Form 16-1-3575 U.S. Producers' Questionnaire

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

TB Tires (F) - US producer questionnaire

Trucks and Bus Tires from China, Inv. 701-TA-556 and 731-TA-1311 (Final)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 16-1-3575; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
TRUCK AND BUS TIRES FROM CHINA
This questionnaire must be received by the Commission by November 15, 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 and antidumping duty investigations concerning truck and bus tires from China (Inv.
Nos. 701-TA-556 and 731-TA-1311 (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 truck and bus 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: TIRES)
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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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on January 29, 2016, by
United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers
International Union (“USW”), Pittsburg, PA. Countervailing and/or antidumping duties may be assessed
on the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available
at https://www.usitc.gov/investigations/701731/2016/truck_and_bus_tires_china/final.htm
Truck and bus tires covered by these investigations are new pneumatic tires, of rubber, with a truck or
bus size designation. Truck and bus tires covered by this investigation may be tube-type, tubeless, radial,
or non-radial.
Subject tires have, at the time of importation, the symbol ‘‘DOT’’ on the sidewall, certifying that the tire
conforms to applicable motor vehicle safety standards. Subject tires may also have one of the following
suffixes in their tire size designation, which also appear on the sidewall of the tire:
TR—Identifies tires for service on trucks or buses to differentiate them from similarly sized
passenger car and light truck tires;
MH—Identifies tires for mobile homes; and
HC—Identifies a 17.5 inch rim diameter code for use on low platform trailers.
All tires with a ‘‘TR,’’ ‘‘MH,’’ or ‘‘HC’’ suffix in their size designations are covered by this investigation
regardless of their intended use.
In addition, all tires that lack one of the above suffix 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 ‘‘Truck-Bus’’ section of the Tire and Rim Association Year Book, as updated annually, unless the tire
falls within one of the specific exclusions set out below.
Truck and bus 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 truck and bus tires produced in the subject country whether mounted on wheels
or rims in the subject country or in a third country. Truck and bus tires are covered whether or not they
are accompanied by other parts, e.g., a wheel, rim, axle parts, bolts, nuts, etc. Truck and bus tires that
enter attached to a vehicle are not covered by the scope.
Specifically excluded from the scope of this investigation are the following types of tires:
(1) Pneumatic tires, of rubber, that are not new, including recycled and retreaded tires; and
(2) non-pneumatic tires, such as solid rubber tires.
The subject merchandise is currently classifiable under Harmonized Tariff Schedule of the United States
(HTSUS) subheadings: 4011.20.1015 and 4011.20.5020. Tires meeting the scope description may also
enter under the following HTSUS subheadings: 4011.69.0020, 4011.69.0090, 4011.99.4520,
4011.99.4590, 4011.99.8520, 4011.99.8590, 8708.70.4530, 8708.70.6030, 8708.70.6060, and
8716.90.5059. While HTSUS subheadings are provided for convenience and for customs purposes, the
written description of the subject merchandise is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.

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U.S. Producers’ Questionnaire - Truck And Bus Tires

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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.

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U.S. Producers’ Questionnaire - Truck And Bus Tires
I-1a.

Page 4

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

I-1b.

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

I-2.

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

Additional discussion on establishments consolidated in this questionnaire:

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U.S. Producers’ Questionnaire - Truck And Bus Tires
I-3.

Page 5

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

Support

Oppose

Take no position

China AD
China 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 truck and bus tires from China into the United States or
that are engaged in exporting truck and bus tires from China 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 truck and bus tires?
No
Firm name

Yes--List the following information.
Address

Affiliation

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U.S. Producers’ Questionnaire - Truck And Bus Tires
I-7.

Page 6

Aftermarket distribution network.--Does your firm, or a related firm, own its own aftermarket
distribution network?

Yes1

If yes, please describe geographic coverage of this network and the types
of additional services your firm’s ore the related firms provide to your
customers through this network.

If yes, please ensure that all revenue and profit from your aftermarket distribution network is excluded
from this questionnaire response (e.g. question II-7 and III-9a). The revenues and profits in these tables
should only reflect the results of your domestic production operations, and not further distribution and
retailing operations.

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U.S. Producers’ Questionnaire - Truck And Bus Tires

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nathanael Comly
([email protected] or 202-205-3174). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of truck and bus 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)

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U.S. Producers’ Questionnaire - Truck And Bus Tires
II-3a.

Page 8

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

2013

2014

January-September
2015

2015

2016

Overall production capacity
Production of:
Truck and bus tires1

Passenger vehicle and light
truck (PVLT) tires
Off-the-road (OTR) tires
Other products2
Total
1
2

Data entered for production of truck and bus 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

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U.S. Producers’ Questionnaire - Truck And Bus Tires
II-3e.

Product shifting.—
(i)

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

(ii)

II-4.

Page 9

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 truck and bus 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 - Truck And Bus Tires
II-5.

Page 10

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce truck and bus tires in and/or admit
truck and bus 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 truck and bus tires into a foreign trade zone (FTZ) for use in distribution of truck
and bus 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 truck and bus 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 - Truck And Bus Tires
II-7.

Page 11

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of truck and bus tires 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 in which the party purchasing the
tires acquire the legal ownership of/ title to the tires (do not include U.S. shipments to your own
firm’s distribution and retail stores). 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. The majority of commercial U.S. shipments in this industry is understood to be
of unmounted truck and bus tires, but commercial U.S. shipments can include shipments of
mounted truck or bus tires if your firm mounts the tires for customers prior to shipment. Any
shipments of mounted truck or bus tires reported should include only the value of the tire and,
therefore, be exclusive of the value of the wheel/rim on which it was shipped/sold.
“Lease U.S. shipments” – Shipments made within the United States of a commercial transaction
(either arm's length or potentially to related entities) in the ordinary course of business in which
your firm retains the legal ownership of/ title to the tires shipped. Report lease shipment
quantities once at the time of an actual physical transfer of a tire to the leasee(s): include both
initial shipments and replacement shipment quantities. Report lease shipment values at fair
market value at the time of physical transfer of the tire to the leasee.
“Branded tire” –A truck or bus tire produced or packaged for sale under the name of the
manufacturer of the tire or a brand name owned by the manufacturer.
“Private label tire” --A truck or bus tire produced or packaged for sale under the name other than
of the manufacturer of the tire or a brand name owned by the manufacturer.
“Internal consumption” – Product consumed internally by your firm.
“Transfers to related firms” –Shipments made to related domestic firms and to your own firm’s
distribution and retail stores. Such transactions are valued at fair market value based on the value
of arm’s length commercial transactions at the same level of trade (i.e. to independent distributors
and retailers).
“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.

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U.S. Producers’ Questionnaire - Truck And Bus Tires
II-7.

Page 12

Production, shipment, and inventory data.--Continued

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.
Quantity (in 1,000 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):
Radial(C)
Bias ply - tubed(D)
Bias ply - tubeless (E)
Total production (F)

U.S. shipments:
2
Commercial shipments:
Radial
Quantity) (G)
Value (H)
Bias ply - tubed
Quantity (I)
Value (J)
Bias ply - tubeless
Quantity(K)
Value (L)
Total commercial U.S. shipments
Quantity (M)
Value (N)
Lease shipments:
Quantity (O)

Value (P)
Internal consumption:
Quantity (Q)
4

Value (R)
Transfers to related firms:
Quantity (S)
4

Value (T)
Export shipments:
Quantity (U)

Value (V)
End-of-period inventories (quantity) (W)
Continued on next page.

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U.S. Producers’ Questionnaire - Truck And Bus Tires
II-7.

Page 13

Production, shipment, and inventory data.--Continued

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
Of the data reported to U.S. commercial shipments in 2015 above, please indicate the share of quantity
(percent) your firm sold as a mounted truck or bus tire.
3
Please indicate the total number of tires your firm had outstanding on lease on the following dates:
Dec 31, 2013

Dec 31, 2014

Dec 31, 2015

Sept 30, 2015

Sept 30, 2016

Total quantity of tires under
lease obligations outstanding (in
1,000s of tires)

Lease shipments, 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:
.

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, D and E), less total shipments (i.e., lines G, I, K, M, O, Q, S, U). 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+E – G – I – K – M – O – Q – S U= 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 - Truck And Bus Tires
II-8.

Page 14

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

2013

2014

January-September
2015

2015

2016

Channels of distribution:
Commercial U.S. shipments:
To OEMS (quantity) (X)
To aftermarket suppliers.-Private label (quantity) (Y)
Branded (quantity) (Z)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines O, P and Q) 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
X + Y + Z – G - I - K = zero ("0"), if not
revise.

2013

2014
0

January-September
2015

2015
0

2016
0

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U.S. Producers’ Questionnaire - Truck And Bus Tires
II-9.

Page 15

Employment data.--Report your firm’s employment-related data related to the production of
truck and bus 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

2013

2014

January-September
2015

2015

2016

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

II-10.

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

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U.S. Producers’ Questionnaire - Truck And Bus Tires
II-11.

Page 16

Purchases.--Other than direct imports, has your firm otherwise purchased truck and bus 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 1,000 tires)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Purchases from U.S.
importers1 of truck and bus
tires from—
China
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1

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

II-12.

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

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Page 17

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202-2053432, [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 truck and bus tires:

Does your firm prepare profit/loss statements for truck and bus 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 truck and bus 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.).

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Page 18

III-4.

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

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced truck and bus 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

Truck and bus tires

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of truck and bus 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 truck and
bus 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 - Truck And Bus Tires
III-8.

Page 19

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on truck and bus
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.

Mounted truck and bus tires.--The majority of net sales in this industry is understood to be of
unmounted truck and bus tires, but net sales reported in question III-9a can include sales of
mounted truck or bus tires. However, any sales of mounted truck or bus tires should exclude the
value of the wheel/rim on which it was shipped/sold, and likewise costs associated with the
wheel/rim should not be included in the cost data. Additional details relating to the included
sales of mounted truck and bus tires are requested in question III-9c (below).
Retreading of truck and bus tires.--The data reported in question III-9a should not include any
profit or loss information relating to your firm's retreading business. Separate data are
requested for those operations in question III-9e (below).

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 20

III-9a. Operations on truck and bus tires.--Report the revenue and related cost information requested
below on the truck and bus 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. Please
refer to the definition of transfers to related firms (fair market value) in question II-7.
Quantity (in 1,000 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.

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 21

III-9b. Raw materials for truck and bus tires.—Please indicate the share of total raw material costs
reported in III-9a in 2015 for the following raw material inputs:
Share of total raw
material costs
(percent)
%
%
%
%
%
0.0 %

Products
Rubber (natural and/or synthetic)
Carbon black
Fabric
Bead wire
Other1:
Total (should sum to 100 percent)
1

Please indicate any other notable "other" raw materials not expressly identified above
and provide the share of the total raw material costs that they account for:

III-9c.

Sales of mounted truck and bus tires.—Of the data provided in question III-9a, please provide
the share (percent) that your firm sold in 2015 as mounted truck and bus tires: sales
percent; sales value
percent; and total costs/expenses (COGS and SG&A
quantity
expenses)
percent.

III-9d. Selling/marketing expenses for truck and bus tires.—Please describe the primary selling and
marketing expenses reported in table III-9a and the manner in which these expenses are distinct
with respect to the OEM and replacement markets.

III-9e. Retread operations.—Please provide information on your firm’s retread operations for the
three most recently completed fiscal years.
Quantity (in 1,000 tires) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January-September
2015

2015

2016

Number of tires retreaded (1,000 tires)
Revenue associated with retread
operations ($1,000)
Total costs/expenses1 associated with
retread operations ($1,000)
Operating profit from retread operations
($1,000)
Capital expenditures associated with
retread operations ($1,000)
Research and development expenses
associated with retread operations
($1,000)
1

Including COGS and SG&A expenses

Business Proprietary
U.S. Producers’ Questionnaire - Truck And Bus Tires
III-9f.

Page 22

Tire leasing operations. – Please provide information on your firm’s tire leasing operations
Quantity (in 1,000 tires) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January-September
2015

2015

2016

Number of tires shipped under lease
(1,000 tires)
Revenue recognized on leasing
operations ($1,000)1
Total costs/expenses2 associated with
leasing operations ($1,000)
Operating profit from leasing operations
($1,000)

Report revenue under lease programs as recognized in your firm's accounting records. The revenue
reported here will not match the fair value data provided in question II-7.
2
Including COGS and SG&A expenses
Please describe the following
Fee basis:
Accounting recognition:
primarily as capital leases,
primarily as operating leases, or
split between capital and operating leases. Please describe:
Maintenance and service obligations:
Lessee customers:

evenly

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 23

III-9g. 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

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U.S. Producers’ Questionnaire - Truck And Bus Tires

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 assets, like cash, accounts receivable,
inventories, and other current assets, and long-term assets, like property, plant, and equipment,
net of depreciation) associated with the U.S. production, warehousing, and sale of truck and bus
tires. If your firm does not maintain some or all of the specific asset information necessary to
calculate total assets for truck and bus 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 and III-9f (but should not include assets relating to
re-tread operations reported in III-9e). 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 truck and bus 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

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.

2016

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U.S. Producers’ Questionnaire - Truck And Bus Tires

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

If no, please explain.

III-15. 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 truck and bus tires from China?
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

(please describe)

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 26

III-16. 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 truck and bus tires from China?
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

(please describe)

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 27

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
truck and bus tires from China?
No

Yes

If yes, my firm anticipates negative effects as follows:

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

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 28

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Michele Breaux (202-2052781, [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.--Truck and bus tire, tires designated for drive application (excluding all-position/allpurpose tires), size 11R22.5, 16 ply rating, load range of H, speed rating L (75
mph).
Product 2.-- Truck and bus tire, tires designated for drive application (excluding allposition/all-purpose tires), size 11R24.5, 16 ply rating, load range of H, speed
rating L (75 mph).
Product 3.-- Truck and bus tire, tires designated for drive application (excluding allposition/all-purpose tires), size 295/75R22.5, 14 ply rating, load range of G, speed
rating L (75 mph).
Product 4.-- Truck and bus tire, tires designated for drive application (excluding allposition/all-purpose tires), size 285/75R24.5, 14 ply rating, load range of G, speed
rating L (75 mph).

Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
During January 2013-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.

Business Proprietary
U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 29

IV-2(a). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to original equipment manufacturers (OEMs).

US – SALES TO OEMs
Report data in actual number of tires and actual dollars (not 1,000s).
(Quantity in number of tires, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

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

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 30

IV-2(a). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm into the aftermarket (e.g., to dealers and service centers for tire replacements)

US – SALES TO AFTERMARKET
Report data in actual number of tires and actual dollars (not 1,000s).
(Quantity in number of tires, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 31

IV-2(b). 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 truck and
bus 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 truck and bus 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 truck and bus tires usually quoted (check
one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire - Truck And Bus Tires
IV-6.

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

Share of 2015
OEM sales
Share of 2015
aftermarket
sales
IV-7.

Page 32

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)

0.0

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

No
Quantity
Price
Both
Yes
No

OEM market
Short-term
contracts
Annual contracts
(multiple deliveries (multiple deliveries
for 12 months)
for less than 12
months)
365

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

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U.S. Producers’ Questionnaire - Truck And Bus Tires
IV-7.

Page 33

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

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

365

No
Quantity

Meet or release
provision

Price
Both
Yes
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 truck and bus tires?

Source

Share of 2016 sales

From inventory

Produced to order

Total (should sum to 100.0%)

0.0

Lead time (average
number of days)

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U.S. Producers’ Questionnaire - Truck And Bus Tires
IV-9.

Page 34

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced truck
and bus 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 truck and bus 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 truck and bus 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

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Page 35

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

Truck and bus tires

Total
(should sum to
100.0% across)

Other inputs

For OEMs, a new
Heavy Duty (Class 7 or
8) Truck or Bus1

0.0 %

For OEMs, a new
Medium Duty (Class 6
or lower) Truck or Bus1

0.0 %

Other
1

This line is asking how much do "truck and bus tires" account for the total cost to produce the
class of truck or bus in question for an OEM (estimates are acceptable). The other inputs include
everything else that makes up a truck/bus. Include trailer costs in this calculation/analysis if
appropriate.
2
Describe the end use
.

IV-12. Substitutes.-- Can other products be substituted for truck and bus tires?
No

Substitute
1.
2.
3.

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for truck and bus tires?
No Yes

Explanation

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 36

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

Market

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

OEM market
Within the United
States
Outside the
United States
Aftermarket
Within the United
States
Outside the
United States
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of truck and bus tires since January 1, 2013?
No

Yes

If yes, please describe and quantify if possible.

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 37

IV-15. Conditions of competition.-(c) Is the truck and bus tires market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to truck and bus tires?
If yes, describe.
Check all that apply.

Please describe.

Skip to question IV-16.

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

Yes

If yes, describe.

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

Yes

If yes, please describe.

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

Explain, noting how raw material price changes
have affected your firm’s selling prices for truck
and bus tires.

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U.S. Producers’ Questionnaire - Truck And Bus Tires

Page 38

IV-18. Retreading.—
(a)

Did your firm sell truck and bus tires with retreading warrantees/guarantees?

Check all that apply.

Please describe.

Skip to question III-19.

Yes-casings covered

Number of years that casings covered.

to
retreads

Yes-retreading covered

Number of retreads covered.
to
and/or
Number of years that retreads covered.

years

Yes-other
If yes, estimate the proportion of 2015 sales with retreading warrantees/guarantees.
(b)

Estimate of the additional price of a truck and bus tire with retreading
warrantees/guarantees relative to one without.
to
percent

IV-19. Product categories.—
(a) Is the U.S. truck and bus tires market divided into categories (e.g., Best/Better/Good; Tier
1/Tier 2/Tier 3; Flagship/Secondary/Mass-market)?
No
Yes

1.
2.
3.
4.
5.

File Type	application/pdf
File Title	US producer questionnaire
Subject	Title 7 investigations
Author	Nate Comly
File Modified	2016-10-06
File Created	2016-10-06