16-2-3601 U.S. Importers' Questionnaire

OMB No. 3117-0016/USITC No. 16-2-3601; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ 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 imported phosphor copper (as defined on next page) from any country 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

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U.S. Importers’ 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.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary,
in importing phosphor copper (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
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
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. Importers’ Questionnaire – Phosphor Copper

Page 3

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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Porscha
Stiger (202-205-3241, [email protected]).

Business Proprietary
U.S. Importers’ Questionnaire – Phosphor Copper
I-1.

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
40 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-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of phosphor copper,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

I-3.

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

Firm name

Yes--List the following information

Address

Extent of
ownership
(percent)

Business Proprietary
U.S. Importers’ Questionnaire – Phosphor Copper
I-4.

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

Yes--List the following information.

Firm name

I-5.

Address

Yes--List the following information.

Firm name

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on
phosphor copper. More than one answer may be applicable.
Importer of record

I-7.

Affiliation

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

I-6.

Page 5

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of phosphor copper but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).

Firm name

Address

Contact person
and phone
number

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U.S. Importers’ Questionnaire – Phosphor Copper
I-8.

Page 6

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters phosphor copper
into, or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also
indicate whether your firm imports phosphor copper under the TIB (temporary importation
under bond) program.
“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, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
No

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

Third-country trade activities.--To your knowledge, have the products subject to this
proceeding been the subject of any other import relief proceedings in the United States or in
any other countries?
No

Yes–Please specify.

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U.S. Importers’ Questionnaire – Phosphor Copper

Page 7

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 importation of phosphor copper since January 1, 2013.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

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

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U.S. Importers’ Questionnaire – Phosphor Copper
II-3.

Page 8

Arranged imports.--Has your firm imported or arranged for the importation of phosphor copper
for delivery after September 30, 2015?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes–Fill out the table below.
Quantity (in pounds)

Period/Source

Oct-Dec 2016

Jan-Mar 2017

Apr-Jun 2017

Jul-Sept 2017

Korea
Other sources1
II-4.

Reasons for importing if producer.--If your firm also produces phosphor copper in the United
States, please indicate the reasons for importing this product. If your firm’s reasons differ by
source, please elaborate.

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U.S. Importers’ Questionnaire – Phosphor Copper

Page 9

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial shipments”—Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” –Product consumed internally by your firm.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
Such transactions are valued at fair market value.
“Export shipments”—Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories” –Finished goods inventory, not raw materials or work in progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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U.S. Importers’ Questionnaire – Phosphor Copper
II-5.

Page 10

IMPORTS FROM KOREA.–Report your firm’s imports and your firm’s shipments and inventories
of phosphor copper imported from Korea by your firm during the specified periods.

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

2013

2014

January-September
2015

2015

2016

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:2
Quantity (D)
Value (E)

0

0

0

0

0

0

0

0

0

0

Internal consumption/
company transfers:
Quantity (F)
Value3 (G)
Export shipments:4
Quantity (H)
Value (I)
End-of-period inventories
(quantity) (J)
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (K)
To end users (quantity) (L)
1

Please identify the foreign producers, if known:
.
Data will populate here once reported in question II-6.
3
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, 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:
.
2

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U.S. Importers’ Questionnaire – Phosphor Copper
II-5.

Page 11

IMPORTS FROM KOREA.–Continued

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

2013

2014

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

0

January-September
2015

0

2015
0

2016
0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) 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 item
K + L – D = zero ("0"), if not revise.

2013

2014
0

January-September
2015

0

2015
0

2016
0

0

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U.S. Importers’ Questionnaire – Phosphor Copper
II-6.

Page 12

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

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

2013

2014

January-September
2015

2015

2016

Business Proprietary
U.S. Importers’ Questionnaire – Phosphor Copper
II-7a.

Page 13

IMPORTS FROM ALL OTHER SOURCES.–Report your firm’s imports and your firm’s shipments
and inventories of phosphor copper imported from all other sources combined by your firm
during the specified periods.

(list sources:

ALL OTHER SOURCES COMBINED
)
Quantity (in pounds), value (in $1,000)
Calendar years

Item

2013

2014

January-September
2015

2015

2016

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:2
Quantity (D)
Value (E)

0

0

0

0

0

0

0

0

0

0

Internal consumption/
company transfers:
Quantity (F)
Value3 (G)
Export shipments:4
Quantity (H)
Value (I)
End-of-period inventories
(quantity) (J)
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (K)
To end users (quantity) (L)
1

Please identify the foreign producers, if known:
.
Data will populate here once reported in question II-8.
3
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, 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:
.
2

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U.S. Importers’ Questionnaire – Phosphor Copper
II-7.

Page 14

IMPORTS FROM ALL OTHER SOURCES.–Continued

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

2013

2014

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

0

January-September
2015

0

2015
0

2016
0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) 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 item
K + L – D = zero ("0"), if not revise.

2012

2013
0

January-September
2014

0

2014
0

2015
0

0

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U.S. Importers’ Questionnaire – Phosphor Copper
II-8.

Page 15

Commercial U.S. shipments by phosphor content and form (AOS).-- 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 (M)
Value (N)
Ingot/waffle.-Quantity (O)
Value (P)
15 percent phosphor content.—
Shot.-Quantity (Q)
Value (R)
Ingot/waffle.-Quantity (S)
Value (T)
Other phosphor content.—
Shot.-Quantity (U)
Value (V)
Ingot/waffle.-Quantity (W)
Value (X)

2013

2014

January-September
2015

2015

2016

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U.S. Importers’ Questionnaire – Phosphor Copper
II-7.

Page 16

Other explanations.--If your firm would like to further explain a response to a question in Part II
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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U.S. Importers’ Questionnaire – Phosphor Copper

Page 17

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Craig Thomsen (202-2053226, [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

PRICE DATA
III-2a. 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 your firm imported
from Korea:
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 (commercial sales) and landed duty
paid (for internal consumption -- see Part II Definitions on p. 9 for definition of “import values”) 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 import from Korea 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 III-2c.

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U.S. Importers’ Questionnaire – Phosphor Copper

Page 18

III-2b. Price data.--Report below the quarterly price data1 for pricing products2 imported from Korea
and sold by your firm.

Korea
Commercial sales

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

Period of shipment

(Quantity in pounds, value in dollars)
Product 1
Quantity
Value

Product 2
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 III.
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:

III-2c.

Import cost data.--During January 2013-September 2016, did your firm import from Korea and
internally consume any of the products listed on page 17 (or any products that were competitive
with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-2f.

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U.S. Importers’ Questionnaire – Phosphor Copper

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III-2d. Import cost data.— Report below the quarterly price data1 for pricing products2 imported from
Korea and sold by your firm.

Korea
Internally consumed

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

Period of shipment

(Quantity in pounds, value in dollars)
Product 1
Quantity
Value

Product 2
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 III.
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:

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U.S. Importers’ Questionnaire – Phosphor Copper

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III-2e. Additional costs for your direct imports of phosphor copper for your firm’s own use or
company transfer.
(i)

If your firm reported direct import costs above (question III-2d to II-2e), please identify
the factors that add to your cost of importing directly since January 1, 2013, NOT
including costs already reflected in the landed, duty-paid (LDP) cost. Also estimate the
share of the LDP cost this factor represents and explain the specific costs associated
with each category.

Factors
Logistical or supply chain costs
Warehousing costs
Compliance costs
Currency conversion costs
Other
(ii)

III-2f.

Explanation

To which source does your firm compare costs in determining your additional
transaction costs to directly import?
U.S. Importers

(iii)

Estimated share of LDP
(percent)

U.S. Producers

Both

Neither

If your firm reported data above (questions III-2d through III-2e), briefly identify the
benefits of directly importing phosphor copper instead of purchasing phosphor copper
from a U.S. importer or from a U.S. producer.

Pricing data methodology.—If your firm reported data in response to any of the questions III-2a
through III-2f, 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.

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U.S. Importers’ Questionnaire – Phosphor Copper
III-3.

Page 21

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

Set
price
lists

Contracts

Other

If other, describe

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

III-4.

Yes

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

Quantity
discounts

III-5.

If yes, describe.

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for phosphor copper imported from Korea?
Net 30
days

(b)

Net 60
days

2/10 net 30
days

Other

Other (specify)

On what basis are your firm’s prices of imported phosphor copper from Korea usually
quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Importers’ Questionnaire – Phosphor Copper
III-6.

Contract versus spot.--Approximately what share of your firm’s sales of phosphor copper
imported from Korea 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
III-7.

Page 22

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
phosphor copper from Korea (or check “not applicable” if your firm does not sell on a long-term,
short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Annual contracts
(multiple
deliveries for 12
months)
365

No
Quantity
Price
Both

Meet or release
provision

Yes

Indexed to raw
material costs1

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. Importers’ Questionnaire – Phosphor Copper
III-8.

Lead times.--What is your firm’s share of sales of phosphor copper imported from Korea 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 phosphor copper?

Source

Share of
2015 sales

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

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

Page 23

Lead time
(days)

0.0 %

Shipping information.—
(a)

What is the approximate percentage of the total delivered cost of phosphor copper
imported from Korea 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)

When your firm sells phosphor copper imported from Korea, from where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of phosphor copper imported
from Korea that are delivered the following distances from your firm’s U.S. point of
shipment.
Distance from your firm’s U.S. point of shipment

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

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

Page 24

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold phosphor
copper imported from subject countries since January 1, 2013 (check all that apply)?
Geographic area

Korea

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.
III-11. End uses.--List the end uses of the phosphor copper that your firm imports from Korea. For each
end-use 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

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

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

Explanation

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

Page 25

III-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.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within
the United
States
Outside
the United
States

III-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.

III-15. Conditions of competition.—
(a) Is the phosphor copper market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to phosphor copper?
Check all that apply.

Please describe.

No

Skip to question III-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.

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

Page 26

III-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.

III-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.

III-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.

III-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.

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

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

Page 27

III-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:

III-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:

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

Page 28

III-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

City

State

Share of 2015
sales (%)

1
2
3
4
5
6
7
8
9
10

III-24. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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

Page 29

Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

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

Page 30

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 did not import 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.