Form 16-1-3515 U.S. Producers' Questionnaire

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

US producer questionnaire

Circular Welded Carbon-Quality Steel Pipe from Oman, Pakistan, United Arab Emirates, and Vietnam, Inv. No. 701-TA-549 and 731-TA-1299-1300, 1302-1303 (Final)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No.16-1-3515; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
CIRCULAR WELDED CARBON-QUALITY STEEL PIPE FROM OMAN, PAKISTAN,
THE UNITED ARAB EMIRATES, AND VIETNAM
This questionnaire must be received by the Commission by August 12, 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 circular welded carbon-quality steel
pipe (“circular welded pipe”) from Oman, Pakistan, the United Arab Emirates (“UAE”), and Vietnam (Inv. Nos. 701-TA549 and 731-TA-1299, 1300, 1302, and 1303 (Final)). The information requested in the questionnaire is requested under
the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a
subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)). Further information on this questionnaire can be obtained from Jordan Harriman (202-205-2610,
[email protected]).
Name of firm
Address
City

State

Zip Code

Website
Has your firm produced circular welded pipe (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: CWP4)
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

Email address
Fax:

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

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PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to a petition filed on October 28, 2015, by Bull
Moose Tube Company, Chesterfield, MO; EXLTUBE, Kansas City, MO; Wheatland Tube, a division of JMC
Steel Group, Chicago, IL; and Western Tube & Conduit, Long Beach, CA. Countervailing and/or
antidumping duties may be assessed on the subject imports as a result of these proceedings if the
Commission makes an affirmative determination of injury, threat, or material retardation, and if the U.S.
Department of Commerce makes an affirmative determination of subsidization and/or dumping.
Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2016/circular_welded_carbon_quality_steel_pipe_oman/
final.htm
Circular welded pipe covered by these investigations is welded carbon-quality steel pipes and tube, of
circular cross-section, with an outside diameter (O.D.) not more than nominal 16 inches (406.4 mm),
regardless of wall thickness, surface finish (e.g., black, galvanized, or painted), end finish (plain end,
beveled end, grooved, threaded, or threaded and coupled), or industry specification (e.g., American
Society for Testing and Materials International (ASTM), proprietary, or other), generally known as
standard pipe, fence pipe and tube, sprinkler pipe, and structural pipe (although subject product may
also be referred to as mechanical tubing). Specifically, the term “carbon quality” includes products in
which:
(a) iron predominates, by weight, over each of the other contained elements;
(b) the carbon content is 2 percent or less, by weight; and
(c) none of the elements listed below exceeds the quantity, by weight, as indicated:
(i) 1.80 percent of manganese;
(ii) 2.25 percent of silicon;
(iii) 1.00 percent of copper;
(iv) 0.50 percent of aluminum;
(v) 1.25 percent of chromium;
(vi) 0.30 percent of cobalt;
(vii) 0.40 percent of lead;
(viii) 1.25 percent of nickel;
(ix) 0.30 percent of tungsten;
(x) 0.15 percent of molybdenum;
(xi) 0.10 percent of niobium;
(xii) 0.41 percent of titanium;
(xiii) 0.15 percent of vanadium; or
(xiv) 0.15 percent of zirconium.
Covered products are generally made to standard O.D. and wall thickness combinations. Pipe multistenciled to a standard and/or structural specification and to other specifications, such as American
Petroleum Institute (API) API-5L specification, may also be covered by the scope of these investigations.
In particular, such multi-stenciled merchandise is covered when it meets the physical description set
forth above, and also has one or more of the following characteristics: is 32 feet in length or less; is less
than 2.0 inches (50 mm) in outside diameter; has a galvanized and/or painted (e.g., polyester coated)
surface finish; or has a threaded and/or coupled end finish.
Standard pipe is ordinarily made to ASTM specifications A53, A135, and A795, but can also be made to
other specifications. Structural pipe is made primarily to ASTM specifications A252 and A500. Standard

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 3

and structural pipe may also be produced to proprietary specifications rather than to industry
specifications.
Sprinkler pipe is designed for sprinkler fire suppression systems and may be made to industry
specifications such as ASTM A53 or to proprietary specifications.
Fence tubing is included in the scope regardless of certification to a specification listed in the exclusions
below, and can also be made to the ASTM A513 specification. Products that meet the physical
description set forth above but are made to the following nominal outside diameter and wall thickness
combinations, which are recognized by the industry as typical for fence tubing, are included despite
being certified to ASTM mechanical tubing specifications:
O.D. in inches (nominal)
1.315
1.315
1.315
1.315
1.315
1.315
1.315
1.660
1.660
1.660
1.660
1.660
1.900
1.900
1.900
1.900
1.900
1.900
2.375
2.375
2.375
2.375
2.375
2.375
2.375
2.875
2.875
3.500
3.500
4.000
4.000
4.500

Wall thickness in inches
(nominal)
0.035
0.047
0.055
0.065
0.072
0.083
0.095
0.055
0.065
0.083
0.095
0.109
0.047
0.055
0.065
0.072
0.095
0.109
0.047
0.055
0.065
0.072
0.095
0.109
0.120
0.109
0.165
0.109
0.165
0.148
0.165
0.203

The scope of this proceeding does not include:

Gage
20
18
17
16
15
14
13
17
16
14
13
12
18
17
16
15
13
12
18
17
16
15
13
12
11
12
8
12
8
9
8
7

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U.S. Producers’ Questionnaire – Circular Welded Pipe

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(a) pipe suitable for use in boilers, superheaters, heat exchangers, refining furnaces and feedwater
heaters, whether or not cold drawn, which are defined by standards such as ASTM A178 or ASTM A192;
(b) finished electrical conduit, i.e., Electrical Rigid Steel Conduit (also known as Electrical Rigid Metal
Conduit and Electrical Rigid Metal Steel Conduit), Finished Electrical Metallic Tubing, and Electrical
Intermediate Metal Conduit, which are defined by specifications such as American National Standard
(ANSI) C80.1-2005, ANSI C80.3-2005, or ANSI C80.6-2005, and Underwriters
Laboratories Inc. (UL) UL-6, UL-797, or UL-1242;
(c) finished scaffolding, i.e., component parts of final, finished scaffolding that enter the United States
unassembled as a “kit.” A kit is understood to mean a packaged combination of component parts that
contains, at the time of importation, all of the necessary component parts to fully assemble final,
finished scaffolding;
(d) tube and pipe hollows for redrawing;
(e) oil country tubular goods produced to API specifications;
(f) line pipe produced to only API specifications, such as API 5L, and not multi-stenciled; and
(g) mechanical tubing, whether or not cold-drawn, other than what is included in the
above paragraphs.
The products subject to this proceeding are currently classifiable in Harmonized Tariff Schedule of the
United States (HTSUS) statistical reporting numbers 7306.19.1010, 7306.19.1050, 7306.19.5110,
7306.19.5150, 7306.30.1000, 7306.30.5015, 7306.30.5020, 7306.30.5025, 7306.30.5032, 7306.30.5040,
7306.30.5055, 7306.30.5085, 7306.30.5090, 7306.50.1000, 7306.50.5030, 7306.50.5050, and
7306.50.5070. The HTSUS subheadings above are provided for convenience and U.S. Customs purposes
only. The written description of the scope of the proceeding 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.
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.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
I-1a.

Page 5

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 circular welded pipe,
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:

.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
I-3.

Page 6

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

Support

Oppose

Take no position

Oman – AD
Pakistan – AD
Pakistan – CVD
UAE – AD
Vietnam – AD

I-4.

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

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing circular welded pipe from Oman, Pakistan, the UAE, and
Vietnam into the United States or that are engaged in exporting circular welded pipe from
Oman, Pakistan, the UAE, and Vietnam to the United States?
No
Firm name

Yes--List the following information.
Address

Affiliation

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U.S. Producers’ Questionnaire – Circular Welded Pipe
I-6.

Page 7

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

Yes--List the following information.
Address

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202-2052610, [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 circular welded pipe 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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U.S. Producers’ Questionnaire – Circular Welded Pipe
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Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce circular welded pipe, 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
Overall production capacity

2013

2014

January-June
2015

2015

2016

1

Production of:
Circular welded pipe2
Line pipe (up to 16” O.D.)

0

0

0

0

0

0

0

0

0

0

3

Line pipe (above 16” O.D.)
Mechanical tubing4
OCTG
Other products5
Total
1

Indicate the approximately share of capacity and production reported here that relates to
merchandise produced using electric resistance weld ("ERW") production methods (
percent ERW)
and what share using continuous weld ("CW") production method (
percent CW).
2
Data entered for production of circular welded pipe will populate here once reported in question II-7.
3
These data should exclude any line pipe that otherwise matches the definition of circular welded pipe
provided on pages 2-4.
4
These data should exclude any mechanical tubing that otherwise matches the definition of circular
welded pipe provided on pages 2-4. Any product, regardless of whether it is called mechanical tubing by
actors in the industry, that meets the definition of circular welded pipe must be reported as circular
welded pipe in question II-7.
5
Please identify these products:
.

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.

hours

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

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II-3d.

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

II-3e.

Product shifting.—
(i)

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

(ii)

II-4.

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.

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

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

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
II-5.

Page 11

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce circular welded pipe in and/or admit
circular welded pipe into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No

(b)

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 circular welded pipe into a foreign trade zone (FTZ) for use in distribution of
circular welded pipe and/or the production of downstream articles?
No/Don’t know

II-6.

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2013, has your firm imported circular welded pipe?
“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’ Questionnaire – Circular Welded Pipe
II-7.

Page 12

Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of circular welded pipe 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.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
II-7.

Page 13

Production, shipment and inventory data.-Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2013

2014

January-June
2015

2015

2016

1

Average production capacity (quantity)
(A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:2
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value3 (G)
Transfers to related firms:
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
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
Please estimate the share of your firm’s commercial U.S. shipments in 2015 that were certified as lead-free under the
Safe Drinking Water Act:
percent.
3
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:
.
4
Identify your firm’s principal export markets:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar years

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

2013

2014

0

January-June
2015

0

2015

0

2016

0

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

0
.

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U.S. Producers’ Questionnaire – Circular Welded Pipe
II-8.

Page 14

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

January-June
2015

2015

2016

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To end users (quantity) (N)
To retailers (quantity) (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for commercial U.S. commercial
shipments (i.e., line D) in each time period. If the calculated fields below return values other than zero
(i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D = zero ("0"), if not
revise.

2013

2014
0

January-June
2015

0

2015
0

2016
0

0

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U.S. Producers’ Questionnaire – Circular Welded Pipe
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Page 15

US shipments by nominal pipe size and wall thickness.—Please report the quantity (in short
tons) and value (in $1,000) of your firms' U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of circular welded pipe in 2015
by nominal pipe size ("NPS") and wall thickness.
Calendar year 2015

Wall thickness (down) and
diameter thickness (across)

NPS ⅛
NPS 2 ½
NPS 4
NPS 9
through NPS through NPS through NPS through NPS
2
3½
8
16

Total

Quantity (short tons); Value ($1,000)
Schedule 5s and 5.-Quantity

0

Value

0

Schedule 10s and 10.-Quantity

0

Value

0

Schedules 20, 30, 40s, and 40.-Quantity

0

Value

0

All other wall thicknesses.-Quantity

0

Value

0

Total.-Quantity

0

0

0

0

0

Value

0

0

0

0

0

RECONCILIATION OF US SHIPMENTS.-- Please ensure that the total quantity and total value reported for
U.S. shipment in 2015 in this grid equal the quantity reported for U.S. shipments (i.e., lines D, F, and H for
quantity; and lines E, G, I for value) in 2015 in question II-7. The following reconciliation sums the total
quantity and the total value in this grid and subtracts out the reported data from question II-7. If the
calculated fields below return values other than zero (i.e., “0”), the data reported must be revised prior
to submission to the Commission.
Reconciliation

2015

Quantity reconciliation, should = zero ("0"), if not
revise

0

Value reconciliation, should = zero ("0"), if not
revise

0

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
II-9b.

Page 16

US shipments by production standard/stenciling.—Please report the quantity (in short tons) of
your firms' U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption,
and transfers to related firms) of circular welded pipe in 2015 by production standard/stenciling.
Calendar year 2015
U.S. shipments by production standard/ stenciling

Quantity (short tons)

Produced to single standard/ single stenciled.—
ASTM A53 (X)
ASTM A135/A795 (Y)
ASTM A500/A252 (Z)
ASTM A513 (AA)
ASTM A252
In-scope fence tubing standards1
Other standards, proprietary or otherwise2
Produced to multiple standards/ multi-stenciled3
No standard4
Total

0

1

These include WT40 and SS40.
Please list and described these standards in order of importance (i.e., involving the greatest
volume):
3
Please identify the most relevant (i.e., involving the greatest volume) multi-stencil combinations
reported by your firm:
4
Please these products
2

RECONCILIATION OF US SHIPMENTS.-- Please ensure that the total quantity reported for U.S. shipment in
2015 in this grid equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in 2015 in question
II-7). The following reconciliation sum the total quantity and the total value in this grid and subtracts out
the reported data from question II-7. If the calculated fields below return values other than zero (i.e.,
“0”), the data reported must be revised prior to submission to the Commission.
Reconciliation
Quantity reconciliation, should = zero ("0"), if not
revise

2015
0

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
II-9c.

Page 17

Shipments by various additional attributes.—Please check all that apply to any portion of your
firms U.S. shipments in 2015.
End finishes:
Plain end/ square cut
Beveled
Threaded
Threaded and coupled
Other end finishes (describe:
)
Surface finishes:
Black
Painted
Galvanized
Other surface finishes (describe:

)

Lengths:
Single random lengths (approx. 20 feet)
Double random lengths (approx. 40 feet)
Triple random lengths (approx. 60 feet)
Quadruple random lengths (approx. 80 feet
Other lengths (describe:
)
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 – Circular Welded Pipe
II-11.

Page 18

Employment data.--Report your firm’s employment-related data related to the production of
circular welded pipe and provide an explanation for any trends in these data.
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 6.
“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

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

2013

2014

January-June
2015

2015

2016

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
II-12.

Page 19

Purchases.--Other than direct imports, has your firm otherwise purchased circular welded pipe
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

January-June
2015

2015

2016

Purchases from U.S.
importers1 of circular welded
pipe from—
Oman
Pakistan
UAE
Vietnam
Korea
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1

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

II-13.

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 – Circular Welded Pipe

Page 20

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, [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 circular welded pipe:

2.

Does your firm prepare profit/loss statements for circular welded pipe:
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,
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 circular welded pipe, as
well as specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system/Inventories.--Briefly describe your firm’s cost accounting system (e.g.,
standard cost, job order cost, etc.) and your firm’s basis for valuing raw material inventories
(e.g., FIFO, LIFO, weighted average) related to circular welded pipe operations, as well as the
average number of weeks of hot-rolled steel inventories maintained for normal circular welded
pipe operations.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 21

III-4a. Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-4b. Allocation changes.--Did changes in your firm’s production or sale of products other than
circular welded pipe impact the allocations of fixed costs (e.g., other factory costs, general and
administrative expenses) to circular welded pipe operations? Please describe. Please take into
account products produced not only in the facilities where your firm produces circular welded
pipe, but also firm-wide production.

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced circular welded pipe, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products

Share of sales

Circular Welded Pipe

1

%
2

%

Line pipe (above 16” O.D.)

%

Line pipe (up to 16” O.D.)

Mechanical tubing
OCTG

3

%
%

4

Other
%
1
As defined in pages 2-4 of this questionnaire.
2
These data should exclude any line pipe that otherwise matches the definition of
circular welded pipe provided on pages 2-4.
3
These data should exclude any mechanical tubing that otherwise matches the definition
of circular welded pipe provided on pages 2-4.
4
Please identify these products:
.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of circular welded pipe 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.

Page 22

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of circular
welded pipe that your firm purchases from related suppliers and that are reflected in table III9a. 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

III-8.

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 circular
welded pipe) 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.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 23

III-9a. Operations on circular welded pipe.--Report the revenue and related cost information
requested below on the circular welded pipe 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.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January-June

2015

2015

2016

2

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

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
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 – Circular Welded Pipe

Page 24

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-10a. Effects of increasing hot-rolled steel prices on reported profitability.--Please discuss your firm’s
experience with increasing prices for hot-rolled steel and the lag between purchases of this raw
material and its use in the production of circular welded pipe. How has this timing difference
(i.e., between raw materials valued at historical cost and used in the production of circular
welded pipe and the subsequent sale of circular welded pipe at current market prices) impacted
your firm’s reported profitability in table III-9a? When hot-rolled steel prices increase, to what
extent do customers resist price increases on circular welded pipe? To what extent to
customers accelerate purchases of circular welded pipe in anticipation of higher prices in the
future?

III-10b. Effects of decreasing hot-rolled steel prices on reported profitability.--Please discuss your
firm’s experience with decreasing prices for hot-rolled steel and the lag between purchases of
this raw material and its use in the production of circular welded pipe. How has this timing
difference (i.e., between raw materials valued at historical cost and used in the production of
circular welded pipe and the subsequent sale of circular welded pipe at current market prices)
impacted your firm’s reported profitability in table III-9a? When hot-rolled steel prices
decrease, to what extent do customers immediately push for price decreases on circular welded
pipe? To what extent do customers delay purchases of circular welded pipe in anticipation of
lower prices in the future?

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 25

III-11a. 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

January-June

2015

2015

2016

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

III-11b. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in the table above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 26

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of circular welded pipe. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for circular
welded pipe 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
Total assets (net)
1

III-13.

2013

2014

2015

1

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for circular welded pipe.
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

January-June

2015

2015

2016

Capital expenditures
R & D expenses
1

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

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 circular welded pipe from Oman, Pakistan, the UAE, and Vietnam?
No

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

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

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

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 circular welded pipe from Oman, Pakistan, the
UAE, and Vietnam?
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 – Circular Welded Pipe

Page 29

III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
circular welded pipe from Oman, Pakistan, the UAE, and Vietnam?
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.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 30

PART IV.-- PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202-2053489, [email protected]).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax

PRICE DATA
IV-2.
(a) 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.—ASTM A-53 schedule 40 black plain-end, with nominal outside diameter of 2-4
inches inclusive;
Product 2.—ASTM A-53 schedule 40 galvanized plain-end, with nominal outside diameter of 2-4
inches inclusive;
Product 3.-- ASTM A-53 schedule 40 black plain-end, with nominal outside diameter of 6-8
inches inclusive; and
Product 4.-- Schedule 40 galvanized fence tube, with nominal outside diameter of 1-1/4 – 3
inches, inclusive.
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-June 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(s) as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 31

IV-2a. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to distributors and service centers.

Sales to distributors and service centers
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

Period of shipment
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
2016:
January-March
April-June
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:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 32

IV-2a. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to end users.

Sales to end users
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

Period of shipment
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
2016:
January-March
April-June
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:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 33

IV-2a. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to retailers.

Sales to retailers
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

Period of shipment
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
2016:
January-March
April-June
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:
Product 4:

(b)

No

Yes

Does your firm produce pricing product 4 (“Schedule 40 galvanized fence tube, with
nominal outside diameter of 1-1/4 – 3 inches, inclusive”) to ATSM standards?
If yes, provide the estimated
share of commercial
shipments produced to
ATSM standards in 2015
%

Please list the relevant ATSM standards

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
(c)

Page 34

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

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
IV-3.

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

IV-4.

Other

If other, describe

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

Quantity
discounts

IV-5.

Contracts

Set
price
lists

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 circular welded pipe?
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 circular welded pipe usually quoted
(check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
circular welded pipe 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
IV-7.

Page 35

%

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

%

%

0.0

%

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced circular welded pipe (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)
365

No
Quantity

Fixed quantity
and/or price

Price
Both

Meet or release
provision

Yes

Indexed to raw
material costs1

Yes1

No

No

Not applicable
1

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)

Please describe any indexing mechanisms and relevant raw materials:

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

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
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 circular welded pipe?

Source

Share of 2015 sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)
IV-9.

Page 36

Lead time (average
number of days)

0.0 %

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced circular
welded pipe 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 circular welded pipe 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 circular welded pipe 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

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 37

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

Circular welded pipe

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Substitutes.--Can other products be substituted for circular welded pipe?
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 circular welded pipe?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.-(a)

Indicate how demand within the United States and outside of the United States (if
known) for circular welded pipe 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

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe
(b)

Page 38

What effects, if any, do the prices of gas and oil have on demand for and price of circular
welded pipe?

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

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a) Is the circular welded pipe market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to circular
welded pipe? 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
circular welded pipe since January 1, 2013?
No

Yes

If yes, describe.

IV-16. Impact of Allied.-- Did U.S. producer Allied’s exit from the market affect U.S. prices for circular
welded pipe?
No

Yes

If yes, describe the effects.

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 39

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply circular welded
pipe 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-18. Raw materials.--How have circular welded pipe raw material prices changed since January 1,
2013?
Fluctuate
Explain, noting how raw material price changes
Overall
No
Overall
with no
have affected your firm’s selling prices for circular
increase change decrease clear trend
welded pipe.

IV-19. Interchangeability.--Is circular welded pipe 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
Countrypair

Oman

Pakistan

UAE

Vietnam

Korea

All other
sources

United
States
Oman
Pakistan
UAE
Vietnam
Korea
For any country-pair producing circular welded pipe which is sometimes or never
interchangeable, please identify the country-pair and explain the factors that limit or preclude
interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 40

IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between circular welded pipe
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
Countrypair

Oman

Pakistan

UAE

Vietnam

Korea

All other
sources

United
States
Oman
Pakistan
UAE
Vietnam
Korea
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of circular welded pipe, identify the country-pair and report
the advantages or disadvantages imparted by such factors:

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 41

IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for circular welded pipe since January 1, 2013. Indicate the share of the quantity of
your firm’s total shipments of circular welded pipe that each of these customers accounted for
in 2015.

Customer’s name

City

State

Share of 2015
sales (%)

1
2
3
4
5
6
7
8
9
10

IV-22. Competition from imports
(a)

Lost revenue.--Since January 1, 2013: To avoid losing sales to competitors selling
circular welded pipe from Oman, Pakistan, the UAE, and Vietnam, 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 circular welded pipe to
imports of this product from Oman, Pakistan, the UAE, and Vietnam?
No

Yes

Business Proprietary
U.S. Producers’ Questionnaire – Circular Welded Pipe

Page 42

IV-23. 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 – Circular Welded Pipe

Page 43

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

Pin: CWP4

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


File Typeapplication/pdf
File TitleUS producer questionnaire
SubjectTitle 7 investigations
AuthorSzustakowski, Michael
File Modified2016-06-30
File Created2016-06-30

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