16-1-3543 U.S. Producers' Questionnaire

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

ESBR (P)--US producer

Emulsion Styrene-Butadiene Rubber from Brazil, Korea, Mexico, and Poland

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 16-1-3543; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN EMULSION STYRENE-BUTADIENE RUBBER
This questionnaire must be received by the Commission by August 4, 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 antidumping investigations concerning emulsion styrene-butadiene rubber (“ESBR”) from Brazil,
Korea, Mexico, and Poland (Inv. Nos. 731-TA-1334-1337 (Preliminary)). The information requested in the questionnaire
is requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as
directed can result in a subpoena or other order to compel the submission of records or information in your firm’s
possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

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

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

YES

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

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

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

Business Proprietary
U.S. Producers’ Questionnaire - ESBR (Preliminary)

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PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to petitions filed on July 21, 2016, by Lion
Elastomers LLC (Port Neches, TX) and East West Copolymer, LLC (Baton Rouge, LA). Antidumping duties
may be assessed on the subject imports as a result of these proceedings if the Commission makes an
affirmative determination of injury, threat, or material retardation, and if the U.S. Department of
Commerce makes an affirmative determination of dumping. Questionnaires and other information
pertinent to this proceeding are available at

https://www.usitc.gov/investigations/701731/2016/emulsion_styrene_butadiene_rubber_brazil_korea/preliminary.htm

Certain emulsion styrene-butadiene rubber (“ESBR”). The product covered by these investigations is
emulsion styrene-butadiene rubber, regardless of form. ESBR consists of cold non-pigmented rubbers
and cold oil extended non-pigmented rubbers that contain at least one percent of organic acids from the
emulsion polymerization process. ESBR is produced and sold in accordance with a generally accepted set
of product specifications issued by the International Institute of Synthetic Rubber Producers (“IISRP”).
The scope of these investigations covers grades of ESBR included in the IISRP 1500 and 1700 series of
synthetic rubbers. The 1500 grades are light in color and are often described as “Clear” or “White
Rubber.” The 1700 grades are oil-extended and thus darker in color, and are often called “Brown
Rubber.” Specifically excluded from the scope of these investigations are products which are
manufactured by blending ESBR with other polymers, high styrene resin master batch, carbon black
master batch (i.e., IISRP 1600 series and 1800 series) and latex (an intermediate product).
The products subject to these investigations are currently imported under the following Harmonized
Tariff Schedule of the United States (“HTSUS”) provisions: 4002.19.0015 and 4002.19.0019. ESBR is
described by Chemical Abstract Services (“CAS”) Registry No. 9003- 55-8. This CAS number also refers to
other types of styrene butadiene rubber. Although the HTSUS subheadings and CAS registry number are
provided for convenience and customs purposes, the written description of the scope of these
investigations is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.

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

Business Proprietary
U.S. Producers’ Questionnaire - ESBR (Preliminary)
I-1a.

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 Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

I-1b.

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

I-2.

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 ESBR, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
I-3.

Page 5

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

Support

Oppose

Take no position

Brazil
Korea
Mexico
Poland
I-4.

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

Firm name

I-5.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing ESBR from Brazil, Korea, Mexico, and Poland into the
United States or that are engaged in exporting ESBR from Brazil, Korea, Mexico, and Poland to
the United States?
No
Firm name

I-6.

Yes--List the following information.

Yes--List the following information.
Address

Affiliation

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

Yes--List the following information.
Address

Affiliation

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nathanael Comly
([email protected], 202-205-3174). 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 ESBR since January 1, 2013.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
II-3a.

Page 7

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce ESBR, 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 years
Item

2013

2014

January-June
2015

2015

2016

Overall production capacity
Production of:
ESBR1

Carbon black master batch
(“CBMB”)
Solution styrene-butadiene
rubber (“SSBR”)
Other products2
Total
1
2

Data entered for production of ESBR will populate here once reported in question II-7.
Please identify these products:
.

II-3b.

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

II-3c.

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

II-3d.

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

hours

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
II-3e.

Page 8

Product shifting.—
(i)

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

(ii)

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

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
II-4.

Page 9

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

II-5.

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

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

(b)

No/Don’t know

II-6.

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2013, has your firm imported ESBR?
“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 - ESBR (Preliminary)
II-7.

Page 10

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

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Production, shipment and inventory data.--

II-7.

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

2013

2014

January-June
2015

2015

2016

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2

Value (G)
Transfers to related firms:
Quantity (H)
2

Value (I)
Export shipments:
Quantity (J)

Value (K)
4

End-of-period inventories (quantity) (L)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above:
.
3
Identify your firm’s principal export markets:
.

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

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

2013

2014

January-June
2015

2015

2016

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

0
.

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
II-8.

Page 12

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

2013

2014

January-June
2015

2015

2016

U.S. shipments:
Commercial shipments:
To distributors (quantity) (M)
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 years
Reconciliation
M + N – D = zero ("0"), if not revise.

2013

2014
0

January-June
2015

2015
0

2016
0

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
II-8.

Page 13

U.S. shipments by product type.--Report your firm’s U.S. shipments by type of ESBR.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item

2013

2014

January-June
2015

2015

2016

U.S. shipments:
Commercial shipments:
1500-series ESBR:
Quantity (O)
Value (P)
1700-series ESBR:
Quantity (Q)
Value (R)
All other in-scope ESBR:
Quantity (S)
Value (T)
Internal consumption and
transfers to related firms:
1500-series ESBR:
Quantity (U)
Value (V)
1700-series ESBR:
Quantity (W)
Value (X)
All other in-scope ESBR:
Quantity (Y)
Value (Z)
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 years
Reconciliation
Commercial shipments:
Quantity: O + Q + S – D = zero
("0"), if not revise.

2013

2014

January-June
2015

2015

2016

Value: P + R + T – D = zero ("0"), if
not revise.

Internal consumption/transfers:
Quantity: U + W + Y – F – H = zero
("0"), if not revise.

Value: V + X + Z – G – I = zero

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
("0"), if not revise.

Page 14

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II-9.

Page 15

Employment data.--Report your firm’s employment-related data related to the production of
ESBR and provide an explanation for any trends in these data.
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.

Calendar years
Item

2013

2014

January-June
2015

2015

2016

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

II-10.

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
II-11.

Page 16

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

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

(Quantity in 1,000 pounds)
Calendar years
Item

2013

2014

January-June
2015

2015

2016

Purchases from U.S.
importers of ESBR from—
Brazil1
Korea2
Mexico3
Poland4
All other sources (AOS)5
Purchases from domestic
producers6
Purchases from other
sources6
1

Please list the name of the importer(s) from which your firm purchased Brazilian product:
.
Please list the name of the importer(s) from which your firm purchased Korean product:
.
3
Please list the name of the importer(s) from which your firm purchased Mexican product:
.
4
Please list the name of the importer(s) from which your firm purchased Polish product:
.
5
Please list the name of the importer(s) from which your firm purchased AOS product:
.
6
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
2

II-12.

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

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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 ESBR:

Does your firm prepare profit/loss statements for ESBR:
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 ESBR, 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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Page 18

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 produced in the facilities in which your firm
produced ESBR, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products

Share of sales

ESBR

%
%
%
%
%

III-6.

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

Related supplier

Share of total COGS

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
III-8.

Page 19

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 20

III-9a. Operations on ESBR.--Report the revenue and related cost information requested below on the
ESBR operations of your firm’s U.S. establishment(s).1 Include both domestic and export sales of
ESBR, but do not report resales of purchased ESBR. 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 in chronological
order from left to right 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) 2053188 before completing this section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January-June

2015

2016

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.

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 21

III-9b. Operations on ESBR – U.S. commercial sales and exports only (“open market sales”).--Report
the revenue and related cost information requested below on the ESBR operations of your
firm’s U.S. establishment(s).1 Include both domestic and export commercial sales of ESBR, but
do not report resales of purchased ESBR. 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 in chronological order from left
to right 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

2013

2014

January-June

2015

2016

Net sales quantities:
Commercial sales quantities from III-9a

Total COGS

Gross profit or (loss)

Net sales values:
Commercial sales values from III-9a
Cost of goods sold (COGS):
Raw materials

Direct labor
Other factory costs

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 - ESBR (Preliminary)
III-9c.

Page 22

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.

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 or III9b, please specify all material (significant) nonrecurring items (charges and gains) in the
schedule below, the specific table III-9a or 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-9a or III-9b; i.e., if an aggregate nonrecurring item has been
allocated to table III-9a or III-9b, only the allocated value amount included in table III-9a or 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 the reported
financial results of the subject product in table III-9a and III-9b.
Fiscal years ended--

2013

2014

January-June

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

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Page 23

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 or III-9b.

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

III-13.

2013

2014

2015

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for ESBR. 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

2016

Total capital expenditures

Research and development expenses
1

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.

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 24

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

Fiscal year

Specify fiscal year

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

If no, please explain.

III-15a. Effects of imports on investment.--Since January 1, 2013, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of ESBR from Brazil, Korea, Mexico, and Poland?
No

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

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

Yes

If yes, indicate which country and why:

(please describe)

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Page 25

III-16a. Effects of imports on growth and development.--Since January 1, 2013, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of ESBR from Brazil, Korea, Mexico, and Poland?
No

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

Lowering of credit rating

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

Other

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

Yes

If yes, indicate which country and why:

(please describe)

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Page 26

III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
ESBR from Brazil, Korea, Mexico, and Poland?
No

Yes

If yes, my firm anticipates negative effects as follows:

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

Yes

If yes, indicate which country and why:

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 27

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Emily Burke (202-205-3191,
[email protected]).
IV-1.

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

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2013 of the following products produced by your
firm.
Product 1.--IISRP 1502 grade of ESBR in all forms
Product 2.--IISRP 1507 grade of ESBR in all forms
Product 3.--IISRP 1712 grade of ESBR in all forms
Product 4.--IISRP 1783 grade of ESBR in all forms

Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
During January 2013-June 2016, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question IV-3.

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
IV-2.

Page 28

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Please indicate what physical form each pricing product takes in the ‘Note’ section.

Report data in actual pounds and actual dollars (not 1,000s).
Product 1
Quantity
Value

(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

Product 4
Period of shipment
Quantity
Value
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
your firm’s product. Also, please indicate the physical form of each product and explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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 - ESBR (Preliminary)
IV-3.

Price setting.--How does your firm determine the prices that it charges for sales of ESBR (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 29

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 ESBR?
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 ESBR usually quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced ESBR
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
Short-term
Annual
Total
contracts
contracts
contracts
Spot sales
(should
(multiple
(multiple
(multiple
(for a single
sum to
deliveries for
deliveries for
deliveries for 12
delivery)
100.0%)
more than 12
less than 12
months)
months)
months)
Share of 2015
%
%
%
%
0.0 %
sales

IV-6.

Business Proprietary
U.S. Producers’ Questionnaire - ESBR (Preliminary)
IV-7.

Page 30

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced ESBR (or check “not applicable” if your firm does not sell on a long-term, shortterm 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 your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced ESBR?

Source

Share of 2015 Lead time (average
sales
number of days)

From inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

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U.S. Producers’ Questionnaire - ESBR (Preliminary)
IV-9.

Page 31

Shipping information.-(a)

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

(b)

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

(c)

Indicate the approximate percentage of your firm’s sales of ESBR that are delivered the
following distances from its 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 ESBR 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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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 32

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

ESBR

Tires

Total
(should sum to
100.0% across)

Other inputs
%

0.0 %

IV-12. Substitutes.-- Can other products be substituted for ESBR?
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 ESBR?
No Yes

Explanation

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

Market

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within
the United
States
Outside
the United
States
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of ESBR since January 1, 2013?
No

Yes

If yes, please describe and quantify if possible.

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 33

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

Please describe.

Skip to question IV-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
ESBR since January 1, 2013?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply ESBR since
January 1, 2013 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, been unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

IV-17. Raw materials.--How have ESBR raw material prices changed since January 1, 2013?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for ESBR.

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Page 34

IV-18. Interchangeability.--Is ESBR 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
0 = no familiarity with products from a specified country-pair
Countrypair

Brazil

Korea

Mexico

Poland

China

Germany

Other
countries

United
States
Brazil
Korea
Mexico
Poland
China
Germany
For any country-pair producing ESBR 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 - ESBR (Preliminary)

Page 35

IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between ESBR produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Countrypair

Brazil

Korea

Mexico

Poland

China

Germany

Other
countries

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

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 36

IV-20. Interchangeability of products.-- Are certain grades of ESBR interchangeable with each other
and/or interchangeable with certain out-of-scope related products (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 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

Product-pair
1700 series ESBR

All other ESBR

Solution styrenebutadiene rubber
(“SSBR”)

Carbon black
master batch
(“CBMB”)

1500 series ESBR
1700 series ESBR
All other ESBR
SSBR
For any product-pair that is sometimes or never interchangeable, identify the product-pair
and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 37

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

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Telephone

City

State

Share
of
2015
sales
(%)

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U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 38

IV-22. Competition from imports
(a)

Lost revenue.--Since January 1, 2013: To avoid losing sales to competitors selling ESBR
from Brazil, Korea, Mexico, and Poland, did your firm:
No
Yes
Reduce prices
Roll back announced price increases

(b)

Lost sales.--Since January 1, 2013: Did your firm lose sales of ESBR to imports of this
product from Brazil, Korea, Mexico, and Poland?
No

(c)

Yes

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

IV-22. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire - ESBR (Preliminary)

Page 39

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2016/emulsion_styrene_butadiene_rubber_brazil_korea/preli
minary.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: ESBR

• 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	USITCQUESTIONNAIRE
Subject	Title 7 investigations
Author	Nate Comly
File Modified	2016-07-26
File Created	2016-07-26