Form 16-1-3600 U.S. Producers' Questionnaire

OMB No. 3117-0016/USITC No. 16-1-3600; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
PHOSPHPOR COPPER FROM KOREA
This questionnaire must be received by the Commission by January 5, 2017
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping investigation concerning phosphor copper from Korea (Inv. No. 731-TA-1314 (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 phosphor copper (as defined on next page) at any time since January 1, 2013?

NO

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

YES

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

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: PHOS)
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
proceeding or other proceedings 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 – Phosphor Copper

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 9, 2016, by
Metallurgical Products Company, West Chester, PA. 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 (“Commerce”) makes an
affirmative determination of dumping. Questionnaires and other information pertinent to this
proceeding are available at
https://wwwadmin.usitc.gov/investigations/title_7/2016/phosphor_copper_korea/final.htm.
Phosphor copper covered by this investigation is master alloys 1 of copper containing between five
percent and 17 percent phosphorus by nominal weight, regardless of form (including but not limited to
shot, pellet, waffle, ingot, or nugget), and regardless of size or weight. Subject merchandise consists
predominantly of copper (by weight), and may contain other elements, including but not limited to iron
(Fe), lead (Pb), or tin (Sn), in small amounts (up to one percent by nominal weight). Phosphor copper is
frequently produced to JIS H2501 and ASTM B–644, Alloy 3A standards or higher; however, merchandise
covered by this investigation includes all phosphor copper, regardless of whether the merchandise
meets, fails to meet, or exceeds these standards.
This merchandise is currently classified in the Harmonized Tariff Schedule of the United States (“HTSUS”)
under subheading 7405.00.1000. This HTSUS subheading is provided for convenience and customs
purposes; the written description of the scope of this investigation is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
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

1

A ‘‘master alloy’’ is a base metal, such as copper, to which a relatively high percentage of one or two other
elements is added.

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U.S. Producers’ Questionnaire – Phosphor Copper

Page 3

similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
I-1a.

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

Dollars

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

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.

No

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of phosphor copper, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
1
2
3
4
5
6
1

I-3.

City, State

Zip (5 digit)

Additional discussion on establishments consolidated in this questionnaire:

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

Description

.

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Country

Support

Page 4

Oppose

Take no position

Korea
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 phosphor copper from Korea into the United States or
that are engaged in exporting phosphor copper from Korea 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 phosphor copper?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Phosphor Copper

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Porscha Stiger (202-2053241, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of phosphor copper 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 – Phosphor Copper
II-3a.

Page 6

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

2013

2014

January-September
2015

2015

2016

Overall production capacity
Production of:
Phosphor copper1

0

0

0

0

0

0

0

0

0

0

2

Other products
Total
1
2

Data entered for production of phosphor copper 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 – Phosphor Copper
II-3e.

Product shifting.—
(i)

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

(ii)

II-4.

Page 7

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 phosphor copper?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No

II-5.

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

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce phosphor copper in and/or admit
phosphor copper into a foreign trade zone (FTZ)?
“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).

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import phosphor copper into a foreign trade zone (FTZ) for use in distribution of
phosphor copper and/or the production of downstream articles?

(b)

No/Don’t know

II-6.

Page 8

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2013, has your firm imported phosphor copper?
“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

II-7.

Yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

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

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U.S. Producers’ Questionnaire – Phosphor Copper

Page 9

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.
II-7.
Production, shipment, and inventory data.—Continued
Quantity (in pounds) and value (in $1,000)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

1

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

0

0

0

0

0

0

0

0

0

0

Internal consumption:
Quantity (F)
3

Value (G)
Transfers to related firms:
Quantity (H)
3

Value (I)
Export shipments:
Quantity (J)

4

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

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Data will populate into this grid when entered in question II-9.
3
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:
4
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 L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar years

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

2013

2014

0

January-September
2015

0

2015

0

2016

0

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

0
.

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
II-8.

Page 10

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

2013

2014

January-September
2015

2015

2016

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To end users (quantity) (N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for commercial U.S. shipments (i.e.,
line D) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.

2013

2014
0

January-September
2015

0

2015
0

2016
0

0

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U.S. Producers’ Questionnaire – Phosphor Copper
II-9.

Page 11

Commercial U.S. shipments by phosphor content and form.-- Report your firm’s commercial
U.S. shipments by phosphor content and form.
Quantity (in pounds) and value (in $1,000)
Calendar years
Item

Commercial U.S. shipments.-8 percent phosphor content.—
Shot.-Quantity (O)
Value (P)
Ingot/waffle.-Quantity (Q)
Value (R)
15 percent phosphor content.—
Shot.-Quantity (S)
Value (T)
Ingot/waffle.-Quantity (U)
Value (V)
Other phosphor content.—
Shot.-Quantity (W)
Value (X)
Ingot/waffle.-Quantity (Y)
Value (Z)

2013

2014

January-September
2015

2015

2016

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
II-10.

Page 12

Employment data.--Report your firm’s employment-related data related to the production of
phosphor copper and provide an explanation for any trends in these data.
“Production and 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-11.

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.

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
II-12.

Page 13

Purchases.--Other than direct imports, has your firm otherwise purchased phosphor copper
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 pounds)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Purchases from U.S.
importers1 of phosphor
copper from—
Korea
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-13.

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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U.S. Producers’ Questionnaire – Phosphor Copper

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, [email protected]).
III-1.

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

III-2.

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

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

B.1.

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

2.

Does your firm prepare profit/loss statements for phosphor copper:
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,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

3.

4.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes phosphor copper, 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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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 phosphor copper, and provide the share of net sales accounted for by these products
in your firm’s most recent fiscal year.
Products

Share of sales

Phosphor copper

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of phosphor copper 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 phosphor
copper 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 – Phosphor Copper
III-8.

Page 16

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

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III-9a. Operations on phosphor copper.--Report the revenue and related cost information requested
below on the phosphor copper 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.
Quantity (in pounds) and value (in $1,000)
Fiscal years ended-Item

2013

2014

January-September

2015

2015

2016

2

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

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor
Other factory costs

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

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

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

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U.S. Producers’ Questionnaire – Phosphor Copper

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

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

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

2013

2014

January-September

2015

2015

2016

Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in table III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
Value ($1,000)
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Page 19

III-10b. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in table III-10a above, 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-10a identify where these items are
reported in table III-9a.

III-11. Effects of changes in export shipments on financial performance.—Please discuss how
increases or decreases in export shipments during the period of investigation have affected your
company’s reported profitability in table III-9a. Please include in your response how changes in
export shipments affect profitability on U.S. commercial shipments.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of phosphor copper. If your firm does not maintain some
or all of the specific asset information necessary to calculate total assets for phosphor copper 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

Describe

1

2013

2014

2015

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
III-13.

Page 20

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for phosphor copper. Provide data for
your firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended--

Item

2013

2014

January-September

2015

2015

2016

Capital expenditures
Research and development expenses
1

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

2

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

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.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended-Reconciliation

2013

2014

January-September
2015

2015

2016

Quantity: Trade data from part II
less financial data from part III, = zero
("0") except as noted above.

0

0

0

0

0

Value: Trade data from part II less
financial data from part III, = zero
("0") except as noted above.

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-7?
Yes

No

If no, please explain.

Business Proprietary
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Page 21

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 phosphor copper from Korea?
No

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

(please describe)

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-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 phosphor copper from Korea?
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)

Business Proprietary
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Page 22

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
phosphor copper from Korea?
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.

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Page 23

PART IV.-- PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Craig Thomsen (202-2053226, [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.—15% phosphor copper shot that meets or exceeds JIS H2501 Grade 1, Class A, 15 P
Cu A, P content approximately 14.8%. P 14.7% to 14.9%, P+Cu>99.75%, Fe<0.03%,
Pb<0.01%, Sn<0.01%, in drums or comparable containers
Product 2. —15% phosphor copper ingot/waffle that meets or exceeds JIS H2501 Grade 1, Class
A, 15 P Cu A, P content approximately 14.8%. P 14.7% to 14.9%, P+Cu>99.75%,
Fe<0.03%, Pb<0.01%, Sn<0.01%, in drums or comparable containers

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

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
IV-2.

Page 24

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

Report data in actual pounds and actual dollars (not 1,000s).
Product 1
Period of shipment

Quantity

Product 2
Value

Quantity

Value
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:

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

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

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
IV-3.

Price setting.-(a)

How does your firm determine the prices that it charges for sales of phosphor copper
(check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.

Transaction
by
transaction

(b)

Contracts

Other

Yes

If other, describe

If yes, describe.

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

Quantity
discounts

IV-5.

Set
price
lists

Do your firm’s contracts for sales of phosphor copper include any provision for price
adjustment based on raw materials costs?
No

IV-4.

Page 25

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 phosphor copper?
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 phosphor copper usually quoted (check
one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
phosphor copper 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
IV-7.

Page 26

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

%

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

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

Yes1

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 – Phosphor Copper
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 phosphor copper?

Source

Share of 2015 sales

From inventory

%

Produced to order

%

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

Page 27

Lead time (average
number of days)

0.0 %

Shipping information.-(a)

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

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced phosphor copper 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
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Page 28

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

phosphor copper

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Substitutes.-- Can other products be substituted for phosphor copper?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for phosphor copper?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for phosphor copper has changed since January 1, 2013. Explain any trends
and describe the principal factors that have affected these changes in demand.

Market
Within
the United
States
Outside
the United
States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Page 29

IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of phosphor copper since January 1, 2013?
No

Yes

If yes, please describe and quantify if possible.

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

Please describe.

No

Skip to question IV-16.

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

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply phosphor copper
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.

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Page 30

IV-17. Raw materials.--How have phosphor copper 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
phosphor copper.

IV-18. Shot vs Ingot.--How often can shot form phosphor copper be used in place of ingot/waffle form copper?
Always

Frequently Sometimes

Rarely

Never

If “Frequently,” “Sometimes,” or “Rarely,” please
explain.

IV-19. 8% vs. 15% phosphor copper.--Are there any differences in end uses or customers for 8%
phosphor copper as compared to 15% phosphor copper?
No

Yes

If yes, please describe.

IV-20. Packaging.--What type of packaging (e.g., 55 gallon drum) does your firm use for its sales of
phosphor copper?

IV-21. Interchangeability.--Is phosphor copper produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

Korea

Other countries

United States
Korea
For any country-pair producing phosphor copper which is sometimes or never interchangeable,
please identify the country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire – Phosphor Copper

Page 31

IV-22. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between phosphor copper
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

Korea

Other countries

United States
Korea
For any country-pair for which factors other than price always or frequently are a significant factor in
your firm’s purchases of phosphor copper, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

IV-23. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for phosphor copper since January 1, 2013. Indicate the share of the quantity of your
firm’s total shipments of phosphor copper that each of these customers accounted for in 2015.
Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2015
sales (%)

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IV-24. Competition from imports
(a)

Lost revenue.--Since January 1, 2013: To avoid losing sales to competitors selling
phosphor copper from Korea, did your firm:
No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2013: Did your firm lose sales of phosphor copper to
imports of this product from Korea?
No

Yes

IV-25. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, 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 33

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/title_7/2016/phosphor_copper_korea/final.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: PHOS

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.