Form 16-1-3531 U.S. Producers Questionnaire

OMB No. 3117-0016/USITC No. 16-1-3531; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
IRON CONSTRUCTION CASTINGS FROM BRAZIL, CANADA, AND CHINA
This questionnaire must be received by the Commission by August 19, 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 countervailing and antidumping duty orders concerning iron construction castings from
Brazil, Canada, and China (Inv. Nos. 701-TA-249 and 731-TA-262, 263, and 265 (Fourth 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 iron construction castings (as defined on the next page) at any time since January 1,
2010?

NO

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

YES

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

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

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 2

PART I.—GENERAL INFORMATION
Background. The Department of Commerce issued antidumping duty orders on imports of “heavy” and
“light” iron construction castings from Canada on March 5, 1986 and from Brazil and China on May 9,
1986. On May 15, 1986, Commerce issued a countervailing duty order on imports of “heavy” iron
construction castings from Brazil. On September 23, 1998, Commerce issued the final results of a
changed circumstance review concerning iron construction castings from Canada, in which the
antidumping duty order with respect to ‘‘light’’ castings was revoked. On October 1, 2015, the
Commission instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c))
(the Act) to determine whether revocation of the orders would be likely to lead to continuation or
recurrence of material injury to the domestic industry within a reasonably foreseeable time. If both the
Commission and Commerce make affirmative determinations, the orders will remain in place. If either
the Commission or Commerce makes negative determinations, the Department of Commerce will
revoke the orders. Questionnaires and other information pertinent to this proceeding are available
at https://www.usitc.gov/investigations/701731/2015/iron_construction_castings_brazil_canada_and_c
hina/fourth_review_full.htm
Iron construction castings covered by these reviews consist of heavy castings and light castings.
Heavy castings -- manhole covers, rings, and frames, catch basin grates and frames, cleanout covers and
frames used for drainage or access purposes for public utility, water and sanitary systems, collectively
imported under Harmonized Tariff Schedule (HTS) statistical reporting number 7325.10.0010 until 1999.
Starting in 2000, heavy castings were imported under the following statistical reporting numbers:
7325.10.0010, 7325.10.0020, and 7325.10.0025. Heavy castings may also be imported under HTS
statistical reporting number 7325.10.0080 as “other.” Heavy castings from Brazil are subject to both
antidumping and countervailing duty orders. Heavy castings from Canada and China are subject to
antidumping duty orders.
Light castings -- valve, service, and meter boxes which are placed below ground to encase water, gas, or
other valves, or water and gas meters. These types of light castings were imported under HTS statistical
reporting number 7325.10.0050 until 1999. Starting in 2000, these light castings were imported under
the following two reporting numbers: 7325.10.0030 and 7325.10.0035. Light castings may also be
imported under HTS statistical reporting number 7325.10.0080 as “other.” Light castings from Brazil and
China are subject to antidumping duty orders.
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

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 3

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.
I-1.

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.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
I-2.

Page 4

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 iron construction castings,
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

I-3.

Additional discussion on establishments consolidated in this questionnaire:

Position regarding continuation of orders.--Does your firm support or oppose continuation of
the antidumping and/or countervailing duty orders currently in place for iron construction
castings from the following countries?
Country
Heavy castings:
Brazil (CVD)
Brazil (AD)
Canada (AD)
China (AD)
Light castings:
Brazil (AD)
China (AD)

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
I-4.

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

Firm name

I-5.

Page 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 iron construction castings from Brazil, Canada, and/or
China into the United States or that are engaged in exporting iron construction castings from
Brazil, Canada, and/or China to the United States?
No
Firm name

Yes--List the following information.
Address

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
I-6.

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, that are engaged in importing iron construction castings from countries
other than Brazil, Canada, and/or China into the United States or that are engaged in exporting
iron construction castings from countries other than Brazil, Canada, and/or China 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 iron construction castings?
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 iron construction
castings?

No

Yes

If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Porscha Stiger (202-2053241, [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 iron construction castings 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 – Iron Construction Castings
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 iron
construction castings 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 iron construction castings (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 order is 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 iron construction castings in the future if the countervailing
and antidumping duty orders on iron construction castings from Brazil, Canada, and China 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 iron construction castings (in 1,000 pounds) for
2016 and 2017.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
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 iron construction castings, 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

2013

2014

January-June
2015

2015

2016

Overall production
capacity
Production of:
Heavy castings1
1

Light castings

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Other products
Total
1

Data entered for production of iron construction castings will populate here once reported in
questions II-6a (heavy castings) and II-6c (light casting).
2
Please identify these products:
.

II-5b.

Operating parameters.--The production capacity reported in II-5a 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 – Iron Construction Castings
II-5e.

Page 10

Product shifting.--Is your firm able to switch production (capacity) between iron construction
castings 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-5g.

Production process.--What production process methods does your firm use to make light iron
construction castings?
Sand-cast method

Shell-mold method

Permanent-mold method

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
II-6.

Page 11

Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of iron construction castings 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 – Iron Construction Castings
II-6a.

Page 12

Production, shipment and inventory data (HEAVY CASTINGS).-Quantity (in 1,000 pounds) and value (in $1,000)
Calendar year
2013

Item

2014

January-June
2015

2015

2016

HEAVY CASTINGS

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 – Iron Construction Castings
II-6a.

Page 13

Production, shipment and inventory data (HEAVY CASTINGS).--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

2013

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

2014

0

January-June
2015

0

2015

0

2016

0

0

1

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

II-6b.

Channels of distribution (HEAVY CASTINGS).-- Report your firm’s commercial U.S. shipments by
channel of distribution.
Quantity (in 1,000 pounds)
Calendar year
2013

2014

January-June
2015

Item

2015

2016

HEAVY CASTINGS

Channels of
distribution:
U.S. commercial
shipments to
distributors
(quantity) (M)
U.S. commercial
shipments to end
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.

2013

2014
0

January-June
2015

0

2015
0

2016
0

0

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
II-6c.

Page 14

Production, shipment and inventory data (LIGHT CASTINGS).-Quantity (in 1,000 pounds) and value (in $1,000)
Calendar year
2013

Item

2014

January-June
2015

2015

2016

LIGHT CASTINGS

Average production
capacity1 (quantity) (O)
Beginning-of-period
inventories (quantity)
(P)
Production (quantity)
(Q)
U.S. shipments:
Commercial
shipments:
quantity (R)
value (S)
Internal
consumption:2
quantity (T)
value (U)
Transfers to related
firms:2
quantity (V)
value (W)
Export shipments:3
quantity (X)
value (Y)
End-of-period
inventories (quantity)
(Z)
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 – Iron Construction Castings
II-6c.

Page 15

Production, shipment and inventory data (LIGHT CASTINGS).--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line Z) should be equal to the beginning-of-period inventories (i.e., line P),
plus production (i.e., line Q), less total shipments (i.e., lines R, T, V, and X). 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

2013

P+Q–R–T–V–X–Z
= should equal zero
("0") or provide an
explanation.1

2014

0

January-June
2015

0

2015

0

2016

0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
II-6d.

Channels of distribution (LIGHT CASTINGS).-- Report your firm’s commercial U.S. shipments by
channel of distribution.
Quantity (in 1,000 pounds)
Calendar year
2013

2014

January-June
2015

Item

2015

2016

LIGHT CASTINGS

Channels of
distribution:
U.S. commercial
shipments to
distributors
(quantity) (AA)
U.S. commercial
shipments to end
users (quantity)
(AB)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines AA and BB) in each time period equal the quantity reported for commercial U.S. commercial
shipments (i.e., line R) 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
AA + AB – R = zero
("0"), if not revise.

2013

2014
0

January-June
2015

0

2015
0

2016
0

0

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
II-7.

Page 16

Employment data.--Report your firm’s employment-related data related to the production of
iron construction castings 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
2013
Item

2014

January-June
2015
HEAVY CASTINGS

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

2015

2016

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
II-7.

Page 17

Employment data.--Continued
Calendar year
2013
Item

2014

January-June
2015

2015

2016

LIGHT CASTINGS

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

II-8.

Transfers to related firms.--If your firm reported transfers to related firms in question II-6a or II6c, 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 – Iron Construction Castings
II-9a.

Page 18

Purchases (HEAVY CASTINGS).--Other than direct imports, has your firm otherwise purchased
heavy castings since January 1, 2013?
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
2013
Item

2014

2015

January-June
2015

2016

HEAVY CASTINGS

Purchases from U.S.
importers1 of heavy
castings from—
Brazil
Canada
China
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 – Iron Construction Castings
II-9b.

Page 19

Purchases (LIGHT CASTINGS).--Other than direct imports, has your firm otherwise purchased
light castings since January 1, 2013?
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
2013
Item

2014

2015

January-June
2015

2016

LIGHT CASTINGS

Purchases from U.S.
importers1 of light
castings from—
Brazil
China
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 – Iron Construction Castings
II-10.

Page 20

Toll production.--Since January 1, 2013, has your firm been involved in a toll agreement
regarding the production of iron construction castings?
“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-11.

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

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce iron construction castings in and/or
admit iron construction castings 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 iron construction castings into a foreign trade zone (FTZ) for use in distribution of
iron construction castings and/or the production of downstream articles?

(b)

No/Don’t know

II-12.

Yes--Identify the firms and the FTZs.

Direct imports.--Since January 1, 2013, has your firm imported iron construction castings?
“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 – Iron Construction Castings

Page 21

For questions II-13 and II-14, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II-13.

Effect of order(s).--Describe the significance of the existing countervailing and antidumping duty
orders covering imports of iron construction castings from Brazil, Canada, and China in terms of
their effect on your firm’s production capacity, production, U.S. shipments, inventories,
purchases, employment, revenues, costs, profits, cash flow, capital expenditures, research and
development expenditures, and asset values. You may wish to compare your firm’s operations
before and after the imposition of the orders.

II-14.

Likely effect of revocation of order(s).--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 iron construction castings in the
future if the countervailing and antidumping duty orders on iron construction castings from
Brazil, Canada, and China were to be revoked?
No

II-15.

Yes--Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation for any trends or
projections you may provide.

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 – Iron Construction Castings

Page 22

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202-7084725, [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 iron construction castings:

2.
3.

4.

Does your firm prepare profit/loss statements for iron construction castings:
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 iron construction
castings, as well as specific statements and worksheets) used to compile these data.

III-3.

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

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 23

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
iron construction castings, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products

Share of sales

Heavy castings

%

Light castings

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of iron construction castings 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 iron
construction castings that your firm purchases from related suppliers and that are reflected in
table III-9a and/or table III-9b. 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 – Iron Construction Castings
III-8.

Page 24

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 heavy castings) and/or
III-9b (financial results on light castings) 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 and/or III-9b.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 25

III-9a. Operations on HEAVY castings.--Report the revenue and related cost information requested
below on the heavy castings operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact David
Boyland at (202) 708-4725 before completing this section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended--

2013

2014

January-June

2015

2015

2016

HEAVY CASTINGS

Item
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 – Iron Construction Castings

Page 26

III-9b. Operations on LIGHT castings.--Report the revenue and related cost information requested
below on the heavy castings operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact David
Boyland at (202) 708-4725 before completing this section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended--

2013

2014

January-June

2015

Item

2015

2016

LIGHT CASTINGS

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 – Iron Construction Castings

Page 27

III-9c. Financial data reconciliation.--The calculable line items from question III-9a and III-9b (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.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 28

III-10a. Nonrecurring items (charges and gains) included in financial results on heavy castings.--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 reported financial results 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-10b. Nonrecurring items (charges and gains) included in financial results on light castings.--For each
annual and interim period for which financial results are reported in question III-9b, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-9b 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-9b; i.e., if an aggregate nonrecurring item has been allocated to table III-9b, only the allocated
value amount included in table III-9b 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 reported financial results in table III-9b.
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-9b.
specific line item in table III-9b 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

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 29

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-10a and/or III-10b
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 questions III-10a and/or III10b identify where these items are reported in table III-9a and/or III-9b.

III-12. Asset values (heavy castings and light castings).--Report the total assets (i.e., both current and
long-term assets) associated with the production, warehousing, and sale of heavy castings and
light castings, respectively. If your firm does not maintain some or all of the specific asset
information necessary to calculate total assets for heavy castings and light castings 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 and/or
III-9b. 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 heavy and light castings, respectively, if these
assets are also related to other products. Please provide a brief explanation if there are any
substantial changes in total asset value during the period; e.g., due to asset write-offs,
revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item

2013
1

Total assets (heavy castings) (net)
Total assets (light castings) (net)1
1
2

Describe
Describe

2014

2015

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 30

III-13. Capital expenditures and research and development (R&D) expenses (heavy castings and light
castings).--Report your firm’s capital expenditures and R&D expenses for heavy castings and
light castings, respectively. 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

1

Capital expenditures (heavy castings)
Capital expenditures (light castings)2
R&D expenses (heavy castings)3
R&D expenses (light castings)4
1

Please describe the nature, focus, and significance of your firm’s capital expenditures on heavy castings.
Please describe the nature, focus, and significance of your firm’s capital expenditures on light castings.
3
Please describe the nature, focus, and significance of your firm’s R&D expenses related to heavy castings.
4
Please describe the nature, focus, and significance of your firm’s R&D expenses related to light castings.
2

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

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a and/or III-9b should reconcile
with the data reported in question II-6a and/or II-6c (including export shipments) as long as they
are reported on the same calendar year basis.
Do these data in question III-9a and/or III-9b reconcile with data in question II-6a and/or II-6b?
Yes

No

If no, please explain.

III-15. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 31

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Andrew Knipe (202-2052390, [email protected]).
IV-1.

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

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products produced by your firm.
Product 1.-- Standard heavy duty manhole cover and frame assemblies of gray cast iron,
approximately 300 pounds weight (250 to 350 pounds actual weight)
(Heavy Casting).
Product 2.-- Standard light duty manhole cover and frame assemblies of gray cast iron,
approximately 150 pounds weight (140 to 160 pounds actual weight)
(Heavy Casting).
Product 3.-- Standard 5-1/4" valve boxes of gray cast iron for 4" through 12" valves; 2-piece
screw type; approximate height 27 to 37 inches; equivalent to Tyler 562-S, with lid
(Light Casting).
Product 4.-- Standard 5-1/4" valve boxes of gray cast iron for 4" through 12" valves; 2-piece
screw type; approximate height 40 to 60 inches; equivalent to Tyler 6644, with lid
(Light Casting).

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

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

Page 32

IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Period of shipment
Quantity
Value
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
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:
Product 4:

IV-2c. Pricing data methodology.-- Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
IV-3.

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

IV-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

IV-5.

Page 33

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 iron construction castings?
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 iron construction castings usually
quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
IV-6.

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

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

Share of 2015 sales
Heavy iron construction
castings
Light iron construction
castings
IV-7.

Page 34

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

Annual
contracts
(multiple
deliveries for
12 months)

Spot sales
(for a single
delivery)

Total
(should
sum to
100.0%)

%

%

%

%

0.0

%

%

%

%

%

0.0

%

Contract provisions.—
(a)

Please fill out the table regarding your firm’s typical sales contracts for U.S.-produced
heavy iron construction castings (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

Fixed quantity
and/or price
Meet or release
provision
Not applicable

No
Quantity
Price
Both
Yes
No

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

Annual contracts
(multiple
deliveries for 12
months)
365

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

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
IV-7.

Page 35

Contract provisions.—Continued
(b)

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

No

Not applicable

IV-8.

Lead times.--What is your firm’s share of sales from inventory vs. 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 iron construction castings?

Source

Share of 2015
sales

Heavy iron construction castings
From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

Light iron construction castings
From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

Lead time
(average number
of days)

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
IV-9.

Page 36

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced iron
construction castings that is accounted for by U.S. inland transportation costs?
Heavy iron construction castings
%
Light iron construction castings

%

(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 iron construction castings
that are delivered the following distances from your firm’s production facility.
Distance from your firm’s U.S. point of shipment

Share of 2015
sales

Heavy iron construction castings
Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

Distance from your firm’s U.S. point of shipment

Share of 2015
sales

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

√ if applicable

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IV-11. End uses.-(a)

Select among the following list the products made with the heavy and/or light iron
construction castings that your firm manufactures. For each end-use product, what
percentage of the total cost is accounted for by iron construction castings vs. other
inputs (such as labor, energy, and other raw materials)?
Share of total cost in each of the product(s)
your firm produces accounted for by

Product(s) made from iron
construction castings that
your firm manufactures

No

Yes

Iron construction
castings

Total
(should
sum to
100.0%
across)

Other inputs

Manhole covers, rings and
frames (heavy)

% +

%

=

0.0 %

Catch basins, grates and
frames (heavy)

% +

%

=

0.0 %

Cleanout covers and frames
(heavy)

% +

%

=

0.0 %

Valve and service boxes
(light)

% +

%

=

0.0 %

% +

%

=

0.0 %

% +

%

=

0.0 %

Meter boxes (light)
Other
(please describe:
(b)

)

Have there been any changes in the end uses of heavy and/or light iron construction
castings since January 1, 2010? Do you anticipate any future changes?

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

No

Yes

Explain

Business Proprietary
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IV-12. Substitutes.-(a)

Can other products be substituted for heavy iron construction castings?
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 heavy iron construction
castings?
No Yes

Explanation

1.
2.
3.
(b)

Can other products be substituted for light iron construction castings?
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 light iron construction
castings?
No Yes

Explanation

1.
2.
3.
(c)

Have there been any changes in the number or types of products that can be
substituted for iron construction castings 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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IV-13. Availability of supply.--Has the availability of iron construction castings in the U.S. market
changed since January 1, 2010? Do you anticipate any future changes?
Availability in the U.S.
market

No

Please explain, noting the countries and reasons for
Yes the changes.

Changes since January 1, 2010:
U.S.-produced product
Subject imports
Nonsubject imports
Anticipated changes:
U.S.-produced product
Subject imports
Nonsubject imports
IV-14. Demand trends.-(a)

Indicate how demand within the United States and outside of the United States (if
known) for heavy iron construction castings 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.
HEAVY CASTINGS

Market

Overall
increase

No
change

Fluctuate
Overall
with no
decrease clear trend
Demand since January 1, 2010

Within
the U.S.
Outside
the U.S.
Anticipated future demand
Within
the U.S.
Outside
the U.S.

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
(b)

Page 40

Indicate how demand within the United States and outside of the United States (if
known) for light iron construction castings 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.
LIGHT CASTINGS

Market

Overall
increase

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Demand since January 1, 2010
Within
the U.S.
Outside
the U.S.
Anticipated future demand
Within
the U.S.
Outside
the U.S.
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of iron construction castings since January 1, 2010? Do you anticipate any future
changes?
Changes in
product range,
product mix, or
marketing
Changes since
January 1, 2010
Anticipated
changes

No

Yes

Explain

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings
IV-16.

Page 41

Conditions of competition.-(a)

Is the iron construction castings market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to iron
construction castings?

Check all that apply.
No

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 iron construction castings since January 1, 2010?

No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply iron construction
castings 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.

IV-18. Raw materials.-- Indicate how iron construction castings raw material prices have changed since
January 1, 2010, and how you expect they will change in the future.

Raw
materials
prices
Changes since
January 1,
2010
Anticipated
changes

Fluctuate Explain, noting how raw material
with no price changes have affected your
clear
firm’s selling prices for iron
Overall
No
Overall
increase change decrease trend
construction castings.

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IV-19. Price comparisons.--Please compare market prices of iron construction castings in U.S. and nonU.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 iron construction castings
supply (including production capacity and capacity utilization) and demand in (1) the United
States, (2) each of the other major producing/consuming countries, including Brazil, Canada,
and/or China, 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 iron construction castings
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 iron construction castings between the U.S. and alternative country markets
within a 12-month period.

IV-22. Barriers to trade.--Are your firm’s exports of iron construction castings subject to any tariff or
non-tariff barriers to trade in other countries?

No

Yes

If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2010, or that are expected to occur in the future.

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IV-23. Interchangeability.-(a)

Are heavy iron construction castings 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

Brazil

Canada

China

Other countries

United States
Brazil
Canada
China
HEAVY CASTINGS
For any country-pair producing heavy iron construction castings that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

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IV-23. Interchangeability.--Continued
(b)

Are light iron construction castings produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?

Country pair

Brazil

China

Other countries

United States
Brazil
China
LIGHT CASTINGS
For any country-pair producing light iron construction castings that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire – Iron Construction Castings

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IV-24. Factors other than price.—
(a)

Are differences other than price (e.g., quality, availability, transportation network,
product range, technical support, etc.) between heavy iron construction castings
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

Brazil

Canada

China

Other countries

United States
Brazil
Canada
China
HEAVY CASTINGS
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of heavy iron construction castings, identify the country-pair and
report the advantages or disadvantages imparted by such factors:

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IV-24. Factors other than price.--Continued
(b)

Are differences other than price (e.g., quality, availability, transportation network,
product range, technical support, etc.) between light iron construction castings
produced in the United States and in other countries a significant factor in your firm’s
sales of the products?

Country pair

Brazil

China

Other countries

United States
Brazil
China
LIGHT CASTINGS
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of light iron construction castings, 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, including any distinction between heavy and
light construction castings that was not otherwise identified in the question(s), 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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Page 47

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website
at: https://www.usitc.gov/investigations/701731/2015/iron_construction_castings_braz
il_canada_and_china/fourth_review_full.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: IRON

• 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.