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pdfOMB No. 3117‐0016/USITC No. 16‐1‐3472; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
HYDROFLUOROCARBON BLENDS AND COMPONENTS FROM CHINA
This questionnaire must be received by the Commission by WEDNESDAY, APRIL 28, 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 investigation concerning hydrofluorocarbon blends and components from China (inv.
No. 731‐TA‐1279 (Final)). The information requested in the questionnaire is requested under the authority of the Tariff
Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to
compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced or reclaimed any in‐scope HFC components R‐32, R‐125, or R‐143a, out‐of‐scope HFC
component R‐134a, or any in‐scope HFC blends R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A at any time since
January 1, 2013?
1.
2.
YES (Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
NO (Proceed to question 2)
Has your firm produced and/or reclaimed any out‐of‐scope refrigerant blend (see pp. 2‐3 for definitions) since January 1, 2013?
YES‐‐(Only complete parts I and V on pp. 6‐9 and 62‐76 of this questionnaire)
NO‐‐(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
Data reported in this questionnaire relate to the production of (check all that apply):
3.
HFC components
Reclaimed/reconstituted in‐scope HFC blends
In‐scope HFC blends
Out‐of‐scope refrigerant blends
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the following
link: https://dropbox.usitc.gov/oinv/. (PIN: 1279)
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
Signature
Phone:
Email address
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 2
PART I.‐‐GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on June 25, 2015, by The
American HFC Coalition and its members (Amtrol, Inc., West Warwick, Rhode Island; Arkema, Inc., King
of Prussia, Pennsylvania; The Chemours Company FC LLC, Wilmington, Delaware; Honeywell
International Inc., Morristown, New Jersey; Hudson Technologies, Pearl River, New York; Mexichem
Fluor Inc., St. Gabriel, Louisiana; Worthington Industries, Inc., Columbus, Ohio) and District Lodge 154 of
the International Association of Machinists and Aerospace Workers. 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:
https://www.usitc.gov/investigations/701731/2016/hydrofluorocarbon_blends_and_componen
ts_china/final.htm
Certain hydroflurocarbon blends and components: The products covered by these investigations are
blended hydrofluorocarbons (“HFCs”) and single HFC components of those blends thereof, whether or
not imported for blending, including the following:
HFC components covered by the scope of this investigation:
(1) R‐32 or “Difluoromethane” has the chemical formula CH2F2, and is registered as CAS No. 75‐
10‐5. It may also be known HFC‐32, FC‐32, Freon‐32, Methylene difluoride, Methylene fluoride,
Carbon fluoride hydride, halocarbon R32, fluorocarbon R32, and UN 3252.
R‐32 is sold under various trade names, including Solkane®32, Forane®32, and Klea®32.
(2) R‐125 or “1,1,1,2,2‐Pentafluoroethane” has the chemical formula CF3CHF2 and is registered
as CAS No. 354‐33‐6. R‐125 may also be known as HFC‐125, Pentafluoroethane, Freon 125, and
Fc‐125.
R‐125 is sold under various trade names, including Solkane®125, Klea®125, Genetron®125, and
Forane®125.
(3) R‐143a or “1,1,1‐Trifluoroethane” has the chemical formula CF3CH3 and is registered as CAS
No. 420‐46‐2. R‐143a may also be known as HFC‐143a, Methylfluoroform, 1,1,1‐Trifluoroform,
and UN2035.
R‐143a is sold under various trade names, including Solkane®143a, Genetron®143a, and
Forane®125.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 3
HFC blends covered by the scope of this investigation:
(1) R‐404A: a zeotropic mixture consisting of 52 percent R‐143a, 44 percent by weight R‐125,
and 4 percent 1,1,1,2‐Tetrafluoroethane (“R‐134a”).
R‐404A is sold under various trade names, including Forane® 404A, Genetron® 404A, Solkane®
404A, Klea® 404A, and Suva®404A.
(2) R‐407A: a zeotropic mixture of 20 percent R‐32, 40 percent R‐125, and 40 percent R‐134a.
R‐407A is sold under various trade names, including Forane® 407A, Solkane® 407A, Klea®407A,
and Suva®407A.
(3) R‐407C: a zeotropic mixture of 23 percent R‐32, 25 percent R‐125, and 52 percent R‐134a.
R‐407C is sold under various trade names, including Forane® 407C, Genetron® 407C, Solkane®
407C, Klea® 407C and Suva® 407C.
(4) R‐410A: a zeotropic mixture of 50 percent R‐32 and 50 percent R‐125.
R‐410A is sold under various trade names, including EcoFluor R410, Forane® 410A, Genetron®
R410A and AZ‐20, Solkane® 410A, Klea® 410A, Suva® 410A, and Puron®.
(5) R‐507A: an azeotropic mixture of 50 percent R‐125 and 50 percent R‐143a also known as R‐
507.
R‐507A is sold under various trade names, including Forane® 507, Solkane® 507, Klea®507,
Genetron®AZ‐50, and Suva®507.
The foregoing percentages are nominal percentages by weight. Actual percentages of single
component refrigerants by weight may vary by plus or minus two percent points from the
nominal percentage identified above.
Products excluded from the scope of this investigation:
Excluded from this investigation are:
(1) Blends of refrigerant chemicals that include products other than HFCs, such as blends
including chlorofluorocarbons (CFCs) or hydrochlorofluorocarbons (HCFCs).
(2) Patented HFC blends, such as ISCEON® blends, including MO99™ (RR‐438A), MO79 (R‐422A),
MO59 (R‐417A), MO49Plus™ (R‐437A) and MO29™ (R‐422D), and Genetron® Performax™ LT (R‐
407F), Choice® R‐421A, and Choice® R‐421B.
(3) HFC component R‐134a.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 4
HFC blends included in the scope of this investigation are currently classified in the Harmonized Tariff
Schedule of the United States (“HTS”) in statistical reporting numbers 3824.78.0020 and 3824.78.0050.1
Single component HFCs included in the scope of this investigation are currently classified in statistical
reporting number 2903.39.2035.2 Although the HTSUS statistical reporting numbers and CAS registry
numbers are provided for convenience and customs purposes, the written description of the scope is
dispositive.
Practical terminology for products in this questionnaire
Components
In‐scope HFC components = three (3) components, R‐32, R‐125, and R‐143a.
Out‐of‐scope HFC component = one (1) component, R‐134a.3
HFC components = four (4) components, R‐32, R‐125, R‐143a, and R‐134a.
Blends
In‐scope HFC blends = five (5) blends, R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A.
Out‐of‐scope refrigerant blends = any blend that uses at least one in‐scope HFC component and
is not part of the 5 "in‐scope HFC blends" listed above. These include all other refrigerant
blends, including HFC, HCFC, and HFO blends. This includes proprietary and patented refrigerant
blends. See question V‐5 for a list of various out‐of‐scope refrigerant blends.
Producer.‐‐If your firm produces HFC components R‐32, R‐125, R‐143a, or R‐134a, HFC blends R‐404A, R‐
407A, R‐407C, R‐410A, or R‐507A, you are considered a “producer” in this investigation.
Reclaimer.‐‐If your firm removes impurities from any in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐
410A, and R‐507A) through reclaiming, reconstituting, and/or recycling in order to produce the in‐scope
HFC blends by bringing these blends back to AHRI standards for customers, you must complete a
producer questionnaire.
Repackers.‐‐If your firm has both blending and repacking operations, please report your blending
operations only.
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.
1 Prior to 2016, HFC blends were classified in HTS statistical reporting number 3824.78.0000.
2 Prior to 2016, single component HFCs were classified in HTS statistical reporting number 2903.39.2030.
3 With the exception of questions in sections II‐4a and II‐4 on your firm’s ability to shift from within scope to
out‐of‐scope components and blends, discussion and data for out‐of‐scope HFC component refer only to R‐134a.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 5
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 HFC blends and components and your responses to the
questions in Part I of the producer questionnaire will be provided to the U.S. Department of Commerce,
upon its request, for use in connection with (and only in connection with) its requirement pursuant to
section 702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination
concerning the extent of industry support for the petition requesting this proceeding. Any information
provided to Commerce will be transmitted under the confidentiality and release guidelines set forth
above. Your response to these questions constitutes your consent that such information be provided to
Commerce under the conditions described above.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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?
No
Yes
I‐2.
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 HFC components (R‐32, R‐
125, R‐143a, and R‐134a) or in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A),
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
I‐3.
Petition support.‐‐Does your firm support or oppose the petition?
Country
China
I‐4.
I‐5.
Page 7
Support
Oppose
Take no position
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing HFC components (R‐32, R‐125, R‐143a, and R‐134a) or in‐
scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) from China into the United
States or that are engaged in exporting HFC components (R‐32, R‐125, R‐143a, and R‐134a) or
in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) from China to the United
States?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of in‐scope HFC blends or HFC components?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
I‐7.
Page 8
In‐scope HFC blends under previous patent protection.—
Patent ownership/expiration.‐‐Prior to the patent expiration of any in‐scope HFC blends (R‐
404A, R‐407A, R‐407C, R‐410A, and R‐507A) in 2010 and 2011, did your firm produce any in‐
scope HFC blends while they were under patent?
No
Yes‐‐please provide details in the table below.
HFC blend
Owned patent
in the United
States?
Production under
lease agreement?
Patent expiration date
R‐404A
R‐407A
R‐407C
R‐410A
R‐507A
Please provide the details of your firm’s purchases/sales of licensing rights to produce or sell the
in‐scope HFC blends above while they were under patent, including restrictions on the volume
of production/sales allowed under the licensing agreement(s):
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
I‐8.
Page 9
Reclaiming operations.—
Reclaimer.‐‐a firm that removes impurities from in‐scope HFC blends R‐404A, R‐407A, R‐407C,
R‐410A, and R‐507A through reclaiming, reconstituting, and/or recycling in order to produce in‐
scope and/or out‐of‐scope refrigerant blends.
(a)
Has your firm produced in‐scope or out‐of‐scope HFC blend with reclaimed (used) in‐
scope HFC blends (i.e., your firm takes used R‐404A, R‐407A, R‐407C, R‐410A, or R‐507,
then use the remaining HFC components to produce a refrigerant blend, including both
in‐scope HFC blends or other refrigerant blends)?
No
Yes—Please check all that are applicable.
R‐404A
R‐407A
R‐407C
R‐410A
R‐507A
Out‐of‐scope blends
(b)
For reclaimers, what percentage of your business is involved in the following activities:
Activities of reclaimers
Share of firm's total
sales (percent)
Reclaiming in‐scope HCF blends
Reclaiming R‐22
Other reclamation activities
Non reclamation activities
Total (should sum to 100.0 percent)
0.0
(c)
For reclaimers, please describe how reclaiming fits into the overall operations of your
business.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 10
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Joanna Lo (202‐205‐1888,
[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 R‐32, R‐125, R‐143a, R‐404A, R‐407A, R‐407C, R‐410A,
and/or R‐507A since January 1, 2013.
(check as many as appropriate)
(please describe)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 11
II‐3a. Production using same machinery.‐‐Please report your firm’s production of all types of HFC
components and/or refrigerant blends made on the same equipment and machinery used to
produce R‐32, R‐125, R‐143a, R‐404A, R‐407A, R‐407C, R‐410A, and/or R‐507A, 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.
“In‐scope HFC components”‐‐three (3) components, R‐32, R‐125, R‐143a.
“In‐scope HFC blends”‐‐five (5) blends, R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A.
“Other products”‐‐any product in addition to HFC components and/or in‐scope HFC
blends made using the same machinery and equipment. These may include patented
and proprietary HFC blends, CFC, HCFC, or HFO blends as well as other blends.
Quantity (in short tons)
Calendar years
Item
2013
2014
2015
Machinery and equipment used to produce HFC components:
Overall production capacity
Production of:
In‐scope HFC components1
Out‐of‐scope R‐134a
2
3
Other products
Total
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Machinery and equipment used to produce HFC blends:
Overall production capacity
Production of:
In‐scope HFC blends4
Other products (such as out‐of‐
scope refrigerant blends)5
Total
1
Data entered for in scope HFC component production will populate here once reported in question
II‐8.
2
Data entered for R‐134a production will populate here once reported in question II‐8.
3
Please describe these products: .
4
Data entered for production will populate here once reported in question II‐10.
5
Please describe these products: .
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 12
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating
hours per week, weeks per year.
II‐3c. Capacity allocation.‐‐If your firm produces products other than R‐32, R‐125, R‐143a, R‐404A, R‐
407A, R‐407C, R‐410A, and/or R‐507A using the same equipment (as reported above), please
describe the methodology used to allocate overall machinery and equipment capacity reported in
question II‐3a (above) for the following:
(i)
Capacity allocated for in‐scope HFC components (as reported in question II‐8).
(ii)
Capacity allocated for in‐scope HFC blends (as reported in question II‐10).
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐3e. Swap agreements using imported HFC Components.‐‐
“Swap Agreement”‐‐Agreement between two firms whereby firm A produces one HFC
component X and trades a portion of that HFC component X for firm B’s production and/or
imports of HFC component Y.
Since January 1, 2013, has your firm used imported HFC components (R‐32, R‐125, R‐143a,
and/or R‐134a) to satisfy any portion of your swap agreement?
No/NA
Yes‐‐Please describe the source of the imported HFC components
and quantities supplied.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
II‐3f.
Page 13
Product shifting between components.‐‐Is your firm able to produce more than one individual
HFC component (R‐32, R‐125, R‐143a, and R‐134a) using the same equipment and/or labor?
No
Yes‐‐ Please describe the factors that affect your firm’s ability to shift
production among the above four HFC components (e.g., time, cost, relative
price change, etc.), and the degree to which these factors enhance or
constrain such shifts.
II‐3g.
Product shifting from components to other products.‐‐Is your firm able to switch production from
HFC components (R‐32, R‐125, R‐143a, and R‐134a) to 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: .
Please describe the factors that affect your firm’s ability to shift production from HFC components
(R‐32, R‐125, R‐143a, and R‐134a) to other products (e.g., time, cost, relative price change, etc.), and
the degree to which these factors enhance or constrain such shifts.
II‐3h. Product shifting between in‐scope blends.‐‐Is your firm able to produce more than in‐scope
HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) using the same equipment and/or
labor?
No
Yes‐‐ (i.e., have produced different HFC blends using the same equipment and/or
labor).
Please describe the factors that affect your firm’s ability to shift production among HFC blends (e.g.,
time, cost, relative price change, etc.), and the degree to which these factors enhance or constrain
such shifts.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
II‐3i.
Page 14
Product shifting from in‐scope HFC blends to other products.‐‐Is your firm able to switch
production from the five in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) to
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: .
Please describe the factors that affect your firm’s ability to shift production between products (e.g.,
time, cost, relative price change, etc.), and the degree to which these factors enhance or constrain
such shifts.
II‐3j.
Capital investments.‐‐
(i)
Please describe and quantify the amount of capital investments needed to produce one or
more of the HFC components (R‐32, R‐125, R‐143a, and R‐134a). Exclude the costs of any
blending operations in the United States.
(ii)
Please describe and quantify the amount of capital investments needed to produce one or
more of the in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A). Exclude
the costs of any HFC component operations in the United States.
(iii)
Please describe and quantify the amount of capital investments needed to provide
reclaimation services (excluding the costs of any blending operations) in the United States.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
II‐4.
Page 15
Tolling.‐‐
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce in‐scope HFC blends (R‐404A,
R‐407A, R‐407C, R‐410A, and R‐507A) and/or HFC components (R‐32, R‐125, R‐143a, and R‐
134a) that it then returns to the first firm with a charge for processing costs, overhead, etc.
Since January 1, 2013, has your firm been involved in a toll agreement regarding the production
of in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) and/or HFC components
(R‐32, R‐125, R‐143a, and R‐134a)?
No
Yes‐‐Please describe the toll arrangement(s) and name the firm(s) involved
and check all that apply.
(Check all the apply)
Our firm is a toller for HFC components (actually produces) using raw materials provided
by another firm.
Our firm is a tollee for HFC components (another firm actually produces) using raw
materials provided by our firm.
Our firm is a toller for in‐scope HFC blends (actually produces) using raw materials
provided by another firm.
Our firm is a tollee for in‐scope HFC blends (another firm actually produces) using raw
materials provided by our firm.
II‐5.
Repackaging.‐‐
“Repackaging agreement”‐‐Agreement between two firms whereby the first firm supplies
in‐scope HFC blends and the second firm repackages the supplied in‐scope HFC blends.
Since January 1, 2013, has your firm been involved in a repackaging agreement regarding
in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A)?
No
Yes‐‐Please describe the repackaging arrangement(s) and name the firm(s)
involved and check all that apply. NOTE.‐‐Generally, in parts II, III, and
IV of this questionnaire, data relating to resales including those that
have been repackaged should not be included in the provided data.
(Check all the apply)
Our firm repackages in‐scope HFC blends as part of a repackaging agreement using HFC
blends supplied by another firm.
Our firm supplies in‐scope HFC blends to another firm for repackaging.
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II‐6.
Page 16
Foreign trade zones.—
“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.
(a)
Firm's FTZ operations.‐‐Does your firm produce HFC components (R‐32, R‐125, R‐143a,
and R‐134a) or in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A)
and/or admit HFC components (R‐32, R‐125, R‐143a, and R‐134a) or in‐scope HFC blends
(R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) into a foreign trade zone (FTZ)?
No
Yes‐‐Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import HFC components (R‐32, R‐125, R‐143a, and R‐134a) or in‐scope HFC blends (R‐
404A, R‐407A, R‐407C, R‐410A, and R‐507A) into a foreign trade zone (FTZ) for use in
distribution of HFC components (R‐32, R‐125, R‐143a, and R‐134a) or in‐scope HFC
blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) and/or the production of
downstream articles?
No/Don’t know
Yes‐‐Identify the firms and the FTZs.
II‐7.
Importer.‐‐Since January 1, 2013, has your firm imported HFC components (R‐32, R‐125, R‐143a,
and R‐134a) or in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A)?
“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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Trade Data 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.
“Swap Agreement”‐‐Agreement between two firms whereby firm A produces one HFC
component X and trades a portion of that HFC component X for firm B’s production and/or
imports of HFC component Y.
Note.‐‐Re‐sales of purchased HFC components (including repackaged and reclaimed
components) should not be include in questions II‐8 through II‐14 below. However, if purchased
HFC components were blended, then the data on the production of HFC blends should be
provided in questions II‐10 through II‐14.
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‐8.
Page 18
Production, shipment and inventory data for HFC components.‐‐Report your firm’s production
capacity, production, shipments, and inventories related to the production of HFC components
(including both the in‐scope HFC components R‐32, R‐125, and R‐143a and the out‐of‐scope HFC
component R‐134a) in its U.S. establishment(s) during the specified periods.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2013
2014
2015
1
Average production capacity (quantity):
R‐32 (A)
R‐125 (B)
R‐143a (C)
Out‐of‐scope R‐134a (D)
Total capacity of HFC components (E)
0
Beginning‐of‐period inventories (quantity) (F)
Production (quantity):
R‐32 (G)
0
R‐125 (H)
R‐143a (I)
Out‐of‐scope R‐134a (J)
Total production of HFC components (K)
0
0
0
Quantity received, net (M)
Net monetary exchange3 (N)
4
Total available for shipment (O)
1
0
Swap transactions of components: 2
Quantity given, net (L)
0
0
0
The average production capacity reported is based on operating
hours per week, weeks per year. Please
describe the methodology used to allocate overall production capacity reported in question II‐3a to the HFC components
R‐32, R‐125, R‐143a, and R‐134a reported here. .
2
Please describe the swap transactions including (i) the goods involved, (ii) how your firms accounts for the
nonmonetary exchange, (iii) the counterparties to the exchange(s), and (iv) the economic rationale for this business
model. .
3
Was there any monetary consideration exchanged, also known as a boot in accounting slang, involved in the swap
transactions? No Yes‐‐Report the net amount exchanged (report negative values if your firm paid, positive
values if your firm received consideration) in line N and describe how the amount exchanged was determined .
4
Total available for shipment in a given year is the net after swap quantity available for shipment (e.g., BOP inventories,
plus production, net of swap exchanges).
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Production, shipment and inventory data for HFC components.—Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
U.S. shipments of in‐scope HFC components
(R‐32, R‐125, & R‐143a):5
Commercial shipments:
Quantity (P)
Value (Q)
Internal consumption:
Quantity (R)
2013
2014
2015
0
0
0
0
0
0
6
Value (S)
Transfers to related firms:
Quantity (T)
6
Value (U)
U.S. shipments of out‐of‐scope
HFC component (R‐134a):5
Commercial shipments:
Quantity (V)
Value (W)
Internal consumption:
Quantity (X)
0
0
0
0
0
0
6
Value (Y)
Transfers to related firms:
Quantity (Z)
6
Value (AA)
7
Export shipments:
In‐scope HFC components
(R‐32, R‐125, and R‐143a).‐‐
Quantity (AB)
Value (AC)
Out‐of‐scope HFC component (R‐134a).‐‐
Quantity (AD)
Out‐of‐scope HFC component (R‐134a)
(quantity) (AG)
5
Value (AE)
End‐of‐period inventories:
In‐scope HFC components (R‐32, R‐125,
and R‐143a) (quantity) (AF)
Data will populate in this grid for commercial U.S. shipments based on what is entered into question II‐9.
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: .
7
Identify your firm’s principal export markets: .
6
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RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐
of‐period inventories (i.e., lines AF and AG) should be equal total product available for shipment (i.e., line O),
less total shipments (i.e., lines P, R, T, V, X, Z, AB, and AD). 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
2013
O – P – R – T – V – X – Z – AB – AD – AF –
AG = should equal zero ("0") or provide
an explanation.1
1
2014
0
2015
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate: .
II‐9.
Commercial shipments of HFC components by individual component and channel.‐‐Report
your firm’s commercial U.S. shipments by individual component and channel of distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
Commercial U.S. shipments:
R‐32:
Sold to distributors and
service companies and/or to
equipment owners/end users:
Quantity (AH)
Value (AI)
Sold to blenders/repackagers
Quantity (AK)
Value (AK)
Sold to original equipment
manufacturers
Quantity (AL)
Value (AM)
Question continued next page
2013
2014
2015
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Commercial shipments of HFC components by individual component and channel.‐‐Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
R‐125:
Sold to distributors and
service companies and/or to
equipment owners/end users:
Quantity (AN)
Value (AO)
Sold to blenders/repackagers
Quantity (AP)
Value (AQ)
Sold to original equipment
manufacturers
Quantity (AR)
Value (AS)
R‐143a:
Sold to distributors and
service companies and/or to
equipment owners/end users:
Quantity (AT)
Value (AU)
Sold to blenders/repackagers
Quantity (AV)
Value (AW)
Sold to original equipment
manufacturers
Quantity (AX)
Value (AY)
R‐134a (out‐of‐scope):
Sold to distributors and
service companies and/or to
equipment owners/end users:
Quantity (AZ)
Value (BA)
Sold to blenders/repackagers
Quantity (BB)
Value (BC)
Sold to original equipment
manufacturers
Quantity (BD)
Value (BE)
2013
2014
2015
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II‐10. Production, shipment and inventory data for in‐scope HFC blends.‐‐Report your firm’s
production capacity, production, shipments, and inventories related to the production of in‐
scope HFC blends in its U.S. establishment(s) during the specified periods. Data can include
production of in‐scope HFC blends produced from reclaimed components and blends.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2013
2014
2015
1
Average production capacity (quantity)
(BF)
Beginning‐of‐period inventories
(quantity) (BG)
Production (quantity):
R‐404A (BH)
R‐407A(BI)
R‐407C (BJ)
R‐410A (BK)
R‐507A (BL)
0
0
0
0
0
0
0
0
0
Export shipments:
Quantity (BT)
Value (BU)
Total production of in‐scope HFC
blends (BM)
U.S. shipments:
Commercial shipments:2
Quantity (BN)
Value (BO)
Internal consumption:
Quantity (BP)
3
Value (BQ)
Transfers to related firms:
Quantity (BR)
3
Value (BS)
4
End‐of‐period inventories (quantity) (BV)
1
The production capacity (see definitions in instruction booklet) reported is based on operating hours per week,
weeks per year. Please describe the methodology used to calculate production capacity, and explain any changes
in reported capacity (use additional pages as necessary). .
2
Data will populate in this grid for commercial U.S. shipments based on what is entered into question II‐12.
3
Internal consumption, transfers to related firms, and swap transactions must be valued at fair market value. In the
event that your firm uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus,
etc.) and provide value data using that basis for each of the periods noted above: .
4
Identify your firm’s principal export markets: . Please describe the product mix of your export shipments as
compared to your U.S. shipments (i.e., is it similar or different, please indicate how so).
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II‐10. Production, shipment and inventory data for in‐scope HFC blends.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line BV) should be equal to beginning of period inventories (i.e., line BG)
plus production (i.e., line BM), less total shipments (i.e., linesBN, BP, BR and BT). 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
BG + BM –BN – BP – BR – BT – BV =
should equal zero ("0") or provide an
explanation.1
1
2013
2014
0
2015
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate: .
0
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II‐11. Sources of inputs used in the production of in‐scope HFC blends.—Report your firm’s
production of in‐scope HFC blends, by source of new HFC components (e.g., R‐32, R‐124, 143a,
and 134a in lines BW, BX, BZ, and CA) as well as reclaimed HFC components or blends (in line
CC), for the specified periods.
Quantity (in short tons)
Calendar years
Item
2013
Production of in‐scope HFC blends using HFC
components‐‐
Produced in the United States (including
swapped)1 by your firm (BW)
2014
2015
0
0
0
Imported from China (direct imports or
purchases of imports) (BZ)1
Imported from sources other than China
(direct imports or purchases of imports)
(CA) 1
0
0
0
0
0
0
Purchased by your firm and produced in the
United States by another firm (BX)
Total production using domestic
components (BY)
Total production using imported sources
(CB)2
Production of in‐scope HFC blends using
reclaimed inputs (components or blends)
regardless of source (CC)3
Total production of blends (CD)
1
Count as domestic any inputs used by your firm with swapped merchandise if your firm gave its own domestic product
for a component of foreign origin (known or unknown). Count as foreign any inputs used by your firm (even if the actual
component used was produced in the United States) if your firm procured the domestic component pursuant to swap
arrangement in which you gave imported components.
2
Please provide the value or cost of the imported HFC components embodied in line CB:
Item
2013
2014
2015
Value of imported inputs ($1,000)
3
Additions of commercially procured new HFC components and/or HFC blends mixed with the reclaimed gases should
be reported as appropriate based on the source of those materials in lines BW, BX, BZ, and CA. But the volume of
reclaimed inputs should be reported in CC.
RECONCILIATION OF PRODUCTION.—Total production of blends reported in II‐11 by source of inputs
should equal total production of blends reported in II‐10 by type of blend.
Calendar years
Reconciliation
CD – BM = should equal zero ("0"), if not
revise
2013
2014
0
2015
0
0
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II‐12. Commercial shipments of in‐scope HFC blends by individual blend and channel.‐‐Report your
firm’s commercial U.S. shipments of in‐scope HFC blends by individual blend and by channel of
distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
Commercial U.S. shipments:
R‐404A:
Sold to distributors and service
companies and/or to equipment
owners/end users:
Quantity (CE)
2013
2014
Value (CF)
Sold to blenders/repackagers
Quantity (CG)
Value (CP)
Question continued next page
Value (CN)
Sold to original equipment
manufacturers
Quantity (CO)
Value (CL)
Sold to blenders/repackagers
Quantity (CM)
Value (CJ)
R‐407A:
Sold to distributors and service
companies and/or to equipment
owners/end users s:
Quantity (CK)
Value (CH)
Sold to original equipment
manufacturers
Quantity (CI)
2015
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II‐12. Commercial shipments of in‐scope HFC blends by individual blend and channel.‐‐Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
Commercial U.S. shipments:
R‐407C:
Sold to distributors and service
companies and/or to equipment
owners/end users:
Quantity (CQ)
2013
2014
Value (CR)
Sold to blenders/repackagers
Quantity (CS)
Value (DH)
Value (DF)
Sold to original equipment
manufacturers
Quantity (DG)
Value (DD)
Sold to blenders/repackagers
Quantity (DE)
Value (DB)
R‐507A:
Sold to distributors and service
companies and/or to equipment
owners/end users:
Quantity (DC)
Value (CZ)
Sold to original equipment
manufacturers
Quantity (DA)
Value (CX)
Sold to blenders/repackagers
Quantity (CY)
Value (CV)
R‐410A:
Sold to distributors and service
companies and/or to equipment
owners/end users:
Quantity (CW)
Value (CT)
Sold to original equipment
manufacturers
Quantity (CU)
2015
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II‐13. Employment data.‐‐Report your firm’s employment‐related data related to the production of in‐
scope HFC blends and four HFC components (R‐32, R‐125, R‐143a, and R‐134a) 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.
“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
In‐scope HFC components
Average number of PRWs (number)
Hours worked by PRWs
(1,000 hours)
2013
2014
Wages paid to PRWs ($1,000)
Out‐of‐scope HFC component R‐134a
Average number of PRWs (number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
In‐scope HFC blends
Average number of PRWs (number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
2015
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II‐14. Related firms.‐‐If your firm reported transfers to related firms in question II‐8, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a non‐
market formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.
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II‐15. Purchases of HFC components and in‐scope HFC blends from China.‐‐Other than direct imports,
has your firm otherwise purchased HFC components (R‐32, R‐125, R‐143a, and R‐134a) and/or
in‐scope HFC blends (R‐404A, R‐407A, R‐407C, R‐410A, and R‐507A) from China since January 1,
2013?
“Purchase”‐‐ A transaction to buy the four HFC components and/or the (5) HFC blends 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 four HFC components and/or the five in‐scope HFC blends.
“Direct import”‐‐A transaction to buy from a foreign producer where your firm is the importer
of record or consignee. (Per question II‐7, if your firm directly imports HFC components and/or
in‐scope HFC blends, your firm should be submitting a separate U.S. importers' questionnaire
response).
Note.‐‐Re‐sales of purchased HFC components (including repackaged and reclaimed
components) should not be include in questions II‐8 through II‐14 above. However, if purchased
HFC components were blended, then the data on the production of HFC blends should be
provided in questions II‐10 through II‐14.
No
Yes‐‐Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in short tons)
Calendar years
Item
Purchases of HFC components imported from
China
R‐321
R‐125
2
R‐143a
3
Out‐of‐scope R‐134a
4
Purchases of in‐scope HFC blends imported
from China5
1
2013
2014
2015
Please list the name(s) of the importer(s) from China from which your firm purchased R‐32: .
Please list the name(s) of the importer(s) from China from which your firm purchased R‐125: .
3
Please list the name(s) of the importer(s) from China from which your firm purchased R‐143a: .
4
Please list the name(s) of the importer(s) from China from which your firm purchased R‐134a: .
5
Please list the name(s) of the importer(s) from China from which your firm purchased in‐scope HFC blends:
.
2
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II‐16. 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.
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PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[email protected]).
III‐1. Contact information.‐‐ Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
Fax
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain
below:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include in‐scope HFC components
and/or in‐scope HFC blends:
2. Does your firm prepare profit/loss statements for in‐scope HFC components
and/or in‐scope HFC blends?
Yes
No
3. 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
4. Accounting basis: GAAP, cash, tax, or other comprehensive
basis of accounting (specify)
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 group that includes in‐scope HFC components and
in‐scope HFC blends, as well as specific statements and worksheets) used to compile these data.
III‐3a. Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.). Please also specify, as applicable, how HFC component swap
transactions are reflected in reported cost of goods sold (table III‐9a and table III‐9d).
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III‐3b. Swap accounting.‐‐From the perspective of the relevant business unit responding to this
questionnaire and as applicable, please describe in the space below how HFC component swaps
are recognized in the normal course of business. Your response should include a description of
the specific manufacturing costs that are recognized pursuant to the swap exchange (e.g.,
variable costs only or fully‐absorbed manufacturing costs) and the extent to which this
treatment is reflected in the relevant costs reported in table III‐9a, III‐9b, and/or III‐9d.
(Note: With regard to operations on in‐scope HFC components, the Commission requests that
HFC component swaps (from the perspective of relevant in‐scope HFC components given up in
exchange) be reported at fair market value and corresponding costs be reported in cost of goods
sold (see instructions to table III‐9a). With regard to operations on in‐scope HFC blends, HFC
components received pursuant to a swap and used to produce in‐scope HFC blends should, as
applicable, be included in in‐scope HFC blends costs of goods (see instructions to table III‐9d).)
III‐3c. Swap ratios.‐‐To the extent that your company engages in HFC component swaps, please
identity the parties to the arrangement, relevant swap ratios, and how the reported ratios were
determined. Please also describe the extent to which relevant swap ratios changed during the
period and the reason for such changes.
III‐4.
Allocation basis.‐‐With respect to in‐scope HFC components, relevant out‐of‐scope HFC
components, and in‐scope HFC blends, please briefly describe your firm’s allocation basis, if any,
for cost of goods sold, 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 in‐scope HFC components and in‐scope HFC blends, and provide the share of net sales
accounted for by these products in your firm’s most recent fiscal year.
Products
Share of sales
In‐scope HFC components
%
In‐scope HFC blends
%
%
%
%
%
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
III‐6.
Page 33
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of in‐scope HFC components and/or in‐scope HFC blends 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 in‐scope HFC
components and in‐scope HFC blends that your firm purchases from related suppliers and that
are reflected in in‐scope HFC components cost of goods sold (COGS) (III‐9a and III‐9b) and in‐
scope HFC blends COGS (III‐9d), respectively. 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, or negotiated transfer price to approximate fair market value.
In‐scope HFC components COGS
Input
Related supplier
Share of total COGS1
Basis of input valuation as recorded in the firm’s accounting books and records:
In‐scope HFC blends COGS2
Input
Related supplier
Share of total COGS1
Basis of input valuation as recorded in the firm’s accounting books and records:
1
Share of total COGS specific to in‐scope HFC components and in‐scope HFC blends, respectively.
2
Information relevant to any out‐of‐scope HFC component which is used to produce in‐scope HFC
blends should be reported, if applicable, in this section of the table.
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III‐8.
Page 34
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported for in‐scope HFC components COGS (III‐9a
and III‐9b) and in‐scope HFC blends COGS (III‐9d) 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 and reflected in the COGS reported in III‐9a, III‐9b, and III‐9d.
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III‐9a. Overall operations on in‐scope HFC components.‐‐Report the revenue and related cost
information requested below on the in‐scope HFC component operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Note that transfers to related firms,
internal consumption, and swaps (from the perspective of relevant in‐scope HFC components
given up in exchange) 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. If your firm
was involved in in‐scope HFC component tolling operations (either as the toller or as the tollee),
please contact David Boyland at (202)708‐4725 before completing this section of the
questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2013
2014
0
2015
0
0
Transfers to related firms (“Transfers”)
0
0
0
Internal consumption (“IC”)
0
0
0
Swaps
Total net sales quantities
Net sales values:2
Commercial sales
0
0
0
0
0
0
0
0
0
Transfers to related firms
0
0
0
Internal consumption
0
0
0
Swaps
0
0
0
0
0
0
0
0
0
0
0
0
Total net sales values
3
Cost of goods sold (COGS):
Primary raw materials
Direct labor
4
Other factory costs
0
0
0
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
Selling, general, and administrative (SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
4
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Table continued on following page.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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III‐9a. Operations on in‐scope HFC components.—Continued
1 Include only relevant revenue items (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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
To the extent applicable (and whether associated with domestic or export revenue items), COGS should include costs associated with CS,
Transfers, IC, and swaps (i.e., the relevant cost of HFC components given up in exchange and recognized in COGS).
4
Please report relevant by‐product revenue as an offset to other factory costs, as opposed to a component of other income.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9b. Operations on in‐scope HFC components – U.S. commercial shipments and exports only
(“open market sales”).‐‐Report the revenue and related cost information requested below on
the in‐scope HFC component operations of your firm’s U.S. establishment(s).1 Include both
domestic and export commercial sales of the in‐scope HFC components your firm produced, but
do not report resales of products. 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. If your firm was involved in in‐scope HFC
component tolling operations (either as the toller or as the tollee), please contact David Boyland
at (202)708‐4725 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2013
2014
2015
2
Net sales quantities:
Commercial sales (“CS”)
0
0
0
Net sales values:2
Commercial sales
0
0
0
0
0
0
Direct labor
0
0
0
Other factory costs4
0
0
0
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
3
Cost of goods sold (COGS):
Primary raw materials
Selling, general, and administrative (SG&A) expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
0
0
All other expense items
0
0
0
All other income items4
0
0
0
0
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only relevant revenue items (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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. Commercial sales quantities and commercial sales values reported here will be
populated from data entered into question III‐9a.
3 COGS (whether for domestic or export sales) should include costs associated with open market sales only. Costs associated with input
purchases from related suppliers should be consistent with and based on information in the firm’s accounting books and records.
4
Please report relevant by‐product revenue as an offset to other factory costs, as opposed to a component of other income.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9c. Internally‐produced HFC component costs recognized in COGS of operations on in‐scope HFC
blends.‐‐Report the requested cost information specific to HFC components produced in your
firm’s U.S. establishment(s) and recognized in table III‐9d financial results on in‐scope HFC
blends. The total amount reported in this table will populate the total line item Cost of
internally‐produced HFC components recognized in COGS as reported in table III‐9d. Relevant
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.
Value (in $1,000)
Fiscal years ended‐‐
Item
Cost of internally‐produced components recognized in
table III‐9d COGS (in‐scope HFC blends):
Raw materials
Direct labor
1
Other factory costs
Total cost of internally‐produced components
2
recognized in III‐9d COGS
1
2013
2014
2015
0
0
0
0
0
0
0
0
0
0
0
0
Please report relevant by‐product revenue as an offset to other factory costs, as opposed to a component of other income.
2
Total cost of internally‐produced components will populate the relevant line item in table III‐9d (in‐scope HFC blends ‐‐ Cost of internally‐
produced components recognized in COGS).
Note.‐‐These costs should, to the extent applicable, reflect all internally produced HFC component costs relevant to the company’s HFC
blending operations and would include both in‐scope HFC components and, if applicable, the out‐of‐scope HFC component R‐134a. Internally‐
produced components which were not further processed into in‐scope HFC blends (e.g., they were sold on a stand‐alone basis and/or
processed into out of scope HFC blends) are not relevant to this table (or table III‐9d) but should instead be reflected in table III‐9a.
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III‐9d. Operations on in‐scope HFC blends.‐‐ Report the revenue and related cost information
requested below on the in‐scope HFC blends operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that transfers to related firms and internal consumption
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. If your firm was involved in in‐
scope HFC blends tolling operations (either as the toller or as the tollee), please contact David
Boyland at (202)708‐4725 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2013
Net sales quantities:2
Commercial sales (“CS”)
2014
0
2015
0
0
Transfers to related firms (“Transfers”)
0
0
0
Internal consumption (“IC”)
0
0
0
0
0
0
0
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Transfers to related firms
Internal consumption
0
0
0
0
0
0
0
0
0
Purchased or swapped components recognized in
COGS (U.S. origin)
0
0
0
Purchased or swapped5 components recognized in
COGS (imported)
0
0
0
Recovered HFC components or blends
0
0
0
All other raw materials (blending operations only)
0
0
0
Direct labor (blending operations only)
0
0
0
Total net sales values
Cost of goods sold (COGS):3
Cost of internally‐produced components
recognized in COGS (from III‐9c)4
5
6
7
Other factory costs (blending operations only)
0
0
0
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
Selling, general, and administrative (SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
0
0
0
0
0
0
0
0
0
0
0
0
All other expense items
0
0
0
All other income items7
0
0
0
0
0
0
0
0
0
Net income or (loss) before income taxes
Depreciation/amortization included above
Table continued on following page.
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III‐9d. Operations on in‐scope HFC blends.‐‐Continued
1 Include only relevant revenue items (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
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
To the extent applicable (and whether associated with domestic or export revenue items), COGS should include costs associated with in‐
scope HFC blends CS, Transfers, and IC.
4
With respect to operations on in‐scope HFC blends, total cost of internally‐produced components recognized in COGS are reported in
question III‐9c and will populate this line item.
5
Relevant HFC components received from a third party pursuant to swap transactions and recognized in in‐scope HFC blends COGS, as
applicable.
6 This input line item is intended primarily for producers who operate as HFC reclaimers. HFC reclaimers should also report conversion
costs and SG&A expenses allocable to HFC reclaiming operations.
7
Please report relevant by‐product revenue related to blending operations as an offset to other factory costs, as opposed to a component
of other income.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
III‐9e. Financial data reconciliation.‐‐The calculable line items in tables III‐9a through III‐9d (i.e., total
net sales quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or
loss)) have been calculated from the data submitted in the other line items. Do the calculated
fields return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
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III‐10. Nonrecurring items (charges and gains) included in in‐scope HFC components and in‐scope
HFC blends financial results.‐‐For each annual period for which financial results are reported in
question III‐9a, III‐9b, and/or III‐9d, please specify all material (significant) nonrecurring items
(charges and gains) in the schedule below, the specific table III‐9a, III‐9b, and/or III‐9d line item
where the nonrecurring items are included, a brief description of the relevant nonrecurring
items, and the associated values (in $1,000), as reflected in table III‐9a, III‐9b, and/or III‐9d; i.e.,
if an aggregate nonrecurring item has been allocated to table III‐9a, III‐9b, and/or III‐9d, only the
allocated value amount included in table III‐9a, III‐9b, and/or III‐9d should be reported in the
schedule below.
Note: The Commission’s objective here is to gather information only on significant nonrecurring
items which impacted the reported financial results in table III‐9a, III‐9b, and/or III‐9d.
Fiscal years ended‐‐
2013
2014
2015
Nonrecurring item: In this column please provide a
Nonrecurring item: In these columns please report the amount of the
brief description of each nonrecurring item and indicate relevant nonrecurring item reported in table III‐9a, III‐9b, and/or III‐9d.
the specific line item in table III‐9a, III‐9b, and/or III‐9d
Value ($1,000)
where the nonrecurring item is classified.
In‐scope HFC components – non‐recurring items reported in III‐9a
1. , classified as
2. , classified as
3. , classified as
4. , classified as
In‐scope HFC components – non‐recurring items reported in III‐9b
1. , classified as
2. , classified as
3. , classified as
4. , classified as
In‐scope HFC blends – non‐recurring items reported in III‐9d
1. , classified as
2. , classified as
3. , classified as
4. , classified as
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III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If nonrecurring items were reported in table III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., III‐10 information designates where these items are reported in
table III‐9a, III‐9b, and/or III‐9d, respectively.
III‐12. Property, plant, and equipment and total assets.‐‐Report the property, plant, and equipment
(PP&E) and total assets (i.e., both current and long‐term assets) associated with the production,
warehousing, and sale of in‐scope HFC components and in‐scope HFC blends, respectively. If
your firm does not maintain some or all of the information necessary to report this information
(specific to in‐scope HFC components and in‐scope HFC blends) in the normal course of
business, please estimate this information based upon a method (such as production, sales, or
costs) that is consistent with your firm’s relevant cost allocations in the preceding tables.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: PP&E and total assets should reflect net assets after any accumulated depreciation and
allowances deducted. PP&E and total assets should be allocated to the subject products if they
are also related to other products. Please provide a brief explanation if there are any
substantial changes in PP&E and/or total assets during the period; e.g., due to asset write‐offs,
revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
2013
2014
2015
In‐scope HFC components
Property, plant, and equipment
(net) 1
1
Total assets (net)
In‐scope HFC blends
Property, plant, and equipment
(net) 2
2
Total assets (net)
1
2
Describe nature of substantial changes in in‐scope HFC components PP&E and total asset balance:
Describe nature of substantial changes in in‐scope HFC blends PP&E and total asset balance:
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III‐13.
Page 43
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses on in‐scope HFC components and in‐
scope HFC blends. Provide data for your firm’s three most recently completed fiscal years.
Value (in $1,000)
Fiscal years ended‐‐
Item
2013
2014
2015
In‐scope HFC components
Capital expenditures1
Research and development
expenses2
Capital expenditures3
Research and development
expenses4
In‐scope HFC blends
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on in‐scope HFC
components:
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to in‐scope HFC
components:
3
Please describe the nature, focus, and significance of your firm’s capital expenditures on in‐scope HFC blends:
4
Please describe the nature, focus, and significance of your firm’s R&D expenses related to in‐scope HFC
blends:
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9b, III‐9d, III‐12, and III‐13 are based on a calendar year or on your firm’s
fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the relevant quantities and values reported in question III‐9a (financial results on
overall operations on in‐scope HFC components) and III‐9d (financial results on overall
operations on in‐scope HFC blends) should reconcile with data reported in question II‐8 and II‐9
(including export shipments) as long as they are reported on the same calendar year basis.
Do relevant data in question III‐9a (financial results on overall operations on in‐scope HFC
components) and III‐9d (financial results on overall operations on in‐scope HFC blends) reconcile
with data in question II‐8 and II‐9?
Yes
No
If no, please explain.
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III‐15. Effects of imports on investment.‐‐Since January 1, 2013, 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 in‐scope HFC blends and components from China?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
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‐16. Effects of imports on growth and development.‐‐Since January 1, 2013, 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 in‐scope HFC blends and components from China?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
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III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
in‐scope HFC blends and components from China?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
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PART IV.‐‐ PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Michele Breaux (202‐205‐
2781, [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, 2013 of the following products produced by your
firm.
Product 1.‐‐ R‐410A in bulk containers (1,000 lbs. or greater);
Product 2.‐‐ R‐410A in 25‐lb. disposable tanks or cylinders;
Product 3.‐‐ R‐404A in 24‐lb. disposable tanks or cylinders;
Product 4.‐‐ R‐407C in 25‐lb. disposable tanks or cylinders;
Product 5.‐‐ R‐32 in bulk containers (1,000 lbs. or greater);
Product 6.‐‐ R‐125 in in bulk containers (over 1,000 lbs. or greater).
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 2013‐December 2015, did your firm produce and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.‐‐Please complete the following pricing data table(s) as appropriate.
No.‐‐Skip to question IV‐3.
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.
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IV‐2a. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds and actual dollars (not 1,000s).
(Quantity in pounds , value in dollars)
Product 1
Product 2
Product 3
Period of shipment
Quantity
Value
Quantity
Value
Quantity
Value
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
October‐
December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
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IV‐2a. Price data.—Continued
Report below the quarterly price data1 for pricing products2 produced and sold by your firm.
Report data in actual pounds and actual dollars (not 1,000s).
(Quantity in pounds , value in dollars)
Product 4
Product 5
Product 6
Period of shipment
Quantity
Value
Quantity
Value
Quantity
Value
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
October‐
December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
Product 6:
IV‐2b. Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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IV‐2c. Price data component country‐of‐origin.‐‐Report below the average share of total quantity of
each individual in‐scope HFC blend pricing products’ (e.g., products 1 through 4) input HFC
components by source.
Percent total quantity over period
(January 2013‐December 2015)
Product
Domestic
components1
(percent)
Total (should
Components
sum to
imported from
1
all other sources 100.0% across
in each row)
(percent)
Components
imported from
China1
(percent)
Product 1‐ R‐410A in bulk
containers (1,000 lbs. or
greater)
0.0
Product 2‐ R‐410A in 25‐lb.
disposable tanks or
cylinders
0.0
Product 3‐ R‐404A in 24‐lb.
disposable tanks or
cylinders
0.0
Product 4‐ R‐407C in 25‐lb.
disposable tanks or
cylinders
0.0
1
Count as domestic any inputs used by your firm with swapped merchandise if your firm gave its own
domestic product for a component of foreign origin (knowingly or unknowingly). Count as foreign any inputs
used by your firm (even if the actual component used was produced in the United States) if your firm procured
the domestic component pursuant to swap arrangement in which you gave imported components.
IV‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales of in‐scope HFC
blends and/or in‐scope HFC components (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
In‐scope HFC
components
In‐scope HFC
blends
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
IV‐4.
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV‐5.
Page 50
No
discount
policy
Annual total
volume
discounts
Other
Describe
In‐scope HFC
components
In‐scope HFC
blends
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced in‐scope HFC blends
and/or in‐scope HFC components?
Net 30
days
(b)
Net 60
days
2/10
net 30
days
Other
Other (specify)
In‐scope HFC
components
In‐scope HFC
blends
On what basis are your firm’s prices of domestic in‐scope HFC blends and/or in‐scope
HFC components usually quoted (check one)?
Delivered
F.o.b.
If f.o.b., specify point
In‐scope HFC
components
In‐scope HFC
blends
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
IV‐6.
Page 51
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced in‐
scope HFC blends and/or in‐scope HFC components 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 2014
sales
In‐scope HFC
components
In‐scope HFC
blends
IV‐7.
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for
less than 12
12 months)
months)
Spot sales
(for a single
delivery)
Total
(should
sum to
100.0%)
%
%
%
%
0.0
%
%
%
%
%
0.0
%
Contract provisions.—
(a)
In‐scope HFC components.‐‐Please fill out the table regarding your firm’s typical sales
contracts for U.S.‐produced in‐scope HFC components (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
Average contract
duration
Item
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)
# of days
365
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
IV‐7.
Page 52
Contract provisions‐‐Continued
(b)
In‐scope HFC blends.‐‐Please fill out the table regarding your firm’s typical sales
contracts for U.S.‐produced in‐scope HFC blends (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
Short‐term contracts
(multiple deliveries
for less than 12
months)
Average contract
duration
# of days
Long‐term contracts
(multiple deliveries for
more than 12 months)
365
Yes
No
Quantity
Price
Both
Yes
No
Price renegotiation
(during contract
period)
Fixed quantity
and/or price
Meet or release
provision
Not applicable
IV‐8.
Annual contracts
(multiple
deliveries for 12
months)
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 in‐scope HFC blends and/or in‐scope HFC components?
Lead time
Share of 2015 (average number
of days)
Source
sales
In‐scope HFC components
From inventory
%
Produced to order
%
0.0
%
Total (should sum to 100.0%)
In‐scope HFC blends
From inventory
%
Produced to order
%
0.0
%
Total (should sum to 100.0%)
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
IV‐9.
Page 53
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced in‐
scope HFC blends and/or in‐scope HFC components that is accounted for by U.S. inland
transportation costs? percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of in‐scope HFC blends and/or
in‐scope HFC components 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‐10. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced in‐scope HFC blends and/or in‐scope HFC components since January 1, 2013 (check all
that apply)?
Geographic area
√ if applicable
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI, among others.
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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IV‐11. End uses.—
(a)
End use industries.‐‐For 2015, report the quantity of U.S. commercial shipments of your
firm’s U.S. produced in‐scope HFC blends by end use.
2015
R‐404A
R‐407A
End‐use application
R‐407C
R‐410A
Total
commercial
U.S.
R‐507A shipments
Quantity (short tons)
Residential a/c units and heat
pumps
0
Commercial a/c units
0
Commercial refrigeration units
0
Transport refrigeration units
0
Process refrigeration units
0
0
0
0
0
0
0
0
1
Other
Total commercial U.S.
shipments
1
Explain the other end uses: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐ Data in question II‐12 should
reconcile with data reported in this question, (i.e., the reconciliations below should return zero, "0"). If
the reconciliations are not returning zero, please revise the inconsistency in the data prior to submission
of the completed questionnaire to the Commission.
Reconciliation
R‐404A
R‐407A
R‐407C
R‐410A
R‐507A
Total
Should equal zero ("0"), if not
revise here (or question II‐12).
0
0
0
0
0
0
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IV‐11. End uses.—Continued
(b)
Cost share.‐‐For each end‐use product, what percentage of the total cost is accounted
for by in‐scope HFC blends and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
In‐scope HFC blends
Other inputs
Residential a/c units
and heat pumps
%
%
0.0 %
Commercial a/c units
%
%
0.0 %
Commercial
refrigeration units
%
%
0.0 %
Transport
refrigeration units
%
%
0.0 %
Process refrigeration
units
%
%
0.0 %
%
%
0.0 %
1
Other
1
Explain the other end uses: .
IV‐12. Substitutes.—
(a)
Component substitutes.‐‐ Can other products be substituted for in‐scope HFC
components?
No
Yes‐‐Please fill out the table.
In‐scope
Direct
HFC
Replacement?
component
replaced No
Yes
Explain, noting if Have changes in the price of this
any changes to substitute affected the price for
in‐scope components?
equipment are
needed.
No
Yes
Explanation
1.
2.
3.
Substitute
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IV‐12. Substitutes.—Continued
(b)
Blend substitutes.‐‐ Can other products be substituted for in‐scope HFC blends?
No
Yes‐‐Please fill out the table.
Direct
In‐scope
Replacement?
HFC blend
replaced No
Yes
Explain, noting if Have changes in the price of this
any changes to substitute affected the price for
in‐scope blends?
equipment are
needed.
No
Yes
Explanation
1.
2.
3.
Substitute
IV‐13. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for in‐scope HFC blends and/or in‐scope HFC components has changed since
January 1, 2013. Explain any trends and describe the principal factors that have affected these
changes in demand.
Market
Overall
No
Overall
increase change decrease
Fluctuate
with no
clear trend
Explanation and factors
In‐scope HFC components
Within
the United
States
Outside
the United
States
In‐scope HFC blends
Within
the United
States
Outside
the United
States
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IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of in‐scope HFC blends and/or in‐scope HFC components since January 1, 2013?
No
Yes
If yes, please describe and quantify if possible.
IV‐15. Conditions of competition.‐‐
(a)
Is the market for in‐scope HFC blends and/or in‐scope HFC components subject to
business cycles (other than general economy‐wide conditions) and/or other conditions
of competition distinctive to in‐scope HFC blends and/or in‐scope HFC components? If
yes, describe.
Check all that apply.
Please describe.
In‐scope HFC components
No
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
In‐scope HFC blends
No
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
in‐scope HFC blends and/or in‐scope HFC components since January 1, 2013?
No
Yes
If yes, describe.
In‐scope HFC
components
In‐scope HFC
blends
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply in‐scope HFC
blends and/or in‐scope HFC components since January 1, 2013 (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.
In‐scope HFC
components
In‐scope HFC
blends
IV‐17. Raw materials.‐‐How have raw material prices for in‐scope HFC blends and in‐scope HFC
components changed since January 1, 2013?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for in‐
scope HFC blends and in‐scope HFC component.
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U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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IV‐18. Interchangeability.‐‐Are in‐scope HFC blends and/or in‐scope HFC components 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
In‐scope HFC Components
Country‐pair1
In‐scope United States
HFC
Components China
In‐scope
HFC blends
1
China
Other
Countries
In‐scope HFC blends
China
United States
China
Other Countries
Country comparisons between products of the United States, China, and other countries
should be made on a component by component or blend by blend basis.
For any country‐pair producing products that is sometimes or never interchangeable, identify
the country‐pair and explain the factors that limit or preclude interchangeable use:
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IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between in‐scope HFC blends and/or in‐
scope HFC components 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
In‐scope HFC Components
Country‐pair1
In‐scope United States
HFC
Components China
In‐scope
HFC blends
1
China
Other
Countries
In‐scope HFC blends
China
United States
China
Other Countries
Country comparisons between products of the United States, China, and other countries
should be made on a component by component or blend by blend basis.
For any country‐pair producing products that is sometimes or never interchangeable, identify
the country‐pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
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IV‐20. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for in‐scope HFC blends and/or in‐scope HFC components since January 1, 2013.
Indicate the share of the quantity of your firm’s total shipments of in‐scope HFC blends and
components that each of these customers accounted for in 2015.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2105
sales
(%)
1
2
3
4
5
6
7
8
9
10
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IV‐21. Competition from imports.—
(a)
Lost revenue.‐‐Since January 1, 2013: To avoid losing sales to competitors selling in‐
scope HFC blends and/or in‐scope HFC components from China, did your firm:
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2013: Did your firm lose sales of in‐scope HFC blends and
components to imports of in‐scope HFC blends and/or in‐scope HFC components from
China?
No
Yes
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.—ADDITIONAL PRODUCT INFORMATION
V‐1. Semi‐finished analysis.‐‐For each of the following individual HFC components, provide the
requested assessments. If you do not have the knowledge to be able to respond this question,
please leave it blank.
(a)
Uses in addition to in‐scope HFC blend production.‐‐Indicate whether each individual
HFC component is dedicated to the production of in‐scope HFC blends or has uses in
addition to the production of downstream in‐scope HFC blends. If there are uses for an
individual HFC component other than for the production of in‐scope HFC blends, please
list these other uses. If any in‐scope HFC component can be sold as an individual
component, provide that information in the explanation section of the table below.
HFC
No.‐‐
Yes.‐‐Other
component Dedicated
uses
Explanation (if yes).‐‐Describe the other uses
R‐32
R‐125
R‐143a
R‐134a
(out‐of‐scope)
(b)
Differences in markets.‐‐Are the markets for HFC components, to the degree that the
individual HFC components are sold commercially, separate and/or distinct from the
market(s) for the downstream in‐scope HFC blends? If there are differences in the
markets, please describe them in the space provided. (If there are no markets for the
individual HFC component, leave blank).
HFC
No.‐‐Similar
component market(s)
R‐32
R‐125
R‐143a
R‐134a
(out‐of‐scope)
Yes.‐‐
Separate/
distinct
market(s)
Explanation (if yes).‐‐Describe the differences
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V‐1.
Page 64
Semi‐finished analysis.‐‐Continued
(c)
Similar physical characteristics and functions.‐‐Are there distinct physical
characteristics and functions of HFC components and the in‐scope HFC blends?
No.—
HFC component Similar
Yes.—
Distinct
Explanation (if yes).—Describe the distinct
physical characteristics and functions
R‐32
R‐125
R‐143a
R‐134a
(out‐of‐scope)
(d)
Differences in price or value.‐‐Are there differences in the price for or value of the
individual HFC components and the the downstream in‐scope HFC blends?
Yes.—
No.—
Divergent
Similar
HFC
component price/value price/value
R‐32
R‐125
R‐143a
R‐134a
(out‐of‐scope)
Explanation (if yes).—Describe the differences
in and drivers of price/value
Business Proprietary
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V‐1.
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Semi‐finished analysis.—Continued
(e)
Extensive process to convert to in‐scope HFC blend.‐‐Is the process to create a in‐
scope HFC blend from the individual HFC component extensive and/or complicated?
HFC
component
R‐32
R‐125
R‐143a
R‐134a
(out‐of‐scope)
Yes.—
Extensive/ Explanation (if yes).—Describe the complexities
No.—
of creating a in‐scope HFC blend
Simple complicated
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V‐2.
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Comparability of in‐scope HFC blends vs out‐of‐scope refrigerant blends.‐‐For each of the
following indicate whether in‐scope HFC blends and out‐of‐scope refrigerant blends are: fully
comparable or the same, i.e., have no differentiation between them; mostly comparable or
similar; somewhat comparable or similar; never or not‐at‐all comparable or similar; or no
familiarity with products. If there are differences between individual in‐scope HFC blends and
individual out‐of‐scope refrigerant blends please provide that information in the narrative fields.
(a)
Characteristics and Uses.‐‐How comparable are in‐scope HFC blends and out‐of‐scope
refrigerant blends in physical characteristics and end uses?
Fully comparable
Mostly
comparable
Somewhat
comparable
Not at all
comparable
NA/no familiarity
Please provide a narrative discussion for the comparability ratings you provided in terms of their
characteristics and uses:
(b)
Interchangeability.‐‐How substitutable are in‐scope HFC blends and out‐of‐scope
refrigerant blends in the same application?
Fully
interchangeable
Mostly
interchangeable
Somewhat
interchangeable
Not at all
interchangeable
NA/no
familiarity
Please provide a narrative discussion for the comparability ratings you provided in terms of
their interchangeability:
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V‐2.
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Comparability of in‐scope HFC blends vs out‐of‐scope refrigerant blends.‐‐Continued
(c)
Manufacturing facilities, production processes, and production employees.‐‐Are in‐
scope HFC blends and out‐of‐scope refrigerant blends manufactured using the same
facilities, the same inputs, the same machinery and equipment, and the same
employees?
Fully the same
Mostly the same
Somewhat the
same
Not at all the
same
NA/no familiarity
Please provide a narrative discussion for the comparability ratings you provided in terms of their
manufacturing processes:
(d)
Channels of distribution.‐‐Compare the channels of distribution/market situation
through which in‐scope HFC blends and out‐of‐scope refrigerant blends are sold (i.e.,
sold direct to end users, through distributors, etc.).
Fully comparable
Mostly
comparable
Somewhat
comparable
Not at all
comparable
NA/no familiarity
Please provide a narrative discussion for the comparability ratings you provided in terms of their
channels of distribution:
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V‐2.
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Comparability of in‐scope HFC blends vs out‐of‐scope refrigerant blends.‐‐Continued
(e)
Customer and producer perceptions.‐‐How do customers and producers view the
comparability of in‐scope HFC blends and out‐of‐scope refrigerant blends in the market
(e.g., sales/marketing practices, end uses)?
Fully comparable
Mostly
comparable
Somewhat
comparable
Not at all
comparable
NA/no familiarity
Please provide a narrative discussion for the comparability ratings you provided in terms of their
customer and producer perceptions:
(f)
Price.‐‐Are prices comparable or different for in‐scope HFC blends and out‐of‐scope
refrigerant blends?
Fully comparable
Mostly
comparable
Somewhat
comparable
Not at all
comparable
NA/no familiarity
Please provide a narrative discussion for the comparability ratings you provided in terms of their
prices:
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V‐3.
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Additional product info: Out‐of‐scope refrigerant blends.‐‐Report your firm’s production
capacity, production, shipments, inventories, and financial data related to out‐of‐scope
refrigerant blends (including but not limited to out‐of‐scope HFC, HCFC/CFC, or HFO blends) in
its U.S. establishment(s) during the specified periods. Quantity are being requested in POUNDS
not short tons due to lower volume of merchandise in this category.
OUT‐OF‐SCOPE REFRIGERANT BLENDS
Quantity (pounds) and value (in $1,000)
Calendar years
Item
2013
1
2014
2015
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity) (B)
Production (quantity) (C)
0
0
0
0
0
0
End‐of‐period inventories (quantity) (L)
Net sales quantities
Net sales value
Cost of goods sold (value)
0
0
0
0
0
0
Capital expenditures (value)
Research and development expenses (value)
Net end of period assets (value)
U.S. shipments:
Commercial shipments:2
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
3
Value (G)
Transfers to related firms:
Quantity (H)
3
Value (I)
4
Export shipments:
Quantity (J)
Value (K)
4
Gross profit or (loss) (value)
SG&A expenses (value)
Operating income or (loss) (value)
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
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: .
3
Identify your firm’s principal export markets: .
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RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Calendar years
Reconciliation
2013
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2014
0
2015
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate: .
V‐4.
Channels of distribution.‐‐Report your firm’s commercial U.S. shipments of out‐of‐scope
refrigerant blends by channel of distribution.
OUT‐OF‐SCOPE REFRIGERANT BLENDS
Quantity (pounds) and value (in $1,000)
Calendar years
Item
Channels of distribution:
Commercial U.S. shipments:
Sold to Sold to distributors
and service companies and/or
to equipment owners/end
users:
Quantity (V)
Value (W)
Sold to blenders/repackagers:
Quantity (X)
Value (Y)
Sold to original equipment
manufacturers:
Quantity (Z)
Value (AA)
2013
2014
2015
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
V‐5.
Page 71
Individual out‐of‐scope refrigerant blends reported in question V‐3 and V‐4.‐‐Please check
which out‐of‐scope refrigerant blends accounted for the data reported by your firm in question
V‐3 and V‐4.
1
R‐407B
R‐422A
R‐407D
R‐422B
R‐407E
R‐422C
R‐407F
R‐422D
R‐408A
R‐422E
R‐410B
R‐423A
R‐413A
R‐424A
R‐416A
R‐425A
R‐417A
R‐426A
R‐417B
R‐427A
R‐417C
R‐428A
R‐419A
R‐434A
R‐419B
R‐437A
R‐420A
R‐438A
R‐421A
R‐439A
R‐421B
R‐440A
Other out‐of‐scope refrigerant blends1
R‐442A
R‐444A
R‐445A
R‐448A
R‐449A
R‐449B
R‐450A
R‐451A
R‐451B
R‐452A
R‐453A
R‐454A
R‐454B
R‐504
R‐512A
R‐513A
Please name the individual out‐of‐scope refrigerant blends not otherwise provided in the list above that are
included in questions V‐3 and V‐4 .
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
V‐6.
Page 72
Comparability of out‐of‐scope HFC component R‐134a with either in‐scope HFC components
or in‐scope HFC blends.‐‐For each of the following indicate whether out‐of‐scope HFC
component R‐134a and either in‐scope HFC components or in‐scope HFC blends are: fully
comparable or the same, i.e., have no differentiation between them; mostly comparable or
similar; somewhat comparable or similar; never or not‐at‐all comparable or similar; or no
familiarity with products. If there are differences between R‐134a and either in‐scope HFC
components or in‐scope HFC blends, please provide that information in the narrative fields.
(a) Characteristics and Uses.‐‐How comparable is R‐134a with either in‐scope HFC
components or in‐scope HFC blends in physical characteristics and end uses?
Fully
Mostly
Somewhat
Not at all
NA/no
Comparison
comparable comparable
comparable
comparable
familiarity
R‐134a vs in‐scope HFC
components
R‐134a vs in‐scope HFC
blends
Please provide a narrative discussion for the comparability ratings you provided in terms of their
characteristics and uses:
(b)
Interchangeability.‐‐How substitutable are R‐134a and either in‐scope HFC
components or in‐scope HFC blends in the same application?
Comparison
R‐134a vs in‐scope
HFC components
Fully
Mostly
Somewhat
Not at all
NA/no
interchangeable interchangeable interchangeable interchangeable familiarity
R‐134a vs in‐scope
HFC blends
Please provide a narrative discussion for the comparability ratings you provided in terms of
their interchangeability:
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
V‐6.
Page 73
Comparability of out‐of‐scope HFC component R‐134a with either in‐scope HFC components
or in‐scope HFC blends.‐‐Continued
(c)
Manufacturing facilities, production processes, and production employees.‐‐Are
R‐134a and either in‐scope HFC components or in‐scope HFC blends manufactured
using the same facilities, same inputs, same machinery and equipment, and same
employees?
Comparison
R‐134a vs in‐scope
HFC components
Fully the same
Mostly the
same
Somewhat the
same
Not at all the
same
NA/no
familiarity
R‐134a vs in‐scope
HFC blends
Please provide a narrative discussion for the comparability ratings you provided in terms of their
manufacturing processes:
(d)
Channels of distribution.‐‐Compare the channels of distribution/market situation
through which R‐134a and either in‐scope HFC components or in‐scope HFC blends are
sold (i.e., sold direct to end users, through distributors, etc.).
Comparison
R‐134a vs in‐scope
HFC components
Fully
comparable
Mostly
comparable
Somewhat
comparable
Not at all
comparable
NA/no
familiarity
R‐134a vs in‐scope
HFC blends
Please provide a narrative discussion for the comparability ratings you provided in terms of their
channels of distribution:
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
V‐6.
Page 74
Comparability of out‐of‐scope HFC component R‐134a with either in‐scope HFC components
or in‐scope HFC blends.‐‐Continued
(e) Customer and producer perceptions.‐‐How do customers and producers view the
comparability of R‐134a and either in‐scope HFC components or in‐scope HFC blends in the
market (e.g., sales/marketing practices, end uses)?
Fully
Mostly
Somewhat
Not at all
NA/no
Comparison
comparable
comparable
comparable
comparable
familiarity
R‐134a vs in‐scope
HFC components
R‐134a vs in‐scope
HFC blends
Please provide a narrative discussion for the comparability ratings you provided in terms of their
customer and producer perceptions:
(f)
Price.‐‐Are prices comparable or different for R‐134a and either in‐scope HFC
components or in‐scope HFC blends?
Comparison
R‐134a vs in‐scope
HFC components
Fully
comparable
Mostly
comparable
Somewhat
comparable
Not at all
comparable
NA/no
familiarity
R‐134a vs in‐scope
HFC blends
Please provide a narrative discussion for the comparability ratings you provided in terms of their
prices:
Note.‐‐Part II‐8 included data on swaps, commercial shipments, internal consumption, transfers to
related firms, export shipments, and inventories of R‐134a. Data reported in question V‐7a below should
generally correspond to the same data reported in part II‐8.
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 75
V‐7a. Operations on out‐of‐scope HFC component R‐134a.‐‐Report the revenue and related cost
information requested below on the out of scope HFC component R‐134a operations of your
firm’s U.S. establishment(s), as well as corresponding capital expenditures and R&D expenses.1
Do not report resales of products. Transfers to related firms, internal consumption, and swaps
(from the perspective of relevant R‐134a given up in exchange) 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. If your firm was involved in out of scope HFC component R‐
134a tolling operations (either as the toller or as the tollee), please contact David Boyland at
(202)708‐4725 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2013
2014
2015
2
Net sales quantities:
Commercial sales (“CS”)
0
0
0
Transfers to related firms (“Transfers”)
0
0
0
Internal consumption (“IC”)
0
0
0
Swaps
0
0
0
0
0
0
0
0
0
Total net sales quantities
Net sales values:2
Commercial sales
Transfers to related firms
0
0
0
Internal consumption
0
0
0
Swaps
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
0
0
0
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Direct labor
4
Other factory costs
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
4
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Table continued on following page.
0
0
0
0
0
0
0
0
0
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 76
V‐7a. Operations on out‐of‐scope HFC component R‐134a.‐‐Continued
1 Include only relevant revenue items (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
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 To the extent applicable (and whether associated with domestic or export revenue items), COGS should include costs
associated with CS, Transfers, IC, and swaps (i.e., the relevant cost of R‐134a given up in exchange and recognized in COGS).
4
Please report relevant by‐product revenue related to R‐134a component operations as an offset to other factory costs, as
opposed to a component of other income.
Capital expenditures
0
0
0
Research and development expenses
0
0
0
Business Proprietary
U.S. Producers’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 77
V‐7b. Operations on out‐of‐scope HFC component R‐134a – U.S. commercial shipments and exports
only (“open market sales”).‐‐Report the revenue and related cost information requested below
on the out of scope HFC component R‐134a operations of your firm’s U.S. establishment(s).1
Include both domestic and export commercial sales of the out of scope HFC component R‐134a
your firm produced, but do not report resales of products. 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. If your firm
was involved in out of scope HFC component R‐134a tolling operations (either as the toller or as
the tollee), please contact David Boyland at (202)708‐4725 before completing this section of the
questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2013
2014
2015
0
0
0
0
0
0
2
Net sales values:
Commercial sales
3
Cost of goods sold (COGS):
Primary raw materials
Direct labor
Other factory costs4
0
0
0
0
0
0
0
0
0
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Selling, general, and administrative (SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
Include only relevant revenue items (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
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. Commercial sales quantities and commercial sales values reported here will be
populated from data entered into question V‐7a.
3 COGS (whether for domestic or export sales) should include costs associated with open market sales only. Costs associated with input
purchases from related suppliers should be consistent with and based on information in the firm’s accounting books and records.
4
Please report relevant by‐product revenue as an offset to other factory costs, as opposed to a component of other income.
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’/Blenders'/Reclaimers Questionnaire – HFC Blends and Components from China (F)
Page 78
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/hydrofluorocarbon_blends_and_co
mponents_china/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: 1279
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Please note that submitting your questionnaire by e‐mail may subject
your firm’s business proprietary information to transmission over an unsecure environment and to
possible disclosure. If you choose this option, the Commission warns you that any risk involving possible
disclosure of such information is assumed by the submitter and not by the Commission.
If your firm does not produce or reclaim HFC blends, HFC components, and/or other refrigerant blends
in the United States, 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 | Microsoft Word - US producer q- HFC China (Final) |
| Author | joanna.lo |
| File Modified | 2016-04-06 |
| File Created | 2016-04-06 |