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pdfOMB No. 3117‐0016/USITC No. 16‐1‐3503; Expiration Date: 6/30/2017
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U.S. PRODUCER & TABLETER QUESTIONNAIRE
CHLORINATED ISOCYANURATES FROM CHINA AND SPAIN
This questionnaire must be received by the Commission by June 21, 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 review of the antidumping duty orders concerning chlorinated isocyanurates (“chlorinated isos”)
from China and Spain (Inv. Nos. 731‐TA‐1082‐1083 (Second Review)). 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 chlorinated isos (as defined on the next page) in either powder, granular or tablet form
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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: NACL)
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 or reviews
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
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 2
PART I.—GENERAL INFORMATION
Background. On June 25, 2005, the Department of Commerce issued antidumping duty orders on
imports of chlorinated isos from China and Spain. On September 1, 2015, the Commission instituted a
review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine
whether revocation of the orders would be likely to lead to continuation or recurrence of material injury
to the domestic industry within a reasonably foreseeable time. If both the Commission and Commerce
make affirmative determinations, the orders will remain in place. If either the Commission or
Commerce makes negative determinations, the Department of Commerce will revoke the orders.
Questionnaires and other information pertinent to this proceeding are available at:
https://www.usitc.gov/investigations/701731/2015/chlorinated_isocyanurates_china_and_spain/second_review_full.htm
Chlorinated Isocyanurates (“chlorinated isos”): Chlorinated isos, which are derivatives of cyanuric acid,
described as chlorinated s‐triazine triones. There are three primary chemical compositions of
chlorinated isos:
(1) Trichloroisocyanuric acid (Cl3(NCO)3),
(2) sodium dichloroisocyanurate (dihydrate) (NaCl2(NCO)3(2H2O)), and
(3) sodium dichloroisocyanurate (anhydrous) (NaCl2(NCO)3).
Chlorinated isos are available in powder, granular, and tableted forms. The orders cover all chlorinated
isos.
Reporting of information.‐‐ If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all of your 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.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
I‐1.
Page 3
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‐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 chlorinated isos, 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:
I‐3.
Position regarding continuation of order.‐‐Does your firm support or oppose continuation of
the antidumping duty orders currently in place for chlorinated isos from the following countries?
Country
Support
Oppose
Take no position
China
Spain
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
I‐4.
Page 4
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Extent of
ownership
(percent)
Address
I‐5.
Related SUBJECT importers/exporters.‐‐Does your firm have any related firms, either domestic
or foreign, that are engaged in importing chlorinated isos from China or Spain into the United
States or that are engaged in exporting chlorinated isos from China or Spain to the United
States?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
I‐6.
Related NONSUBJECT importers/exporters.‐‐Does your firm have any related firms, either
domestic or foreign, that are engaged in importing chlorinated isos from countries other than
China and Spain into the United States or that are engaged in exporting chlorinated isos from
countries other than China and Spain to the United States?
No
Yes‐‐List the following information.
Firm name and country
Address
Affiliation
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
I‐7.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of chlorinated isos?
No
Yes‐‐List the following information.
Firm name
I‐8.
Page 5
Address
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for chlorinated isos?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Chris Cassise (202‐708‐5408,
[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 chlorinated isos since January 1, 2013.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
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’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
II‐3.
Page 7
Same equipment, machinery, and workers for granules/powder or tablets &
product shifting.‐‐Has your firm since 2013 produced, or does your firm anticipate producing in
the future, other products on the same equipment and machinery used in the production of
granular/powder or tableted chlorinated isos and/or using the same production and related
workers employed to produce granular/powder or tableted chlorinated isos?
No Yes‐‐Granules/powder (respond below) Yes‐‐Tablets (respond below)
If you checked “yes” (meaning that your firm is able to switch production between
granuler/powder and other products or between tableted chlorinated isos and other product
using the same equipment and labor), please identify the other products, the approximate time
and cost involved in switching, and the minimum relative price change required for your firm to
switch production to or from granular/powder or tableted chlorinated isos.
II‐4.
Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐5.
Type of operation.‐‐Since January 1, 2013, which of the following activity is your firm involved in
the production of chlorinated isos (check all that apply)?
Bulk granules/powder
Tablets
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
II‐6.
Page 8
Tolling.‐‐Since January 1, 2013, has your firm been involved in a toll agreement regarding the
production of chlorinated isos?
II‐7.
II‐8.
A “toll agreement” is defined as an agreement between two firms whereby the first firm
furnishes the raw materials and the second firm uses the raw materials to produce a product
that it then returns to the first firm with a charge for processing costs, overhead, etc.
No
Yes‐‐Name firm(s):
.
If yes, check all that apply:
Your firm is a tollee (i.e., contracts out for the tableting production of chlorinated isos and
retains ownership or title to the raw materials).
Your firm is a toller (i.e., produces tableted chlorinated isos under a service contract for
other firm(s) and does not possess ownership or title to the raw
materials).
IF YOUR FIRM IMPORTS GRANULAR/POWDER CHLORINATED ISOS THAT IS TABLETED UNDER A
TOLLING ARRANGEMENT WITH A THIRD PARTY IN THE UNITED STATES, REPORT YOUR
SHIPMENTS AND SALES OF THE TOLL‐PRODUCED TABLETS IN YOUR U.S. IMPORTERS’
QUESTIONNAIRE. THE TOLL PRODUCER SHOULD COMPLETE THOSE PARTS OF THIS U.S.
PRODUCERS’/TABLETERS’ QUESTIONNAIRE ASSOCIATED WITH ITS TOLL PRODUCTION.
Foreign trade zone.‐‐Does your firm produce chlorinated isos in a foreign trade zone (FTZ)?
No
Yes‐‐Identify FTZ(s):
.
Direct imports.‐‐Since January 1, 2013, has your firm imported chlorinated isos?
“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
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 9
Definitions
Chlorinated Isos:
Granular/powder.‐‐includes both trichloroisocyanuric acid or “trichlor,” which has
approximately 90 percent available chlorine, and sodium dichloroisocyanurate or “dichlor” both
in anhydrous form, with approximately 62 to 63 percent available chlorine, and in dihydrate
form, with approximately 55.0 to 57.1 percent available chlorine.
Tablets.‐‐Multi‐function tablets and sticks made from trichlor or dichlor. Some tablets may
contain additives including algaecides, clarifiers or other materials.
Establishment.‐‐Each facility of a firm involved in the production, importation, and/or purchase of
chlorinated isos (as defined above), including auxiliary facilities operated in conjunction with (whether
or not physically separate from) such facilities.
“Average production capacity” or “capacity” is defined as 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” is defined as all production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Toll agreement” is defined as an 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.
U.S. shipments of chlorinated isos are divided into: (1) U.S. commercial shipments, (2) internal
consumption, (3) transfers to related firms within the United States, and (3) shipped for toll conversion.
“U.S. commercial shipments” are defined as shipments made within the United States as a result of an
arm’s length commercial transaction in the ordinary course of business. The value of a reported U.S.
commercial shipment should be 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” is defined as product consumed internally by your firm.
“Transfers to related firms” are defined as shipments made to related domestic firms. Such transactions
are valued at fair market value.
“Related firm” is defined as a firm that your firm solely or jointly owns, manages, or otherwise
controls. Such transactions are valued at fair market value.
“Shipped for toll conversion” is defined as shipments of granular/powder chlorinated isos to a toller for
conversion into tableted chlorinated isos under a toll agreement.
“Export shipments” are defined as shipments to destinations outside the United States, including
shipments to related firms.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
II‐9.
Page 10
GRANULAR/POWDER CHLORINATED ISOS.‐‐Report your firm’s production capacity, production,
shipments, and inventories to the production of all granular/powder chlorinated isos in its U.S.
establishment(s). Include both production of trichlor or dichlor chlorinated isos. Do not report
data on repackaging and/or resales.
Quantity (in short tons) 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)
U.S. shipments of granular/powder chlorinated isos:
Commercial shipments2
Quantity of commercial shipments (D)
Value of commercial shipments (E)
Shipped for toll conversion:
Quantity of merchandise shipped for tolling (J)
Value of merchandise shipped for tolling (K)
Value tolling fee contracted/paid (L)
Export shipments of granular/powder chlorinated
isos:7
Quantity of export shipments (M)
Value of export shipments (N)
End‐of‐period inventories (quantity) (O)
3
Internal consumption
Quantity of internal consumption (F)
4
Value of internal consumption (G)
5
Transfers to related firms:
Quantity of transfers (H)
4
Value of transfers (I)
6
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
Commercial shipments (row D) in this table are understood to relate to arms‐length sales of chlorinated isos in
powder and/or granular form.
3
Internal consumption (row F) in this table is understood to relate to any powder and/or granular chlorinated isos
used in your firm’s internal processes, including further downstream processing into tableted product.
4
Internal consumption (row G) and transfers to related firms (row I) 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.):
5
Transfers to related firms (row H) is understood to be merchandise shipped to related firms but which is not subject
to a toll arrangement.
6
Merchandise shipped for toll conversion (row J) is understood to be related to any powder/granular chlorinated isos
your firm ships to a third party (related or not) for conversion into tablets under a toll arrangement.
7
Identify your firm’s principal export markets:
.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
II‐9.
Page 11
GRANULAR/POWDER CHLORINATED ISOS.‐‐Continued
RECONCILATION INVENTORIES, SHIPMENT, AND PRODUCTION.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line O) 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, J, and M). 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 the differences (e.g., theft, loss, damage,
record systems issues, etc.)
Calendar years
Reconciliation item
2013
B + C – D – F – H – J – M ‐ O should = zero ("0")
1
2014
0
2015
0
0
1
Reason for inventories, production and shipment data not balancing if reconciliation line not returning zero ("0"):
.
II‐10. TABLETED CHLORINATED ISOS.‐‐Report your firm’s production capacity, production, shipments,
and inventories related to the production of all tableted chlorinated isos (including trichlor
tablets, dichlor tablets, and blended tablets) in its U.S. establishment(s). Do not report data on
repackaging and/or resales.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
1
2013
2014
2015
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity) (B)
Production of tablets:
From internally produced granular/powder isos (C)
From purchases of U.S.‐produced granular/powder
chlorinated isos) (D)
From imported granular/powder chlorinated isos (E)
From granular/powder chlorinated isos that was
transferred to your firm pursuant to a toll
arrangement (F)2
Finished tablets returned to tollee by toller (quantity)
(G)3
0
0
0
Total available for shipment
Table continued next page.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 12
II‐10. TABLETED CHLORINATED ISOS.‐‐Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2013
U.S. shipments of tableted isos:
Commercial shipments:
Quantity (H)
2014
2015
Export shipments of tableted:
Quantity of export shipments (P)
Value of export shipments (Q)
Value (I)
Internal consumption:
Quantity (J)
4
Value (K)
Transfers to related firms:
Quantity (L)
4
Value (M)
Toll production returned:
Quantity shipped back to tollee (N)
Value fee(s) received for returned tablets (O)
5
End‐of‐period inventories (quantity) (R)
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
Report the data here for tablets your firm produced under a toll arrangement (your are the toller) for which you are
receiving a fee your production services. To the degree to which the product is shipped back to the tollee within the
period of production those data should also be reported in line N of this data table.
3
Report the data here for tablets your firm received under a toll arrangement for which you paid a third party to
convert into tablets. Any sales or shipments of the tablets into the market should be reported under commercial
shipments, internal consumption, or transfers to related firms (e.g., not under "toll production returned).
4
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above:
5
Identify your firm’s principal export markets:
.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 13
II‐10. TABLETED CHLORINATED ISOS.‐‐Continued
RECONCILATION INVENTORIES, SHIPMENT, AND PRODUCTION.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line R) should be equal to the beginning‐of‐period inventories (i.e., line
B), plus production (i.e., line C, D, E, and F), plus tableted isos that you had toll produced and returned to
your firm prior to shipment to a customer (i.e., G) less total shipments (i.e., lines H, J, L, N, and P).
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 the differences (e.g.,
theft, loss, damage, record systems issues, etc.)
Calendar years
Reconciliation item
B + C + D + E + F + G – H – J – L – N – P – R
should = zero ("0")1
2013
2014
0
2015
0
0
1
Reason for inventories, production and shipment data not balancing if reconciliation line not returning zero ("0"):
.
II‐11. Related firms.‐‐If your firm reported transfers to related firms in question II‐9 or II‐10, 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.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 14
II‐12. Channels of Distribution.—
a.
Granular/powder form.‐‐Report your firm’s total U.S. commercial shipments of
granular/powder form chlorinated isos, by channel of distribution from its U.S.
establishment(s) during the specified periods.
Quantity (in short tons)
Calendar years
Item
2013
2014
2015
Channels of distribution for commercial U.S. shipments of GRANULAR/POWDER chlorinated isos:
To distributors (quantity)
To repackers/tableters (quantity)
To retailers (quantity)
To industrial market (quantity)
0
0
0
Total U.S. commercial shipments
RECONCILATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., above) in each time period equal the quantities reported for commercial U.S. shipments from
question II‐9 (i.e., line D) in each time period. The calculated fields test this reconciliation. If the
calculated fields below return values other than zero (i.e., “0”), the data in question II‐9 or II‐11a need to
be revised prior to submission to the Commission.
Calendar years
Reconciliation item
Should equal to zero (revise data in II‐9 or
II‐11a if not zero)
2013
2014
0
2015
0
0
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 15
II‐12. Channels of Distribution.—
b.
Tablets.‐‐Report your firm’s total U.S. commercial shipments of tableted chlorinated
isos, by channel of distribution from its U.S. establishment(s) during the specified
periods.
Quantity (in short tons)
Calendar years
Item
2013
2014
2015
Channels of distribution for commercial U.S. shipments of TABLETED chlorinated isos:
To distributors (quantity)
To repackers (quantity)
To retailers (quantity)
To industrial market (quantity)
0
0
0
Total U.S. commercial shipments
RECONCILATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., above) in each time period equal the quantities reported for commercial U.S. shipments from
question II‐10 (i.e., line H) in each time period. The calculated fields test this reconciliation. If the
calculated fields below return values other than zero (i.e., “0”), the data in question II‐10 or II‐11b need
to be revised prior to submission to the Commission.
Calendar years
Reconciliation item
Should equal to zero (revise data in II‐10
or II‐11b if not zero)
2013
2014
0
2015
0
0
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 16
II‐13. Employment Data.‐‐Report your firm’s total number of production‐related workers, hours
worked, and wages paid to production workers of chlorinated isos, at its U.S. establishment(s)
during the specified periods.
“Production Related Workers” or “PRWs” are defined as production and related workers,
including 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.
“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” is defined as 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):
In relation to granular/powder chlorinated isos operations
In relation to tableted chlorinated isos operations
Hours worked by PRWs (1,000 hours):
In relation to granular/powder chlorinated isos operations
In relation to tableted chlorinated isos operations
Wages paid to PRWs (in 1,000s of dollars):
In relation to granular/powder chlorinated isos operations
In relation to tableted chlorinated isos operations
Note.—If your firm produces both tablets and granular/powder, the employment data reported relating
to "tableted" chlorinated isos should only relate the incremental employees, hours, and wages after the
granular/powder form merchandise was produced.
Business Proprietary
U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 17
II‐14(a). Purchases of GRANULAR/POWDER chlorinated isos.‐‐Other than direct imports, has your firm
otherwise purchased granular/powder chlorinated isos since January 1, 2013?
“Purchase” is defined as 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” is defined as a transaction to buy from a foreign producer where your firm is the
importer of record or consignee. (Note if your firm is an importer, you need to complete the
U.S. importers' questionnaire).
No
Yes‐‐Report such purchases below for the specified periods.1 Your firm must
also complete the U.S. Purchasers’ Questionnaire.
(Quantity in short tons)
Calendar years
Item
2013
2014
2015
2
Purchases from U.S. importers of chlorinated isos from‐‐
China
Spain
All other countries
3
Purchases from domestic suppliers
1
Please indicate your firm’s reasons for purchasing this product. If your firm’s reasons differ by
source, please elaborate.
2
Please list the name of the firm(s) from which your firm purchased this imported product. If your
firm’s suppliers differ by source, please identify the source for each listed supplier.
3 Please list the name of the firm(s) from which your firm purchased this domestically produced
product.
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U.S. Producers’/Tableters’ Questionnaire ‐ Chlorinated Isos from China and Japan (F)
Page 18
II‐14(b). Purchases of TABLETED chlorinated isos.‐‐Other than direct imports, has your firm otherwise
purchased tableted chlorinated isos since January 1, 2013?
“Purchase” is defined as 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” is defined as a transaction to buy from a foreign producer where your firm is the
importer of record or consignee.
No
Yes‐‐Report such purchases below for the specified periods.1 Your firm must
also complete the U.S. Purchasers’ Questionnaire.
(Quantity in short tons)
Calendar years
Item
2013
2014
2015
2
Purchases from U.S. importers of chlorinated isos from‐‐
China
Spain
All other countries
2
Purchases from domestic producers:
2
Purchases from other sources:
1
Please indicate your firm’s reasons for purchasing this product. If your firm’s reasons differ by
source, please elaborate.
2 Please list the name of the firm(s) from which your firm purchased this product. If your firm’s
suppliers differ by source, please identify the source for each listed supplier.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 19
II‐15. Anticipated changes in operations.‐‐Does your firm anticipate any changes in the character of
your firm’s operations or organization (as noted above) relating to the production of chlorinated
isos in the future?
No
Yes‐‐Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce chlorinated isos (in short tons) for 2016 and
2017.
For questions II‐16 to II‐18, if your firm’s response differs for particular orders, please indicate and
explain the particular effect of revocation of specific orders.
II‐16. Anticipated changes in operations in the event the orders are revoked.‐‐Would your firm
anticipate any changes in the character of your firm’s operations or organization (as noted
above) relating to the production of chlorinated isos in the future if the antidumping duty orders
on chlorinated isos from China and Spain were to be revoked?
No
Yes‐‐Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce chlorinated isos (in short tons) for 2016 and
2017.
II‐17. Effect of orders.‐‐Describe the significance of the existing antidumping duty orders covering
imports of chlorinated isos from China and Spain in terms of its effect on your firm’s production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, and asset
values. You may wish to compare your firm’s operations before and after the imposition of the
orders.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 20
II‐18. Likely effect of revocation of orders.‐‐Would your firm anticipate any changes in its production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, or asset values
relating to the production of chlorinated isos in the future if the antidumping duty orders on
chlorinated isos from China and Spain were to be revoked?
No
Yes‐‐Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation for any trends or
projections you may provide.
II‐19. 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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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 21
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202‐205‐3432,
[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 chlorinated isos:
2. Does your firm prepare profit/loss statements for chlorinated isos:
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 product group that includes chlorinated isos, 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.).
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U.S. Producers’ Questionnaire –Chlorinated Isos
III‐4.
Page 22
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 produces in the facilities used to produce
chlorinated isos, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
Share of sales
Granulated/powder chlorinated isos
%
Tableted chlorinated isos
%
%
%
%
III‐6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of chlorinated isos 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 chlorinated
isos 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
the 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
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U.S. Producers’ Questionnaire –Chlorinated Isos
III‐8.
Page 23
Inputs 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 chlorinated isos) in a manner
consistent with the 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.
Explanatory note for questions III‐9a through III‐9d: U.S. firms are requested to report their sales and
costs as follows:
For integrated firms (firms producing granulated and powder with tableting operations):
Question III‐9a.—Granulated/Powder operations only with internal
consumption/transfers of granulated/powder for tableting to be reported in III‐9b.
Question III‐9b.‐‐Tablet operations (including sales by tollees which were toll produced
into tablets by another firm)
U.S. firms that produce chlorinated isos in granular/powder form complete question III‐9a. If
your firm transfers or internally consumes the granular/powder forms for purposes other than
to make a tableted form of chlorinated isos, report the internal consumption/transfers in
question III‐9a.
U.S. firms that produce chlorinated isos in granular/powder form and subsequently performs
tableting, please complete question III‐9b in addition to question III‐9a for the tableting portion
of your operations only. Question III‐9b requests the commercial sales quantity and value of the
tableted material, the transferred‐in raw material costs of the granulated product, and the
incremental costs of producing the tableted material.
For tableters (firms with only tableting operations)
Question III‐9c.‐‐Tablet operations for own account
Question III‐9d.—Tablet operations when done as a toller (converting into tablets
another firm's granular/powder isos).
For independent tableters: U.S. firms that produce and sell commercially chlorinated isos in
tablet form from purchased granular chlorinated isos, complete question III‐9c. Do not include
any data related to your firm’s repackaging operations.
For tollers :U.S. firms that toll‐process granular chlorinated isos to produce tableted chlorinated
isos for a fee from tollee firms that supply the granulated chlorinated isos, complete question
III‐9d. Independent tableters should complete question III‐9c regarding their own commercial
operations and III‐9d for their toll operations on behalf of tollees.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 24
III‐9a. Operations on granular/powder chlorinated isos not used in tableting Report the revenue and
related cost information requested below on the chlorinated isos operations of your firm’s U.S.
establishment(s).1 Do not report resales ofpurchased 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. Do not include
any data related to your firm’s repackaging operations.
Quantity (in short tons) and value (in $1,000)
Item
Fiscal years ended‐‐
2013
Net sales quantities:2
Commercial sales (“CS”)
2014
2015
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales (“CS”)
Internal consumption
Transfers to related firms
0
0
0
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
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.
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. IC and Transfers for producing tableted chlorinated isos should be reported in III‐9b.
3
COGS (whether for domestic or export sales) should include costs associated with CS IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 25
III‐9b. Operations on tableted chlorinated isos by producers with production of granular/powder
product.‐‐Report the revenue and related cost information requested below on the tableted
chlorinated isos operations of your firm’s U.S. establishment(s).1 Do not report resales of
purchased 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. Only U.S. firms that produce granular/powder
chlorinated isos and convert their granulated chlorinated isos into tableted chlorinated isos
should respond to this question.
Quantity (in short tons) and value (in $1,000)
Item
Fiscal years ended‐‐
2013
Net sales quantities:2
2014
2015
Raw materials—incremental tableting cost
Direct labor—incremental tableting cost5
2
Net sales values:
Cost of goods sold (COGS): 3
Raw materials‐‐ transferred in/purchased cost4
5
5
Other factory costs—incremental tableting cost
Conversion fee paid to toller6
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
All other expense items
All other income items
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 sales (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
COGS are the costs associated with tableting the granular/power chlorinated isos your firm produced. For the raw materials transferred from your
production of granular/power chlorinated isos, report the production cost and the the incremental cost of tableting, e.g., binder or other materials.
Similarly, labor and other factory costs are those costs associated with tableting the transferred in granular/power chlorinated isos.
4
The "transferred in" value reported here should represent the fully accumalated cost of granular/powder production that is being tabletted (including
the raw materials used to created the granular/powder form chlorinated isos AND the direct labor costs of granular/powder production, AND the factory
overhead costs that accrued to the merchandise during granular/powder production). The "transferred in" raw material cost should approximate the cost
of purchasing granular/powder form cholorinated isos for tableting operations.
5
The " incremental tableting costs" (RM, DL, and OFC) lines should relate solely to the tableting portion of your firms production operations. In others,
the additional marginal costs for converting granular/powder form chlorinated isos into tablets.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 26
III‐9c. Operations on tableted chlorinated isos by tableters.‐‐Report the revenue and related cost
information requested below on the tableted chlorinated isos operations of your firm’s U.S.
establishment(s). Provide data for your firm’s three most recently completed fiscal years. Only
U.S. firms that produce tableted chlorinated isos from purchased granular product should
respond to this question. Do not respond to this question if your firm produces granular
chlorinated isos.
Quantity (in short tons) and value (in $1,000)
Item
Fiscal years ended‐‐
2013
2
2014
2015
Net sales quantities
Net sales values2
Cost of goods sold (COGS):
Granular/powder purchases—domestic4
Granular/powder purchases —imported5
Additional raw materials
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
3
6
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
1
Include only sales (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
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4
Provide a description of the primary domestic raw materials, including granular products provided to your firm, and identify the U.S.
producer(s):
5
Provide a description of the primary imported raw materials, including granular products provided to your firm, and identify their country of
origin:
6
Binder or materials other than granulated chlorinated isos.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 27
III‐9d. Operations on tableted chlorinated isos by TOLLER.‐‐Report the revenue and related cost
information requested below on the tableted chlorinated isos operations of your firm’s U.S.
establishment(s).1 Only U.S. firms that produce tableted chlorinated isos from granular
product provided by a tollee firm on a toll basis should respond to this question.
Item
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
2013
2014
2015
2
Tolling operations:
Net quantity tolled
Net tolling revenue
Total revenue from tolling
operations
Cost of tolling services:
Raw materials not supplied by tollee3
Direct labor
Other factory costs
Total cost of tolling services
Gross profit or (loss)
Selling, general, and administrative
(SG&A) 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
0
0
0
1 Include only sales (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 For example, binder or materials other than chlorinated isos provided by tollee. .
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire –Chlorinated Isos
Page 28
III‐10. 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.
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U.S. Producers’ Questionnaire –Chlorinated Isos
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III‐11. 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, III‐9b
or III‐9c, 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, III‐9b, or III‐9c; i.e., if an aggregate nonrecurring item has been allocated
to one of the tables, only the allocated value amount 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 chlorinated isos in table III‐
9a, III‐9b, or III‐9c.
Fiscal years ended‐‐
2013
2014
2015
Nonrecurring item: In this column Nonrecurring item: In these columns please report the amount of the relevant
please provide a brief description nonrecurring item reported in table III‐9a, III‐9b, or III‐9c.
of each nonrecurring item and
indicate the specific line item and
Value ($1,000)
which table (III‐9a, III‐9b, or III‐9c)
where the nonrecurring item is
classified.
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
III‐12. 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.
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U.S. Producers’ Questionnaire –Chlorinated Isos
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III‐13. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of chlorinated isos. If your firm does not maintain some
or all of the specific asset information necessary to calculate total assets for chlorinated isos 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
1
Total assets (net)
1
Integrated producer
2
Independent tableter
3
Toller
1
Describe
Describe
3
Describe
2
2015
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U.S. Producers’ Questionnaire –Chlorinated Isos
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III‐14a. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for chlorinated isos. Provide data for
your firm’s six most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Item
Fiscal years ended‐‐
2014
Integrated firm
Capital expenditures
Research and development expenses
Independent tableter
Capital expenditures
Research and development expenses
Toller
Capital expenditures
Research and development expenses
1
2
2013
2015
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
III‐14b. Capital investment required to begin tableting operations.—For tableters, discuss the main
capital investments required to begin tableting operations (e.g., the cost of a tablet press). Do
not include any data related to your firm’s repackaging operations.
Capital investments
Value (in $1,000)
Tablet press
Other (specify)
Other (specify)
Other (specify)
Other (specify)
III‐14c. Cost components associated with tableting operations.—For tableters, discuss the main cost
components associated with tableting operations, as well as such components’ percent of
overall tableting costs in fiscal year 2013.
Percent of total
Cost component
tableting costs
%
%
%
%
%
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U.S. Producers’ Questionnaire –Chlorinated Isos
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III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9c, III‐12, and III‐13 are based on a calendar year or 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‐6 (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‐6?
Yes
No
If no, please explain.
III‐15. 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 –Chlorinated Isos
Page 33
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Tana Farrington (202‐205‐
2389, [email protected]).
IV‐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 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 of the following products produced by your firm.
Product 1.‐‐ Granular trichloroisocyanuric acid with approximately 90 percent available
chlorine content (similar to ACL®90 or CDB®), sold in bulk packages equal to or
greater than 1,000 pounds and less than or equal to 2,205 pounds.
Product 2.‐‐ Granular sodium dichloroisocyanuric (dihydrate) with approximately 56 percent
available chlorine content (similar to ACL®56 or CDB®56), sold in bulk packages
equal to or greater than 1,000 pounds and less than or equal to 2,205 pounds,
sold for repackaging for pool treatment use.
Product 3.‐‐ 3‐inch or comparable trichlor tablets, with tablet volume of 6 to 8 ounces, in 35‐
55 pound containers.
Product 4.‐‐ Blended 3‐inch or comparable tablets, with tablet volume of 6 to 8 ounces, with
approximately 85 to 90 percent available chlorine content, in 24‐26 pound
containers.
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 –March 2016, 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.
If you are a toll producer that tablets chlorinated isos for another firm that in turn sells the end product
into the market, do not report any pricing product data. The tollee (who owns the merchandise and sells
it into the market) should report those pricing products.
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U.S. Producers’ Questionnaire –Chlorinated Isos
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IV‐2(a). 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
Quantity
Value
Quantity
Value Quantity
Value
Product 4
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 35
IV‐2(c). 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.
Please note that the questions in this section refer to sales of granular, tabulated, and blended
tableted chlorinated isos. If your response to any question differs depending on whether the
chlorinated isos are granular, tablets, or blended tablets, please note this in your response OR provide
information on such differences in response to question IV‐26 below.
IV‐3. Price setting.‐‐ How does your firm determine the prices that it charges for sales of chlorinated
isos (check all that apply)? If your firm issues price lists, please submit sample pages of a recent
list.
Transaction
by
transaction
Contracts
IV‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐ Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
IV‐5.
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced chlorinated isos?
Net 30
days
Net 60
days
(b)
IV‐6.
Page 36
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic chlorinated isos usually quoted (check
one)?
Delivered
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
chlorinated isos in 2015 was on a (1) long‐term contract basis, (2) annual contract basis, (3)
short‐term contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2015
sales
%
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
IV‐7.
Page 37
Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced chlorinated isos (or check “not applicable” if your firm does not sell on a long‐
term, short‐term and/or annual contract basis).
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)
Average contract
duration
No. of
days
365
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Typical sales
contract provisions
Fixed quantity
and/or price
Meet or release
provision
Not applicable
IV‐8.
Lead times.‐‐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 chlorinated isos?
Share of 2015
Source
sales
Lead time (days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
IV‐9.
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Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced
chlorinated isos that is accounted for by U.S. inland transportation costs? %
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 chlorinated isos that are
delivered the following distances from your firm’s 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 chlorinated isos 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.
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 39
IV‐11. End uses.‐‐
(a)
List the end uses of the chlorinated isos that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by chlorinated isos and
other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
Chlorinated isos
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
(b)
Have there been any changes in the end uses of chlorinated isos since January 1, 2013?
Do you anticipate any future changes?
Changes in end
uses
No
Yes
Explain
Changes since
January 1, 2013
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 40
IV‐12. Substitutes.‐‐
(a)
Can other products be substituted for chlorinated isos?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for chlorinated isos?
No Yes
Explanation
1.
2.
3.
(b)
Have there been any changes in the number or types of products that can be
substituted for chlorinated isos since January 1, 2013? Do you anticipate any future
changes?
Changes in
substitutes
No Yes
Explain
Changes since
January 1, 2013
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 41
IV‐13. Availability of supply.‐‐Has the availability of chlorinated isos in the U.S. market changed since
January 1, 2013? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2013:
U.S.‐produced product
Subject imports
Nonsubject imports
U.S.‐produced product
Subject imports
Nonsubject imports
Anticipated changes:
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 42
IV‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for chlorinated isos has changed since January 1, 2013, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors that
have affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2013
Within
the United
States
Outside
the United
States
Anticipated future demand
Within
the United
States
Outside
the United
States
IV‐15. Product changes.‐‐ Have there been any significant changes in the product range, product mix,
or marketing of chlorinated isos since January 1, 2013? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2013
Anticipated
changes
Explain
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 43
IV‐16. Conditions of competition.‐‐
(a) Is the chlorinated isos market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to chlorinated isos?
Check all that apply.
Please describe.
No
Skip to question IV‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
chlorinated isos since January 1, 2013?
No
Yes
If yes, describe.
IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply chlorinated isos
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, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐18. Raw materials.‐‐ Indicate how chlorinated isos raw materials prices have changed since January
1, 2013, and how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no
clear
Overall
No
Overall
trend
increase change decrease
Explain, noting how raw material
price changes have affected your
firm’s selling prices for chlorinated
isos.
Changes since
January 1,
2013
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 44
IV‐19. Price comparisons.‐‐Please compare market prices of chlorinated isos in U.S. and non‐U.S.
markets, if known. Provide specific information as to time periods and regions for any price
comparisons.
IV‐20. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss chlorinated isos supply
(including production capacity and capacity utilization) and demand in (1) the United States, (2)
each of the other major producing/consuming countries, including China and Spain, and (3) the
world as a whole. Of particular interest is such data from 2013 to the present and forecasts for
the future.
IV‐21. Export constraints.‐‐Describe how easily your firm can shift its sales of chlorinated isos between
the U.S. market and alternative country markets. In your discussion, please describe any
contracts, other sales arrangements, or other constraints that would prevent or retard your firm
from shifting chlorinated isos between the U.S. and alternative country markets within a 12‐
month period.
IV‐22. Barriers to trade.‐‐Are your firm’s exports of chlorinated isos subject to any tariff or non‐tariff
barriers to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2013, or that are expected to occur in the future.
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 45
IV‐23. Interchangeability.‐‐Is chlorinated isos produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
Spain
Other countries
United States
China
Spain
For any country‐pair producing chlorinated isos 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’ Questionnaire –Chlorinated Isos
Page 46
IV‐24. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between chlorinated isos
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
Spain
Other countries
United States
China
Spain
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of chlorinated isos, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 47
IV‐25. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for chlorinated isos since January 1, 2013. Indicate the share of the quantity of your
firm’s total shipments of chlorinated isos that each of these customers accounted for in 2015.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2015
sales
(%)
1
2
3
4
5
6
7
8
9
10
IV‐26. Further explanation of granular, tablets, or blended tablets.‐‐ If your response to any question
in part III above differs depending on whether the chlorinated isos are granular, tablets, or
blended tablets, please use this space to describe any such differences.
IV‐27. 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.
Business Proprietary
U.S. Producers’ Questionnaire –Chlorinated Isos
Page 48
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/701731/2015/chlorinated_isocyanurates_china_and_spain/second_review_full.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: NACL
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non‐encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (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 - U.S. Producer Questionnaire_Isos_2nd Review |
| Author | chris.cassise |
| File Modified | 2016-05-05 |
| File Created | 2016-05-05 |