16-2-3613 U.S. Importers Questionnaire

OMB No. 3117-0016/USITC No. 16-2-3613; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
1-HYDROXYETHYLIDENE-1, 1-DIPHOSPHONIC ACID FROM CHINA
This questionnaire must be received by the Commission by JANUARY 17, 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 countervailing duty and antidumping investigations concerning 1hydroxyethylidene-1, 1-diphosphonic acid (“HEDP”) from China (Inv. Nos. 701-TA-558 and 731-TA-1316
(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 HEDP (as defined on next page) from any country at any time since January 1, 2014?

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: HEDP)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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PART I.—GENERAL INFORMATION
Background .--This proceeding was instituted in response to a petition filed on March 31, 2016, by
Compass Chemical International LLC, Smyrna, GA. Countervailing and antidumping duties may be
assessed on the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce makes
an affirmative determination of subsidization and dumping. Questionnaires and other information
pertinent to this proceeding are available at:
http://www.usitc.gov/investigations/701731/2016/1_hydroxyethylidene_1_1_diphosphonic_acid_china
/final.htm
HEDP.—The products covered by these investigations include all grades of aqueous, acidic (non–
neutralized) concentrations of 1–hydroxyethylidene–1,1–diphosphonic acid (“HEDP”), also referred to as
hydroxethlylidenendiphosphonic acid, hydroxyethanediphosphonic acid, acetodiphosphonic acid, and
etidronic acid. The CAS (Chemical Abstract Service) registry number for HEDP is 2809–21–4.
The merchandise subject to this investigation is currently classified in the Harmonized Tariff Schedule of
the United States (HTSUS) at subheading 2931.90.90. Merchandise covered by the scope may also be
imported under HTSUS subheadings 2811.19.6090, 2931.00.9043, 2931.90.9041, and 2931.90.9047.
While HTSUS subheadings are provided for convenience and customs purposes only, 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 HEDP (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
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

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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 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 HEDP, 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)

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U.S. Importers’ Questionnaire - HEDP
I-4.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing HEDP from China into the United States or that are
engaged in exporting HEDP from China to the United States?
No

Yes--List the following information.

Firm name

I-5.

Country

Yes--List the following information.

Firm name

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on HEDP.
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 HEDP?
No

I-6.

Page 4

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 HEDP 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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I-8.

Page 5

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters HEDP into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports HEDP 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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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Edward Petronzio (202-2053176, [email protected]). Supply all data requested on a calendar-year basis.
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 HEDP since January 1, 2014.
(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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Arranged imports.--Has your firm imported or arranged for the importation of HEDP for delivery
on or after December 31, 2016?
“Arranged imports” are imports for which your firm has placed an order with a foreign producer
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

Jan-Mar 2017

Apr-Jun 2017

Jul-Sept 2017

Oct-Dec 2017

China
Other sources1
1

II-4.

Identify your other sources:

Reasons for importing if producer.--If your firm also produces HEDP 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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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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II-5.

Page 9

IMPORTS FROM CHINA.–Report your firm’s imports and your firm’s shipments and inventories
of HEDP imported from China by your firm during the specified periods.

China

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

2014

2015

2016

Beginning-of-period inventories (quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ company transfers:
Quantity (F)
Value2 (G)
Export shipments:3
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:
.
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:
3
Identify your firm’s principal export markets:
.
2

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IMPORTS FROM CHINA.–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

2014

2015

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

2016

0

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. commercial
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.

2014

2015
0

2016
0

0

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IMPORTS FROM INDIA.–Report your firm’s imports and your firm’s shipments and inventories
of HEDP imported from India by your firm during the specified periods.

India

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

2014

2015

2016

Beginning-of-period inventories (quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ company transfers:
Quantity (F)
Value2 (G)
Export shipments:3
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:
.
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:
3
Identify your firm’s principal export markets:
.
2

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II-6.

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IMPORTS FROM INDIA.–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

2014

2015

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

2016

0

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. commercial
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.

2014

2015
0

2016
0

0

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Page 13

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

All Other Sources

(list sources:

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

Item

2014

2015

2016

Beginning-of-period inventories (quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ company transfers:
Quantity (F)
Value2 (G)
Export shipments:3
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:
.
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:
3
Identify your firm’s principal export markets:
.
2

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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

2014

2015

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

2016

0

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. commercial
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.
II-8.

2014

2015
0

2016
0

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.

0

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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Aimee Larsen (202-2053179, [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-2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2014 of the following products your firm imported
from China:
Product 1.—all grades of aqueous HEDP typically at 60% concentration (whether referred to as “HEDP”
or “1-hydroxyethylidene-1, 1-diphosphonic acid”, “hydroxethlylidenendiphosphonic acid”,
“hydroxyethanediphosphonic acid”, “acetodiphosphosphonic acid”, “etidronic acid,” or
substantially similar names) sold in bulk containers (e.g., ISO containers, or bulk tank cars, or rail
cars) .
Product 2.-- all grades of aqueous HEDP typically at 60% concentration (whether referred to as “HEDP”
or “1-hydroxyethylidene-1, 1-diphosphonic acid”, “hydroxethlylidenendiphosphonic acid”,
“hydroxyethanediphosphonic acid”, “acetodiphosphosphonic acid”, “etidronic acid,” or
substantially similar names) sold in drums.
Product 3.-- all grades of aqueous HEDP typically at 60% concentration (whether referred to as “HEDP”
or “1-hydroxyethylidene-1, 1-diphosphonic acid”, “hydroxethlylidenendiphosphonic acid”,
“hydroxyethanediphosphonic acid”, “acetodiphosphosphonic acid”, “etidronic acid,” or
substantially similar names) sold in intermediate bulk containers (IBS’s).
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 2014-December 2016, did your firm import from China 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 III-3.

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III-2(a). Price data.--Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.

China

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

(Quantity in pounds, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Period of shipment
Quantity
Quantity
Value
2014:
January-March
April-June
July-September
OctoberDecember
2015:
January-March
April-June
July-September
OctoberDecember
2016:
January-March
April-June
July-September
OctoberDecember
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:
Product 3:

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

India

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

(Quantity in pounds, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Period of shipment
Quantity
Quantity
Value
2014:
January-March
April-June
July-September
OctoberDecember
2015:
January-March
April-June
July-September
OctoberDecember
2016:
January-March
April-June
July-September
OctoberDecember
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:
Product 3:

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III-2(C). Price data.--Report below the quarterly price data1 for pricing products2 imported from all other
sources (AOS) and sold by your firm.

All Other Sources

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

(Quantity in pounds, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Period of shipment
Quantity
Quantity
Value
2014:
January-March
April-June
July-September
OctoberDecember
2015:
January-March
April-June
July-September
OctoberDecember
2016:
January-March
April-June
July-September
OctoberDecember
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:
Product 3:

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.

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U.S. Importers’ Questionnaire - HEDP
III-3.

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

III-4.

Contracts

Other

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for HEDP imported from China?
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 HEDP from China usually quoted (check
one)?
Delivered

III-6.

Set
price
lists

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

Quantity
discounts

III-5.

Page 19

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of HEDP imported from
China in 2016 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?

Share of 2016
sales

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

%

Business Proprietary
U.S. Importers’ Questionnaire - HEDP
III-7.

Page 20

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
HEDP from China (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
Meet or release
provision

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

Annual contracts
(multiple deliveries
for 12 months)

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

365

No
Quantity
Price
Both
Yes
No

Not applicable

III-8.

Lead times.--What is your firm’s share of sales of HEDP imported from China 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 HEDP?

Source

Share of 2016 sales

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Lead time (average
number of days)

Business Proprietary
U.S. Importers’ Questionnaire - HEDP
III-9.

Page 21

Shipping information.—
(a)

What is the approximate percentage of the total delivered cost of HEDP imported from
China 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 HEDP imported from China, from where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of HEDP imported from China
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

%

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold HEDP
imported from subject countries since January 1, 2014 (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.

China

Business Proprietary
U.S. Importers’ Questionnaire - HEDP

Page 22

III-11. End uses.--List the end uses of the HEDP that your firm imports from China. For each end-use
product, what percentage of the total cost is accounted for by HEDP and other inputs?
Share of total cost of end-use product
accounted for by
End use product

HEDP

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

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

Explanation

1.
2.
3.
III-13. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for HEDP has changed since January 1, 2014. 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

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Business Proprietary
U.S. Importers’ Questionnaire - HEDP

Page 23

III-14. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of HEDP since January 1, 2014?
No

Yes

If yes, please describe.

III-15. Conditions of competition.—
(a) Is the HEDP market subject to business cycles (other than general economy-wide conditions)
and/or other conditions of competition distinctive to HEDP?
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
HEDP since January 1, 2014?
No

Yes

If yes, describe.

III-16. Supply constraints.--Has your firm refused, declined, or been unable to supply HEDP since
January 1, 2014 (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. Importers’ Questionnaire - HEDP

Page 24

III-17. Raw materials.-- How have HEDP raw materials prices changed since January 1, 2014?
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 HEDP.

III-18. Interchangeability.--Is HEDP 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

China

India

Other countries

United States
China
India
For any country-pair producing HEDP that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Importers’ Questionnaire - HEDP

Page 25

III-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between HEDP 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

China

India

Other countries

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

Business Proprietary
U.S. Importers’ Questionnaire - HEDP

Page 26

III-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for HEDP since January 1, 2014. Indicate the share of the quantity of your firm’s total
shipments of HEDP that each of these customers accounted for in 2016.
Customer’s name

City

State

Share of 2016 sales (%)

1
2
3
4
5
6
7
8
9
10

III-21. 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 - HEDP

Page 27

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
http://www.usitc.gov/investigations/701731/2016/1_hydroxyethylidene_1_1_diphosph
onic_acid_china/preliminary.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: HEDP

• 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.