16-1-3559 U.S. Producers' Questionnaire

OMB No. 3117-0016/USITC No. 16-1-3559; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN CARBON AND ALLOY STEEL CUT-TO-LENGTH PLATE (“CTL PLATE”)
FROM AUSTRIA, BELGIUM, BRAZIL, CHINA, FRANCE, GERMANY,
ITALY, JAPAN, KOREA, SOUTH AFRICA, TAIWAN, AND TURKEY
This questionnaire must be received by the Commission by October 24, 2016
See last page for filing instructions.
NO EXTENSIONS WILL BE GIVEN. LATE QUESTIONNAIRES MAY NOT BE INCORPORATED.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning CTL plate from Austria, Belgium,
Brazil, China, France, Germany, Italy, Japan, Korea, South Africa, Taiwan, and Turkey (Inv. Nos. 701-TA-560-561 and 731TA-1317-1328 (Final)). The information requested in the questionnaire is requested under the authority of the Tariff Act
of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to
compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

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

NO
YES

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

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PART I.—GENERAL INFORMATION
Background.-- his proceeding was instituted in response to petitions filed on April 8, 2016, by
ArcelorMittal USA LLC (Chicago, Illinois), Nucor Corporation (Charlotte, North Carolina), and SSAB
Enterprises, LLC (Lisle, Illinois). Countervailing and/or antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes affirmative determinations of
injury, threat, or material retardation, and if the U.S. Department of Commerce makes affirmative
determinations of subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available at
https://usitc.gov/investigations/701731/2016/carbon_and_alloy_steel_cut_to_length_plate_austria/fin
al.htm
CTL plate covered by these investigations is certain carbon and alloy steel hot-rolled or forged flat plate
products not in coils, whether or not painted, varnished, or coated with plastics or other non-metallic
substances (cut-to-length plate). Subject merchandise includes plate that is produced by being cut-tolength from coils or from other discrete length plate and plate that is rolled or forged into a discrete
length. The products covered include (1) Universal mill plates (i.e., flat-rolled products rolled on four
faces or in a closed box pass, of a width exceeding 150 mm but not exceeding 1250 mm, and of a
thickness of not less than 4 mm, which are not in coils and without patterns in relief), and (2) hot-rolled
or forged flat steel products of a thickness of 4.75 mm or more and of a width which exceeds 150 mm
and measures at least twice the thickness, and which are not in coils, whether or not with patterns in
relief. The covered products described above may be rectangular, square, circular or other shapes and
include products of either rectangular or non-rectangular cross-section where such non-rectangular
cross-section is achieved subsequent to the rolling process, i.e., products which have been ‘‘worked
after rolling’’, (e.g., products which have been beveled or rounded at the edges).
For purposes of the width and thickness requirements referenced above, the following rules apply:
(1) except where otherwise stated where the nominal and actual thickness or width measurements vary,
a product from a given subject country is within the scope if application of either the nominal or actual
measurement would place it within the scope based on the definitions set forth above unless the
product is already covered by an order existing on that specific country (e.g., orders on hot-rolled flatrolled steel); and
(2) where the width and thickness vary for a specific product (e.g., the thickness of certain products with
non-rectangular cross-section, the width of certain products with non-rectangular shape, etc.), the
measurement at its greatest width or thickness applies.
Steel products included in the scope of these investigations are products in which: (1) iron
predominates, by weight, over each of the other contained elements; and (2) the carbon content is 2
percent or less by weight.
Subject merchandise includes cut-to-length plate that has been further processed in the subject country
or a third country, including but not limited to pickling, oiling, levelling, annealing, tempering, temper
rolling, skin passing, painting, varnishing, trimming, cutting, punching, beveling, and/or slitting, or any
other processing that would not otherwise remove the merchandise from the scope of the
investigations if performed in the country of manufacture of the cut-to-length plate.
All products that meet the written physical description, are within the scope of these investigations
unless specifically excluded or covered by the scope of an existing order. The following products are
outside of, and/or specifically excluded from, the scope of these investigations:

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(1) products clad, plated, or coated with metal, whether or not painted, varnished or coated with plastic
or other non-metallic substances;
(2) military grade armor plate certified to one of the following specifications or to a specification that
references and incorporates one of the following specifications:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•

MIL-A-12560,
MIL-DTL-12560H,
MIL-DTL-12560J,
MIL- DTL-12560K,
MIL-DTL-32332,
MIL-A-46100D,
MIL-DTL-46100-E,
MIL-46177C,
MIL-S-16216K Grade HY80,
MIL-S-16216K Grade HY100,
MIL-S-246245A HSLA-80,
MIL-S-24645A HSLA-100,
T9074-BD-GIB-010/0300 Grade HY80,
T9074-BD-GIB-010/0300 Grade HY100,
T9074-BD-GIB-010/0300 Grade HSLA80,
T9074-BD-GIB-010/0300 Grade HSLA100, and
T9074-BD-GIB-010/0300 Mod. Grade HSLA115,

Except that any cut-to-length plate certified to one of the above specifications, or to a military grade
armor specification that references and incorporate one of the above specifications, will not be excluded
from the scope if I is also dual- or multiple-certified to any other non-armor specification that otherwise
would fall within the scope of this order;
(3) stainless steel plate, containing 10.5 percent or more of chromium by weight;
(4) CTL plate meeting the requirements of ASTM A-829, Grade E 4340 that are over 305 mm in actual
thickness.

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(5) Alloy forged and rolled CTL plate greater than or equal to 152.4 mm in actual thickness meeting each
of the following requirements:
(a) Electric Furnace melted, ladle refined & vacuum degassed and having a chemical
composition (expressed in weight percentages):
•
•
•
•
•
•
•
•
•
•
•
•

Carbon 0.23-0.28,
Silicon 0.05-0.20,
Manganese 1.20-1.60,
Nickel not greater than 1.0,
Sulfur not greater than 0.007,
Phosphorus not greater than 0.020,
Chromium 1.0-2.5,
Molybdenum 0.35-0.8,
Boron 0.002-0.004,
Oxygen not greater than 20 ppm,
Hydrogen not greater than 2 ppm,
Nitrogen not greater than 60 ppm;

(b) With a Brinell hardness measured in all parts of the product including mid thickness falling
within one of the following ranges:
(i) 270-300 HBW,
(ii) 290-320 HBW, or
(iii) 320-350 HBW;
(c) Having cleanliness in accordance with ASTM E45 method A (Thin and Heavy): A not exceeding
1.5, B not exceeding 1.0, C not exceeding 0.5, D not exceeding 1.5; and
(d) Conforming to ASTM A578-S9 ultrasonic testing requirements with acceptance criteria 2 mm
flat bottom hole;

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(6) Alloy forged and rolled steel CTL plate over 407 mm in actual thickness and meeting the following
requirements:
(a) Made from Electric Arc Furnace melted, Ladle refined & vacuum degassed, alloy
steel with the following chemical composition (expressed in weight percentages):
•
•
•
•
•
•
•
•
•
•
•
•

Carbon 0.23-0.28,
Silicon 0.05-0.15,
Manganese 1.20-1.50,
Nickel not greater than 0.4,
Sulfur not greater than 0.010,
Phosphorus not greater than 0.020,
Chromium 1.2-1.5,
Molybdenum 0.35-0.55,
Boron 0.002-0.004,
Oxygen not greater than 20 ppm,
Hydrogen not greater than 2 ppm, and
Nitrogen not greater than 60 ppm;

(b) Having cleanliness in accordance with ASTM E45 method A (Thin and Heavy): A not
exceeding 1.5, B not exceeding 1.5, C not exceeding 1.0, D not exceeding 1.5;
(c) Having the following mechanical properties:
(i)

With a Brinell hardness not more than 237 HBW measured in all parts of the
product including mid thickness; and having a Yield Strength of 75ksi min and
UTS 95ksi or more, Elongation of 18% or more and Reduction of area 35% or
more; having charpy V at -75 degrees F in the longitudinal direction equal or
greater than 15 ft. lbs (single value) and equal or greater than 20 ft. lbs (average
of 3 specimens) and conforming to the requirements of NACE MR01-75; or

(ii)
With a Brinell hardness not less than 240 HBW measured in all parts of the
product including mid thickness; and having a Yield Strength of 90 ksi min and UTS 110
ksi or more, Elongation of 15% or more and Reduction of area 30% or more; having
charpy V at -40 degrees F in the longitudinal direction equal or greater than 21 ft. lbs
(single value) and equal or greater than 31 ft. lbs (average of 3 specimens);
(d) Conforming to ASTM A578-S9 ultrasonic testing requirements with acceptance criteria 3.2
mm flat bottom hole; and
(e) Conforming to magnetic particle inspection in accordance with AMS 2301;

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(7) Alloy forged and rolled steel CTL plate over 407 mm in actual thickness and meeting the following
requirements:
(a)
Made from Electric Arc Furnace melted, ladle refined & vacuum degassed, alloy steel
with the following chemical composition (expressed in weight percentages):
•
•
•
•
•
•
•
•
•
•
•
•
•

Carbon 0.25-0.30,
Silicon not greater than 0.25,
Manganese not greater than 0.50,
Nickel 3.0-3.5,
Sulfur not greater than 0.010,
Phosphorus not greater than 0.020,
Chromium 1.0-1.5,
Molybdenum 0.6-0.9,
Vanadium 0.08 to 0.12
Boron 0.002-0.004,
Oxygen not greater than 20 ppm,
Hydrogen not greater than 2 ppm, and
Nitrogen not greater than 60 ppm.

(b) Having cleanliness in accordance with ASTM E45 method A (Thin and Heavy): A not
exceeding 1.0(t) and 0.5(h), B not exceeding 1.5(t) and 1.0(h), C not exceeding 1.0(t) and 0.5(h),
and D not exceeding 1.5(t) and 1.0(h);
(c) Having the following mechanical properties: A Brinell hardness not less than 350 HBW
measured in all parts of the product including mid thickness; and having a Yield Strength of
145ksi or more and UTS 160ksi or more, Elongation of 15% or more and Reduction of area 35%
or more; having charpy V at -40 degrees F in the transverse direction equal or greater than 20 ft.
lbs (single value) and equal or greater than 25 ft. lbs (average of 3 specimens);
(d) Conforming to ASTM A578-S9 ultrasonic testing requirements with acceptance criteria 3.2
mm flat bottom hole; and
(e) Conforming to magnetic particle inspection in accordance with AMS 2301.
At the time of the filing of the petition, there was an existing antidumping duty order on certain cut-tolength carbon-quality steel plate products from Korea. See Notice of Final Determination of Sales at Less
Than Fair Value: Certain Cut-To-Length Carbon-Quality Steel Plate Products from Korea, 64 FR 73196
(Dep't Commerce Dec. 29, 1999), as amended, 65 FR 6585 (Dep't Commerce Feb 10, 2000) (1999 Korea
AD Order). The scope of the antidumping duty investigation with regard to cut-to-length plate from
Korea covers only (1) subject cut-to-length plate not within the physical description of cut-to-length
carbon quality steel plate in the 1999 Korea AD Order, regardless of producer or exporter; and (2) cutto-length plate produced and/or exported by those companies that were excluded or revoked from the
1999 Korea AD Order as of April 8, 2016. The only revoked or excluded company is Pohang Iron and
Steel Company, also known as POSCO.

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At the time of the filing of the petition, there was an existing countervailing duty order on certain cut-tolength carbon-quality steel plate from Korea. See Final Affirmative Countervailing Duty Determination:
Certain Cut-to-Length Carbon-Quality Steel Plate From the Republic of Korea, 64 FR 73176 (Dep't
Commerce Dec. 29, 1999), as amended, 65 FR 6587 (Dep't Commerce Feb. 10, 2000) (1999 Korea CVD
Order). The scope of the countervailing duty investigation with regard to cut-to-length plate from Korea
covers only (1) subject cut-to-length plate not within the physical description of cut-to-length carbon
quality steel plate in the 1999 Korea CVD Order regardless of producer or exporter, and (2) cut-to-length
plate produced and/or exported by those companies that were excluded or revoked from the 1999
Korea CVD Order as of April 8, 2016. The only revoked or excluded company is Pohang Iron and Steel
Company, also known as POSCO.
Excluded from the scope of the antidumping duty investigation on cut-to-length plate from China are
any products covered by the existing antidumping duty order on certain cut-to-length carbon steel plate
from the People's Republic of China. See Suspension Agreement on Certain Cut-to-Length Carbon Steel
Plate From the People's Republic of China; Termination of Suspension Agreement and Notice of
Antidumping Duty Order, 68 FR 60081 (Dep't Commerce Oct. 21, 2003), as amended, Affirmative Final
Determination of Circumvention of the Antidumping Duty Order on Certain Cut-to-Length Carbon Steel
Plate From the People's Republic of China, 76 FR 50996, 50996-97 (Dep't of Commerce Aug. 17, 2011).
On August 17, 2011, the U.S. Department of Commerce found that the order covered all imports of
certain cut-to-length carbon steel plate products with 0.0008 percent or more boron, by weight, from
China not meeting all of the following requirements: aluminum level of 0.02 percent or greater, by
weight; a ratio of 3.4 to 1 or greater, by weight, of titanium to nitrogen; and a hardenability test (i.e.,
Jominy test) result indicating a boron factor of 1.8 or greater.
The products subject to the investigations are currently classified in the Harmonized Tariff Schedule of
the United States (HTSUS) under item numbers: 7208.40.3030, 7208.40.3060, 7208.51.0030,
7208.51.0045, 7208.51.0060, 7208.52.0000, 7211.13.0000, 7211.14.0030, 7211.14.0045, 7225.40.1110,
7225.40.1180, 7225.40.3005, 7225.40.3050, 7226.20.0000, and 7226.91.5000.
The products subject to the investigations may also enter under the following HTSUS item numbers:
7208.40.6060, 7208.53.0000, 7208.90.0000, 7210.70.3000, 7210.90.9000, 7211.19.1500, 7211.19.2000,
7211.19.4500, 7211.19.6000, 7211.19.7590, 7211.90.0000, 7212.40.1000, 7212.40.5000, 7212.50.0000,
7214.10.000, 7214.30.0010, 7214.30.0080, 7214.91.0015, 7214.91.0060, 7214.91.0090, 7225.11.0000,
7225.19.0000, 7225.40.5110, 7225.40.5130, 7225.40.5160, 7225.40.7000, 7225.99.0010, 7225.99.0090,
7226.11.1000, 7226.11.9060, 7226.19.1000, 7226.19.9000, 7226.91.0500, 7226.91.1530, 7226.91.1560,
7226.91.2530, 7226.91.2560, 7226.91.7000, 7226.91.8000, and 7226.99.0180.
The HTSUS subheadings above are provided for convenience and customs purposes only. The written
description of the scope of the investigations is dispositive.

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Page 8

Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
I-1a.

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.

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U.S. Producers’ Questionnaire - CTL plate

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.

Page 9

No

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment” – Each facility of a firm involved in the production of CTL plate, 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 - CTL plate
I-3.

Page 10

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

Support

Oppose

Take no position

Austria (AD)
Belgium (AD)
Brazil (AD)
China (AD)
China (CVD)
France (AD)
Germany (AD)
Italy (AD)
Japan (AD)
Korea (AD)
Korea (CVD)
South Africa (AD)
Taiwan (AD)
Turkey (AD)
I-4.

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

Firm name

Yes--List the following information.

Address

Extent of
ownership
(percent)

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U.S. Producers’ Questionnaire - CTL plate
I-5.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing CTL plate from Austria, Belgium, Brazil, China, France,
Germany, Italy, Japan, Korea, South Africa, Taiwan, and/or Turkey into the United States or that
are engaged in exporting CTL plate from Austria, Belgium, Brazil, China, France, Germany, Italy,
Japan, Korea, South Africa, Taiwan, and/or Turkey to the United States?
No
Firm name

I-6.

Page 11

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 CTL plate?
No
Firm name

Yes--List the following information.
Address

Affiliation

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Carolyn Carlson (202-2053002, [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 CTL plate 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 - CTL plate
II-3a.

Page 13

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce CTL plate, and the combined production
capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in short tons)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Quantity (in short tons)
CTL PLATE ROLLED AND CUT:
Overall production capacity
Production of:
Total CTL plate production (A)
Other products1
Total mill production

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

CTL PLATE FROM COIL
Overall production capacity
Production of:
Total CTL plate production (B)
Other products2
Total cutting production
CTL PLATE FORGED
Overall production capacity
Production of:
Total CTL plate production (C)
Other products3
Total forged production
1

Please identify your firm's other mill (i.e., rolled) products:
.
Please identify your firm's other products produced on your firm's coil slitting machinery:
3
Please identify your firm's other products produced on your firm's forging machinery:
2

.

.

RECONCILIATION OF PRODUCTION.-Calendar years
Reconciliation
A + B + C - H = should equal zero, if
not revise prior to submission.

2013

2014
0

January-September
2015

0

2015
0

2016
0

0

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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, including whether constraints relate to mill equipment or cutting line
equipment.

II-3e.

Product shifting.-(i)

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

(ii)

hours

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 - CTL plate
II-4.

Page 15

Tolling.--Since January 1, 2013, has your firm been involved in a toll agreement regarding the
production of CTL plate?
“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 CTL plate in and/or admit CTL plate into
a foreign trade zone (FTZ)?

(a)

“Foreign trade zone” – 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 CTL plate into a foreign trade zone (FTZ) for use in distribution of CTL plate
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 CTL plate?
“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 - CTL plate
II-7.

Page 16

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of CTL plate 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.
“Commercial U.S. 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.
“Tool steel” – Alloy steels which contain the following combinations of elements in the quantity
by weight respectively indicated: (i) more than 1.2 percent carbon and more than 10.5 percent
chromium; or (ii) not less than 0.3 percent carbon and 1.25 percent or more but less than 10.5
percent chromium; or (iii) not less than 0.85 percent carbon and 1 percent to 1.8 percent,
inclusive, manganese; or (iv) 0.9 percent to 1.2 percent, inclusive, chromium and 0.9 percent to
1.4 percent, inclusive, molybdenum; or (v) not less than 0.5 percent carbon and not less than 3.5
percent molybdenum, or (vi) not less than 0.5 percent carbon and not less than 5.5 percent
tungsten.
“High Speed Steel” – Alloy steel containing, with or without other elements, at least two of the
three elements molybdenum, tungsten and vanadium with a combined content by weight of 7
percent or more, 0.6 percent or more of carbon amd 3 to 6 percent of chromium.

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 - CTL plate
II-7.

Page 17

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

2013

2014

January-September
2015

2015

2016

1

Average production capacity (quantity) (F)
Beginning-of-period inventories (quantity)
(G)
Production (quantity) (H)
U.S. shipments:
Commercial shipments:
Quantity (I)
Value (J)
Internal consumption:
Quantity (K)
2

Value (L)
Transfers to related firms:
Quantity (M)
2

Value (N)
Export shipments:
Quantity (O)

3

Value (P)
End-of-period inventories (quantity) (Q)
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
G + H – I – K – M – O – Q = should equal
zero ("0") or provide an explanation.1
1

2013

2014

0

January-September
2015

0

2015

0

2016

0

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

0
.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 18

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.

II-8.

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

2013

2014

January-September
2015

2015

2016

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (R)
To end users
Construction (quantity) (S)
Other (quantity) (T)
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. 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

2013

R + S + T – I = zero ("0"), if not revise.

II-9.

2014
0

January-September
2015

0

2015
0

2016
0

0

U.S. shipments of X-70, tool steel, and high speed steel plate.--Report the quantity and value of
your firm’s U.S. shipments (commercial U.S. shipments, internal consumption, and transfers to
related firms) of CTL plate during the specified periods. (Note.--Please report data that in
inclusive of the data reported in question II-7).

Quantity (in short tons) and value (in $1,000)
Calendar years
Item
U.S. shipments of X-70 plate.-Quantity
Value
U.S. shipments of tool steel plate.-Quantity
Value
U.S. shipments of high speed steel
plate.-Quantity
Value

2013

2014

January-September
2015

2015

2016

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
II-10.

Page 19

Employment data.--Report your firm’s employment-related data related to the production of
CTL plate 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 September periods, calculate similarly and divide by 9.
“Hours worked” – includes time paid for sick leave, holidays, and vacation time. Include
overtime hours actually worked; do not convert overtime pay to its equivalent in straight time
hours.
“Wages paid” – Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.

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

2013

2014

January-September
2015

2015

2016

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
II-11.

Page 20

Product type.--Please indicate the type of CTL plate your firm produced in 2015.

Type of CTL plate

Carbon structural steel plate
CrMo pressure vessel plate
Ni pressure vessel plate
Other pressure vessel plate
Tool steel plate
Mold steel plate
Wear/resistant/abrasion resistant plate
Oil-drilling platform plate
Shipbuilding plate
X-70 (or higher) plate for line pipe having a width not exceeding 120 inches
X-70 (or higher) plate for line pipe having a width greater than 120 inches

1

Other plate for line pipe
Sour service plate
High-speed steel plate
Heat-resisting steel plate
Ultra high strength steel (UHSS) or advanced high strength steel (AHSS) plate
Forged alloy steel plate
1

Please report the maximum thickness of X-70 grade CTL plate your firm produced in 2015.

II-12. 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 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 - CTL plate
II-13.

Page 21

Purchases.--Other than direct imports, has your firm otherwise purchased CTL plate 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 short tons)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Purchases from U.S.
importers1 of CTL plate
from-Austria
Belgium
Brazil
China
France
Germany
Italy
Japan
Korea
South Africa
Taiwan
Turkey
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 - CTL plate
II-14.

Page 22

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 - CTL plate

Page 23

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[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 CTL plate:

2.

Does your firm prepare profit/loss statements for CTL plate:
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)

3.

4.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes CTL plate, 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 - CTL plate

Page 24

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

Share of sales

CTL plate

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CTL plate 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 CTL plate
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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
III-8.

Page 25

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 CTL plate) in a
manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III-9a.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 26

III-9a. Operations on CTL plate.--Report the revenue and related cost information requested below on
the CTL plate 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.
PLEASE NOTE: The due date for the January-September data in 2016 for III-9a, III-10, and III-13
(cells shaded) is 9:00am October 31, 2016. Submissions prior to that date, if possible, are
appreciated. When the data are available, please re-submit the questionnaire with a cover letter
indicating the submission is to provide the interim financial data at questions III-9a, III-10,
and/or III-13. In the re-submission of the questionnaire, DO NOT make changes to any other part
of the questionnaire, unless changes were requested by USITC staff. This does not extend the
deadline for the rest of the questionnaire, which is October 24, 2016.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January-September

2015

2015

2016

2

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

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

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III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

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

2013

2014

January-September

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 28

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

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

2013

2014

2015

1

Total assets (net)
1

III-13.

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for CTL plate. 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-September

2015

2015

2016

Capital expenditures
Research and development expenses
1

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 29

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

Fiscal year

Specify fiscal year

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

No

If no, please explain.

III-15a. Effects of imports on investment.--Since January 1, 2013, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of CTL plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea,
South Africa, Taiwan, or Turkey?
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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U.S. Producers’ Questionnaire - CTL plate

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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 CTL plate from Austria, Belgium, Brazil, China,
France, Germany, Italy, Japan, Korea, South Africa, Taiwan, or Turkey?
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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U.S. Producers’ Questionnaire - CTL plate

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III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
CTL plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South Africa,
Taiwan, or Turkey?
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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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Craig Thomsen (202-2053236, [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.--Hot-rolled CTL carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 96” in width, 0.250”
thick.
Product 2.--Hot-rolled CTL carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 96” in width,
0.3125” thick.
Product 3.--Hot-rolled CTL carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 120” in width,
0.375” through 3.00” in thickness.
Product 4.--Hot-rolled CTL carbon steel plate, high strength low alloy (HSLA), ASTM A-572,
Grade 50, mill edge, not cleaned or oiled, in cut lengths, 72” through 120” in
width, 0.5” through 1.5” in thickness.
Product 5.--Hot-rolled CTL carbon steel plate, API X-70 or equivalent as rolled, mill or cut edge,
not heat treated, not cleaned or oiled, in cut lengths, 72” through 152” in width,
0.375” through 1.0” thick.
Product 6.--Hot-rolled CTL plate, AISI A2 or equivalent as rolled, mill edge, annealed, descaled, in random lengths from 73”-144”, 20”-41” in width and from 0.187”
through 3.5” thick.

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).

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During January 2013-September 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.
IV-2.

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.

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

Product 3
Quantity
Value

Period of shipment
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-2.

Page 34

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
(Quantity in short tons, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
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
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
Product 6:

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 - CTL plate
IV-3.

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

IV-4.

Contracts

Other

If other, describe

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 CTL plate?
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 CTL plate usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 35

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 CTL
plate in 2015 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?

Share of 2015
sales

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-7.

Page 36

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced CTL plate (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 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 CTL plate?

Source

Share of 2015
sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Lead time
(average number
days)

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate
IV-9.

Page 37

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced CTL
plate 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 CTL plate that are delivered
the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced CTL plate since January 1, 2013 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 38

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

CTL plate

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

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

Explanation

1.
2.
3.

IV-13. Availability of merchandise.--Are certain grades/types/sizes of CTL plate only available from
certain sources?

No

Yes

If yes, please identify the sources, firms, the grade/type/size, and
approximate cost per short ton in 2015 of these grades/types/sizes.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 39

IV-14. Demand trends.—
(a)

Indicate how demand within the United States and outside of the United States (if
known) for CTL plate has changed since January 1, 2013. Explain any trends and describe
the principal factors that have affected these changes in demand. If not known for a
particular sector, please leave that row blank.
January 1, 2013-December 31, 2014

Market

Overall
increase

No change

Overall
decrease

Since January 1, 2015
Overall
increase

Within the United States
Within the United States
for the following sectors:
Agricultural and
electrical equipment
Automotive
Construction
Machinery, tools &
industrial equipment
Oil and gas industry
Rail transportation
Shipbuilding and
marine equipment
Wind towers
Other1
Outside the United
States
1

Please describe the "other" sectors:

(b)

Please explain any principal factors contributing to these trends.

No change

Overall
decrease

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 40

IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of CTL plate since January 1, 2013?
No

Yes

If yes, please describe and quantify if possible.

IV-16. Conditions of competition.-(a) Is the CTL plate market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to CTL plate? If yes,
describe.
Check all that apply.

Please describe.

No

Skip to question IV-16.

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

Yes

If yes, describe.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 41

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply CTL plate since
January 1, 2013 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, been unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

IV-18. Raw material prices.—
(a)

If known, how have prices for raw material used to produce CTL plate changed since
January 1, 2013?

Overall increase

(b)

No change

Overall decrease

Fluctuate with no
clear trend

Don’t
know

Have any changes in raw material costs affected your firm’s price negotiations and/or
selling prices (including surcharges) since January 1, 2013? If there are relevant
surcharges, please identify them specifically.
No

(c)

Yes

Please explain.

Are your firm’s sales of CTL plate indexed to raw material costs?

No

Yes

Please explain, identifying the particular index or indices, and how
frequently prices are adjusted based on the index or indices.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 42

IV-19. Interchangeability.--Is CTL plate 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
Other sources1

Mexico

Canada

Turkey

Taiwan

South Africa

Korea1

Japan

Italy

Germany

France

China

Brazil

Belgium

Austria

Country-pair

United States
Austria
Belgium
Brazil
China
France
Germany
Italy
Japan
Korea1
South Africa
Taiwan
Turkey
Canada
Mexico
For any country-pair producing CTL plate that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

1

Korea include product from POSCO for all products, and other producers for high alloy plates;
Other sources includes Korean producers other than POSCO for products other than high alloy
plates.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 43

IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between CTL plate 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
Other sources1

Mexico

Canada

Turkey

Taiwan

South Africa

Korea1

Japan

Italy

Germany

France

China

Brazil

Belgium

Austria

Country-pair

United States
Austria
Belgium
Brazil
China
France
Germany
Italy
Japan
Korea1
South Africa
Taiwan
Turkey
Canada
Mexico
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of CTL plate, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

1

Korea include product from POSCO for all products, and other producers for high alloy plates;
Other sources includes Korean producers other than POSCO for products other than high alloy
plates.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 44

IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for CTL plate since January 1, 2013. Indicate the share of the quantity of your firm’s
total shipments of CTL plate that each of these customers accounted for in 2015.
Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2015 sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 45

IV-22. Competition from imports
(a)

Lost revenue.--Since January 1, 2013: To avoid losing sales to competitors selling CTL
plate from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South
Africa, Taiwan, and Turkey, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2013: Did your firm lose sales of CTL plate to imports of this
product from Austria, Belgium, Brazil, China, France, Germany, Italy, Japan, Korea, South
Africa, Taiwan, and Turkey?
No

Yes

IV-23. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire - CTL plate

Page 46

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://usitc.gov/investigations/701731/2016/carbon_and_alloy_steel_cut_to_length_p
late_austria/final.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.--Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: CTLP

• 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.