16-3-3602 U.S. Purchasers' Questionnaire

OMB No. 3117-0016/USITC No. 16-3-3602; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PURCHASERS’ 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 possession (19 U.S.C. § 1333(a)). Further information on this questionnaire can be
obtained from Craig Thomsen (202-205-3226, [email protected]).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased phosphor copper (as defined on next page) from any source (domestic or foreign) 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 submitting 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. Purchasers’ 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.

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. Purchasers’ Questionnaire –Phosphor copper

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Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
I-1.

OMB statistics.--Please report 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
25 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 your U.S. establishment(s) covered
by this questionnaire, if different from that listed on the cover page. 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 purchase of phosphor copper, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

Business Proprietary
U.S. Purchasers’ Questionnaire –Phosphor copper
I-3.

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

Yes--List the following information.

Firm name

I-4.

Address

Yes--List the following information.

Firm name

Address

Affiliation

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, which import phosphor copper from countries other than Korea into the
United States or which export phosphor copper from countries other than Korea to the United
States?
No

Yes--List the following information.

Firm name and country

I-6.

Extent of ownership
(percent)

Related SUBJECT importers/exporters.--Does your firm have any related firms, either domestic
or foreign, which import phosphor copper from Korea into the United States or which export
phosphor copper from Korea to the United States?
No

I-5.

Page 4

Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, which
produce phosphor copper?
No
Firm name

Yes--List the following information.
Address

Affiliation

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U.S. Purchasers’ Questionnaire –Phosphor copper

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PART II.--PURCHASES
Contact information.-- Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this questionnaire.
Name
Title
Email
Telephone
Fax
Purchases.— Report your firm’s total U.S. purchases of phosphor copper. (Do not include
imports for which your firm was the importer of record; such imports should be reported in your
U.S. importer’s questionnaire.)

II-1.

Item

2013

2014

Purchases of phosphor copper
produced in--

2015

Quantity (in pounds)

United States
Korea
All other countries:1
Sources unknown
Total purchases
1

II-2.

0

0

Please identify these countries:
Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of
phosphor copper from different sources have changed since January 1, 2013.

Source of Did not
purchases purchase Decreased Increased Constant Fluctuated
United
States
Korea
All other
countries
Sources
unknown

Explanation for trend

0

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U.S. Purchasers’ Questionnaire –Phosphor copper

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II-3.

Purchases from one country only.--If your firm has purchased phosphor copper from only one
country, please explain the reasons for doing so.

II-4.

Supplier identification.--Please list your firm’s FIVE largest suppliers for phosphor copper since
January 1, 2013. Also, provide the share of the quantity of your firm’s total purchases of
phosphor copper that each of these suppliers accounted for in 2015.

No.

Supplier’s name

City and state

Share of quantity of
2015 purchases

1

%

2

%

3

%

4

%

5

%

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PART III.--MARKET CHARACTERISTICS AND PURCHASING PRACTICES
III-1.

Firm type.--Which of the following best describes your firm as a purchaser of phosphor copper
(check all that apply)?
End user
End user
(copper tube
(rod or alloy
manufacturer) manufacturer)

End user
(Other:
___________)

Distributor

Other

Describe other

If your firm is a distributor of phosphor copper, please answer questions III-2 and III-3.
III-2.

Competition for sales.--Does your firm compete for sales to customers with the manufacturers
or importers from which your firm purchases phosphor copper?
No

III-3.

Yes

If yes, please describe.

Types of customers.--What are the major types of consumers to which your firm sells phosphor
copper?

If your firm is an end user of phosphor copper, please answer questions III-4 and III-5.
III-4.

End uses.-(a) List the top 3 products your firm makes using phosphor copper and estimate the percent of
your total production cost that is accounted for by phosphor copper and by other inputs
(such as labor, energy, and other raw materials).
Share of total cost in each of the product(s) your
firm produces accounted for by
Product(s) your firm
produces

phosphor copper

Total
(should
sum to
100.0%
across)

Other inputs
% +

%

=

0.0 %

% +

%

=

0.0 %

% +

%

=

0.0 %

Business Proprietary
U.S. Purchasers’ Questionnaire –Phosphor copper
III-5.

Demand for end use products.-(a)

Has the demand for your firm’s final products incorporating phosphor copper changed
since January 1, 2013?
Increased

(b)

No change

Decreased

Fluctuated

Has this had any effect on your firm’s demand for phosphor copper?
No

III-6.

Page 8

Yes

Explain

Substitutes.—
(a)

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.
(b) Which form(s) of phosphor copper does your firm purchase? (Select all that apply.)
How often can one be used in place of the other?
Shot

Please explain:

Ingot/waffle

Always

Frequently

Sometimes

Never

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U.S. Purchasers’ Questionnaire –Phosphor copper
III-7.

Page 9

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-8.

Packaging.--What type of packaging (e.g., 55 gallon drum) of phosphor copper does your firm
purchase?

III-9.

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
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Within the United
States
Outside the United
States
III-10. Country preferences.--Do you or your customers ever specifically order phosphor copper from
one country in particular over other possible sources of supply?
No

Yes

If yes, identify the countries and explain.

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U.S. Purchasers’ Questionnaire –Phosphor copper

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III-11. Importance of purchasing domestic product.--Please fill out the table below, estimating the
percentage of your firm’s total 2015 purchases of phosphor copper that required phosphor
copper produced in the United States.

Purchases that did not require domestic product
Purchases that were required by law or regulation to be domestic product
(e.g., government purchases under “Buy American” provisions)
Purchases that were not required by law or regulation, but were required by
your customers to be domestic product
Purchases that were required to be domestic product for other reasons
(explain:
)
Total (should sum to 100.0%)

Estimated percentage of
your firm’s total 2015
purchases of phosphor
copper
%
%
%
%
0.0 %

III-12. 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?

Check all that apply.

Please describe.

No

Skip to question III-13.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) 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.

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U.S. Purchasers’ Questionnaire –Phosphor copper

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III-13. Decisions based on producer and country-of-origin.--How often does your firm, and if known,
do your customers, make purchasing decisions involving phosphor copper based on its producer
or country of origin?
Always

Usually

Sometimes

Never

If at least sometimes, explain.

Decision based on producer
Your firm
Your
customers
Decision based on country of origin
Your firm
Your
customers
III-14. Availability of supply.--Has the availability of phosphor copper in the U.S. market changed since
January 1, 2013?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
U.S.-produced product
Subject imports
Nonsubject imports
III-15. Supply constraints.--Has any firm refused, declined, or been unable to supply your firm with
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-16. Availability of merchandise.--Are certain grades/types/sizes of phosphor copper only available
from certain country sources?
No

Yes

If yes, please identify the countries and the grade/type/size.

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III-17. Purchasing frequency.-(a)

How frequently does your firm make purchases of phosphor copper (check one)?
Daily

(b)

Weekly

Monthly

Quarterly

Annually

Other

If other, specify

Has this purchasing frequency changed since January 1, 2013?
No

Yes

If yes, please describe.

III-18. Number of suppliers contacted.--How many suppliers does your firm generally contact before
making a purchase? Between
and
firms
III-19. Supplier negotiations.-(a)

Does your firm’s purchases of phosphor copper usually involve negotiations between
supplier and purchaser?

No

(b)

Yes

If yes, explain the factors your firm generally negotiates and note
whether your firm quotes competing prices during negotiations.

Are your firm’s purchase prices indexed to raw material costs?
Purchases

No

Yes

Please explain (e.g. the indexing mechanism,
relevant raw materials, any premiums, etc.)

By Contract
Spot market
(c)

Do prices of phosphor copper in shot form affect your firm’s price negotiations for
phosphor copper in ingot/waffle form, or vice versa?
No

Yes

If yes, explain.

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U.S. Purchasers’ Questionnaire –Phosphor copper

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III-20. Change in suppliers.--Has your firm changed suppliers since January 1, 2013?

No

Yes

If yes, please list the supplier(s), whether the firm was added or
dropped, and the reasons for the change.

III-21. New suppliers.--Are you aware of any new suppliers, either foreign or domestic, that have
entered the market since January 1, 2013?
No

Yes

If yes, please identify the firms.

III-22. Supplier qualification.--Do you require your suppliers to be or to become certified or qualified
to sell phosphor copper to your firm?
If yes, provide the following information.
• The number of days to qualify a new supplier.
• A general description of the certification or qualification process. Also, a brief
description of the factors that you consider when qualifying a new supplier (e.g., quality
of product, reliability of supplier, etc.).

No

Yes

Number
of days Process and factors

III-23. Failure to certify.--Since January 1, 2013, have any domestic or foreign producers failed in their
attempts to certify or qualify their phosphor copper with your firm or have any producers lost
their approved status?

No

Yes

If yes, please identify these firms, the countries where they are located,
and the reasons why they failed the certification/qualification.

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U.S. Purchasers’ Questionnaire –Phosphor copper

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III-24. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase phosphor copper (examples include availability,
extension of credit, contracts, price, quality, range of supplier’s product line, traditional supplier,
etc.).
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
III-25. Purchasing factors.--Please rate the importance of the following factors in your firm’s
purchasing decisions for phosphor copper.

Factor

Very
important

Somewhat
important

Not
important

Availability
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Packaging
Price
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs
III-26. Quality characteristics.--What characteristics does your firm consider when determining the
quality of phosphor copper?

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U.S. Purchasers’ Questionnaire –Phosphor copper

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III-27. Minimum quality.--How often does phosphor copper from the following countries meet
minimum quality specifications for your uses or your customers’ uses?

Source

Always

Usually

Sometimes

Rarely or
never

Don’t
know

United States
Korea
China
Other:
III-28. Frequency of decisions based on price.--How often does your firm purchase the phosphor
copper that is offered at the lowest price?
Always

Usually

Sometimes

Never

III-29. Choice of product not based on price.--If you purchased phosphor copper from one country
source although a comparable product was available from another country source at a lower
price, please explain your reasons for doing so (please specify by country).

III-30. Price leaders.— A price leader is defined as (1) one or more firms that initiate a price change,
either upward or downward, that is followed by other firms, or (2) one or more firms that have a
significant impact on prices. A price leader is not necessarily the lowest-priced supplier.
Please list the names of any firms you considered price leaders in the phosphor copper market
since January 1, 2013.
Firm(s)

Describe how the firm(s) exhibited price leadership

III-31. Purchasing subject imports rather than domestic products.—
(a)

Since January 2013, did your firm purchase imports of phosphor copper from Korea
instead of U.S.-produced phosphor copper?
Source
Korea

Yes
(also respond to parts (b) and (c))

No
(If “No”, skip to next question)

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U.S. Purchasers’ Questionnaire –Phosphor copper

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III-32. Purchasing subject imports rather than domestic products.— (continued)
(b)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source

Yes

No

Korea
(c)

If you responded “Yes” to part (a), was price a primary reason for purchasing subject
imports rather than domestic product?

Source

Yes

If Yes, estimate the quantity
of imports purchased instead
of domestic product since
January 2013
(in pounds)

No

If No, please indicate the
reason your firm purchased
imports instead of domestic
product

Korea
III-33. U.S. producers and import competition.—
(a)

Since January 1, 2013, in connection with a sale or offer to sell phosphor copper to your
firm, did U.S. producers reduce their prices of domestically produced phosphor copper
in order to compete with lower-priced imports of phosphor copper from the subject
countries?
Source

Yes (also respond to
question part (b))

No (If “No”, skip to next
question)

Don’t know

Korea
(b)

If your firm responded “yes”, please provide an estimate of the reduction in U.S.
producers’ prices, and any additional explanations, such as timing (e.g., months/years),
frequency of price reductions, or other market/competitive factors.

Source
Korea

Estimated
reduction in U.S.
prices
(percent)
%

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

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PART IV.—PRODUCT COMPARISONS
IV-1.

Country knowledge.--Please indicate the countries of origin for phosphor copper for which your
firm has actual marketing/pricing knowledge.

United States

Korea

China

Other
countries

Other countries (specify)

IV-2. 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. Purchasers’ Questionnaire –Phosphor copper
IV-3.

Page 18

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:

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U.S. Purchasers’ Questionnaire –Phosphor copper
IV-4.

Page 19

Factor country comparisons.--For the factors listed below, please rate how phosphor copper
produced in each country you identified in your response to the first question in Part IV
compares with phosphor copper produced in each of the other countries you identified.

Inferior

Comparable

Superior

Inferior

Comparable

Superior

Inferior

Comparable

Factor

Superior

If you are unfamiliar with the product from a particular country, please leave the boxes for those
country comparisons blank.
Product from
Product from
United States
United States
Product from
Korea compared to
compared to
compared to
product from
product from
product from
Korea
all other sources
All other sources

Availability
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Packaging
Price1
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs1
1

A rating of superior on price and U.S. transportation costs indicates that the first country generally has lower
prices/U.S. transportation costs than the second country.

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U.S. Purchasers’ Questionnaire –Phosphor copper

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PART V.—ADDITIONAL INFORMATION
V-1.

Other explanations.--If your firm would like to further explain a response to any question that
did not provide a narrative response box, please note the question number and the explanation
in the space provided below.

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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://wwwadmin.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 purchase 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 your firm submits (see
19 CFR § 207.7). Service of the questionnaire must be made in paper form.