silicomanganese2
0
0
0
0
0
0
0
0
0
0
Ferromanganese
Other products
Total3
1
Data reported on overall production capacity will populate here once reported in question II-4a.
Silicomanganese production should equal production reported in question II-8.
3
Please ensure that total production (reported here) on the machinery and equipment used to produce
silicomanganese does not exceed the overall production capacity.
2
II-4c.
Operating parameters.--The production capacity reported in II-4a is based on operating
per week,
weeks per year.
II-4d.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-4a, and explain any changes in reported capacity.
II-4e.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
hours
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-4f.
Event
Event 1
Event 2
Event 3
Event 4
Event 5
Event 6
Event 7
Event 8
Event 9
Event 10
Event 11
Event 12
Event 13
Event 14
Event 15
Event 16
Page 11
Furnace availability.—If your firm idled or ceased producing silicomanganese on any of its furnaces
for any reason, please specify below, for each furnace, the period(s) it was offline and the amount of
affected capacity.
Furnace affected
Period(s) offline
(day/month/year day/month/year)
Reason(s) for being
offline
Quantity of unused
SiMn capacity
(short tons)
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-5.
Page 12
Tolling.--Since January 1, 2012, has your firm been involved in a toll agreement regarding the
production of silicomanganese?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
II-6.
Yes--Please describe the toll arrangement(s) and name the firm(s) involved
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce silicomanganese in and/or admit
silicomanganese into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
(b)
Yes--Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import silicomanganese into a foreign trade zone (FTZ) for use in distribution of
silicomanganese and/or the production of downstream articles?
No/Don’t know
Yes--Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-7.
Page 13
Importer.--Since January 1, 2012, has your firm imported silicomanganese?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
II-8.
Yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of silicomanganese in its U.S.
establishment(s) during the specified periods.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
Such transactions are valued at fair market value.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 14
Production, shipment and inventory data.--
II-8.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
1
Average production capacity (quantity)
(A)
0
0
0
0
0
0
0
0
0
0
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)2
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value3 (G)
Transfers to related firms:
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1
Data on the average production capacity for silicomanganese will populate here from data reported in question II-4a.
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
.Data on the production of silicomanganese will populate here from data reported in question II-4b.
3
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:
4
Identify your firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod 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 any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2012
2013
0
January-September
2014
0
2014
0
2015
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
0
.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-9.
Page 15
Channels of distribution.-- Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To end users (quantity) (N)
Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.
2012
2013
0
January-September
2014
0
2014
0
2015
0
0
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-10.
Page 16
Employment data.--Report your firm’s employment-related data related to the production of
silicomanganese and provide any explanation for any trends in these data.
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to September periods, calculate similarly and divide by 9.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II-11.
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 nonmarket 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 - Silicomanganese
II-12.
Page 17
Purchases.--Other than direct imports, has your firm otherwise purchased silicomanganese
since January 1, 2012?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign producer where your firm is the importer
of record or consignee.
No
Yes--Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in short tons)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Purchases from U.S.
importers1 of
silicomanganese from—
Australia
Other
Purchases from domestic
producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this
product:
.
II-13.
Other explanations:--If your firm would like to further explain a response to a question in Part II
that did not provide a narrative 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.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 18
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Justin Jee (202-205-3186, [email protected]).
III-1.
Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
Fax
III-2.
Accounting system.--Briefly describe your 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:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include silicomanganese:
2.
Does your firm prepare profit/loss statements for silicomanganese:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)
3.
4.
Note: The Commission may request that your company submit copies of its financial statements,
including internal profit-and-loss statements for the division or product group that includes
silicomanganese, as well as those statements and worksheets used to compile data for your firm’s
questionnaire response.
III-3.
Cost accounting system.--Briefly describe your 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.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
III-5.
Page 19
Other products.--Please list the products your firm produced in the facilities in which your firm
produced silicomanganese, 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
Silicomanganese
%
%
%
%
%
III-6.
Does your firm purchase (or otherwise obtain) inputs (raw materials, labor, energy, or any other
services) used in the production of silicomanganese from any related parties?
Yes--Continue to question III-7.
III-7.
No--Continue to question III-9a.
Inputs from related parties.--Please identify the inputs used in the production of
silicomanganese that your firm purchases (or otherwise obtains) from related parties and that
are reflected in table III-9a. For “Share of total COGS” please report this information by relevant
input on the basis of your most recently completed fiscal year. For “Input valuation” please
describe the basis, as recorded in your company’s own accounting system, of the purchase cost
from the related party; e.g., the related party’s actual cost, cost plus, negotiated transfer price
to approximate fair market value.
Input
Related party
Share of total COGS
(percent)
Input valuation as recorded in the firm’s accounting books and records
III-8.
Inputs purchased from related parties.--Please confirm that the inputs purchased or otherwise
obtained from related parties, as identified in III-7, were reported in III-9a (financial results on
silicomanganese) in a manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from
related parties as reported in table III-9a.
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III-9a. Operations on silicomanganese.--Report the revenue and related cost information requested
below on the silicomanganese operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related parties should be consistent with and
based on information in the firm’s accounting books and records. Provide data for your firm’s
three most recently completed fiscal years, and for the specified interim periods. If your firm
was involved in tolling operations (either as the toller or as the tollee), please contact Justin Jee
at 202-205-3186 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended—
Item
2012
2013
January-September
2014
2014
2015
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials
3
Direct labor
Other factory costs
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.
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.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2
Note.–The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III-9b. Financial data reconciliation.--The calculable line items from question III-9a (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.
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-9a 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-9a; i.e., if an aggregate nonrecurring item has been allocated to table III-9a, only the allocated
value amount included in table III-9a 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 financial results of the subject product in table III-9a.
Fiscal years ended-2012
2013
January-September
2014
2014
2015
Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in table III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
Value ($1,000)
1.
, classified
2.
, classified
3.
, classified
4.
, classified
5.
, classified
6.
, classified
7.
, classified
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III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in table III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., III-10 information designates where these items are reported in
table III-9a.
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of silicomanganese. If your firm does not maintain some
or all of the specific asset information necessary to calculate total assets for silicomanganese in
the normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with your 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
Total assets (net)
1
2012
2013
2014
1
Describe
III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on silicomanganese. Provide data for
your firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended--
Item
2012
2013
January-September
2014
2014
Capital expenditures
Research and development expenses
III-13b. Capital expenditures.--Please indicate the nature, focus, and significance of your firm’s capital
expenditures on the subject product.
2015
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III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13a 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-9a 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-9a reconcile with data in question II-8?
Yes
No
If no, please explain.
III-15. Effects of imports on investment.--Since January 1, 2012, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of silicomanganese from Australia?
No
Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
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III-16. Effects of imports on growth and development.--Since January 1, 2012, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of silicomanganese from Australia?
No
Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
silicomanganese from Australia?
No
Yes
If yes, my firm anticipates negative effects as follows:
III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative 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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PART IV.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Tana Farrington (202-2052389, [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 for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2012 of the following products produced by your
firm.
Product 1.-- Standard grade (65-68% Mn) bulk silicomanganese sold to distributors under
contracts
Product 2.-- Standard grade (65-68% Mn) bulk silicomanganese sold to steel producers under
contracts
Product 3.-- Standard grade (65-68% Mn) bulk silicomanganese sold to distributors as spot
sales
Product 4.-- Standard grade (65-68% Mn) bulk silicomanganese sold to steel producers as spot
sales
Contracts are transactions over a quarterly or longer period, with prices either fixed or indexed to a
published price.
Spot sales are transactions to be supplied within approximately two weeks forward in the spot
market. (See Ryan’s Notes Price Assessment Methodology).
Please note that values should be f.o.b, U.S. point of shipment and should not 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, allowances, rebates, prepaid freight, and the value of returned goods).
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Page 26
During January 2012-September 2015, 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.
During January 2012-September 2015, did your firm produce any bulk silicomanganese other
(e.g., 72% Mn content) than standard grade from Australia, Georgia, and/or South Africa, and
sell to unrelated U.S. customers?
Yes.--Please contact Tana Farrington ([email protected]) for further
instruction.
No.
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IV-2(a). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Contracts are transactions over a quarterly or longer period, with prices either fixed or indexed to a
published price.
Report data in actual short tons and actual dollars (not 1,000s). Also report the specific grade(s) (e.g.
grade B, grade C) and average manganese content for each product.
(Quantity in short tons, value in dollars)
Product 1
Standard grade (65-68% Mn)
Contract sales
To distributors
Grade(s):
Average manganese content:
Quantity
Value
Product 2
Standard grade (65-68% Mn)
Contract sales
To steel producers
Grade(s):
Average manganese content:
Quantity
Value
Period of shipment
2012:
January-March
April-June
July-September
October-December
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your 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 your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
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IV-2(a). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Spot sales are transactions to be supplied within approximately two weeks forward in the spot
market. (See Ryan’s Notes Price Assessment Methodology).
Report data in actual short tons and actual dollars (not 1,000s). Also report the specific grade(s) (e.g.
grade B, grade C) and average manganese content for each product.
(Quantity in short tons, value in dollars)
Product 3
Standard grade (65-68% Mn)
Spot sales
To distributors
Grade(s):
Average manganese content:
Quantity
Value
Product 4
Standard grade (65-68% Mn)
Spot sales
To steel producers
Grade(s):
Average manganese content:
Quantity
Value
Period of shipment
2012:
January-March
April-June
July-September
October-December
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your 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 your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 3:
Product 4:
IV-2(b). Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.
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Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
IV-3. Price setting.-- How does your firm determine the prices that it charges for sales of
silicomanganese (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction
IV-4.
Other
If other, describe
Discount policy.-- Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
IV-5.
Contracts
Set
price
lists
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Pricing terms.-(a)
What are your firm’s typical sales terms for its U.S.-produced silicomanganese?
Net 30
days
(b)
Net 60
days
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic silicomanganese usually quoted (check
one)?
Delivered
F.o.b.
If f.o.b., specify point
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U.S. Producers’ Questionnaire - Silicomanganese
IV-6.
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
silicomanganese in 2014 was on a (1) long-term contract basis, (2) annual contract basis, (3)
short-term contract basis, and (4) spot sales basis?
Share of 2014
sales
IV-7.
Page 30
Long-term
contracts
(multiple
deliveries for
more than 12
months)
%
Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
0.0
%
Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced silicomanganese (or check “not applicable” if your firm does not sell on a longterm and/or short-term contract basis).
Typical sales
contract provisions
Item
Average contract
duration
# of days
Price renegotiation
(during contract
period)
Fixed quantity
and/or price
Meet or release
provision
Not applicable
Yes
No
Quantity
Price
Both
Yes
No
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
365
Long-term contracts
(multiple deliveries for
more than 12 months)
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IV-8.
Page 31
Price Indices.-(a)
Does your firm base sales prices on published prices from the following sources?
No—Skip to question IV-9.
Yes--Check all that apply to your firm.
Data series
(Check all applicable)
Ryan’s Notes
Platt’s Metal Week
U.S. Import Statistics
Source(s) other than those
listed above 1
1
(b)
List the source(s)
What types of your firm’s sales are based on these published prices?
Long-term
contracts
(multiple
deliveries for
more than 12
months)
Annual
contracts
(multiple
deliveries for 12
months)
Short-term
contracts
(multiple
deliveries for
less than 12
months)
Spot sales
(for a single
delivery)
If other, describe
(c)
Please describe how your firm uses these published prices, including adjustments or
discounts given and the type of purchaser.
(d)
Since January 1, 2012, did your firm report its sales prices, on either a spot or contract
basis, to Ryan’s Notes, Platt’s, or other publications?
No
Spot sales prices
Contract sales prices
Yes
If yes, please indicate
If yes, please list how frequently your
the publication(s) firm reports its prices
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(e)
If yes to III-25(d), does your firm know whether its reported prices were used in the
published price index?
No
IV-9.
Yes
If yes, please describe how your firm’s reported prices were incorporated into
the published price index, to the best of your knowledge.
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 silicomanganese?
Source
Share of 2014 Lead time (average
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
IV-10. Shipping information.-(a)
What is the approximate percentage of the total delivered cost of U.S.-produced
silicomanganese that is accounted for by U.S. inland transportation costs?
percent
(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 silicomanganese 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 (should sum to 100.0%)
0.0
%
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IV-11. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced silicomanganese since January 1, 2012 (check all that apply)?
Geographic area
√ if applicable
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI, among others.
IV-12. End uses.--List the end uses of the silicomanganese that your firm manufactures. For each enduse product, what percentage of the total cost is accounted for by silicomanganese and other
inputs?
Share of total cost of end use product
accounted for by
End use product
Silicomanganese
Other inputs
Total
(should sum to
100.0% across)
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-13. Substitutes.-- Can other products be substituted for silicomanganese?
No
Substitute
1.
2.
3.
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 silicomanganese?
No Yes
Explanation
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Page 34
IV-14. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for silicomanganese has changed since January 1, 2012. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Overall
increase
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Within
the United
States
Outside
the United
States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of silicomanganese since January 1, 2012?
No
Yes
If yes, please describe and quantify if possible.
IV-16. Conditions of competition.-(a) Is the silicomanganese market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to silicomanganese? If
yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV-17.
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
silicomanganese since January 1, 2012?
No
Yes
If yes, describe.
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IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply silicomanganese
since January 1, 2012 (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, supply
agreements/contract disputes, product quality complaints, lack of availability, etc.)?
No
Yes
If yes, please describe.
IV-18. Raw materials.--How have silicomanganese raw materials prices changed since January 1, 2012?
Overall
increase
Fluctuate
with no Explain, noting how raw material price changes
clear
have affected your firm’s selling prices for
No
Overall
change decrease
trend
silicomanganese.
IV-19. Interchangeability.--Is silicomanganese produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair
Australia
Georgia
South Africa
Other countries
United States
Australia
Georgia
South Africa
For any country-pair producing silicomanganese 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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IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between silicomanganese
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair
Australia
Georgia
South Africa
Other countries
United States
Australia
Georgia
South Africa
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of silicomanganese, identify the country-pair and report the
advantages or disadvantages imparted by such factors:
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IV-21. Customer identification--List the names and contact information for your firm’s 10 largest U.S.
customers for silicomanganese since January 1, 2012. Indicate the share of the quantity of your
firm’s total shipments of silicomanganese that each of these customers accounted for in 2014.
Customer’s name
1
2
3
4
5
6
7
8
9
10
City
State
Share of 2014 sales (%)
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IV-22. Competition from imports
(a)
Lost revenue.--Since January 1, 2012: To avoid losing sales to competitors selling
silicomanganese from Australia, did your firm:
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2012: Did your firm lose sales of silicomanganese to
imports of this product from Australia?
No
Yes
IV-23. 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.
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the Commission’s
website
at: http://www.usitc.gov/investigations/title_7/2015/silicomanganese_australia/final.htm..
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods
noted below. If your firm is unable to complete the MS Word questionnaire or
cannot use one of the electronic methods of submission, please contact the
Commission for further instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy
of the signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/ Pin: SIMN
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Please note that submitting your questionnaire by e-mail may
subject your firm’s business proprietary information to transmission over an unsecure environment and
to possible disclosure. If you choose this option, the Commission warns you that any risk involving
possible disclosure of such information is assumed by the submitter and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a
copy of the completed questionnaire on parties to the proceeding that are subject to
administrative protective order (see 19 CFR '207.7). A list of such parties may be obtained from
the Commission’s Secretary (202-205-1803). A certificate of service must accompany the
completed questionnaire you submit (see 19 CFR '207.7). Service of the questionnaire must be
made in paper form.
| File Type | application/pdf |
| File Title | US producer questionnaire |
| Subject | Title 7 investigations |
| Author | Martinez, Keysha |
| File Modified | 2015-10-29 |
| File Created | 2015-10-29 |