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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3633; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
CASED PENCILS FROM CHINA
This questionnaire must be received by the Commission by April 14, 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 review of the antidumping duty order concerning cased pencils from China (Inv. No. 731‐TA‐669
(Fourth Review)). The information requested in the questionnaire is requested under the authority of the Tariff Act of
1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to compel
the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced cased pencils (as defined on the next page) at any time since January 1, 2011?
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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: PENCIL)
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 or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Phone:
Signature
Fax:
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Cased Pencils
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐On December 28, 1994, the Department of Commerce (“Commerce”) issued an
antidumping duty order on imports of cased pencils from China. On June 1, 2016, the Commission
instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to
determine whether revocation of the order would be likely to lead to continuation or recurrence of
material injury to the domestic industry within a reasonably foreseeable time. If both the Commission
and Commerce make an affirmative determination, the order will remain in place. If either the
Commission or Commerce makes a negative determination, Commerce will revoke the order.
Questionnaires and other information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2016/cased_pencils_china/fourth_review_full.htm.
Cased pencils covered by this investigation are shipments of certain cased pencils of any shape or
dimension (except as described below) which are writing and/or drawing instruments that feature cores
of graphite or other materials, encased in wood and/or man‐made materials, whether or not decorated
and whether or not tipped (e.g., with erasers, etc.) in any fashion, and either sharpened or
unsharpened.
The pencils subject to the order are currently classifiable under subheading 9609.10.00 of the
Harmonized Tariff Schedule of the United States (`HTSUS').
Specifically excluded from the scope of the order are mechanical pencils, cosmetic pencils, pens,
noncased crayons (wax), pastels, charcoals, chalks, and pencils produced under U.S. patent number
6,217,242, from paper infused with scents by the means covered in the above‐referenced patent,
thereby having odors distinct from those that may emanate from pencils lacking the scent infusion. Also
excluded from the scope of the order are pencils with all of the following physical characteristics: (1)
Length: 13.5 or more inches; (2) sheath diameter: not less than one‐and‐one quarter inches at any point
(before sharpening); and (3) core length: Not more than 15 percent of the length of the pencil. In
addition, pencils with all of the following physical characteristics are excluded from the scope of the
order: Novelty jumbo pencils that are octagonal in shape, approximately ten inches long, one inch in
diameter before sharpening, and three‐and‐one eighth inches in circumference, composed of turned
wood encasing one‐and‐one half inches of sharpened lead on one end and a rubber eraser on the other
end. Although the HTSUS subheading is provided for convenience and customs purposes, the written
description of the scope of the order is dispositive.
Reporting of information.‐‐ If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your files, worksheets, and
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 3
supporting documents used in the preparation of the questionnaire response. Please also retain a copy
of the final document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
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.
I‐2.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of cased pencils, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
Covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I‐3.
Position regarding continuation of order.‐‐Does your firm support or oppose continuation of
the following antidumping duty order currently in place for cased pencils?
Country
China
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
I‐4.
Page 5
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Extent of
ownership
(percent)
Address
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing cased pencils into the United States or that are engaged
in exporting cased pencils to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of cased pencils?
No
Yes‐‐List the following information.
Firm name
I‐7.
Page 6
Country
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for cased pencils?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 7
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [email protected]). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐ Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of cased pencils since January 1, 2011.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
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U.S. Producers’ Questionnaire –Cased pencils
II‐3.
Page 8
Anticipated changes in operations.‐‐Does your firm anticipate any changes in the character of
operations or organization (as noted above) relating to the production of cased pencils in the
future?
No
Yes‐‐Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce cased pencils (in 1,000 gross) for 2017 and 2018.
II‐4.
Anticipated changes in operations in the event the order is revoked.‐‐Would your firm
anticipate any changes in the character of its operations or organization (as noted above)
relating to the production of cased pencils in the future if the antidumping duty order on cased
pencils from China were to be revoked?
No
Yes‐‐Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce cased pencils (in 1,000 gross) for 2017 and 2018.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 9
II‐5a. Production using same machinery.‐‐ Please report your firm’s production of products made on
the same equipment and machinery used to produce cased pencils, and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Gross” – A set of 144 pencils. Numerical responses in this questionnaire related to quantity
amounts should be input in thousands of gross. For example, an answer of 1,500,000 gross
would be input as “1,500”.
Quantity (in 1,000 gross)
Calendar year
Item
2014
Overall production
capacity
Production of:
Cased pencils1
2
Other products
Total
1
2
2015
2016
0
0
0
0
0
0
Data entered for production of cased pencils will populate here once reported in question II‐6.
Please identify these products: .
II‐5b. Operating parameters.‐‐The production capacity reported in II‐5a is based on operating hours
per week, weeks per year.
II‐5c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐5a, and explain any changes in reported capacity.
II‐5d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
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U.S. Producers’ Questionnaire –Cased pencils
Page 10
II‐5e. Product shifting.‐‐Is your firm able to switch production (capacity) between cased pencils and other
products using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products: .
II‐5f. Product shifting factors.‐‐Please describe the factors that affect your firm’s ability to shift
production capacity between products (e.g., time, cost, relative price change, etc.), and the degree
to which these factors enhance or constrain such shifts.
II‐6.
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of cased pencils in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“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. Such transactions are
valued at fair market value.
“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.
“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.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
II‐6.
Page 11
Production, shipment, and inventory data. ‐‐Continued
Quantity (in 1,000 gross) and value (in $1,000)
Calendar year
Item
2014
2015
2016
Average production
capacity1 (quantity) (A)
Beginning‐of‐period
inventories (quantity)
(B)
Production (quantity)
(C)
U.S. shipments:
Commercial
shipments:
quantity (D)
value (E)
Internal
consumption:2
quantity (F)
value (G)
Transfers to related
firms:2
quantity (H)
value (I)
3
Export shipments:
quantity (J)
value (K)
End‐of‐period
inventories (quantity)
(L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity (use additional pages as necessary).
.
2
Internal consumption and transfers to related firms should be valued at fair market value. In the event that your firm uses a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data using that basis
for each of the periods noted above: .
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 12
II‐6. Production, shipment, and inventory data.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
2014
B + C – D – F – H – J – L
= should equal zero
("0") or provide an
explanation.1
2015
2016
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐7. Channels of distribution.‐‐ Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in 1,000 gross)
Calendar year
Item
2014
Channels of
distribution:
U.S. commercial
shipments to
distributors
(quantity) (M)
2015
2016
U.S. commercial
shipments to
retailers (quantity)
(N)
U.S. commercial
shipments to end
users (quantity) (O)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) 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 year
Reconciliation item
M + N + O– D = zero
("0"), if not revise.
2014
2015
0
2016
0
0
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
II‐8.
Page 13
Historical cased pencils shipment data (2011‐13)‐‐Report the quantity and value of your firm’s
U.S. shipments (include commercial shipments, internal consumption, and transfers, but do not
include exports) of cased pencils produced in your U.S. establishment(s) during the specified
periods.
Quantity (in 1,000 gross) and value (in $1,000)
Calendar year
Item
2011
2012
2013
Cased Pencils
Quantity
Value
II‐9.
Employment data.‐‐Report your firm’s employment‐related data related to the production of
cased pencils and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
2014
2015
2016
Employment data:
Average number of
PRWs (number) (P)
Hours worked by
PRWs (1,000 hours)
(Q)
Wages paid to
PRWs ($1,000) (R)
Explanation of trends:
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U.S. Producers’ Questionnaire –Cased pencils
Page 14
II‐10. Transfers to related firms.‐‐If your firm reported transfers to related firms in question II‐6,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non‐market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 15
II‐11. Purchases.‐‐Other than direct imports, has your firm otherwise purchased cased pencils since
January 1, 2011?
No
Yes‐‐ Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity and
value of such purchases below for the specified periods.
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
No
Yes‐‐Report such purchases below and explain the reasons for your firms'
purchases:
Reason for purchases:
Quantity (in 1,000 gross)
Calendar year
Item
Purchases from U.S.
importers1 of cased
pencils from—
China
2014
2015
2016
China ‐ Beijing FILA
Dixon Stationary
Company
All other sources
Purchases from
domestic producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
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U.S. Producers’ Questionnaire –Cased pencils
Page 16
II‐12. Toll production.‐‐Since January 1, 2011, has your firm been involved in a toll agreement
regarding the production of cased pencils?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes‐‐ Please describe the toll arrangement(s) and name the firm(s) involved.
II‐13. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce cased pencils in and/or admit cased
pencils into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes‐‐Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import cased pencils into a foreign trade zone (FTZ) for use in distribution of cased
pencils and/or the production of downstream articles?
No/Don’t know
Yes‐‐Identify the firms and the FTZs.
II‐14. Direct imports.‐‐Since January 1, 2011, has your firm imported cased pencils?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
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U.S. Producers’ Questionnaire –Cased pencils
Page 17
II‐15. Effect of order.‐‐Describe the significance of the existing antidumping duty order covering
imports of cased pencils from China in terms of its effect on your firm’s production capacity,
production, U.S. shipments, inventories, purchases, employment, revenues, costs, profits, cash
flow, capital expenditures, research and development expenditures, and asset values. You may
wish to compare your firm’s operations before and after the imposition of the order.
II‐16. Likely effect of revocation of order.‐‐Would your firm anticipate any changes in its production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, or asset values
relating to the production of cased pencils in the future if the antidumping duty order on cased
pencils from China were to be revoked?
No
Yes‐‐Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation for any trends or
projections you may provide.
II‐17. Other explanations:‐‐If your firm would like to explain further a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
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U.S. Producers’ Questionnaire –Cased pencils
Page 18
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202‐205‐3247, [email protected]).
III‐1. Contact information.‐‐ Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
Fax
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain below:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for which
financial statements are prepared that include cased pencils:
2. Does your firm prepare profit/loss statements for cased pencils:
Yes
No
3. How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, Monthly,
quarterly, semi‐annually, annually
4. Accounting basis: GAAP, cash, tax, or other comprehensive basis of
accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes cased pencils, as well as
specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire –Cased pencils
III‐4.
Page 19
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produces in the facilities in which it produces
cased pencils, and provide the share of net sales accounted for by these products in your firm’s
most recent fiscal year.
Products
Share of sales
Cased Pencils
%
%
%
%
%
III‐6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of cased pencils from any related suppliers (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)?
Yes‐‐Continue to question III‐7.
III‐7.
No‐‐Continue to question III‐9a.
Inputs from related suppliers.‐‐Please identify the inputs used in the production of cased
pencils that your firm purchases from related suppliers and that are reflected in table III‐9a. For
“Share of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
the company’s own accounting system, of the purchase cost from the related supplier; e.g., the
related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
III‐8.
Page 20
Inputs from related suppliers at cost.‐‐Please confirm that the inputs purchased from related
suppliers, as identified in III‐7, were reported in III‐9a (financial results on cased pencils) in a
manner consistent with the firm’s accounting books and records.
Yes
No‐‐In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III‐9a.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 21
III‐9a. Operations on cased pencils.‐‐Report the revenue and related cost information requested
below on the cased pencils operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years.
Quantity (in 1,000 gross) and value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
2016
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms
(“Transfers”)
0
0
0
Internal consumption
Transfers to related firms
0
0
0
Direct labor
Other factory costs
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative
expenses
0
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
Net income or (loss) before income
taxes
Depreciation/amortization
included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 22
III‐9b. Raw materials for cases pencils.—Please indicate the share of total raw material costs reported
in III‐9a in 2016 for the following raw material inputs:
Share of total raw
material costs
Products
(percent)
Graphite / lead
%
Casing material: wood or man‐made
%
Other1
%
Total (should sum to 100 percent)
0.0 %
1
Please indicate any other notable "other" raw materials not expressly identified above
and provide the share of the total raw material costs that they account for:
III‐9c. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 23
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual period for which financial results are reported in question III‐9a, please specify all
material (significant) nonrecurring items (charges and gains) in the schedule below, the specific
table III‐9a line item where the nonrecurring items are included, a brief description of the
relevant nonrecurring items, and the associated values (in $1,000), as reflected in table III‐9a;
i.e., if an aggregate nonrecurring item has been allocated to table III‐9a, only the allocated value
amount included in table III‐9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in table III‐9a.
Fiscal years ended‐‐
2014
2015
2016
Nonrecurring item: In this column please provide a
Nonrecurring item: In these columns please report the amount of the relevant nonrecurring
brief description of each nonrecurring item and
item reported in table III‐9a.
indicate the specific line item in table III‐9a where the
nonrecurring item is classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 24
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in table III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in table III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of cased pencils. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for cased pencils in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in table III‐9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
1
Total assets (net)
1
Describe
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 25
III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for cased pencils. Provide data for your
firm’s three most recently completed fiscal years.
Value (in $1,000)
Item
Capital expenditures
Research and development
expenses
Fiscal years ended‐‐
2015
2014
2016
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐6 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Full year data
Reconciliation
Quantity: Trade data from part II
less financial data from part III, = zero
("0") except as noted above.
Value: Trade data from part II less
financial data from part III, = zero
("0") except as noted above.
2014
2015
2016
0
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 26
Do these data in question III‐9a reconcile with data in question II‐6?
Yes
No
If no, please explain.
III‐15. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 27
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Grace Kenneally (202‐708‐
1669, [email protected]).
IV‐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 IV.
Name
Title
Email
Telephone
Fax
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products produced by your firm.
Product 1.—Commodity (economy) pencils – retail packaging (i.e., sold to retail outlets).
Product 2.—Commodity (economy) pencils – boxed (i.e., sold to wholesalers or office supply
stores).
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).
(a) During 2014‐2016, did your firm produce and sell to unrelated U.S. customers any of the
above listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data tables as appropriate.
No.‐‐Skip to question IV‐3.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 28
IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in 1,000 gross and actual dollars (not $1,000).
(Quantity in 1,000 gross, value in dollars)
Product 1
Quantity
Value
Quantity
Product 2
Period of shipment
Value
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
October‐December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide
a description of the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
IV‐2(c). Pricing data methodology.‐‐ Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
IV‐3.
Price setting.‐‐ How does your firm determine the prices that it charges for sales of cased
pencils (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction
Contracts
IV‐4.
Page 29
Set
price
lists
Other
If other, describe
Discount policy.‐‐ Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
Annual
total
volume
discounts
IV‐5.
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced cased pencils?
Net 30
days
Net 60
days
No
discount
policy
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic cased pencils usually quoted (check
one)?
Delivered
F.o.b.
If f.o.b., specify point
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
IV‐6.
Page 30
Contract versus spot.‐‐ Approximately what share of your firm’s sales of its U.S.‐produced cased
pencils in 2016 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2016
sales
IV‐7.
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
0.0
%
Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced cased pencils (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Long‐term contracts
(multiple deliveries for
more than 12 months)
365
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
IV‐8.
Lead times.‐‐What is the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.‐produced cased pencils?
Share of 2016 Lead time (Average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
Annual contracts
(multiple
deliveries for 12
months)
Short‐term contracts
(multiple deliveries
for less than 12
months)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
IV‐9.
Page 31
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced cased
pencils that is accounted for by U.S. inland transportation costs? %
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of cased pencils that are
delivered the following distances from your firm’s production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced cased pencils since January 1, 2011 (check all that apply)?
Geographic area
√ if applicable
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.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 32
IV‐11. Substitutes.‐‐
(a)
Can other products be substituted for cased pencils?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for cased pencils?
No Yes
Explanation
1.
2.
3.
(b)
Have there been any changes in the number or types of products that can be
substituted for cased pencils since January 1, 2011? Do you anticipate any future
changes?
Changes in
substitutes
No Yes
Explain
Changes since
January 1, 2011
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 33
IV‐12. Availability of supply.‐‐Has the availability of cased pencils in the U.S. market changed since
January 1, 2011? Do you anticipate any future changes? Note: Nonsubject imports include
imports from Beijing FILA Dixon Stationary Company.
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2011:
U.S.‐produced product
Subject imports
Nonsubject imports
U.S.‐produced product
Subject imports
Nonsubject imports
Anticipated changes:
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 34
IV‐13. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for cased pencils has changed since January 1, 2011, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors that
have affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2011
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States
IV‐14. Product changes.‐‐ Have there been any significant changes in the product range, product mix,
or marketing of cased pencils since January 1, 2011? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2011
Anticipated
changes
Explain
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 35
IV‐15. Conditions of competition.‐‐
(a) Is the cased pencils market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to cased pencils?
Check all that apply.
Please describe.
No
Skip to question IV‐17.
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
cased pencils since January 1, 2011?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply cased pencils
since January 1, 2011 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, been unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐17. Raw materials.‐‐ Indicate how cased pencils raw material prices have changed since January 1,
2011, and how you expect they will change in the future.
Raw
materials
prices
Fluctuate
Explain, noting how raw material
with no
price changes have affected your
clear
Overall
No
Overall
trend firm’s selling prices for cased pencils.
increase change decrease
Changes since
January 1,
2011
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 36
IV‐18. Price comparisons.‐‐Please compare market prices of cased pencils in U.S. and non‐U.S.
markets, if known. Provide specific information as to time periods and regions for any price
comparisons.
IV‐19. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss cased pencils supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China, and (3) the world as a whole.
Of particular interest is such data from 2011 to the present and forecasts for the future.
IV‐20. Export constraints.‐‐Describe how easily your firm can shift its sales of cased pencils between
the U.S. market and alternative country markets. In your discussion, please describe any
contracts, other sales arrangements, or other constraints that would prevent or retard your firm
from shifting cased pencils between the U.S. and alternative country markets within a 12‐month
period.
IV‐21. Barriers to trade.‐‐Are your firm’s exports of cased pencils subject to any tariff or non‐tariff
barriers to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2011, or that are expected to occur in the future.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 37
IV‐22. Interchangeability.‐‐Are cased pencils produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)? If your answer
differs for China (all other firms) and China (Beijing FILA Dixon Stationary Company), please
explain.
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
Other countries
United States
China
For any country‐pair producing cased pencils that is sometimes or never interchangeable,
identify the country‐pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 38
IV‐23. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between cased pencils produced
in the United States and in other countries a significant factor in your firm’s sales of the
products? If your answer differs for China (all other firms) and China (Beijing FILA Dixon
Stationary Company), please explain.
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
Other countries
United States
China
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of cased pencils, identify the country‐pair and report the advantages
or disadvantages imparted by such factors:
IV‐24. Bundling sales of cased pencils with other products.‐‐Does your firm bundle the sales of cased
pencils with other products?
Estimated share
of your sales of
cased pencils in
2016 that were Describe the other products that are included in typical
No
Yes sold in a bundle bundled sales
IV‐25. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire –Cased pencils
Page 39
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://usitc.gov/investigations/701731/2016/cased_pencils_china/fourth_review_full.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: PENCIL
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). 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.
| File Type | application/pdf |
| File Title | Microsoft Word - CP--US Producer--to Commission |
| Author | jordan.harriman |
| File Modified | 2017-03-02 |
| File Created | 2017-03-02 |