Form 16-1-3428 U.S. Producer Questionnaire

OMB No. 3117-0016/USITC No. 16-1-3428; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN NEW PNEUMATIC OFF-THE-ROAD TIRES FROM
CHINA, INDIA, AND SRI LANKA
This questionnaire must be received by the Commission by January 22, 2016
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 and countervailing duty investigations concerning certain new pneumatic off-the-road
tires (“OTR tires”) from China, India, and Sri Lanka (Inv. Nos. 701-TA-551-553 and 731-TA-1307-1308 (Preliminary)). 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 OTR tires (as defined on next page) or mounted OTR on rims in the United States 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: OTR2)
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, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used:
(i) by the Commission, its employees and Offices, and contract personnel (a) for developing or maintaining the records of this or a
related proceeding, or (b) in internal investigations, audits, reviews, and evaluations relating to the programs, personnel, and
operations of the Commission including under 5 U.S.C. Appendix 3; or
(ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all contract
personnel will sign appropriate nondisclosure agreements
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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PART I.—GENERAL INFORMATION
Background. These proceedings were instituted in response to a petition filed on January 8, 2016, by
Titan Tire Corporation of Des Moines, Iowa and the United Steel, Paper and Forestry, Rubber,
Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC of
Pittsburgh, Pennsylvania. Antidumping and/or countervailing duties may be assessed on the subject
imports as a result of these proceedings 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 subsidization and/or dumping. Questionnaires and other information pertinent to
these proceedings are available at
https://www.usitc.gov/investigations/701731/2016/certan_new_pneumatic_off_the_road_tires_china/
preliminary.htm.
OTR tires covered by these investigations include the following: new pneumatic tires designed for offthe-road (OTR) and off-highway use, subject to exceptions identified below. Certain OTR tires are
generally designed, manufactured and offered for sale for use on off-road or off-highway surfaces,
including but not limited to, agricultural fields, forests, construction sites, factory and warehouse
interiors, airport tarmacs, ports and harbors, mines, quarries, gravel yards, and steel mills. The vehicles
and equipment for which certain OTR tires are designed for use include, but are not limited to: (1)
agricultural and forestry vehicles and equipment, including agricultural tractors,1 combine harvesters,2
agricultural high clearance sprayers,3 industrial tractors,4 log-skidders,5 agricultural implements,
highway-towed implements, agricultural logging, and agricultural, industrial, skid-steers/mini-loaders;6
(2) construction vehicles and equipment, including earthmover articulated dump products, rigid frame
haul trucks,7 front end loaders,8 dozers,9 lift trucks, straddle carriers,10 graders,11 mobile cranes,12
compactors; and (3) industrial vehicles and equipment, including smooth floor, industrial, mining,
counterbalanced lift trucks, industrial and mining vehicles other than smooth floor, skid-steers/mini-

1

Agricultural tractors are dual-axle vehicles that typically are designed to pull farming equipment in the field
and that may have front tires of a different size than the rear tires.
2
Combine harvesters are used to harvest crops such as corn or wheat.
3
Agricultural sprayers are used to irrigate agricultural fields.
4
Industrial tractors are dual-axle vehicles that typically are designed to pull industrial equipment and that may
have front tires of a different size than the rear tires.
5
A log-skidder has a grappling lift arm that is used to grasp, lift and move trees that have been cut down to a
truck or trailer for transport to a mill or other destination.
6
Skid-steer loaders are four-wheel drive vehicles with the left-side drive wheels independent of the right-side
drive wheels and lift arms that lie alongside the driver with the major pivot points behind the driver’s shoulders.
Skid-steer loaders are used in agricultural, construction and industrial settings.
7
Haul trucks, which may be either rigid frame or articulated (i.e., able to bend in the middle) are typically used
in mines, quarries and construction sites to haul soil, aggregate, mined ore, or debris.
8
Front loaders have lift arms in front of the vehicle. They can scrape material from one location to another,
carry material in their buckets, or load material into a truck or trailer.
9
A dozer is a large four-wheeled vehicle with a dozer blade that is used to push large quantities of soil, sand,
rubble, etc., typically around construction sites. They can also be used to perform “rough grading” in road
construction.
10
A straddle carrier is a rigid frame, engine-powered machine that is used to load and offload containers from
container vessels and load them onto (or off of) tractor trailers.
11
A grader is a vehicle with a large blade used to create a flat surface. Graders are typically used to perform
“finish grading.” Graders are commonly used in maintenance of unpaved roads and road construction to prepare
the base course onto which asphalt or other paving material will be laid.
12
I.e., “on-site'” mobile cranes designed for off-highway use.

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Page 3

loaders, and smooth floor off-the-road counterbalanced lift trucks.13 The foregoing list of vehicles and
equipment generally have in common that they are used for hauling, towing, lifting, and/or loading a
wide variety of equipment and materials in agricultural, construction and industrial settings. Such
vehicles and equipment, and the descriptions contained in the footnotes are illustrative of the types of
vehicles and equipment that use certain OTR tires, but are not necessarily all-inclusive.
While the physical characteristics of certain OTR tires will vary depending on the specific applications
and conditions for which the tires are designed (e.g., tread pattern and depth), all of the tires within the
scope have in common that they are designed for off-road and off-highway use. Except as discussed
below, OTR tires included in the scope of the proceeding range in size (rim diameter) generally but not
exclusively from 8 inches to 54 inches. The tires may be either tube-type14 or tubeless, radial or nonradial, and intended for sale either to original equipment manufacturers or the replacement market.
Certain OTR tires, whether or not attached to wheels or rims, are included in the scope. However, if a
subject tire is imported attached to a wheel or rim, only the tire is covered by the scope. Subject
merchandise includes certain OTR tires produced in the subject countries whether attached to wheels or
rims in a subject country or in a third country.
Excluded from the scope of these investigations are any products covered by the existing antidumping
and countervailing duty orders on certain OTR tires from the People’s Republic of China. See Certain
New Pneumatic Off-the-Road Tires From the People’s Republic of China: Notice of Amended Final
Affirmative Determination of Sales at Less Than Fair Value and Antidumping Duty Order, 73 Fed. Reg.
51,624 (Dep’t Commerce Sept. 4, 2008); Certain New Pneumatic Off-the-Road Tires From the People’s
Republic of China: Countervailing Duty Order, 73 Fed. Reg. 51,627 (Dep’t Commerce Sept. 4, 2008).15
In addition, specifically excluded from the scope are new pneumatic tires designed, manufactured and
offered for sale primarily for on-highway or on-road use, including passenger cars, race cars, station
wagons, sport utility vehicles, minivans, mobile homes, motorcycles, bicycles, on-road or on-highway
trailers, light trucks, and trucks and buses. Such tires generally have in common that the symbol “DOT”
must appear on the sidewall, certifying that the tire conforms to applicable motor vehicle safety
standards. Such excluded tires may also have the following designations that are used by the Tire and
Rim Association:
Prefix letter designations:
P--Identifies a tire intended primarily for service on passenger cars;
LT--Identifies a tire intended primarily for service on light trucks; and,
ST--Identifies a special tire for trailers in highway service.
13

A counterbalanced lift truck is a rigid framed, engine-powered machine with lift arms that has additional
weight incorporated into the back of the machine to offset or counterbalance the weight of loads that it lifts so as
to prevent the vehicle from overturning. An example of a counterbalanced lift truck is a counterbalanced fork lift
truck. Counterbalanced lift trucks may be designed for use on smooth floor surfaces, such as a factory or
warehouse, or other surfaces, such as construction sites, mines, etc.
14

While tube-type tires are subject to the scope of this proceeding, tubes and flaps are not subject
merchandise and therefore are not covered by the scope of this proceeding, regardless of the manner in which
they are sold (e.g., sold with or separately from subject merchandise).
15
In these prior investigations, the Department found that imports of OTR tires mounted on wheels were not
within the scope of subject merchandise. See Certain New Pneumatic Off-The-Road Tires from the People's
Republic of China: Final Affirmative Determination of Sales at Less Than Fair Value and Partial Affirmative
Determination of Critical Circumstances, 73 Fed. Reg. 40,485 (Dep’t Commerce July 15, 2008) and accompanying
Issues and Decision Memorandum at Comment 19.

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Suffix letter designations:
TR--Identifies a tire for service on trucks, buses, and other vehicles with rims having
specified rim diameter of nominal plus 0.156” or plus 0.250”;
MH--Identifies tires for Mobile Homes;
HC--Identifies a heavy duty tire designated for use on “HC” 15” tapered rims used on trucks,
buses, and other vehicles. This suffix is intended to differentiate among tires for light
trucks, and other vehicles or other services, which use a similar designation.
Example: 8R17.5 LT, 8R17.5 HC;
LT--Identifies light truck tires for service on trucks, buses, trailers, and multipurpose
passenger vehicles used in nominal highway service; and
MC--Identifies tires and rims for motorcycles.
The following types of tires are also excluded from the scope: Pneumatic tires that are not new,
including recycled or retreaded tires and used tires; non-pneumatic tires, including solid rubber tires;
tires of a kind designed for use on aircraft, all-terrain vehicles, and vehicles for turf, lawn and garden,
golf and trailer applications. Also excluded from the scope are radial and bias tires of a kind designed for
use in mining and construction vehicles and equipment that have a rim diameter equal to or exceeding
39 inches. Such tires may be distinguished from other tires of similar size by the number of plies that the
construction and mining tires contain (minimum of 16) and the weight of such tires (minimum 1500
pounds).
The subject merchandise is currently imported under Harmonized Tariff Schedule of the United States
(“HTSUS”) statistical reporting numbers: 4011.20.1025, 4011.20.1035, 4011.20.5030, 4011.20.5050,
4011.61.00.00, 4011.62.00.00, 4011.63.00.00, 4011.69.00.50, 4011.92.00.00, 4011.93.40.00,
4011.93.8000, 4011.94.4000, 4011.94.8000, 8431.49.9038, 8431.49.9090, 8709.90.0020, and
8716.90.1020. Tires meeting the scope description may also be imported under the following HTSUS
provisions: 4011.99.4550, 4011.99.8550, 8424.90.9080, 8431.20.0000, 8431.39.0010, 8431.49.1090,
8431.49.9030, 8432.90.0005, 8432.90.0015, 8432.90.0030, 8432.90.0080, 8433.90.5010, 8503.00.9560,
8708.70.0500, 8708.70.2500, 8708.70.4530, and 8716.90.5035. While HTSUS provisions are provided
for convenience and customs purposes, the written description of the subject merchandise is
dispositive.
Unmounted OTR tires. -- OTR tires that are not attached to wheels or rims.
Mounted OTR tires. – OTR tires that are attached to wheels or rims.
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.

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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.
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 OTR tires 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.

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U.S. Producers’ Questionnaire - OTR tires
I-1a.

Page 6

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 OTR tires, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

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U.S. Producers’ Questionnaire - OTR tires
I-3.

Page 7

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

Support

Oppose

Take no position

China - AD
China - CVD
India - AD
India - CVD
Sri Lanka - CVD
I-4.

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

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing OTR tires from China, India, or Sri Lanka into the United
States or that are engaged in exporting OTR tires from China, India, or Sri Lanka to the United
States?
No
Firm name

Yes--List the following information.
Address

Affiliation

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U.S. Producers’ Questionnaire - OTR tires
I-6.

Page 8

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

Yes--List the following information.
Address

Affiliation

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Justin Enck (202-205-3363,
[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 OTR tires since January 1, 2012.
(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)

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II-3a.

Page 10

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce OTR tires, and the combined production
capacity on this shared equipment and machinery in the periods indicated.
“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).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.

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II-3a.

Page 11

Production using same machinery.—Continued
Quantity (in number of tires)
Calendar years

Item

2012

2013

January-September
2014

2014

Unmounted OTR tires

2015

7

Overall capacity on the
machinery and equipment that
produces unmounted OTR tires1
(A)
Production on the same
machinery and equipment of:
Unmounted OTR tires2 (B)

0

0

0

0

0

0

0

0

0

0

3

Other products (C)
Total production (D)

Mounted OTR tires

7

Overall capacity on the
machinery and equipment that
mounts OTR tires4 (E)
Production on the same
machinery and equipment of:
Mounted OTR tires5 (F)

0

0

0

0

0

0

0

0

0

0

6

Other products (G)
Total production (H)
1

If your firm does not produce any other products (i.e., no data in line C) on the same machinery and equipment as
unmounted OTR tires, then the capacity reported in line A should be exactly equal to the capacity data reported in
question II-7 (line I). If, however, your firm does produce "other" products on the same machinery and equipment,
then the capacity reported in this question (line A) should cover the production of subject unmount OTR tires and the
other products in line C, while capacity reported in question II-7 (line I) should be an allocated capacity amount based
on product mix (i.e., only a portion of the overall capacity reported here).
2
Data entered for production of unmounted OTR tires will populate here once reported in question II-7.
3
Please identify these products produced using the same machinery and equipment as used to produce unmounted
OTR tires:
.
4
If your firm does not produce any other products (i.e., no data in line G) on the same machinery and equipment as
it mounts OTR tires, then the capacity reported in line E should be exactly equal to the capacity data reported in
question II-9 (line X). If, however, your firm does produce "other" products on the same machinery and equipment,
then the capacity reported in this question (line E) should cover the production of subject mounted OTR tires and the
other products in line G, while capacity reported in question II-9 (line X) should be an allocated capacity amount based
on product mix (i.e., only a portion of the overall capacity reported here).
5
Data entered for production of mounted OTR tires will populate here once reported in question II-9.
6
Please identify these products produced using the same machinery and equipment as used to mount OTR tires:
.
7
Defined on page 4.

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U.S. Producers’ Questionnaire - OTR tires
II-3b.

Operating parameters.--The production capacity reported in II-3a is based on:
Hours per week
Weeks per year

II-3c.

Unmounted OTR tires

Mounted OTR tires

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
Unmounted OTR tires

II-3d.

Page 12

Mounted OTR tires

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

Mounted OTR tires

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U.S. Producers’ Questionnaire - OTR tires
II-3e.

Product shifting.—
Unmounted OTR Tires.--Is your firm able to switch production (capacity) between
unmounted OTR tires and other products using the same equipment and/or labor?

(i)

No

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

(ii)

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

(iii)

Mounted OTR Tires.--Is your firm able to switch production (capacity) between mounted
OTR tires and other products using the same equipment and/or labor?
No

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

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

(iv)

II-4.

Page 13

Tolling.--Since January 1, 2012, has your firm been involved in a toll agreement regarding the
production of OTR tires or the mounting of OTR tires?
“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

Yes--Please describe the toll arrangement(s) and provide the name(s) the
firm(s) involved

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U.S. Producers’ Questionnaire - OTR tires
II-5.

Page 14

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce OTR tires in and/or admit OTR tires into
a foreign trade zone (FTZ)?

(a)

“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

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 OTR tires into a foreign trade zone (FTZ) for use in distribution of OTR tires
and/or the production of downstream articles?

(b)

No/Don’t know

II-6.

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2012, has your firm imported OTR tires?
“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

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

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Definitions
“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).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“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.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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II-7.

Page 16

Production, shipment and inventory data for unmounted OTR tires.--Report your firm’s
production capacity, production, shipments, and inventories related to the production of
unmounted OTR tires in its U.S. establishment(s) during the specified periods.
Quantity (in number of tires) and value (in $1,000)
Calendar years
Item

2012

2013

January-September
2014

2014

2015

Average production
capacity1 (quantity) (I)
Beginning-of-period
inventories (quantity) (J)
Production (quantity) (K)
U.S. shipments:
Commercial
shipments:2
Quantity (L)
Value (M)
Internal consumption:3
Quantity (N)
Value4 (O)
Transfers to related
firms:
Quantity (P)
Value4 (Q)
Export shipments:5
Quantity (R)
Value (S)
End-of-period inventories
(quantity) (T)
1

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
Report the share of your 2014 commercial shipments of OTR tires that were sold with kits:
.
3
Internal consumption includes OTR tires that your firm will mount to a wheel or tire assembly prior to sale (mounting
operations are reported in question II-9).
4
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:
.
5
Identify your firm’s principal export markets:
.

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

II-7.

Page 17

Production, shipment and inventory data for unmounted OTR tires.--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line T) should be equal to the beginning-of-period inventories (i.e., line I),
plus production (i.e., line K), less total shipments (i.e., lines L, N, P, R). 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

I + K – L – N – P – R – T = should equal
zero ("0") or provide an explanation.1

0

January-September
2014

0

2014
0

2015
0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.

II-8.

Channels of distribution for unmounted OTR tires.-- Report your firm’s commercial U.S.
shipments of unmounted OTR tires by channel of distribution.
Quantity (in number of tires)

Calendar years
Item

2012

January-September

2013

2014

2014

2015

Channels of distribution:
Commercial U.S.
shipments:
To OEM (quantity) (U)
To distributors
(quantity)(V)
To tire mounters
(quantity) (W)1
1

Indicate the name of the tire mounters:
Calendar years
Reconciliation

U + V + W– L = zero ("0"), if not
revise.

2012

2013
0

January-September
2014

0

2014
0

2015
0

0

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

II-9.

Page 18

Production, shipment and inventory data for mounted OTR tires.--Report your firm’s
production capacity, production, shipments, and inventories related to the production of OTR
tires mounted on wheel and tire assemblies (mounted OTR tires) in its U.S. establishment(s)
during the specified periods.
Quantity (in number of tires) and value (in $1,000)1
Calendar years
Item

Average production capacity
(quantity) (X)

2012

2013

January-September
2014

2014

2015

2

Beginning-of-period inventories
(quantity) (Y)
Production of mounted OTR tires
(quantity):
Using OTR tires your firm produced
internally (Z)3
Using domestically produced OTR
tires your firm purchased (AA)
Using OTR tires manufactured in—
China (AB)4
India (AC)5
Sri Lanka (AD)6
Using OTR tires manufactured in a
subject country (AE)

0

0

0

0

0

0

0

0

0

0

Using OTR tire imports from a
nonsubject country (i.e., other than
China, India, or Sri Lanka) (AF)
Total production of mounted
OTR tires (AG)
U.S. shipments of mounted OTR tires
Commercial shipments:
Quantity (AH)
Value (AI)
Internal consumption:7
Quantity (AJ)
Value (AK)
Transfers to related firms:
Quantity (AL)
Value (AM)
Export shipments:8
Quantity (AN)
Value (AO)
End-of-period inventories (quantity)
(AP)
Footnotes next page

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 19

Production, shipment and inventory data for mounted OTR tires.—Continued

II-9.
1

Quantities should be based on the number of tires (not whole assemblies) and shipment values reported in this table
should reflect only the value of the tire (and not the value of the wheel, rim, or tire assembly on which the OTR tire is
mounted).
2
The production capacity (see definitions section above) reported is based on operating
hours per week,
weeks per year. Please describe the methodology used to calculate production capacity, and explain any changes in
reported capacity (use additional pages as necessary).
.
3
These tires are a subset of the production reported in II-7.
4
Please provide the name of the producer(s)
.
5
Please provide the name of the producer(s)
.
6
Please provide the name of the producer(s)
.
7
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:
.
8
Identify your firm’s principal export markets:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line AP) should be equal to the beginning-of-period inventories (i.e., line
Y), plus total production (i.e., line AG), less total shipments (i.e., lines AH, AJ, AL, AN). 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
January-September
Reconciliation

2012

2013

Y + AG – AH – AJ – AL – AN -AP= should
equal zero ("0") or provide an
explanation.1

0

2014

0

2014

0

2015

0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
II-10.

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in number of tires)

Calendar years
Item

2012

2013

January-September
2014

2014

2015

Channels of distribution:
Commercial U.S. shipments:
To OEM (quantity) (AQ)
To Distributors (quantity)(AR)
Calendar years
Reconciliation
AQ + AR – AH = zero ("0"), if not
revise.

2012

2013
0

January-September
2014

0

2014
0

2015
0

0

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
II-11.

Page 20

Employment data.--Report your firm’s employment-related data related to the production of
OTR tires 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

OTR tire production operations
Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
OTR tire mounting operations
Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:

2015

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 21

II-12.

Related firms.--If your firm reported transfers to related firms in question II-7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a 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.

II-13.

Purchases of unmounted OTR tires.--Other than direct imports, has your firm otherwise
purchased unmounted OTR tires 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 number of tires)
Calendar years
Item

2012

2013

January-September
2014

2014

2015

Unmounted OTR tires
Purchases from U.S.
importers1 of unmounted
OTR tires from—
China
India
Sri Lanka
All other sources
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:
.

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
II-14.

Page 22

Purchases of mounted OTR tires.--Other than direct imports, has your firm otherwise purchased
already mounted OTR tires 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 number of tires)
Calendar years
Item

2012

2013

January-September
2014

2014

2015

Mounted OTR tires
For the purposes of the this table, assume that the country of origin
is the location where the tire was manufactured
Purchases from U.S.
importers1 of mounted OTR
tires from—
China
India
Sri Lanka
All other sources
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-15.

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 - OTR tires

Page 23

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[email protected]).
III-1.

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

III-2.

Accounting system.--Briefly describe your firm’s financial accounting system.
A.

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

B.1.

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

2.

Does your firm prepare profit/loss statements for OTR tires:
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: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes OTR tires, as well as
specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 24

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.

III-5.

Other products.--Please list the products your firm produced in the facilities in which your firm
produced OTR tires, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products

Share of sales

OTR tires

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of OTR tires from any related suppliers (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)?
Yes--Continue to question III-7.

III-7.

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of OTR tires
that your firm purchases from related suppliers 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 supplier; e.g.,
the related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair
market value.
Input

Related supplier

Share of total COGS (percent)
%
%
%
%
Input valuation as recorded in the firm’s accounting books and records

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
III-8.

Page 25

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on OTR tires) 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
suppliers as reported in table III-9a.

In relation to COGS data:
• Integrated producers that manufacture mounted and unmounted tires (complete both III-9a
and III-9b for COGS, as relevant)
• Tire producers with no mounting operations (complete only III-9a for COGS); response will
populate in III-9b
• Mounters (complete only III-9b for COGS)
III-9a. Internally produced unmounted OTR tires costs recognized in COGS.--Report the requested
cost information specific to OTR tires (actual tire production) produced in your firm’s U.S.
establishment(s) and recognized in financial results reported in question III-9b). Input
purchases from related suppliers 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.
Value (in $1,000)
Fiscal years ended-Item

2012

2013

January-September
2014

2014

2015

Cost of internally produced unmounted
OTR tires recognized in COGS (question
III-9b):
Raw materials (internally produced
1
unmounted OTR tires)
Direct labor(internally produced
unmounted OTR tires)
Other factory costs (internally
produced unmounted OTR tires)
Total cost of internally produced
unmounted OTR tires
1

0

Identify the primary components of your firm's raw material costs:

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 26

III-9b. Operations on all OTR tires (both mounted and unmounted).-- Report the revenue and related
cost information requested below on all OTR tires operations (including mounted and
unmounted OTR tire sales) of your firm’s U.S. establishment(s).1 Do not report resales of
products that were not produced or mounted by your firm. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers 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 Jennifer Brinckhaus at (202) 205-3188 before completing this section
of the questionnaire.
•
•

Net sales quantities should be in 1,000s of tires. For firms with tire mounting operations,
report quantities based on tires not completed assemblies.
Net sales values should be in $1,000s. For firms with tire mounting operations, report values
exclusive of (e.g., deducting the) value of the wheel, rim, or tire assembly on which the OTR
tires are mounted.
Quantity (in number of tires) 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

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

3

4

Cost of goods sold (COGS):
Cost of internally produced unmounted OTR
5
tires recognized in COGS (from III-9a)
Purchased domestic OTR tires recognized in
COGS (U.S.-origin tires)
Purchased imported OTR tires recognized in
COGS (foreign-origin tires)
6

Raw materials (mounting operations only)
Direct labor (mounting operations only)
Other factory costs (mounting operations
only)
Total COGS
Gross profit or (loss)

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 27

III-9b. Operations on all OTR tires (both mounted and unmounted).--Continued
Quantity (in number of tires) and value (in $1,000)
Fiscal years ended-Item

2012

2013

January-September
2014

2014

2015

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

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
Net sale values of any mounted OTR tires should be exclusive of (e.g., deducting the) value of the wheel, rim, or tire assembly on which
the OTR tire is mounted. Please report below (1) the cost of the wheel, rim, or tire assembly and (2) the value attributable to the wheel, rim,
or assembly that you excluded from your calculation of the net sales values above for your sales of mounted OTR tires:
Fiscal years ended-January-September
Item
2012
2013
2014
2014
2015
Cost of wheel, rim, or tire assembly
Amount excluded from net sale value
attributable to wheel, rim, or assembly
4
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
5
Total cost of internally produced unmounted OTR tires recognized in COGS are reported in question III-9a and will populate in this grid.
6
Other raw materials should not include the cost of wheel, rim, or tire assembly on which the OTR tires is mounted since those values are
to have been deducted already from the net sales value.
2

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

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
III-9c.

Page 28

Financial data reconciliation.--The calculable line items from question III-9a and III-9b (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-9b, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-9b 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-9b; i.e., if an aggregate nonrecurring item has been allocated to table III-9b, only the allocated
value amount included in table III-9b 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-9b.
Fiscal years ended-2012
Nonrecurring item: In this column please provide a brief
description of each nonrecurring item and indicate the
specific line item in table III-9a or III-9b where the
nonrecurring item is classified.
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

2013

January-September
2014

2014

2015

Nonrecurring item: In these columns please report the amount of the relevant
nonrecurring item reported in table III-9a or III-9b.
Value ($1,000)

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 29

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., just as responses to question III-10 identify where these items
are reported in table III-9b.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of OTR tires. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for OTR tires in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in table III-9b. 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) relating to:
Unmounted OTR tires

2012

2013

2014

1

Mounted OTR tires
Total assets (net)
1

Describe

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
III-13.

Page 30

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for OTR tires. 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

2015

Capital expenditures:
Unmounted OTR tires
Mounted OTR tires
Total Cap-Ex

0

0

0

0

0

0

0

0

0

0

Research and development expenses
Unmounted OTR tires
Mounted OTR tires
Total R&D expenses
1

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.

2

Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 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-7 (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-7?
Yes

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 31

III-15a. 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 OTR tires from China, India, and Sri Lanka?
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

III-15b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 32

III-16a. 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 OTR tires from China, India, and Sri Lanka?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the issue
of stocks or bonds
Ability to service debt

Other

III-16b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires

Page 33

III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
OTR tires from China, India, and Sri Lanka?
No

Yes

If yes, my firm anticipates negative effects as follows:

III-17b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

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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Page 34

PART IV.-- PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202-2053489, [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.

Irrigation pivot tire, size 11.2-38, ply rating of 6, weight from 90 to 125 lbs., rim width 10 inches.
Product 1.-- Irrigation pivot tire, size 11.2-38, ply rating of 6, weight from 90 to 125 lbs., rim
width 10 inches, unmounted, tire only.
Product 2.-- Irrigation pivot tire, size 11.2-38, ply rating of 6, weight from 90 to 125 lbs., rim
width 10 inches, sold as part of a kit.
Product 3.-- Irrigation pivot tire, size 11.2-38, ply rating of 6, weight from 90 to 125 lbs., rim
width 10 inches, wheel-mounted tire.
Rear farm tire, size 9.5-24, ply rating of 6, weight from 48 to 58 lbs., rim width 8 inches.
Product 4.-- Rear farm tire, size 9.5-24, ply rating of 6, weight from 48 to 58 lbs., rim width 8
inches, unmounted, tire only.
Product 5.-- Rear farm tire, size 9.5-24, ply rating of 6, weight from 48 to 58 lbs., rim width 8
inches, sold as part of a kit.
Product 6.-- Rear farm tire, size 9.5-24, ply rating of 6, weight from 48 to 58 lbs., rim width 8
inches, wheel-mounted tire.
Front farm tire, size 9.5L-15, ply rating of 8, weight from 25 to 32 lbs., rim width 8 inches.
Product 7.-- Front farm tire, size 9.5L-15, ply rating of 8, weight from 25 to 32 lbs., rim width 8
inches, unmounted, tire only.
Product 8.-- Front farm tire, size 9.5L-15, ply rating of 8, weight from 25 to 32 lbs., rim width 8
inches, sold as part of a kit.
Product 9.-- Front farm tire, size 9.5L-15, ply rating of 8, weight from 25 to 32 lbs., rim width 8
inches, wheel-mounted tire.
Skid steer tire, size 10-16.5, ply rating of 10, weight from 55 to 85 lbs., rim width 8.25 inches.
Product 10.-- Skid steer tire, size 10-16.5, ply rating of 10, weight from 55 to 85 lbs., rim width
8.25 inches, unmounted, tire only.
Product 11.-- Skid steer tire, size 10-16.5, ply rating of 10, weight from 55 to 85 lbs., rim width
8.25 inches, sold as part of a kit.
Product 12.-- Skid steer tire, size 10-16.5, ply rating of 10, weight from 55 to 85 lbs., rim width
8.25 inches, wheel-mounted tire.

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Page 35

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 or rebates).
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 tables as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
IV-2.

Page 36

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. For values, only report the value of the tire. Do not include the value of the kit or
wheel on which the tire has been mounted. Please identify tire country(ies)-of-origin in each
product’s respective footnote.

Report data in actual tires and actual dollars (not 1,000s).
(Quantity in tires, value in dollars)
Irrigation pivot tire, size 11.2-38, ply rating of 6, weight from 90 to 125 lbs., rim width 10 inches.
3
4
Product 1 (tire only)
Product 2 (tires in kits)
Product 3 (wheel-mounted)
Period of shipment
Quantity
Value
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
Rear farm tire, size 9.5-24, ply rating of 6, weight from 48 to 58 lbs., rim width 8 inches.
5
6
Product 4 (tire only)
Product 5 (tires in kits)
Product 6 (wheel-mounted)
Period of shipment
Quantity
Value
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

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U.S. Producers’ Questionnaire - OTR tires
IV-2.

Page 37

Price data.--(continued).

(Quantity in tires, value in dollars)
Front farm tire, size 9.5L-15, ply rating of 8, weight from 25 to 32 lbs., rim width 8 inches.
7
8
Product 7 (tire only)
Product 8 (tires in kit kits)
Product 9 (wheel-mounted)
Period of shipment
Quantity
Value
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

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
IV-2.

Page 38

Price data.--(continued).

Skid steer tire, size 10-16.5, ply rating of 10, weight from 55 to 85 lbs., rim width 8.25 inches.
9
10
Product 10 (tire only)
Product 11 (tires in kits)
Product 12 (wheel-mounted)
Period of shipment
Quantity
Value
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
NOTES:
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.
3
Product 2 country-of-origin of the tire:
4

Product 3 country-of-origin of the tire:

5

Product 5 country-of-origin of the tire:

6

Product 6 country-of-origin of the tire:

7

Product 8 country-of-origin of the tire:
Product 9 country-of-origin of the tire:
9
Product 11 country-of-origin of the tire:
10
Product 12 country-of-origin of the tire:
8

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, 2, 3:
Product 4, 5, 6:
Product 7, 8, 9:
Product 10, 11, 12:

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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.
IV-3.

Cost share of tires in kits or wheel-mounted tires.-(a)

Question IV-2 above requested price data for only tires (whether sold individually, as
part of a kit or as a wheel-mounted tire). Below, please provide the estimated share that
the tire normally accounts for in the sales price of kits and/or wheel-mounted tires in
2015. (Please refer back to your firm’s response in III-9b, footnote 3 when reporting for
wheel-mounted tires.)

Type

(b)

Percent of total price
accounted for by the tire
(percent)

Kits

%

Wheel-mounted tires

%

Does the share of total price of kits or wheel-mounted tires attributable to only the tire
vary by year or by how the tire is sold (unmounted tire only, as part of a kit, or as a
wheel-mounted tire)?
No

Yes

If yes, please describe.

By year
By tire type
IV-4.

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

Contracts

Set
price
lists

Other

If other, describe

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
IV-5.

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

Quantity
discounts

IV-6.

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 OTR tires?
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 OTR tires usually quoted (check one)?
Delivered

IV-7.

Page 40

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced OTR
tires in 2015 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?

Share of 2015
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

%

Business Proprietary
U.S. Producers’ Questionnaire - OTR tires
IV-8.

Page 41

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced OTR tires (or check “not applicable” if your firm does not sell on a long-term,
short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

No

Not applicable
IV-9.

Lead times.--What is your firm’s share of sales 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 OTR tires?

Source

Share of 2015 Lead time (average
sales
number of days)

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

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IV-10. Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced OTR
tires 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 OTR tires 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

%

IV-11. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced OTR tires 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.
IV-12. End uses.--List the end uses of the OTR tires that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by OTR tires and other inputs?
Share of total cost of end use product
accounted for by
End use product

OTR tires

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

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IV-13. Substitutes.-- Can other products be substituted for OTR tires?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

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

Explanation

1.
2.
3.

IV-14. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for OTR tires has changed since January 1, 2012. Explain any trends and
describe the principal factors that have affected these changes in demand.

Market

Type

Within
the
United
States

Tires only

Outside
the
United
States

Kits
Wheel-mounted
tires
Tires only
Kits
Wheel-mounted
tires

Overall
increase

No
change

Fluctuate
with no
clear
Overall
decrease trend

Explanation and factors

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IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of OTR tires since January 1, 2012?
No

Yes

If yes, please describe and quantify if possible.

IV-16. Conditions of competition.-(a) Is the OTR tires market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to OTR tires? 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
OTR tires 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 OTR tires 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, etc.)?
No

Yes

If yes, please describe.

IV-18. Raw materials.--How have raw materials prices for tires and wheel-mounted tires changed since
January 1, 2012?

Type
Tires only
Wheel-mounted tires
I

Overall
increase

No
change

Overall
decrease

Fluctuate
with no
clear trend

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

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V-19. Interchangeability.--Is OTR tires 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
Tires only
Country-pair

China

India

Sri Lanka

Other countries

Sri Lanka

Other countries

Sri Lanka

Other countries

United States
China
India
Sri Lanka
Kits
Country-pair

China

India

United States
China
India
Sri Lanka
Wheel-mounted tires
Country-pair

China

India

United States
China
India
Sri Lanka
For any country-pair producing OTR tires that is sometimes or never interchangeable, identify the country-pair and
explain the factors that limit or preclude interchangeable use:

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Page 47

IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between OTR tires 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
Tires only
Country-pair

China

India

Sri Lanka

Other countries

Sri Lanka

Other countries

Sri Lanka

Other countries

United States
China
India
Sri Lanka
Kits
Country-pair

China

India

United States
China
India
Sri Lanka
Wheel-mounted tires
Country-pair

China

India

United States
China
India
Sri Lanka
For any country-pair for which factors other than price always or frequently are a significant factor in your firm’s
sales of OTR tires, identify the country-pair and report the advantages or disadvantages imparted by such factors:

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Page 48

IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for OTR tires since January 1, 2012. Indicate the share of the quantity of your firm’s
total shipments of OTR tires that each of these customers accounted for in 2015.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2015
sales
(%)

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IV-21. Competition from imports
(a)

Lost revenue.--Since January 1, 2012: To avoid losing sales to competitors selling OTR
tires from China, India, and/or Sri Lanka, 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 OTR tires to imports of this
product from China, India, and/or Sri Lanka?
No

(c)

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: LSLR)

IV-22. 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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PART V.—OTR TIRES MOUNTED ON WHEELS OR TIRE ASSEMBLIES
Further information on this part of the questionnaire can be obtained from Justin Enck (202-205-3363,
[email protected]). Supply all data requested on a calendar-year basis.
V-1.

Tire mounting operations.— For firms with operations that involve mounting OTR tires on
wheels or tire assemblies, provide the following information with respect to your mounting
operations only.
(a)

Source and extent of firm’s capital and investment

(b)

Quantity and type of parts sourced in the United States

(c)

Describe your firm’s value-added operations performed in the United States

(d)

Technical expertise involved in U.S. production activity

(e)

Any other cost activities in the United States directly leading to the production of OTR
tires.

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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:
https://www.usitc.gov/investigations/701731/2016/certan_new_pneumatic_off_the_ro
ad_tires_china/preliminary.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: OTR2

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you 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 (202205-1803). 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.