15-2-3409 U.S. Importer Questionnaire

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

US importer questionnaire

Silicomanganese from Australia, Inv. No. 731-TA-1269 (Final)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 15-2-3409; Expiration Date: 6/30/2017
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U.S. IMPORTERS’ 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 imported silicomanganese (as defined on next page) from any country at any time since January 1,
2012?

(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

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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.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing product (as defined above) into the United States from a foreign manufacturer or through its
selling agent.
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.

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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.

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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
40 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-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of silicomanganese,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

I-3.

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

Firm name

Yes--List the following information

Address

Extent of
ownership
(percent)

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U.S. Importers’ Questionnaire - Silicomanganese
I-4.

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

Yes--List the following information.

Firm name

I-5.

Address

Yes--List the following information.

Firm name

Address

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on
silicomanganese. More than one answer may be applicable.
Importer of record

I-7.

Affiliation

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

I-6.

Page 5

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of silicomanganese but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).

Firm name

Address

Contact person
and phone
number

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I-8.

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FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters silicomanganese
into, or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also
indicate whether your firm imports silicomanganese under the TIB (temporary importation
under bond) program.
“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, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S. Code § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
No

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

Third-country trade activities.--To your knowledge, have the products subject to this
proceeding been the subject of any other import relief proceedings in the United States or in
any other countries?
No

Yes–Please specify.

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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 importation 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)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(please describe)

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II-3.

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Arranged imports.--Has your firm imported or arranged for the importation of silicomanganese
for delivery on or after October 1, 2015?
“Arranged imports” are imports for which your firm has placed an order with a foreign producer
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes–Fill out the table below.
Quantity (in short tons)

Period/Source

Oct-Dec 2015

Jan-Mar 2016

Apr-Jun 2016

Jul-Sept 2016

Australia
Other sources:1
1

II-4.

Identify your other sources:

Reasons for importing.--If your firm also produces silicomanganese in the United States, please
indicate the reasons for importing this product. If your firm’s reasons differ by source, please
elaborate.

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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.

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II-5.

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IMPORTS FROM AUSTRALIA.–Report your firm’s imports and your firm’s shipments and
inventories of silicomanganese imported from Australia by your firm during the specified
periods. +Link to definitions

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

2012

2013

January-September
2014

2014

2015

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/
company transfers:
Quantity (F)
Value2 (G)
Export shipments:3
Quantity (H)
Value (I)
End-of-period inventories
(quantity) (J)
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (K)
To end users (quantity) (L)
1

Please identify the foreign producers, if known:
.
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, 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:
.
2

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IMPORTS FROM AUSTRALIA.–Continued

II-5.

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line J) should be equal to the beginning-of-period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, and H). 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

2012

2013

A + B – D – F – H – J = should equal zero
("0") or provide an explanation.1

January-September
2014

2014
0

2015
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) in each time period equal the quantity reported for commercial U.S. commercial
shipments (i.e., line D) in each time period. If the calculated fields below return values other than zero
(i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item

2012

K + L – D = zero ("0"), if not revise.

2013
0

January-September
2014

2014
0

2015
0

Imports of low-carbon silicomanganese from Australia.—The scope of this investigation
includes silicomanganese except low-carbon silicomanganese (+Link to product description).
Imports of all silicomanganese products typically enter under the following HTS statistical
reporting number: 7202.30.0000.

II-6.

Did your firm import low-carbon silicomanganese or other out-of-scope merchandise from
Australia under HTS statistical reporting number 7202.30.0000? Such imports should be
reported in the table below but should not be included in II-5.
No

Yes–Please report the quantity and value below.
Quantity (in short tons), value (in $1,000)
Calendar years

Item
1

Imports:
Quantity (B)
Value (C)

2012

2013

January-September
2014

2014

2015

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II-7.

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IMPORTS FROM GEORGIA.–Report your firm’s imports and your firm’s shipments and
inventories of silicomanganese imported from Georgia by your firm during the specified
periods. +Link to definitions

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

2012

2013

January-September
2014

2014

2015

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IMPORTS FROM GEORGIA.–Continued

II-7.

2012

2013

A + B – D – F – H – J = should equal zero
("0") or provide an explanation.1

January-September
2014

2014
0

2015
0

2012

K + L – D = zero ("0"), if not revise.

2013
0

January-September
2014

2014
0

2015
0

Imports of low-carbon silicomanganese from Georgia.—The scope of this investigation includes
silicomanganese except low-carbon silicomanganese (+Link to product description). Imports
of all silicomanganese products typically enter under the following HTS statistical reporting
number: 7202.30.0000.

II-8.

Did your firm import low-carbon silicomanganese or other out-of-scope merchandise from
Georgia under HTS statistical reporting number 7202.30.0000? Such imports should be reported
in the table below but should not be included in II-7.
No

Yes–Please report the quantity and value below.
Quantity (in short tons), value (in $1,000)
Calendar years

Item
1

Imports:
Quantity (B)
Value (C)

2012

2013

January-September
2014

2014

2015

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II-9.

Page 14

IMPORTS FROM SOUTH AFRICA.–Report your firm’s imports and your firm’s shipments and
inventories of silicomanganese imported from South Africa by your firm during the specified
periods. +Link to definitions

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

2012

2013

January-September
2014

2014

2015

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IMPORTS FROM SOUTH AFRICA.–Continued

II-9.

2012

2013

A + B – D – F – H – J = should equal zero
("0") or provide an explanation.1

January-September
2014

2014
0

2015
0

2012

K + L – D = zero ("0"), if not revise.

2013
0

January-September
2014

2014
0

2015
0

Imports of low-carbon silicomanganese from South Africa.—The scope of this investigation
includes silicomanganese except low-carbon silicomanganese (+Link to product description).
Imports of all silicomanganese products typically enter under the following HTS statistical
reporting number: 7202.30.0000.

II-10.

Did your firm import low-carbon silicomanganese or other out-of-scope merchandise from
South Africa under HTS statistical reporting number 7202.30.0000? Such imports should be
reported in the table below but should not be included in II-9.
No

Yes–Please report the quantity and value below.
Quantity (in short tons), value (in $1,000)
Calendar years

Item
1

Imports:
Quantity (B)
Value (C)

2012

2013

January-September
2014

2014

2015

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II-11.

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IMPORTS FROM ALL OTHER SOURCES COMBINED.–Report your firm’s imports and your firm’s
shipments and inventories of silicomanganese imported from all other sources combined by
your firm during the specified periods. +Link to definitions

(list sources:

ALL OTHER SOURCES COMBINED
)
Quantity (in short tons), value (in $1,000)
Calendar years

Item

2012

2013

January-September
2014

2014

2015

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IMPORTS FROM ALL OTHER SOURCES COMBINED.–Continued

II-11.

2012

2013

A + B – D – F – H – J = should equal zero
("0") or provide an explanation.1

January-September
2014

2014
0

2015
0

2012

K + L – D = zero ("0"), if not revise.

2013
0

January-September
2014

2014
0

2015
0

Imports of low-carbon silicomanganese from all other sources combined.—The scope of this
investigation includes silicomanganese except low-carbon silicomanganese (+Link to product
description). Imports of all silicomanganese products typically enter under the following HTS
statistical reporting number: 7202.30.0000.

II-12.

Did your firm import low-carbon silicomanganese or other out-of-scope merchandise from all
other sources combined under HTS statistical reporting number 7202.30.0000? Such imports
should be reported in the table below but should not be included in II-11.
No
(list sources:

Yes–Please report the quantity and value below.
)
Quantity (in short tons), value (in $1,000)
Calendar years

Item
1

Imports:
Quantity (B)
Value (C)

2012

2013

January-September
2014

2014

2015

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PART III.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Tana Farrington (202-2052389, [email protected]).
III-1.

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers or direct imports for your own use or transfers to related U.S.
customers since January 1, 2012 of the following products your firm imported from Australia,
Georgia, and/or South Africa:
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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During January 2012-September 2015, did your firm import from Australia, Georgia, and/or
South Africa, 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 pricing data tables III-2(a-c) as appropriate.
No.--Skip to question II-2(d).
During January 2012-September 2015, did your firm import 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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III-2(a). Price data.--Report below the quarterly price data1 for pricing products2 imported from Australia
and sold by your firm to unrelated U.S. customers.
Contracts are transactions over a quarterly or longer period, with prices either fixed or
indexed to a published price.

AUSTRALIA

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):

Product 2
Standard grade (65-68% Mn)
Contract sales
To steel producers
Grade(s):

Average manganese content:
Average manganese content:
Period of shipment
Quantity
Value
Quantity
Value
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 III.
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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III-2(a). Price data.--Report below the quarterly price data1 for pricing products2 imported from Australia
and sold by your firm to unrelated U.S. customers.
Spot sales are transactions to be supplied within approximately two weeks forward in the
spot market. (See Ryan’s Notes Price Assessment Methodology).

AUSTRALIA
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 III.
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:

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III-2(b). Price data.--Report below the quarterly price data1 for pricing products2 imported from Georgia
and sold by your firm to unrelated U.S. customers.
Contracts are transactions over a quarterly or longer period, with prices either fixed or
indexed to a published price.

GEORGIA

Product 2
Standard grade (65-68% Mn)
Contract sales
To steel producers
Grade(s):

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III-2(b). Price data.--Report below the quarterly price data1 for pricing products2 imported from Georgia
and sold by your firm to unrelated U.S. customers.
Spot sales are transactions to be supplied within approximately two weeks forward in the
spot market. (See Ryan’s Notes Price Assessment Methodology).

GEORGIA
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

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Page 24

III-2(c). Price data.--Report below the quarterly price data1 for pricing products2 imported from South
Africa and sold by your firm to unrelated U.S. customers.
Contracts are transactions over a quarterly or longer period, with prices either fixed or
indexed to a published price.

SOUTH AFRICA

Product 2
Standard grade (65-68% Mn)
Contract sales
To steel producers
Grade(s):

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Page 25

III-2(c). Price data.--Report below the quarterly price data1 for pricing products2 imported from South
Africa and sold by your firm to unrelated U.S. customers.
Spot sales are transactions to be supplied within approximately two weeks forward in the
spot market. (See Ryan’s Notes Price Assessment Methodology).

SOUTH AFRICA
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

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Page 26

During January 2012-September 2015, did your firm directly import from Australia for your
firm’s own use or transfer to a related party in the United States any of the above listed
products (or any products that were competitive with these products)?
Yes.--Please complete the pricing table III-2(d) and question III-2(e) as appropriate.
No.--Skip to question III-2(f).

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Page 27

III-2(d). Imports for own use.--Report below the quarterly landed duty-paid cost1 data for standard
grade silicomanganese (65-68% Mn) imported from Australia for your firm’s own use and/or
transfered to a related firm in the United States.
Please note that values should be net landed, duty-paid and should not include U.S.-inland transportation costs.
Net LDP values should reflect the final net amount paid by your firm to the foreign supplier, plus all insurance
and freight costs incurred for international transportation and logistics, as well as all Customs duties, fees, and
brokerage costs associated with clearance through U.S. Customs (e.g., should reflect the cleared cost of goods
FOB U.S. port of entry). As noted above, net LDP values do not include any inland U.S. transportation costs.

AUSTRALIA – DIRECT IMPORTS

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)
Standard grade
Bought under contracts
Grade(s):
Average manganese content:
Quantity
Landed, duty-paid
1
Value

Standard grade
Bought as spot sales
Grade(s):
Average manganese content:
Quantity
Landed, duty-paid
1
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., landed duty-paid values net all discounts, returns, allowances, rebates, prepaid freight, and the value of
returned goods). Moreover, please note that landed duty-paid values are NOT the sales prices at which your firm sells or
transfers silicomanganese to related parties.
2
Pricing product definitions are provided on the first page of Part III.
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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III-2(e). Additional costs for your direct imports of silicomanganese for your firm’s own use or
company transfer.
Additional direct import costs.--There may be additional costs, charges, or expenses incurred by
U.S. importers relating to the sourcing, logistics, or international supply chain (e.g., supply chain
costs, warehousing costs, compliance costs, et cetera.) for their direct imports of
silicomanganese into the United States.
(i)

If your firm reported direct import costs above (question III-2d), please identify the
factors that add to your cost of importing directly since January 1, 2012, estimate the
ratio to the landed duty-paid ("LDP") value the specified factor represents, and explain
in detail the specific costs associated with each category.
Ratio of cost to the net
LDP value1
(percent)

Factors
Detailed explanation
Logistical or supply chain costs
Warehousing costs
Compliance costs
Currency conversion costs
Other
1
Since these are costs that are not included in the net LDP values reported, this ratio is
understood to the approximate percentage greater by which the specified additional direct
import costs would increase the net LDP value if included.
(ii)

To which source does your firm compare costs in determining your additional
transaction costs to directly import?
U.S. Importers

U.S. Producers

Both

Neither

(iii)

If your firm reported data above (question III-2d), briefly identify the benefits of directly
importing silicomanganese instead of purchasing silicomanganese from a U.S. importer
or from a U.S. producer.

(v)

What is the approximate percentage of the total cost of silicomanganese you directly
imported from Australia that is accounted for by U.S. inland transportation or other
logistics costs from the port of importation to your distribution network, warehouses, or
facilities?
percent.

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(v)

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If your firm directly imported silicomanganese from Australia for your firm’s own use in
the United States, did your firm ALSO purchase silicomanganese manufactured in the
United States from U.S. producers? If so, please contact Tana Farrington
([email protected]) to obtain a purchaser questionnaire.
No

Yes

III-2(f). Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.

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.
III-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

III-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

Annual
total
volume
discounts

No
discount
policy

Other

Describe

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U.S. Importers’ Questionnaire - Silicomanganese
III-5.

Pricing terms.-(a)

What are your firm’s typical sales terms for silicomanganese imported from Australia?
Net 30
days

(b)

Net 60
days

2/10 net 30
days

Other

Other (specify)

On what basis are your firm’s prices of imported silicomanganese from Australia usually
quoted (check one)?
Delivered

III-6.

Page 30

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of silicomanganese
imported from Australia 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

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

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U.S. Importers’ Questionnaire - Silicomanganese
III-7.

Page 31

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
silicomanganese from Australia (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)

Short-term
contracts
(multiple deliveries
for less than 12
months)

Annual contracts
(multiple deliveries
for 12 months)

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

365

Yes
No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

Not applicable

III-8.

Price Indices.-(a)

Does your firm base sales prices on published prices from the following sources?
No—Skip to question III-9.
Publication
Ryan’s Notes
Platt’s Metal Week
U.S. import statistics
Source(s) other than those
listed above 1
1

List the source(s)

Yes--Check all that apply to your firm.
(Check all that apply)

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(b)

Page 32

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?

Yes

If yes, please indicate
If yes, please list how frequently your
the publication(s) firm reports its prices

Spot sales prices
Contract sales prices
(e)

If yes to III-25(d), does your firm know whether its reported prices were used in the
published price index?

Yes

If yes, please describe how your firm’s reported prices were
incorporated into the published price index, to the best of your
knowledge.

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U.S. Importers’ Questionnaire - Silicomanganese
III-9.

Page 33

Lead times.--What is your firm’s share of sales of silicomanganese imported from Australia 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 silicomanganese?
Share of
2014 sales

Source
From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0

Lead time
(days)

III-10. Shipping information.—
(a)

What is the approximate percentage of the total delivered cost of silicomanganese
imported from Australia 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)

When your firm sells silicomanganese imported from Australia, from where is it
shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of silicomanganese imported
from Australia that are delivered the following distances from your firm’s U.S. point of
shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

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Page 34

III-11. Geographical shipments--In which U.S. geographic market area(s) has your firm sold
silicomanganese imported from Australia since January 1, 2012 (check all that apply)?
Geographic area

Australia

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.

III-12. End uses--List the end uses of the silicomanganese that your firm imports from Australia. For
each end-use product, what percentage of the total cost is accounted for by silicomanganese
and other inputs?
Share of total cost of end use product
accounted for by
End use product

Silicomanganese

Total
(should sum to
100.0% across)

Other inputs

0.0 %

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Page 35

III-13. Substitutes.-- Can other products be substituted for silicomanganese?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

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

Explanation

1.
2.
3.
III-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

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within
the United
States
Outside
the United
States

III-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.

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Page 36

III-16. Conditions of competition.—
(a) Is the silicomanganese market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to silicomanganese?
Check all that apply.

Please describe.

Skip to question III-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.

III-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.

III-18. Raw materials.-- How have silicomanganese raw materials prices changed since January 1,
2012?

Overall
increase

Fluctuate
with no
clear
No
Overall
change decrease
trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for
silicomanganese.

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Page 37

III-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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U.S. Importers’ Questionnaire - Silicomanganese

Page 38

III-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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Page 39

III-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

City

State

Share of 2014 sales (%)

1
2
3
4
5
6
7
8
9
10

III-22. 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 40

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 did not import 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 importer questionnaire
Subject	Title 7 investigations
Author	Martinez, Keysha
File Modified	2015-10-29
File Created	2015-10-29