16-1-3519 U.S. Producers' Questionnaire

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

SRC pipe and tube R1_Producer questionnaire

Seamless Refined Copper Pipe and Tube from China and Mexico

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 16-1-3519; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
SEAMLESS REFINED COPPER PIPE AND TUBE FROM CHINA AND MEXICO
This questionnaire must be received by the Commission by August 11, 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 seamless refined copper pipe and tube (“SRC pipe
and tube”) from China and Mexico (Inv. Nos. 731-TA-1174-1175 (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 SRC pipe and tube (as defined on the next page) at any time since January 1, 2010?

(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: SRCP)
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 reviews, 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’ Questionnaire – SRC pipe and tube

Page 2

PART I.—GENERAL INFORMATION
Background. On November 22, 2010, the Department of Commerce issued antidumping duty orders on
imports of SRC pipe and tube from China and Mexico. On October 1, 2015, the Commission instituted
reviews 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 a negative determination(s), the Department of Commerce will revoke the order(s).
Questionnaires and other information pertinent to this proceeding are available at
https://usitc.gov/reviews/701731/2015/seamless_refined_copper_pipe_and_tube_china_and/first_revi
ew_full.htm.
SRC pipe and tube covered by these reviews is “all seamless circular refined copper pipes and tubes,
including redraw hollows, greater than or equal to 6 inches (152.4 mm) in length and measuring less
than 12.130 inches (308.102 mm) (actual) in outside diameter (“OD”), regardless of wall thickness, bore
(e.g., smooth, enhanced with inner grooves or ridges), manufacturing process (e.g., hot finished, colddrawn, annealed), outer surface (e.g., plain or enhanced with grooves, ridges, fins, gills), end finish (e.g.,
plain end, swaged end, flared end, expanded end, crimped end, threaded), coating (e.g., plastic, paint),
insulation, attachments (e.g., plain, capped, plugged, with compression or other fitting), or physical
configuration (e.g., straight, coiled, bent, wound on spools).
The scope of these reviews covers, but is not limited to, seamless refined copper pipe and tube
produced or comparable to the American Society for Testing and Materials (“ASTM”) ASTM-B42, ASTMB68, ASTM-B75, ASTM-B88, ASTM-B88M, ASTM-B188, ASTM-B251, ASTM-B251M, ASTM-B280, ASTMB302, ASTM-B306, ASTM-359, ASTM-B743, ASTM-B819, and ASTM-B903 specifications and meeting the
physical parameters described therein. Also included within the scope are all sets of covered products,
including “line sets” of seamless refined copper tubes (with or without fittings or insulation) suitable for
connecting an outdoor air conditioner or heat pump to an indoor evaporator unit. The phrase “all sets of
covered products” denotes any combination of items put up for sale that is comprised of merchandise
subject to the scope.
“Refined copper” is defined as: (1) metal containing at least 99.85 percent by weight of copper; or (2)
metal containing at least 97.5 percent by weight of copper, provided that the content by weight of any
other element does not exceed the following limits:
ELEMENT
Ag – Silver
As – Arsenic
Cd – Cadmium
Cr – Chromium
Mg – Magnesium
Pb – Lead
S – Sulfur
Sn – Tin
Te – Tellurium
Zn – Zinc
Zr – Zirconium
Other elements (each)

LIMITING CONTENT PERCENT BY WEIGHT
0.25
0.5
1.3
1.4
0.8
1.5
0.7
0.8
0.8
1.0
0.3
0.3

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 3

Excluded from the scope of these orders are all seamless circular hollows of refined copper less than 12
inches in length whose OD (actual) exceeds its length. The products subject to these orders are currently
classifiable under subheadings 7411.10.1030 and 7411.10.1090 of the Harmonized Tariff Schedule of the
United States (“HTSUS”). Products subject to these reviews may also enter under HTSUS subheadings
7407.10.1500, 7419.99.5050, 8415.90.8065, and 8415.90.8085. Although the HTSUS subheadings are
provided for convenience and customs purposes, the written description of the scope of these orders is
dispositive.”
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’ Questionnaire – SRC pipe and tube
I-1.

Page 4

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 Reviews, 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 SRC pipe and tube,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
Covered1

City, State

Zip (5 digit)

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

Description

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U.S. Producers’ Questionnaire – SRC pipe and tube
I-3.

Page 5

Position regarding continuation of order.--Does your firm support or oppose continuation of
the antidumping duty orders currently in place for SRC pipe and tube from the following
countries?
Country

Support

Oppose

Take no position

China
Mexico
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 SUBJECT importers/exporters.--Does your firm have any related firms, either domestic
or foreign, that are engaged in importing SRC pipe and tube from China and/or Mexico into the
United States or that are engaged in exporting SRC pipe and tube from China and/or Mexico to
the United States?
No
Firm name

Yes--List the following information.
Address

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
I-6.

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing SRC pipe and tube from countries other than
China and/or Mexico into the United States or that are engaged in exporting SRC pipe and tube
from countries other than China and/or Mexico to the United States?
No

Yes--List the following information.

Firm name and country

I-7.

Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of SRC pipe and tube?
No

Yes--List the following information.

Firm name

I-8.

Page 6

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 SRC pipe and tube?

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’ Questionnaire – SRC pipe and tube

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [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 SRC pipe and tube since January 1, 2010.

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.

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-3.

Page 8

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 SRC pipe
and tube 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 SRC pipe and tube (in 1,000 pounds) for 2016
and 2017.

For question II-4, if your firm’s response differs for particular orders, please indicate and explain the
particular effect of revocation of specific orders.
II-4.

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 SRC pipe and tube in the future if the antidumping duty
orders on SRC pipe and tube from China and/or Mexico 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 SRC pipe and tube (in 1,000 pounds) for 2016
and 2017.

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-5a.

Page 9

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce SRC pipe and tube, 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 1,000 pounds)
Calendar year
Item

2010

2011

2012

January-June

2013

2014

2015

2016

Overall production
capacity
Production of:
SRC pipe and
tube1
Other products
Total
1
2

Data entered for production of SRC pipe and tube will populate here once reported in question II-6.
Please identify these products:
.

II-5b.

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

II-5c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-5a, and explain any changes in reported capacity.

II-5d.

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

hours

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-5e.

Page 10

Product shifting.--Is your firm able to switch production (capacity) between SRC pipe and tube and
other products using the same equipment and/or labor?
No

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

II-5f.

Product shifting factors.--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.

II-6.

Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of SRC pipe and tube 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 – SRC pipe and tube
II-6.

Page 11

Production, shipment and inventory data.-Quantity (in 1,000 pounds) and value (in $1,000)
Calendar year

Item

2010

2011

2012

2013

January-June
2014

2015

2016

Average production
capacity1 (quantity) (A)
Beginning-of-period
inventories (quantity)
(B)
Production (quantity)
(C)
U.S. shipments:
Commercial
shipments:
quantity (D)
value (E)
Internal
consumption:2
quantity (F)
value (G)
Transfers to related
firms:2
quantity (H)
value (I)
Export shipments:3
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 (use additional pages as necessary).
.
2
Internal consumption and transfers to related firms should be valued at fair market value. In the event that your firm uses a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data using that basis
for each of the periods noted above:
.
3
Identify your firm’s principal export markets:
.

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-6.

Page 12

Production, shipment and inventory data.--Continued

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

2010

2011

2012

January-June

2013

2014

2015

2016

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

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-7a.

Page 13

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in 1,000 pounds)
Calendar year
Item

2010

2011

2012

January-June

2013

2014

2015

2016

Channels of distribution:
U.S. commercial
shipments to
distributors/retailer/
wholesalers
(quantity) (M)
U.S. commercial
shipments to
end/OEM users
(quantity)(N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) 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 year
Reconciliation item
M + N– D = zero ("0"),
if not revise.

2010

2011
0

2012
0

January-June

2013
0

2014
0

2015
0

2016
0

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 14

II-7b. End uses.--Report your firm’s commercial U.S. shipments in 2015 by end use.
Quantity (in 1,000 pounds); value ($1,000)
Calendar year 2015
Item

Sold to
distributors

Sold to end
users

Total

U.S. commercial shipments for use in
plumbing applications/ end uses.-Quantity (O)

Value (P)

U.S. commercial shipments for use in
industrial pipe applications/ end uses.-Quantity (Q)

Value (R)

U.S. commercial shipments for use in all
other applications/ end uses.-Quantity (S)

Value (T)
Total U.S. commercial shipments.-Quantity (U)
Value (V)

0
0

RECONCILIATION OF END USES.--Please ensure that the quantities reported for end use
applications by quantity (i.e., lines O, Q, and S) and value (i.e., lines P, R, and T) equal the
quantity reported for commercial U.S. commercial shipment quantity (i.e., line D) and value
(i.e., line E) in 2015. 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 item
Quantity reconciliation: O + Q + S – D =
zero ("0"), or revise
Value reconciliation: P + R + T – E = zero
("0"), or revise

Calendar year 2015
0
0

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-8.

Page 15

Employment data.--Report your firm’s employment-related data related to the production of
SRC pipe and tube 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 year
Item

2010

2011

2012

2013

January-June
2014

2015

2016

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

II-9.

Transfers to related firms.--If your firm reported transfers to related firms in question II-8,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non-market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-10.

Page 16

Purchases.--Other than direct imports, has your firm otherwise purchased SRC pipe and tube
since January 1, 2010?
No

Yes-- Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity
and value of such purchases below for the specified periods.

“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.
Reason for purchases:

Quantity (in 1,000 pounds)
Calendar years
Item

2010

2011

2012

2013

January-June
2014

2015

2016

Purchases from U.S.
importers1 of SRC pipe
and tube from—
China
Mexico
All other sources
Purchases from
domestic producers2
Purchases from other
sources2
1

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

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
II-11.

Page 17

Toll production.--Since January 1, 2010, has your firm been involved in a toll agreement
regarding the production of SRC pipe and tube?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No

II-12.

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

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

(a)

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

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

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

(b)

No/Don’t know

II-13.

Yes--Identify the firms and the FTZs.

Direct imports.--Since January 1, 2010, has your firm imported SRC pipe and tube?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No

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

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 18

For questions II-14 and II-15, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II-14.

Effect of order.--Describe the significance of the existing antidumping duty orders covering
imports of SRC pipe and tube from China and Mexico 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 order.

II-15.

Likely effect of revocation of order.--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 SRC pipe and tube in the future if the antidumping duty orders on
SRC pipe and tube from China and Mexico were to be revoked?
No

II-16.

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

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube

Page 19

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

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 SRC pipe and tube:

2.
3.

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

Page 20

III-4.

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

III-5.

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

Share of sales

SRC pipe and tube

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of SRC pipe and tube 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 SRC pipe and
tube 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

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
III-8.

Page 21

Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in III-9a (financial results on SRC pipe and tube) 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.

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 22

III-9a. Operations on SRC pipe and tube.--Report the revenue and related cost information requested
below on the SRC pipe and tube 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 six most recently completed fiscal years, and for the specified interim periods. If your firm
was involved in tolling operations (either as the toller or as the tollee), please contact Jennifer
Brinckhaus at (202) 205-3188 before completing this section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended-Item

2010

2011

2012

2013

2014

2015

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

Total COGS

Gross profit or (loss)

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

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 – SRC pipe and tube

Page 23

III-9a. Operations on SRC pipe and tube.--Continued
Quantity (in 1,000 pounds) and value (in $1,000)
Item

January-June 2015

January-June 2016

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

Total COGS

Gross profit or (loss)

Total net sales quantities
2

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

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

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 – SRC pipe and tube

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-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-9a line item where the nonrecurring items are included, a brief description
of the relevant nonrecurring items, and the associated values (in $1,000), as reflected in table
III-9a; i.e., if an aggregate nonrecurring item has been allocated to table III-9a, only the allocated
value amount included in table III-9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in table III-9a.
Fiscal years ended-2010

2011

2012

2013

January-June
2014

2015

2016

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

, classified as

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 25

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

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of SRC pipe and tube. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for SRC pipe and
tube 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 III9a. Provide data as of the end of your firm’s six 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

Describe

2010
1

2011

2012

2013

2014

2015

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 26

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for SRC pipe and tube. Provide data for
your firm’s six most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended-Item

2010

Capital expenditures

2011

2012

2013

January-June
2014

2015

2016

Research and
development
expenses2
1
2

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-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 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

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.

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube

Page 27

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Giamalva (202-2053329, [email protected]).
IV-1.

PRICE DATA
IV-2.

IV-2. This section requests quarterly quantity and value data, f.o.b. your U.S. point of
shipment, for your commercial shipments to unrelated U.S. customers during January 2007–
June 2010 of the following products produced by your firm.
Product 1.-- Seamless refined copper pipe and tube, 1/2” Type L, hard temper, 20’ lengths
Product 2.-- Seamless refined copper pipe and tube, 3/8” OD, ACR/RST coil, 50’-100’ lengths
Product 3.-- Seamless refined copper pipe and tube, 3/4” OD, ACR/RST coil, 50’-100’ lengths
Product 4.-- Seamless refined copper pipe and tube, 3/8" OD, smooth bore LWC, 0.0249"0.0327" bottom wall thickness
Product 5.-- Seamless refined copper pipe and tube, 3/4" OD, smooth bore LWC, 0.0327"0.0430" bottom wall thickness
Product 6.-- Seamless refined copper pipe and tube, 3/8" OD, inner-grooved LWC, 0.0110"0.0144" bottom wall thickness

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).
(a) During January 2010 -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.

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 28

IV-2(b). Price data: Plumbing.--Report below the quarterly price data1 for pricing products2 produced
and sold by your firm for use in plumbing applications.

PLUMBING APPLCIATIONS

Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
Product 1
Period of shipment
2010:
January-March
April-June
July-September
OctoberDecember
2011:
January-March
April-June

Quantity

(Quantity in pounds, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Quantity

Value

July-September
OctoberDecember
2012:
January-March
April-June
July-September
OctoberDecember
2013:
January-March
April-June
July-September
OctoberDecember
2014:
January-March
April-June
July-September
OctoberDecember
2015:
January-March
April-June
July-September
OctoberDecember
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 the
product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 29

IV-2(b). Price data: Plumbing.--Report below the quarterly price data1 for pricing products2 produced
and sold by your firm for use in plumbing applications.

PLUMBING APPLCIATIONS

Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
Product 4
Period of shipment
2010:
January-March
April-June
July-September
OctoberDecember
2011:
January-March
April-June

Quantity

(Quantity in pounds, value in dollars)
Product 5
Value
Quantity
Value

Product 6
Quantity

Value

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 30

IV-2(c). Price data: Industrial.--Report below the quarterly price data1 for pricing products2 produced
and sold by your firm for use in industrial applications.

INDUSTRIAL APPLCIATIONS

Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
Product 1
Period of shipment
2010:
January-March
April-June
July-September
OctoberDecember
2011:
January-March
April-June

Quantity

(Quantity in pounds, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Quantity

Value

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 31

IV-2(c). Price data: Industrial.--Report below the quarterly price data1 for pricing products2 produced
and sold by your firm for use in industrial applications.

INDUSTRIAL APPLCIATIONS

Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
Product 4
Period of shipment
2010:
January-March
April-June
July-September
OctoberDecember
2011:
January-March
April-June

Quantity

(Quantity in pounds, value in dollars)
Product 5
Value
Quantity
Value

Product 6
Quantity

Value

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 32

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.

IV-3.

Price setting.-- How does your firm determine the prices that it charges for sales of SRC pipe and
tube (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 SRC pipe and tube?
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 SRC pipe and tube usually quoted
(check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
IV-6.

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

Share of 2015
sales
IV-7.

Page 33

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

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 SRC pipe and tube?

Source

Share of 2015
sales

From inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

Lead time (days)

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
IV-9.

Page 34

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced SRC
pipe and tube that is accounted for by U.S. inland transportation costs?
%

(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 SRC pipe and tube that are
delivered the following distances from your firm’s production facility.
Distance from production facility

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 SRC pipe and tube since January 1, 2010 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 35

IV-11. End uses.-(a)
use

List the end uses of the SRC pipe and tube that your firm manufactures. For each endproduct, what percentage of the total cost is accounted for by SRC pipe and tube and
other inputs?
Share of total cost of end use product
accounted for by
End use product

(b)

SRC pipe and tube

Other inputs

Total
(should sum to
100.0% across)

0.0 %

Have there been any changes in the end uses of SRC pipe and tube since January 1,
2010? Do you anticipate any future changes?

Changes in end
uses
Changes since
January 1, 2010
Anticipated
changes

Yes

Explain

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 36

IV-12. Substitutes.-(a)

Can other products be substituted for SRC pipe and tube?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for SRC pipe and tube?
No Yes

Explanation

1.
2.
3.

(b)

Have there been any changes in the number or types of products that can be
substituted for SRC pipe and tube since January 1, 2010? Do you anticipate any future
changes?
Changes in
substitutes

Changes since
January 1, 2010
Anticipated
changes

No Yes

Explain

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 37

IV-13. Availability of supply.--Has the availability of SRC pipe and tube in the U.S. market changed
since January 1, 2010? Do you anticipate any future changes?
Availability in the U.S.
market

Please explain, noting the countries and reasons for the
No Yes changes.

Changes since January 1, 2010:
U.S.-produced product
Subject imports
Nonsubject imports
Anticipated changes:
U.S.-produced product
Subject imports
Nonsubject imports

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 38

IV-14. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for SRC pipe and tube has changed since January 1, 2010, 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

Overall
increase

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Demand since January 1, 2010
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 SRC pipe and tube since January 1, 2010? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2010
Anticipated
changes

Explain

Business Proprietary
U.S. Producers’ Questionnaire – SRC pipe and tube
IV-16.

Page 39

Conditions of competition.-(a) Is the SRC pipe and tube market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to SRC pipe and tube?
Check all that apply.

Please describe.

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
SRC pipe and tube since January 1, 2010?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply SRC pipe and
tube since January 1, 2010 (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.

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 40

IV-18. Raw materials.-- Indicate how SRC pipe and tube raw material prices have changed since
January 1, 2010, and how you expect they will change in the future.
Fluctuate
with no
clear
Raw materials Overall
No
Overall
prices
increase change decrease trend

Explain, noting how raw material
price changes have affected your
firm’s selling prices for seamless
refined copper pipe and tube.

Refined copper scrap prices
Changes since
January 1, 2010
Anticipated
changes
Copper cathode prices
Changes since
January 1, 2010
Anticipated
changes
IV-19. Price comparisons.--Please compare market prices of SRC pipe and tube 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 SRC pipe and tube 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/or Mexico, and (3)
the world as a whole. Of particular interest is such data from 2010 to the present and forecasts
for the future.
IV-21. Export constraints.--Describe how easily your firm can shift its sales of SRC pipe and tube
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 SRC pipe and tube between the U.S. and alternative country markets within a
12-month period.

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Page 41

IV-22. Barriers to trade.--Are your firm’s exports of SRC pipe and tube subject to any tariff or non-tariff
barriers to trade in other countries?

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,
2010, or that are expected to occur in the future.

IV-23. Interchangeability.--Is SRC pipe and tube 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

Mexico

Other countries

United States
China
Mexico
For any country-pair producing SRC pipe and tube that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 42

IV-24. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between SRC pipe and tube
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

Mexico

Other countries

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

IV-25. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 43

PART V.-- COMPARABILITY.
V-1. Comparability of industrial and plumbing seamless refined copper pipe and tube.
(a) Do industrial and plumbing seamless refined copper pipe and tube have the same physical
characteristics?

Yes

Please describe the similarities and/or differences between the physical
characteristics.

(b) Are industrial and plumbing seamless refined copper pipe and tube interchangeable?

Yes

Please describe what makes these two products interchangeable or not
interchangeable.

(c) Are the manufacturing processes to produce industrial seamless refined copper pipe and tube
similar to those to produce plumbing seamless refined copper pipe and tube?

Yes

Please describe the similarities and/or differences in manufacturing
processes.

(d) Do industrial and plumbing seamless refined copper pipe and tube share the same channels of
distribution?

Yes

Please describe the similarities and/or differences in the channels of
distribution.

(e) Do you or your customers perceive industrial seamless refined copper pipe and tube and
plumbing seamless refined copper pipe and tube to be similar products?
No

Yes

Please describe the similarities and/or differences.

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 44

(f) What share of your firms U.S. sales of seamless refined copper pipe and tube are cleaned and
capped, by market segment?
Share of seamless refined copper pipe and
tube that is cleaned and capped
Market segment

Cleaned and capped

Other

Total
(should sum to
100.0% across)

Plumbing

0.0 %

Industrial

0.0 %

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U.S. Producers’ Questionnaire – SRC pipe and tube

Page 45

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/secretary/fed_reg_notices/meetings/documents/sunset_us_pro
ducer_questionnaire.pdf
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: SRCP

• 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 Type	application/pdf
File Title	US Producer questionnaire - sunst
Author	Sherman, Amy
File Modified	2016-06-30
File Created	2016-06-30