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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3669; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN EMULSION STYRENE‐BUTADIENE RUBBER
This questionnaire must be received by the Commission by May 4, 2017
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping investigations concerning emulsion styrene‐butadiene rubber (“ESBR”) from Brazil,
Korea, Mexico, and Poland (Inv. Nos. 731‐TA‐1334‐1337 (Final)). The information requested in the questionnaire is
requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed
can result in a subpoena or other order to compel the submission of records or information in your firm’s possession (19
U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced ESBR (as defined on next page) 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: ESBR)
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
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 2
PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to petitions filed on July 21, 2016, by Lion
Elastomers LLC (Port Neches, TX) and East West Copolymer, LLC (Baton Rouge, LA). 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 dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/emulsion_styrene_butadiene_rubber_brazil_korea/final.
htm
Certain emulsion styrene‐butadiene rubber (“ESBR”). The product covered by these investigations is
cold‐polymerized emulsion styrene‐butadiene rubber. The scope of the investigation includes, but is not
limited to, ESBR in primary forms, bales, granules, crumbs, pellets, powders, plates, sheets, strip, etc.
ESBR consists of non‐pigmented rubbers and oil‐extended non‐pigmented rubbers, both of which
contain at least one percent of organic acids from the emulsion polymerization process.
ESBR is produced and sold in accordance with a generally accepted set of product specifications issued
by the International Institute of Synthetic Rubber Producers (“IISRP”). The scope of the investigation
covers grades of ESB rubber included in the IISRP 1500 and 1700 series of synthetic rubbers. The 1500
grades are light in color and are often described as ‘‘Clear’’ or ‘‘White Rubber.’’ The 1700 grades are oil‐
extended and thus darker in color, and are often called ‘‘Brown Rubber.’’
Specifically excluded from the scope of this investigation are products which are manufactured by
blending ESBR with other polymers, high styrene resin master batch, carbon black master batch (i.e.,
IISRP 1600 series and 1800 series) and latex (an intermediate product).
The products subject to these investigations are currently imported under the following Harmonized
Tariff Schedule of the United States (“HTSUS”) provisions: 4002.19.0015 and 4002.19.0019. ESBR is
described by Chemical Abstract Services (“CAS”) Registry No. 9003‐55‐8. This CAS number also refers to
other types of styrene butadiene rubber. Although the HTSUS subheadings and CAS registry number are
provided for convenience and customs purposes, the written description of the scope of these
investigations is dispositive.
Importer.‐‐Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing ESBR (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
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 3
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.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b. TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
I‐2.
Page 4
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 ESBR, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐3.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Petition support.‐‐Does your firm support or oppose the petition?
Country
I‐4.
Support
Oppose
Take no position
Brazil
Korea
Mexico
Poland
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
I‐5.
Page 5
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing ESBR from Brazil, Korea, Mexico, and Poland into the
United States or that are engaged in exporting ESBR from Brazil, Korea, Mexico, and Poland to
the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of ESBR?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nathanael Comly
([email protected], 202‐205‐3174). 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 ESBR since January 1, 2014.
(check as many as appropriate)
(If checked, please describe including impact on
production, capacity, and/or employment; 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)
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 7
II‐3a. Production using same machinery.‐‐ Please report your firm’s production of products made on
the same equipment and machinery used to produce ESBR, and the combined production
capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in 1,000 pounds)
Calendar years
Item
2014
1
Overall production capacity
2015
January‐March
2016
2016
2017
0
0
0
0
0
Carbon black master batch (CBMB)
Solution styrene‐butadiene rubber (SSBR)
Hot polymerized ESBR
0
0
0
0
0
Production of:
ESBR2
3
Other products
Total
1
Please describe the reasons for any changes in production capacity:
.
Data entered for production of ESBR will populate here once reported in question II‐7.
3
Please identify these products: .
2
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating hours
per week, weeks per year.
II‐3c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between ESBR 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)
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‐4.
Tolling.‐‐Since January 1, 2014, has your firm been involved in a toll agreement regarding the
production of ESBR?
“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
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
II‐5.
Page 9
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce ESBR in and/or admit ESBR 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
If 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 ESBR into a foreign trade zone (FTZ) for use in distribution of ESBR and/or the
production of downstream articles?
II‐6.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2014, has your firm imported ESBR?
“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
If yes‐‐ COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
II‐7.
Page 10
Production, shipment and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of ESBR 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.
“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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
II‐7.
Page 11
Production, shipment and inventory data.‐‐
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item
2014
2015
January‐March
2016
2016
2017
1
Average production capacity (quantity)
(A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
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 .
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above: .
3
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2014
2015
0
January‐March
2016
0
2016
0
2017
0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
0
.
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
II‐8.
Page 12
Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in 1,000 pounds)
Calendar years
Item
2014
Channels of distribution:
U.S. shipments:
To distributors (quantity) (M)
2015
January‐March
2016
2016
2017
To tire manufacturers (quantity) (N)
To other 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 U.S. shipments (i.e., lines D, F, and H) 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
2014
M + N +O – D – F ‐ H = zero ("0"), if not
revise.
2015
0
January‐March
2016
0
2016
0
2017
0
0
II‐9.
U.S. shipments by product type.‐‐Report your firm’s U.S. shipments in 2016 by type of ESBR.
Item
Calendar year 2016
Quantity (in 1,000 pounds)
U.S. shipments:
Commercial shipments:
1500‐series ESBR (P)
1700‐series ESBR (Q)
Total commercial shipments (R)
Internal consumption and transfers to related firms:
1500‐series ESBR (S)
1700‐series ESBR (T)
0
Total internal consumption or transfers to related firms (U)
0
RECONCILIATION OF SHIPMENTS.‐‐Please ensure that the quantities reported for shipments by grade
(i.e., lines O through T) in 2016 reconcile with their related data point in the prior grid, commercial U.S.
shipments (i.e., line D) and internal consumption or transfers to related firms (i.e., lines F and H). 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.
Reconciliation
Calendar year 2016
Commercial shipments: P + Q– D = zero ("0"), if not revise.
0
Internal consumption and transfers to related firms: S + T– F – H = zero
("0"), if not revise.
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 13
II‐10. Monthly U.S. shipments.—Report the quantities your firm’s monthly U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
ESBR from January 2014 through December 2016
Quantity (in 1,000 pounds)
Calendar years
Month of importation
2014
2015
2016
2017
January (V)
February (W)
March (X)
April (Y)
May (Z)
June (AA)
July (AB)
August (AC)
September (AD)
October (AE)
November (AF)
December (AG)
0
Total (AH)
0
0
0
RECONCILIATION OF MONTHLY SHIPMENTS.‐‐Generally, the data reported for the monthly U.S. shipments in a
year (i.e., lines V through AG) should be equal U.S. shipments reported in question II‐7 (i.e., lines D, F, and H) for
that same year. 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
V +W + X + Y + Z + AA + AB + AC + AD
+ AE + AF + AG – B – D = should equal
zero ("0"), if not revise.
2014
2015
0
January‐March
2016
0
2016
0
0
2017
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 14
II‐11. Employment data.‐‐Report your firm’s employment‐related data related to the production of
ESBR and provide an explanation for any trends in these data.
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to March periods, calculate similarly and divide by 3.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2014
2015
January‐March
2016
2016
2017
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐12. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a 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.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 15
II‐13. Purchases.‐‐Other than direct imports, has your firm otherwise purchased ESBR since January 1,
2014?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
No
Yes‐‐Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in 1,000 pounds)
Calendar years
Item
2014
Purchases from U.S.
importers of ESBR from—
Brazil1
2
Korea
2015
January‐March
2016
2016
2017
3
4
All other sources (AOS)
Purchases from domestic
producers8
Purchases from other
sources8
Mexico
Poland
China
5
Germany6
7
1
Please list the name of the importer(s) from which your firm purchased Brazilian product: .
Please list the name of the importer(s) from which your firm purchased Korean product: .
3
Please list the name of the importer(s) from which your firm purchased Mexican product: .
4
Please list the name of the importer(s) from which your firm purchased Polish product: .
5
Please list the name of the importer(s) from which your firm purchased Chinese product: .
6
Please list the name of the importer(s) from which your firm purchased German product: .
7
Please list the name of the importer(s) from which your firm purchased AOS product: .
8
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
2
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
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II‐14. Swap agreements.—Has your firm entered into any swap agreements involving ESBR since
January 1, 2014? (e.g. your firm provided ESBR to a U.S. purchaser in exchange for that firm
providing ESBR to your firm in another country.)
No
Yes‐‐Report quantities involved below and describe the agreement
(including dates, firms, and countries involved) and any trends in
quantities:
(Quantity in 1,000 pounds)
Calendar years
Item
U.S. shipments
2014
2015
January‐March
2016
2016
2017
II‐15. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below (e.g. trends in capacity, production, or shipments).
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 ‐ ESBR (Final)
Page 17
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202‐205‐3432,
[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 ESBR:
2. Does your firm prepare profit/loss statements for ESBR:
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, 10 Qs,
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 ESBR, 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.).
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
III‐4.
Page 18
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced ESBR, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
III‐6.
Share of sales
ESBR
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of ESBR 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 ESBR that
your firm purchases from related suppliers and that are reflected in question III‐10a. For “Share
of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
your company’s own accounting system, of the purchase cost from the related supplier; e.g., the
related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
III‐8.
Page 19
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in III‐10a (financial results on total ESBR) in
a manner consistent with your firm’s accounting books and records.
Yes
No‐‐In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in question III‐10a.
III‐9a. Inputs of monomer and utilities.—Please provide data for monomer and utilities used in the
production and sale of total ESBR reported in question III‐10a.
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
January‐March
2016
2016
2017
Input monomer (butadiene and styrenes)1
Utility costs (electricity and steam)2
1
2
Please describe the line item in question III‐10a where monomer is classified.
Please describe the line item in question III‐10a where utility costs are classified.
III‐9b. Inputs of monomer and utilities.— In 2016, how many thousands of pounds of input monomer
(butadiene and styrenes) were consumed in your firm’s reported total sales in question III‐10a?
Did the ratio of input monomer to ESBR output (conversion ratio on a per‐pound basis) change
during January 1, 2014 and March 31, 2017? No
Yes
If yes, please explain why.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 20
III‐10a. Operations on ESBR.‐‐Report the revenue and related cost information requested below on the
ESBR operations of your firm’s U.S. establishment(s).1 Include both domestic and export sales of
ESBR, but do not report resales of purchased ESBR. 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 in chronological
order from left to right and for the specified interim periods. If your firm was involved in tolling
operations (either as the toller or as the tollee), please contact Charles Yost at 202‐205‐3432,
before completing this section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
January‐March
2016
2016
2017
Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
Raw materials
Direct labor
Other factory costs
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
Cost of goods sold (COGS):3
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
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.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 21
III‐10b. Operations on ESBR – U.S. commercial sales and exports only (“open market sales”).‐‐Report
the revenue and related cost information requested below on the ESBR operations of your
firm’s U.S. establishment(s).1 Include both domestic and export commercial sales of ESBR, but
do not report resales of purchased ESBR. 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 in chronological order from left
to right and for the specified interim periods. If your firm was involved in tolling operations
(either as the toller or as the tollee), please contact Charles Yost at 202‐205‐3432, before
completing this section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
January‐March
2016
2016
2017
Net sales quantities:2
0
0
0
0
0
0
0
0
0
0
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Commercial sales quantities from III‐10a
Net sales values:2
Commercial sales values from III‐10a
Cost of goods sold (COGS):3
Raw material costs
Direct labor
Other factory costs
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
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.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 22
III‐10c. Financial data reconciliation.‐‐The calculable line items from question III‐10a and III‐10b (i.e.,
total net sales quantities and values, total COGS, gross profit (or loss), total SG&A, and net
income (or loss)) have been calculated from the data submitted in the other line items. Do the
calculated fields return the correct data according to your firm's financial records ignoring non‐
material differences that may arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
III‐11. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐10a or III‐
10b, please specify all material (significant) nonrecurring items (charges and gains) in the
schedule below, the specific question III‐10a or III‐10b line item where the nonrecurring items
are included, a brief description of the relevant nonrecurring items, and the associated values
(in $1,000), i.e., if an aggregate nonrecurring item has been allocated to question III‐10a or III‐
10b, only the allocated value amount included 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.
Fiscal years ended‐‐
Nonrecurring item: In this column please provide a brief
description of each nonrecurring item and indicate the
specific line item in question III‐10a or III‐10b where the
nonrecurring item is classified.
2014
2015
January‐March
2016
2016
2017
Nonrecurring item: In these columns please report the amount of the relevant
nonrecurring item reported in question III‐10a or III‐10b.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 23
III‐12. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐11 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business.
III‐13a. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of ESBR. If your firm does not maintain some or all of the
specific asset information necessary to calculate total assets for ESBR 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 question III‐9a. Provide data as of the
end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
Total assets (net) 1
1
2014
2015
Describe
III‐13b. Assets.—Please provide narrative responses to the questions below.
Please estimate the average age of your firm’s
equipment used to produce ESBR.
Please describe the nature of the technologies
used by your firm to produce ESBR.
Please describe the extent to which the
efficiencies of your firm’s production
equipment and technology have impacted the
ability to expand production or supply of ESBR.
2016
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
III‐14.
Page 24
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for ESBR. Provide data for your firm’s
three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
January‐March
2016
1
Total capital expenditures
2
Research and development expenses
1
2
2016
2017
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
III‐15. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9b, III‐12, and III‐13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Full year data
Reconciliation
2014
Quantity: Trade data from part II
less financial data from part III, = zero
("0") except as noted above.
2015
2016
2017
0
0
Value: Trade data from part II less
financial data from part III, = zero
("0") except as noted above.
0
0
0
Do these data in question III‐10a reconcile with data in question II‐7?
0
0
No
If no, please explain.
0
2016
0
Yes
0
Partial year periods
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 25
III‐16a. Effects of imports on investment.‐‐Since January 1, 2014, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of ESBR from Brazil, Korea, Mexico, and Poland?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
III‐16b. Does your firm’s response differ by country?
No
Yes
If yes, indicate which country and why:
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 26
III‐17a. Effects of imports on growth and development.‐‐Since January 1, 2014, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of ESBR from Brazil, Korea, Mexico, and Poland?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
III‐17b. Does your firm’s response differ by country?
No
Yes
If yes, indicate which country and why:
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 27
III‐18a. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
ESBR from Brazil, Korea, Mexico, and Poland?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐18b. Does your firm’s response differ by country?
No
Yes
If yes, indicate which country and why:
III‐19. 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 ‐ ESBR (Final)
Page 28
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Emily Burke (202‐205‐3191,
[email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in Part IV.
Name
Title
Email
Telephone
Fax
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2014 of the following products produced by your
firm.
Product 1.‐‐IISRP 1502 grade of ESBR in all forms, sold under annual contracts
Product 2.‐‐IISRP 1502 grade of ESBR in all forms, sold as spot sales
Product 3.‐‐IISRP 1507 grade of ESBR in all forms
Product 4.‐‐IISRP 1500 grade of ESBR in all forms
Product 5.‐‐IISRP 1712 grade of ESBR in all forms
Product 6.‐‐IISRP 1783 grade of ESBR in all forms
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‐March 2017, 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.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
IV‐2.
Page 29
Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Please indicate what physical form each pricing product takes in the ‘Note’ section.
Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
Period of shipment
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
2017:
January‐March
(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Quantity
Value
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.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
IV‐2.
Page 30
Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Please indicate what physical form each pricing product takes in the ‘Note’ section.
Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
Period of shipment
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
2017:
January‐March
(Quantity in pounds, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value
Product 6
Quantity
Value
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your firm’s
U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with
the specified product, provide a description of your firm’s product. Also, please explain any anomalies
in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
Product 5:
Product 6:
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
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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.
IV‐3. Price setting.—
(a)
How does your firm determine the prices that it charges for sales of ESBR (check all that
apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
Set
price
lists
Other
If other, describe
(b)
Does your firm use pricing formulas in contract or transaction by transaction sales of
ESBR? If yes, please describe your most commonly used formula.
IV‐4.
No
Yes
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
If yes, please describe.
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
IV‐5.
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced ESBR?
Net 30
days
Net 60
days
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic ESBR usually quoted (check one)?
Delivered
F.o.b.
IV‐6.
Page 32
If f.o.b., specify point
Contract versus spot.‐‐
(a)
Approximately what share of your firm’s sales of its U.S.‐produced ESBR in 2016 was on
a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term contract basis,
and (4) spot sales basis?
Calendar year
2014
2015
Type of sale
2016
Share of sales (percent)
Long‐term contracts
(multiple deliveries for more than 12
months)
Annual contracts
(multiple deliveries for 12 months)
Short‐term contracts
(multiple deliveries for less than 12
months)
Spot sales
(for a single delivery)
0.0
0.0
0.0
Total (each column should sum to
100.0%)
(b)
If your firm experienced large shifts in types of sales, please explain the reasons for the
shifts.
No
Yes
If yes, please describe.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
IV‐7.
Page 33
Contract provisions.—
(a) Please fill out the table regarding your firm’s typical sales contracts for U.S.‐produced ESBR
(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
Short‐term contracts
(multiple deliveries
for less than 12
months)
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
Annual contracts
(multiple
deliveries for 12
months)
Long‐term contracts
(multiple deliveries for
more than 12 months)
365
(b) If your firm allows price renegotiations during a contract period, how often do they occur
during the contract?
N/A
If yes, please describe.
(c) Please describe any pricing mechanisms used during price renegotiations.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
IV‐8.
Page 34
Lead times.‐‐What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.‐produced ESBR?
Share of 2016 Lead time (average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV‐9.
0.0 %
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced ESBR
that is accounted for by U.S. inland transportation costs? percent
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 ESBR that are delivered the
following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced ESBR since January 1, 2014 (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.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 35
IV‐11. End uses.‐‐List the end uses of the ESBR that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by ESBR and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
ESBR
Other inputs
Tires
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐12. Substitutes.‐‐ Can other products be substituted for ESBR?
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 ESBR?
No Yes
Explanation
IV‐13. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for ESBR has changed since January 1, 2014. Explain any trends and describe
the principal factors that have affected these changes in demand.
Overall
No
Overall
increase change decrease
Market
Fluctuate
with no
clear trend
Explanation and factors
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 ESBR since January 1, 2014?
No
Yes
If yes, please describe and quantify if possible.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 36
IV‐15. Conditions of competition.‐‐
(a) Is the ESBR market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to ESBR? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV‐16.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
ESBR since January 1, 2014?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply ESBR 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.
IV‐17. Raw materials.‐‐How have ESBR raw material 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 ESBR.
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U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 37
IV‐18. Interchangeability.‐‐Is ESBR 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
0 = no familiarity with products from a specified country‐pair
Country‐
pair
United
States
Brazil
Korea
Mexico
Poland
China
Germany
Other
countries
Brazil
Korea
Mexico
Poland
China
Germany
For any country‐pair producing ESBR 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 ‐ ESBR (Final)
Page 38
IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between ESBR 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
United
States
Brazil
Korea
Mexico
Poland
China
Germany
Other
countries
Brazil
Korea
Mexico
Poland
China
Germany
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of ESBR, identify the country‐pair and report the advantages or
disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 39
IV‐20. Interchangeability of products.‐‐Are certain grades of ESBR interchangeable with each other
and/or interchangeable with certain out‐of‐scope related products (e.g., do oil extended grades,
types of polymers used, and/or manufacturing techniques affect ESBR being used in the same
applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products 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
1700 series
ESBR
All other out‐
of‐scope cold‐
ESBR
Solution
styrene‐
butadiene
rubber
(“SSBR”)
Carbon black
master batch
(“CBMB”)
Hot
polymerized
styrene‐
butadiene
rubber
Product‐pair
1500 series
ESBR
1700 series
ESBR
All other out‐
of‐scope cold‐
ESBR
SSBR
CBMB
For any product‐pair that is sometimes or never interchangeable, identify the product‐pair and
explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 40
IV‐21. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for ESBR since January 1, 2014. Indicate the share of the quantity of your firm’s total
shipments of ESBR that each of these customers accounted for in 2016.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2016
sales
(%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire ‐ ESBR (Final)
Page 41
IV‐22. Competition from imports
(a) Lost revenue.‐‐Since January 1, 2014: To avoid losing sales to competitors selling ESBR from
Brazil, Korea, Mexico, and Poland, did your firm:
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2014: Did your firm lose sales of ESBR to imports of this
product from Brazil, Korea, Mexico, and Poland?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: ESBR)
IV‐23. 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 ‐ ESBR (Final)
Page 42
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2017/emulsion_styrene_butadiene_rubber_brazil_korea/final.
htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: ESBR
• 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 - ESBR (F)--US producer |
Author | russell.duncan |
File Modified | 2017-04-05 |
File Created | 2017-04-05 |