16-1-3571 U.S. Producer Questionnaire

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

US producer--OTR (Final)

Pneumatic Off-the-Road (OTR) Tires from China, India, and Sri Lanka, Inv. No. 701-551 (FInal)

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

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OMB No. 3117-0016/USITC No. 16-1-3571; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN NEW PNEUMATIC OFF-THE-ROAD TIRES FROM
INDIA AND SRI LANKA
This questionnaire must be received by the Commission by NOVEMBER 9, 2016
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning certain new pneumatic off-the-road
tires (“OTR tires”) from India and Sri Lanka (Inv. Nos. 701-TA-552-553 and 731-TA-1308 (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 OTR tires (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: OTRF)
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 – OTR tires (Final)

Page 2

PART I.—GENERAL INFORMATION
Background. These proceedings were instituted in response to a petition filed on January 8, 2016, by
Titan Tire Corporation of Des Moines, Iowa and the United Steel, Paper and Forestry, Rubber,
Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO, CLC of
Pittsburgh, Pennsylvania. Antidumping and/or countervailing duties may be assessed on the subject
imports as a result of these proceedings if the Commission makes an affirmative determination of injury,
threat, or material retardation, and if the U.S. Department of Commerce makes an affirmative
determination of subsidization and/or dumping. Questionnaires and other information pertinent to
these proceedings are available at
https://www.usitc.gov/investigations/701731/2016/certain_new_pneumatic_off_the_road_tires_india_
and/final.htm
OTR Tires: The scope of these investigations is certain new pneumatic off-the-road tires (certain off road
tires). Certain off road tires are tires with an off road tire size designation. The tires included in the
scope may be either tube-type 1 or tubeless, radial or nonradial, regardless of whether for original
equipment manufacturers or the replacement market.
Subject tires may have the following prefix or suffix designation, which appears on the sidewall of the
tire:
Prefix designations:
DH – Identifies a tire intended for agricultural and logging service which must be mounted on a DH drop
center rim.
VA – Identifies a tire intended for agricultural and logging service which must be mounted on a VA
multipiece rim.
IF – Identifies an agricultural tire to operate at 20 percent higher rated load than standard metric tires at
the same inflation pressure.
VF – Identifies an agricultural tire to operate at 40 percent higher rated load than standard metric tires
at the same inflation pressure.
Suffix designations:
ML – Mining and logging tires used in intermittent highway service.
DT – Tires primarily designed for sand and paver service.
NHS – Not for Highway Service.
TG – Tractor Grader, off-the-road tire for use on rims having bead seats with nominal +0.188” diameter
(not for highway service).
K – Compactor tire for use on 5° drop center or semi-drop center rims having bead seats with nominal
minus 0.032 diameter.
IND – Drive wheel tractor tire used in industrial service.
SL – Service limited to agricultural usage.
FI – Implement tire for agricultural towed highway service.
CFO – Cyclic Field Operation.
SS – Differentiates tires for off-highway vehicles such as mini and skid-steer loaders from other tires
which use similar size designations such as 7.00-15TR and 7.00-15NHS, but may use different rim bead
seat configurations.
1

While tube-type tires are subject to the scope of these proceedings, tubes and flaps are not subject
merchandise and therefore are not covered by the scope of these proceedings, regardless of the manner in which
they are sold (e.g., sold with or separately from subject merchandise).

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U.S. Producers’ Questionnaire – OTR tires (Final)

Page 3

All tires marked with any of the prefixes or suffixes listed above in their sidewall markings are
covered by the scope regardless of their intended use.
In addition, all tires that lack any of the prefixes or suffixes listed above in their sidewall
markings are included in the scope, regardless of their intended use, as long as the tire is of a size
that is among the numerical size designations listed in the following sections of the Tire and Rim
Association Year Book, as updated annually, unless the tire falls within one of the specific
exclusions set forth below.
The sections of the Tire and Rim Association Year Book listing numerical size designations of covered
OTR tires include:
The table of mining and logging tires included in the section on Truck-Bus tires;
The entire section on Off-the-Road tires;
The entire section on Agricultural tires; and
The following tables in the section on Industrial/ATV/Special Trailer tires:
• Industrial, Mining, Counterbalanced Lift Truck (Smooth Floors Only);
• Industrial and Mining (Other than Smooth Floors);
• Construction Equipment;
• Off-the-Road and Counterbalanced Lift Truck (Smooth Floors Only);
• Aerial Lift and Mobile Crane; and
• Utility Vehicle and Lawn and Garden Tractor.
OTR tires, whether or not mounted on wheels or rims, are included in the scope. However, if a subject
tire is imported mounted on a wheel or rim, only the tire is covered by the scope. Subject merchandise
includes OTR tires produced in the subject countries whether mounted on wheels or rims in a subject
country or in a third country. OTR tires are covered whether or not they are accompanied by other
parts, e.g., a wheel, rim, axle parts, bolts, nuts, etc. OTR tires that enter attached to a vehicle are not
covered by the scope.
In addition, specifically excluded from the scope are passenger vehicle and light truck tires, racing tires,
mobile home tires, motorcycle tires, all-terrain vehicle tires, bicycle tires, on-road or on-highway trailer
tires, and truck and bus tires. Such tires generally have in common that the symbol “DOT” must appear
on the sidewall, certifying that the tire conforms to applicable motor vehicle safety standards. Such
excluded tires may also have the following prefixes and suffixes included as part of the size designation
on their sidewalls:
Prefix letter designations:
AT – Identifies a tire intended for service on All-Terrain Vehicles;
P – Identifies a tire intended primarily for service on passenger cars;
LT – Identifies a tire intended primarily for service on light trucks;
T – Identifies a tire intended for one-position “temporary use” as a spare only; and
ST – Identifies a special tire for trailers in highway service.
Suffix letter designations:

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U.S. Producers’ Questionnaire – OTR tires (Final)

Page 4

TR – Identifies a tire for service on trucks, buses, and other vehicles with rims having specified rim
diameter of nominal plus 0.156” or plus 0.250”;
MH – Identifies tires for Mobile Homes;
HC – Identifies a heavy duty tire designated for use on “HC” 15” tapered rims used on trucks, buses, and
other vehicles. This suffix is intended to differentiate among tires for light trucks, and other vehicles or
other services, which use a similar designation.
Example: 8R17.5 LT, 8R17.5 HC;
LT – Identifies light truck tires for service on trucks, buses, trailers, and multipurpose passenger vehicles
used in nominal highway service;
ST – Special tires for trailers in highway service; and
M/C – Identifies tires and rims for motorcycles.
The following types of tires are also excluded from the scope: Pneumatic tires that are not new,
including recycled or retreaded tires and used tires; non-pneumatic tires, including solid rubber tires;
aircraft tires; and turf, lawn and garden, and golf tires. Also excluded from the scope are mining and
construction tires that have a rim diameter equal to or exceeding 39 inches. Such tires may be
distinguished from other tires of similar size by the number of plies that the construction and mining
tires contain (minimum of 16) and the weight of such tires (minimum 1500 pounds).
The subject merchandise is currently classifiable under Harmonized Tariff Schedule of the United States
(HTSUS) subheadings: 4011.20.1025, 4011.20.1035, 4011.20.5030, 4011.20.5050, 4011.61.0000,
4011.62.0000, 4011.63.0000, 4011.69.0090, 4011.92.0000, 4011.93.4000, 4011.93.8000, 4011.94.4000,
4011.94.8000, 8431.49.9038, 8431.49.9090, 8709.90.0020, and 8716.90.1020. Tires meeting the scope
description may also be classifiable under the following HTSUS subheadings: 4011.99.4590,
4011.99.8590, 8424.90.9080, 8431.20.0000, 8431.39.0010, 8431.49.1090, 8431.49.9030, 8432.90.0005,
8432.90.0015, 8432.90.0030, 8432.90.0080, 8433.90.5010, 8503.00.9560, 8708.70.0500, 8708.70.2500,
8708.70.4530, 8716.90.5035 and 8716.90.5056. While HTSUS subheadings are provided for convenience
and customs purposes, the written description of the subject merchandise is dispositive.

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U.S. Producers’ Questionnaire – OTR tires (Final)

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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
I-1a.

Page 6

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

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

I-3.

Additional discussion on establishments consolidated in this questionnaire:

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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
Country

Support

Page 7
Oppose

Take no position

India AD
India CVD
Sri Lanka CVD
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 OTR tires from India and/or Sri Lanka into the United
States or that are engaged in exporting OTR tires from India and/or Sri Lanka 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 OTR tires?
No
Firm name

Yes--List the following information.
Address

Affiliation

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Edward Petronzio (202-2053176, [email protected]). Supply all data requested on a calendar-year basis.

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
II-1.

Page 8

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 OTR tires 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)

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
II-3a.

Page 9

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce OTR tires, 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 1,000s of tires)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Overall production capacity
Production of:
OTR tires1

Passenger vehicle and light
truck (PVLT) tires
Truck and bus tires
Other products2
Total
1
2

Data entered for production of OTR tires 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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
II-3e.

Product shifting.—
(i)

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

(ii)

II-4.

Page 10

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

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

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

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

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U.S. Producers’ Questionnaire – OTR tires (Final)
II-5.

Page 11

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce OTR tires in and/or admit OTR tires 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 OTR tires into a foreign trade zone (FTZ) for use in distribution of OTR tires
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 OTR tires?
“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 – OTR tires (Final)
II-7.

Page 12

Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of OTR tires in its U.S. establishment(s)
during the specified periods. Include data on both mounted and unmounted OTR tires,
however, in the case of mounted OTR tires, report only the value of the tire (i.e., exclude the
value of the rim and assembly) in reported shipment values.
“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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U.S. Producers’ Questionnaire – OTR tires (Final)

Page 13

Production, shipment and inventory data.--

II-7.

Quantity (in 1,000s of tires) and value (in $1,000)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
23
Commercial shipments:
To OEM:
Quantity (D)

Value (E)

To aftermarket:
Quantity (F)

Value (G)

Internal consumption:
Quantity (H)
4

Value (I)
Transfers to related firms:
Quantity (J)
4

Value (K)
5

Export shipments:
Quantity (L)
Value (M)

End-of-period inventories (quantity) (N)
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
Commercial U.S. shipments will be populated into this grid based on data entered in question II-8.
3
Please indicate the approximate share of your firm's commercial U.S. shipments in 2015 that were sold mounted on a
percent.
tire rim.
4
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:
5
Identify your firm’s principal export markets:
.

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U.S. Producers’ Questionnaire – OTR tires (Final)
II-7.

Page 14

Production, shipment and inventory data.--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line N) 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, J, and L). 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 – N = should
equal zero ("0") or provide an
explanation.1
1

2013

2014

January- September
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 – OTR tires (Final)
II-8.

Page 15

Commercial U.S. shipments by market segment and tire size.--Report your firm’s commercial
U.S. shipments by market segment and tire size during the specified periods.
Quantity (in 1,000s of tires) and value (in $1,000)
Calendar years
Item

Commercial U.S. shipments:
To agricultural OEM:
Radial OTR tires
Quantity (O)
Value (P)
Bias OTR tires
Quantity (Q)
Value (R)
To agricultural aftermarket:
Radial OTR tires
Quantity (S)
Value (T)
Bias OTR tires
Quantity (U)
Value (V)
To construction/industrial OEM:
Tires up to and including 25" in rim
diameter
Quantity (W)
Value (X)
Tires greater than 25" in rim diameter
Quantity (Y)
Value (Z)
To construction/industrial aftermarket:
Tires up to and including 25" in rim
diameter
Quantity (AA)
Value (AB)
Tires greater than 25" in rim diameter
Quantity (AC)
Value (AD)
To mining OEM:
Quantity (AE)
Value (AF)
To mining aftermarket:
Quantity (AG)
Value (AH)
Continued on following page.

2013

2014

January- September
2015

2015

2016

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U.S. Producers’ Questionnaire – OTR tires (Final)
II-8.

Page 16

Commercial U.S. shipments by market segment and tire size (Continued).—
Report your firm’s commercial U.S. shipments by market segment and tire size during the
specified periods.
Quantity (in 1,000s of tires) and value (in $1,000)
Calendar years
Item

To all other market segments OEM:
Quantity (AI)

2013

2014

January- September
2015

2015

2016

Value (AJ)
To all other market segments aftermarket:
Quantity (AK)

Value (AL)
1

Please describe these other market segments:

II-9.

Employment data.--Report your firm’s employment-related data related to the production of
OTR tires 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

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U.S. Producers’ Questionnaire – OTR tires (Final)

Page 17

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.

II-11.

Purchases.--Other than direct imports, has your firm otherwise purchased OTR tires 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 1,000s of tires)
Calendar years
Item

2013

2014

January- September
2015

2015

2016

Purchases from U.S.
importers1 of OTR tires
from—
India
Sri Lanka
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 – OTR tires (Final)
II-12.

Page 18

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 – OTR tires (Final)

Page 19

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

III-2.

Accounting system.--Briefly describe your firm’s financial accounting system.
A.

When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include OTR tires:

Does your firm prepare profit/loss statements for OTR tires:
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 OTR tires, 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 – OTR tires (Final)

Page 20

III-4.

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

III-5.

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

Share of sales

OTR tires

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of OTR tires 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 OTR tires
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 – OTR tires (Final)
III-8.

Page 21

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 OTR tires) 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 – OTR tires (Final)

Page 22

III-9a. Operations on OTR tires.--Report the revenue and related cost information requested below on
the OTR tires operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that internal consumption and transfers to related firms must be valued at fair market
value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three most
recently completed fiscal years, and for the specified interim periods. If your firm was involved
in tolling operations (either as the toller or as the tollee), please contact Jennifer Brinckhaus at
202-205-3188 before completing this section of the questionnaire.
Quantity (in 1,000s of tires) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January- September

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.

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 23

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

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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 24

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 OTR tires. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for OTR tires 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 OTR tires. 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

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.

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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 25

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 of net sales reported in question III-9a should reconcile
with the shipment 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 OTR tires from India and Sri Lanka?
No

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

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

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 26

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 OTR tires from India and Sri Lanka?
No

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

Lowering of credit rating

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

Other

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

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 27

III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
OTR tires from India and Sri Lanka?
No

Yes

If yes, my firm anticipates negative effects as follows:

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

Yes

If yes, indicate which country and why:

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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 28

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

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

PRICE DATA
IV-2.

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.-- Irrigation pivot tire, size 11.2-38, ply rating of 6, weight from 90 to 125 lbs., rim
width 10 inches, unmounted, tire only.
Product 2.-- Rear farm tire, size 9.5-24, ply rating of 6, weight from 48 to 58 lbs., rim width 8
inches, unmounted, tire only.
Product 3.-- Front farm tire, size 9.5L-15, ply rating of 8, weight from 25 to 32 lbs., rim width 8
inches, unmounted, tire only.
Product 4.-- Skid steer tire, size 10-16.5, ply rating of 10, weight from 55 to 59 lbs., rim width
8.25 inches, unmounted, tire only.
Product 5.-- Skid steer tire, size 10-16.5, ply rating of 10, weight from 60 to 67 lbs., rim width
8.25 inches, unmounted, tire only.
Product 6.-- Skid steer tire, size 10-16.5, ply rating of 10, weight greater than 67 lbs., rim width
8.25 inches, unmounted, tire only.
Product 7.-- Radial drive farm tire, metric size 380/85R24 (standard size 14.9R24), load index of
131, weight from 136 to 170 lbs., rim width 12 inches, unmounted, tire only.
Product 8.-- Radial drive farm tire, metric size 480/80R42 (standard size 18.4R42), load index
150 to 153, weight from 355 to 375 lbs., rim width 16 inches, unmounted, tire only.

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).

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 29

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 tables as appropriate.
No.--Skip to question IV-3.
IV-2a. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. For values, only report the value of the tire. Do not include the value of the wheel
on which the tire has been mounted.

OEM

Report data in actual tires (not 1,000s) and actual dollars (not 1,000s).
(Quantity in number of tires, value in dollars)
Product 1
Period of shipment

Quantity

Product 2
Value

Quantity

Product 3
Value

Quantity

Product 4
Value

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
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:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
IV-2a. Price data.--(continued).

Page 30

OEM

Report data in actual tires (not 1,000s) and actual dollars (not 1,000s).
(Quantity in number of tires, value in dollars)
Product 5
Period of shipment

Quantity

Product 6
Value

Quantity

Product 7
Value

Quantity

Product 8
Value

Quantity

Value

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
IV-2a. Price data.--(continued).

Page 31

AFTERMARKET

Report data in actual tires (not 1,000s) and actual dollars (not 1,000s).
(Quantity in number of tires, value in dollars)
Product 1
Period of shipment

Quantity

Product 2
Value

Quantity

Product 3
Value

Quantity

Product 4
Value

Quantity

Value

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
IV-2a. Price data.-- (continued).

Page 32

AFTERMARKET

Report data in actual tires (not 1,000s) and actual dollars (not 1,000s).
(Quantity in number of tires, value in dollars)
Product 5
Period of shipment

Quantity

Product 6
Value

Quantity

Product 7
Value

Quantity

Product 8
Value

Quantity

Value

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)

Page 33

IV-2b. Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.

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

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

IV-4.

Other

If other, describe

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

Quantity
discounts

IV-5.

Contracts

Set
price
lists

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced OTR tires?
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 OTR tires usually quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced OTR
tires 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
OEM
Aftermarket
IV-7.

Page 34

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)
%
%
%
%

%
%

0.0
0.0

%
%

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Annual contracts
(multiple deliveries
for 12 months)
365

No
Quantity
Price
Both

Meet or release
provision

Yes

Indexed to raw
material costs1

Yes

No
No

Not applicable
1

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)

Please describe any indexing mechanisms and relevant raw materials:

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

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
IV-8.

Page 35

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 OTR tires?
OEM

Source

Lead time
(average number
of days)

Share of 2015
sales

Lead time
(average number
of days)

Share of 2015
sales

From inventory

Produced to order

0.0

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

Aftermarket

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced OTR
tires 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 OTR tires 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 OTR tires 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 – OTR tires (Final)

Page 36

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

OTR tires

Other inputs

Total
(should sum to
100.0% across)

0.0 %

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

Explanation

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

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

Market

Type

Within the
United States

OEM

Outside the
United States

Aftermarket
OEM
Aftermarket

Overall
increase

No
change

Fluctuate
with no
clear
Overall
decrease trend

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire – OTR tires (Final)
(b)

Page 37

Indicate how demand within the United States, by market segment, for OTR tires has
changed since January 1, 2013. Explain any trends and describe the principal factors
that have affected these changes in demand.

Market segment

Overall
increase

No
change

Fluctuate
with no
clear
Overall
decrease
trend

Explanation and factors

Overall U.S. market
Agricultural
Construction/Industrial
Mining
IV-14. Categories of OTR tires.-(a)

Is the U.S. OTR tire market divided into categories (e.g., Best/Better/Good; Tier 1/Tier
2/Tier 3)?
No

If no, please provide a description of how, if at all, the U.S. market for
OTR tires can be categorized:
.
Please skip to question IV-15.

Yes

If yes, please describe each category and identify the producers and
brands that belong in each category in the table below.

File Type	application/pdf
File Title	US producer questionnaire
Subject	Title 7 investigations
Author	Duncan, Russell
File Modified	2016-09-27
File Created	2016-09-27