16-1-3492 U.S. Producers Questionnaire

OMB No. 3117-0016/USITC No. 16-1-3492; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN CARBON AND ALLOY STEEL CUT-TO-LENGTH PLATE (“CTL PLATE”)
FROM AUSTRIA, BELGIUM, BRAZIL, CHINA, FRANCE, GERMANY,
ITALY, JAPAN, KOREA, SOUTH AFRICA, TAIWAN, AND TURKEY
This questionnaire must be received by the Commission by April 22, 2016
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning CTL plate from Austria, Belgium,
Brazil, China, France, Germany, Italy, Japan, Korea, South Africa, Taiwan, and Turkey (Inv. Nos. 701-TA-559-561 and 731TA-1317-1328 (Preliminary)). The information requested in the questionnaire is requested under the authority of the
Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other
order to compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced CTL plate (as defined on next page) at any time since January 1, 2013?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: CTLP)
CERTIFICATION

I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise. I, the undersigned, acknowledge that information submitted in response to
this request for information and throughout this investigation or other proceeding may be disclosed to and used:
(i) by the Commission, its employees and Offices, and contract personnel (a) for developing or maintaining the records of this or a
related proceeding, or (b) in internal investigations, audits, reviews, and evaluations relating to the programs, personnel, and
operations of the Commission including under 5 U.S.C. Appendix 3; or (ii) by U.S. government employees and contract personnel,
solely for cybersecurity purposes. I understand that all contract personnel will sign appropriate nondisclosure agreements
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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PART I.--GENERAL INFORMATION
Background. This proceeding was instituted in response to petitions filed on April 8, 2016, by
ArcelorMittal USA LLC (Chicago, Illinois), Nucor Corporation (Charlotte, North Carolina), and SSAB
Enterprises, LLC (Lisle, Illinois). Countervailing and/or antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes affirmative determinations of
injury, threat, or material retardation, and if the U.S. Department of Commerce makes affirmative
determinations of subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available at
https://www.usitc.gov/investigations/701731/2016/carbon_and_alloy_steel_cut_to_length_plate_austr
ia/preliminary.htm.
CTL plate covered by these investigations is certain carbon and alloy steel hot-rolled or forged flat plate
products not in coils, whether or not painted, varnished, or coated with plastics or other non-metallic
substances. Subject merchandise includes plate that is produced by being cut-to-length from coils and
plate that is rolled or forged into a discrete length. The products covered include (1) Universal mill plates
(i.e., flat-rolled products rolled on four faces or in a closed box pass, of a width exceeding 150 mm but
not exceeding 1250 mm, and of a thickness of not less than 4 mm, which are not in coils and without
patterns in relief), and (2) hot-rolled or forged flat steel products of a thickness of 4.75 mm or more and
of a width which exceeds 150 mm and measures at least twice the thickness, and which are not in coils,
whether or not with patterns in relief. The covered products described above may be rectangular,
square, circular or other shapes and include products of either rectangular or non-rectangular crosssection where such non-rectangular cross-section is achieved subsequent to the rolling process, i.e.,
products which have been ‘‘worked after rolling’’, (e.g., products which have been beveled or rounded
at the edges).
For purposes of the width and thickness requirements referenced above, the following rules apply:
(1) where the nominal and actual measurements vary, a product is within the scope if application of
either the nominal or actual measurement would place it within the scope based on the definitions set
forth above unless the product is already covered by an existing order (e.g., orders on hot-rolled flatrolled steel); and
(2) where the width and thickness vary for a specific product (e.g., the thickness of certain products with
non-rectangular cross-section, the width of certain products with non-rectangular shape, etc.), the
measurement at its greatest width or thickness applies.
Steel products included in the scope of these investigations are products in which: (1) iron
predominates, by weight, over each of the other contained elements; and (2) the carbon content is 2
percent or less by weight.
Subject merchandise includes cut-to-length plate that has been further processed in a third country,
including but not limited to pickling, oiling, levelling, annealing, tempering, temper rolling, skin passing,
painting, varnishing, trimming, cutting, punching, beveling, and/or slitting, or any other processing that
would not otherwise remove the merchandise from the scope of the investigation if performed in the
country of manufacture of the cut-to-length plate.

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All products that meet the written physical description are within the scope of these investigations
unless specifically excluded or covered by the scope of an existing order. The following products are
outside of, and/or specifically excluded from, the scope of these investigations:
(1) products clad, plated, or coated with metal, whether or not painted, varnished or coated with plastic
or other non-metallic substances;
(2) military grade armor plate made to a domestic (e.g., MIL-DTL, MIL-S, NAV-SEA) or foreign (e.g., IDF,
CMS, Def-Stan 95) armor plate specification;
(3) stainless steel plate, containing 10.5 percent or more of chromium by weight.
(4) CTL plate meeting the requirements of ASTM A-829, Grade E 4340 that are over 12 inches (305 mm)
thick.
(5) Alloy forged and rolled CTL plate greater than or equal to 6 inches (152.4 mm) thick meeting each of
the following requirements:
(a) Electric Furnace melted, Ladle Refined & Vacuum degassed and having a chemical
composition (expressed in weight percentages):
•
•
•
•
•
•
•
•
•
•
•
•

Carbon 0.23-0.28,
Silicon 0.05-0.20,
Manganese 1.20-1.60,
Nickel not greater than 1.0,
Sulfur not greater than 0.007,
Phosphorus not greater than 0.020,
Chromium 1.0-2.5,
Molybdenum 0.35-0.8,
Boron 0.002-0.004,
Oxygen not greater than 20 ppm,
Hydrogen not greater than 2 ppm,
Nitrogen not greater than 60 ppm.

(b) With a Brinell hardness measured in all parts of the product including mid thickness in the
range of:
(i) 270-300 HBW,
(ii) 290-320 HBW, or
(iii) 320-350 HBW;
(c) Having cleanliness in accordance with ASTM E45 method A (Thin and Heavy): A not exceeding
1.5, B not exceeding 1.0, C not exceeding 0.5, D not exceeding 1.5; and
(d) Conforming to ASTM A578-S9 ultrasonic testing requirements with acceptance criteria 2 mm
flat bottom hole.

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(6) Alloy forged and rolled steel CTL plate over 16 inches (407 mm) in thickness and meeting the
following requirements:
Made from Electric Arc Furnace melted, Ladle refined & vacuum degassed, alloy steel with
the following chemical composition (expressed in weight percentages):
•
•
•
•
•
•
•
•
•
•
•
•

Carbon 0.23-0.28,
Silicon 0.05-0.15,
Manganese 1.2-1.50,
Nickel not greater than 0.4,
Sulfur not greater than 0.010,
Phosphorus not greater than 0.020,
Chromium 1.2-1.5,
Molybdenum 0.35-0.55,
Boron 0.002-0.004,
Oxygen not greater than 20 ppm,
Hydrogen not greater than 2 ppm, and
Nitrogen not greater than 60 ppm;

(b) Having cleanliness in accordance with ASTM E45 method A (Thin and Heavy): A not
exceeding 1.5, B not exceeding 1.5, C not exceeding 1.0, D not exceeding 1.5;
(c) Having the following mechanical properties:
(i)

With a Brinell hardness not more than 237 HBW measured in all parts of the
product including mid thickness; and having a Yield Strength of 75ksi min and
UTS 95ksi or more, Elongation of 18% or more and Reduction of area 35% or
more; having charpy V at -75 degrees F in the longitudinal direction equal or
greater than 15 ft. lbs (single value) and equal or greater than 20 ft. lbs (average
of 3 specimens) and conforming to the requirements of NACE MR01-75; or

(ii)

With a Brinell hardness not less than 240 HBW measured in all parts of the
product including mid thickness; and having a Yield Strength of 90 ksi min and
UTS 110 ksi or more, Elongation of 15% or more and Reduction of area 30% or
more; having charpy V at -40 degrees F in the longitudinal direction equal or
greater than 21 ft. lbs (single value) and equal or greater than 31 ft. lbs (average
of 3 specimens);

(d) Conforming to ASTM A578-S9 ultrasonic testing requirements with acceptance criteria 3.2
mm flat bottom hole; and
(e) Conforming to magnetic particle inspection in accordance with AMS 2301.

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(7) Alloy forged and rolled steel CTL plate over 16 inches (407 mm) in thickness and meeting the
following requirements:
(a) Made from Electric Arc Furnace melted, Ladle refined & vacuum degassed, alloy steel with
the following chemical composition (expressed in weight percentages):
•
•
•
•
•
•
•
•
•
•
•
•
•

Carbon 0.25-0.30,
Silicon not greater than 0.25,
Manganese not greater than 0.50,
Nickel 3.0-3.5,
Sulfur not greater than 0.010,
Phosphorus not greater than 0.020,
Chromium 1.0-1.5,
Molybdenum 0.6-0.9,
Vanadium 0.08 to 0.12
Boron 0.002-0.004,
Oxygen not greater than 20 ppm,
Hydrogen not greater than 2 ppm, and
Nitrogen not greater than 60 ppm.

(b) Having cleanliness in accordance with ASTM E45 method A (Thin and Heavy): A not
exceeding 1.0(t) and 0.5(h), B not exceeding 1.5(t) and 1.0(h), C not exceeding 1.0(t) and 0.5(h),
and D not exceeding 1.5(t) and 1.0(h);
(c) Having the following mechanical properties: A Brinell hardness not less than 350 HBW
measured in all parts of the product including mid thickness; and having a Yield Strength of
145ksi or more and UTS 160ksi or more, Elongation of 15% or more and Reduction of area 35%
or more; having charpy V at -40 degrees F in the transverse direction equal or greater than 20 ft.
lbs (single value) and equal or greater than 25 ft. lbs (average of 3 specimens);
(d) Conforming to ASTM A578-S9 ultrasonic testing requirements with acceptance criteria 3.2
mm flat bottom hole; and
(e) Conforming to magnetic particle inspection in accordance with AMS 2301.
At the time of the filing of the petitions, there was an existing antidumping duty order on certain cut-tolength carbon-quality steel plate products from Korea. See Notice of Final Determination of Sales at
Less Than Fair Value: Certain Cut-To-Length Carbon-Quality Steel Plate Products from Korea, 64 Fed.
Reg. 73,196 (Dep’t Commerce Dec. 29, 1999), as amended, 65 Fed. Reg. 6,585 (Dep’t Commerce Feb 10,
2000) (“1999 Korea AD Order”). The scope of the antidumping duty investigation with regard to CTL
plate from Korea covers only (1) subject CTL plate not within the physical description of cut-to-length
carbon quality steel plate in the 1999 Korea AD Order, regardless of producer or exporter; and (2) CTL
plate produced and/or exported by those companies that were excluded or revoked from the 1999
Korea AD Order as of April 8, 2016. Those revoked or excluded companies are POSCO and any POSCO
affiliates.

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At the time of the filing of the petitions, there was an existing countervailing duty order on certain cutto-length carbon-quality steel plate from Korea. See Final Affirmative Countervailing Duty
Determination: Certain Cut-to-Length Carbon-Quality Steel Plate From the Republic of Korea, 64 Fed.
Reg. 73,176 (Dep’t Commerce Dec. 29, 1999), as amended, 65 Fed. Reg. 6,587 (Dep’t Commerce Feb. 10,
2000) (“1999 Korea CVD Order”). The scope of the countervailing duty investigation with regard to CTL
plate from Korea covers only (1) subject CTL plate not within the physical description of cut-to-length
carbon quality steel plate in the 1999 Korea CVD Order regardless of producer or exporter, and (2) CTL
plate produced and/or exported by those companies that were excluded or revoked from the 1999
Korea CVD Order as of April 8, 2016. Those revoked or excluded companies are POSCO and any POSCO
affiliates.
Excluded from the scope of the antidumping duty investigation on CTL plate from China are any
products covered by the existing antidumping duty order on certain cut-to-length carbon steel plate
from China. See Suspension Agreement on Certain Cut-to-Length Carbon Steel Plate From the People’s
Republic of China; Termination of Suspension Agreement and Notice of Antidumping Duty Order, 68
Fed. Reg. 60,081 (Dep’t Commerce Oct. 21, 2003), as amended, Affirmative Final Determination of the
Antidumping Duty Order on Certain Cut-to-Length Carbon Steel Plate From the People’s Republic of
China, 76 Fed. Reg. 50,996, 50,996-97 (Dep’t of Commerce Aug. 17, 2011).
The products subject to these investigations are currently classified in the Harmonized Tariff Schedule of
the United States (HTSUS) under item numbers: 7208.40.3030, 7208.40.3060, 7208.51.0030,
7208.51.0045, 7208.51.0060, 7208.52.0000, 7211.13.0000, 7211.14.0030, 7211.14.0045, 7225.40.1110,
7225.40.1180, 7225.40.3005, 7225.40.3050, 7226.20.0000, and 7226.91.5000. 1
The products subject to the investigations may also enter under the following HTSUS item numbers:
7208.40.6060, 7208.53.0000, 7208.90.0000, 7210.70.3000, 7210.90.9000, 7211.19.1500, 7211.19.2000,
7211.19.4500, 7211.19.6000, 7211.19.7590, 7211.90.0000, 7212.40.1000, 7212.40.5000, 7212.50.0000,
7214.91.0015, 7214.91.0060, 7214.91.0090, 7225.40.5110, 7225.40.5130, 7225.40.5160, 7225.40.7000,
7225.99.0010, 7225.99.0090, 7226.91.0500, 7226.91.1530, 7226.91.1560, 7226.91.2530, 7226.91.2560,
7226.91.7000, 7226.91.8000, and 7226.99.0180.
The HTSUS subheadings above are provided for convenience and customs purposes only. The written
description of the scope of the investigations is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.

1

Effective January 1, 2016, HTS subheading number 7225.40.1115 and 7225.40.1190 were discontinued and
were replaced by HTS subheading 7225.40.1180.

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Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of CTL plate and your responses to the questions in Part I of the
producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for use
in connection with (and only in connection with) its requirement pursuant to section 702(c)(4)/732(c)(4)
of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning the extent of
industry support for the petition requesting this proceeding. Any information provided to Commerce
will be transmitted under the confidentiality and release guidelines set forth above. Your response to
these questions constitutes your consent that such information be provided to Commerce under the
conditions described above.

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U.S. Producers’ Questionnaire - CTL plate
I-1a.

Page 8

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes

I-2.

No

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment” – Each facility of a firm involved in the production of CTL plate, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

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U.S. Producers’ Questionnaire - CTL plate
I-3.

Page 9

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

Support

Oppose

Take no position

Austria (AD)
Belgium (AD)
Brazil (AD)
Brazil (CVD)
China (AD)
China (CVD)
France (AD)
Germany (AD)
Italy (AD)
Japan (AD)
Korea (AD)
Korea (CVD)
South Africa (AD)
Taiwan (AD)
Turkey (AD)
I-4.

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

Firm name

Yes--List the following information.

Address

Extent of
ownership
(percent)

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U.S. Producers’ Questionnaire - CTL plate
I-5.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing CTL plate from Austria, Belgium, Brazil, China, France,
Germany, Italy, Japan, Korea, South Africa, Taiwan, and/or Turkey into the United States or that
are engaged in exporting CTL plate from Austria, Belgium, Brazil, China, France, Germany, Italy,
Japan, Korea, South Africa, Taiwan, and/or Turkey to the United States?
No
Firm name

I-6.

Page 10

Yes--List the following information.
Address

Affiliation

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

Yes--List the following information.
Address

Affiliation

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Mary Messer (202-205-3193,
[email protected]) or Carolyn Carlson (202-205-3002, [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 CTL plate since January 1, 2013.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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II-3a.

Page 12

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce CTL plate, 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.
Quantity (in short tons)
Calendar years
Item

2013

2014

2015

Overall production capacity:
CTL plate (mill product)
CTL plate (cut from coil)1
Production of:
CTL plate produced in a mill (A)
CTL plate cut from coil (B)1
Total CTL plate production (C)

0

0

0

0

0

0

2

Other products (D)
Total (E)
1
2

This product refers to plate cut from coil by your firm as a processor.
Please identify these products:
.

RECONCILIATION OF PRODUCTION.-Calendar years

Reconciliation
A + B - H = should equal zero, if not
revise prior to submission.

2013

2014

0

2015

0

0

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II-3b.

Operating parameters.--The production capacity reported in II-3a is based on operating
per week,
weeks per year.

II-3c.

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

II-3d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity, including whether constraints relate to mill equipment or cutting line
equipment.

II-3e.

Product shifting.-(i)

Is your firm able to switch production (capacity) between CTL plate and other products using
the same equipment and/or labor?
No

(ii)

hours

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

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

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II-4.

Page 14

Tolling.--Since January 1, 2013, has your firm been involved in a toll agreement regarding the
production of CTL plate?
“Toll agreement” – Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No

II-5.

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

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

(a)

“Foreign trade zone” – a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No

Yes--Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import CTL plate into a foreign trade zone (FTZ) for use in distribution of CTL plate
and/or the production of downstream articles?

(b)

No/Don’t know

II-6.

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2013, has your firm imported CTL plate?
“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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U.S. Producers’ Questionnaire - CTL plate
II-7.

Page 15

Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of CTL plate in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm.
“Transfers to related firms” – Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” – A firm that your firm solely or jointly owns, manages, or otherwise controls.
Such transactions are valued at fair market value.
“Export shipments” – Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories” – Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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U.S. Producers’ Questionnaire - CTL plate

Page 16

Production, shipment and inventory data.--Continued

II-7.

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

2013

2014

2015

1

Average production capacity (quantity) (F)
Beginning-of-period inventories (quantity)
(G)
Production (quantity) (H)
U.S. shipments:
Commercial shipments:
Quantity (I)
Value (J)
Internal consumption:
Quantity (K)
2

Value (L)
Transfers to related firms:
Quantity (M)
2

Value (N)
Export shipments:
Quantity (O)

3

Value (P)
4

End-of-period inventories (quantity) (Q)
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:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line Q) should be equal to the beginning-of-period inventories (i.e., line G), plus
production (i.e., line H), less total shipments (i.e., lines I, K, M, O). 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
G + H – I – K – M – O – Q = 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
.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
II-8.

Page 17

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2013

2014

2015

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (R)
To end users (quantity) (S)
Calendar years
Reconciliation
R + S – I = zero ("0"), if not revise.

2013

2014
0

2015
0

0

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
II-9.

Page 18

Employment data.--Report your firm’s employment-related data related to the production of
CTL plate 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

2013

2014

2015

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

II-10.

Related firms.--If your firm reported transfers to related firms in question II-7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
II-11.

Page 19

Purchases.--Other than direct imports, has your firm otherwise purchased CTL plate since
January 1, 2013?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” – A transaction to buy from a foreign producer where your firm is the importer
of record or consignee.
No

Yes--Report such purchases below and explain the reasons for your firms'
purchases:

(Quantity in short tons)
Calendar years
Item

2013

2014

2015

Purchases from U.S.
importers1 of CTL plate
from-Austria:
Belgium:
Brazil:
China:
France:
Germany:
Italy:
Japan:
Korea:
South Africa:
Taiwan:
Turkey
All other sources:
Purchases from domestic
producers2
Purchases from other
sources2
1

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
II-12.

Page 20

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 21

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

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

III-2.

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

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

B.1.

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

2.

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

3.

4.

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

III-3.

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 22

III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-5.

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

Share of sales

CTL plate

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CTL plate 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 CTL plate
that your firm purchases from related suppliers and that are reflected in table III-9a. For “Share
of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
your company’s own accounting system, of the purchase cost from the related supplier; e.g., the
related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input

Related supplier

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
III-8.

Page 23

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on CTL plate) in a
manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III-9a.

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U.S. Producers’ Questionnaire - CTL plate

Page 24

III-9a. Operations on CTL plate.--Report the revenue and related cost information requested below on
the CTL plate operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that internal consumption and transfers to related firms must be valued at fair market
value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three most
recently completed fiscal years, and for the specified interim periods. If your firm was involved
in tolling operations (either as the toller or as the tollee), please contact Jennifer Brinckhaus at
(202) 205-3188 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2013

2014

2015

2

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

0

0

0

0

0

0

Total COGS

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 25

III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-9a line item where the nonrecurring items are included, a brief description
of the relevant nonrecurring items, and the associated values (in $1,000), as reflected in table
III-9a; i.e., if an aggregate nonrecurring item has been allocated to table III-9a, only the allocated
value amount included in table III-9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in table III-9a.
Fiscal years ended--

2013

2014

2015

Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in table III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
Value ($1,000)
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

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U.S. Producers’ Questionnaire - CTL plate

Page 26

III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in table III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in table III-9a.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of CTL plate. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for CTL plate in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in table III-9a. Provide data as of
the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item

2013

2014

2015

1

Total assets (net)
1

III-13.

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for CTL plate. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended--

Item

2013

2014

2015

Capital expenditures
Research and development expenses
1

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 27

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
Do these data in question III-9a reconcile with data in question II-7?
Yes

No

If no, please explain.

III-15a. 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 CTL plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea,
South Africa, Taiwan, or Turkey?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

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

Yes

If yes, indicate which country and why:

(please describe)

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U.S. Producers’ Questionnaire - CTL plate

Page 28

III-16a. 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 CTL plate from Austria, Belgium, Brazil, China,
France, Germany, Italy, Japan, Korea, South Africa, Taiwan, or Turkey?
No

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

Lowering of credit rating

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

Other

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

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 29

III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
CTL plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South Africa,
Taiwan, or Turkey?
No

Yes

If yes, my firm anticipates negative effects as follows:

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

Yes

If yes, indicate which country and why:

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.

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U.S. Producers’ Questionnaire - CTL plate

Page 30

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Craig Thomsen (202-2053236, [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.--Hot-rolled CTL carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 96” in width, 0.250”
thick.
Product 2.--Hot-rolled CTL carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 96” in width,
0.3125” thick.
Product 3.--Hot-rolled CTL carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 120” in width,
0.375” through 3.00” in thickness.
Product 4.--Hot-rolled CTL carbon steel plate, high strength low alloy (HSLA), ASTM A-572,
Grade 50, mill edge, not cleaned or oiled, in cut lengths, 72” through 120” in
width, 0.5” through 1.5” in thickness.
Product 5.--Hot-rolled CTL carbon steel plate, API X-70 or equivalent as rolled, mill or cut edge,
not heat treated, not cleaned or oiled, in cut lengths, 72” through 152” in width,
0.375” through 1.0” thick.

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).

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U.S. Producers’ Questionnaire - CTL plate

Page 31

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 as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-2.

Page 32

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.

Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Period of shipment
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:

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-2.

Page 33

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
(Quantity in short tons, value in dollars)
Product 4
Quantity
Value

Product 5
Period of shipment
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:

Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-3.

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

IV-4.

Contracts

Other

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced CTL plate?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic CTL plate usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 34

F.o.b.

If f.o.b., specify point

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

Share of 2015
sales

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

Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-7.

Page 35

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

No

Not applicable
IV-8.

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 CTL plate?

Source

Share of 2015
sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Lead time (days)

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-9.

Page 36

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced CTL
plate that is accounted for by U.S. inland transportation costs?
percent

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(c)

Indicate the approximate percentage of your firm’s sales of CTL plate 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 CTL plate since January 1, 2013 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

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IV-11. End uses.--List the end uses of the CTL plate that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by CTL plate and other inputs?
Share of total cost of end use product
accounted for by
End use product

CTL plate

Total
(should sum to
100.0% across)

Other inputs
%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Substitutes.--Can other products be substituted for CTL plate?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for CTL plate?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for CTL plate has changed since January 1, 2013. Explain any trends and
describe the principal factors that have affected these changes in demand.

Market
Within
the United
States
Outside
the United
States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of CTL plate since January 1, 2013?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a) Is the CTL plate market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to CTL plate? If yes,
describe.
Check all that apply.

Please describe.

No

Skip to question IV-16.

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
CTL plate since January 1, 2013?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply CTL plate 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.

IV-17. Raw materials.--How have CTL plate raw materials prices 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 CTL
plate.

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IV-18. Interchangeability.--Is CTL plate 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
Other
countries1

Mexico

Canada

Turkey

Taiwan

South
Africa

Korea1

Japan

Italy

Germany

France

China

Brazil

Belgium

Austria

Country-pair
United States
Austria
Belgium
Brazil
China
France
Germany
Italy
Japan
Korea1
South Africa
Taiwan
Turkey
Canada
Mexico

For any country-pair producing CTL plate that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

1

Korea include product from POSCO for all products, and other producers for high alloy plates,
Other countries includes Korean producers other than POSCO for products other than high alloy
plates.

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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 CTL plate 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

Other
countries1

Mexico

Canada

Turkey

Taiwan

South
Africa

Korea1

Japan

Italy

Germany

France

China

Brazil

Belgium

Austria

Country-pair
United States
Austria
Belgium
Brazil
China
France
Germany
Italy
Japan
Korea1
South Africa
Taiwan
Turkey
Canada
Mexico

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

1

Korea include product from POSCO for all products, and other producers for high alloy plates,
Other countries includes Korean producers other than POSCO for products other than high alloy
plates.

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IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for CTL plate since January 1, 2013. Indicate the share of the quantity of your firm’s
total shipments of CTL plate that each of these customers accounted for in 2015.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2015
sales
(%)

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IV-21. Competition from imports
(a)

Lost revenue.--Since January 1, 2013: To avoid losing sales to competitors selling CTL
plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South
Africa, Taiwan, and Turkey, did your firm:
No
Yes
Reduce prices
Roll back announced price increases

(b)

Lost sales.--Since January 1, 2013: Did your firm lose sales of CTL plate to imports of this
product from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South
Africa, Taiwan, and Turkey?
No

(c)

Yes

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

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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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/carbon_and_alloy_steel_cut_to_len
gth_plate_austria/preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.--Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: CTLP

• E-mail.--E-mail the MS Word questionnaire to [email protected] and [email protected]
; include a scanned copy of the signed certification page (page 1). Submitters are strongly encouraged to
encrypt nonpublic documents that are electronically transmitted to the Commission to protect your
sensitive information from unauthorized disclosure. The USITC secure drop-box system and the Electronic
Document Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2
cryptographic algorithms to encrypt data in transit. Submitting your nonpublic documents by a means
that does not use these encryption algorithms (such as by email) may subject your firm’s nonpublic
information to unauthorized disclosure during transmission. If you choose a non-encrypted method of
electronic transmission, the Commission warns you that the risk of such possible unauthorized disclosure
is assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.--If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.