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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3769; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
POLYTETRAFLUOROETHYLENE RESIN (“PTFE RESIN”) FROM CHINA AND INDIA
This questionnaire must be received by the Commission by October 12, 2017
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing and antidumping duty investigations concerning polytetrafluoroethylene resin (“PTFE
resin”) from China and India (Inv. Nos. 701‐TA‐588 and 731‐TA‐1392‐1393 (Preliminary)). 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 PTFE resin (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: PTFE)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements
Name of Authorized Official Title of Authorized Official
Date
Phone:
Signature
Fax:
Email address
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U.S. Producers’ Questionnaire – PTFE RESIN
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on September 28, 2017, by
The Chemours Company FC LLC, Wilmington, Delaware. Countervailing and antidumping duties may be
assessed on the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce
(“Commerce”) makes an affirmative determination of subsidization and/or dumping. Questionnaires
and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/polytetrafluoroethylene_resin_china_and_india/pr
eliminary.htm.
PTFE resin covered by these investigations is polytetrafluoroethylene (PTFE) resin, including but not
limited to granular, dispersion, and coagulated dispersion (also known as fine powder) forms. PTFE resin
is covered by the scope of this investigation whether filled or unfilled, whether or not modified, and
whether or not containing co‐polymer additives, pigments, or other materials. Also included is PTFE wet
raw polymer. The chemical formula for PTFE resin is C2F4, and the Chemical Abstracts Service Registry
number is 9002‐84‐0. PTFE resin further processed into micropowder, having particle size ranging from 1
to 25 microns, is excluded from the scope of this investigation.
PTFE resin is classified in the Harmonized Tariff Schedule of the United States (HTSUS) under statistical
reporting numbers 3904.61.0010 and 3904.61.0090. Subject merchandise may also be classified under
subheading 3904.69. The HTSUS provisions are for convenience and Customs purposes; the written
description of the scope is dispositive.
Reporting of information.‐‐ If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
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PART I.—GENERAL INFORMATION‐‐Continued
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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of PTFE resin and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
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
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Page 4
PART I.—GENERAL INFORMATION‐‐Continued
I‐2.
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 PTFE resin, 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
China (antidumping duty)
India (antidumping duty)
India (countervailing duty)
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)
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Page 5
PART I.—GENERAL INFORMATION‐‐Continued
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing PTFE resin from China and India into the United States or
that are engaged in exporting PTFE resin from China and India 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 PTFE resin?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
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U.S. Producers’ Questionnaire – PTFE RESIN
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Fred Ruggles (202‐205‐3187,
[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 PTFE resin since January 1, 2014.
(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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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 PTFE resin, 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 1,000s of pounds in dry weight)
Calendar years
Item
2014
Overall production
capacity
Production of:
PTFE resin 1
2
Other products
Total
1
2
2015
January‐June
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
Data entered for production of granular PTFE resin will populate here once reported in question II‐7.
Please identify these products: .
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.
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Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between PTFE resin 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 PTFE resin?
“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.
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U.S. Producers’ Questionnaire – PTFE RESIN
II‐5.
Page 9
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce PTFE resin in and/or admit PTFE resin
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 PTFE resin into a foreign trade zone (FTZ) for use in distribution of PTFE resin
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 PTFE resin?
“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
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U.S. Producers’ Questionnaire – PTFE RESIN
II‐7.
Page 10
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of PTFE resin in its U.S. establishment(s)
during the specified periods. Do not report resales of PTFE resin.
“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.
“Commercial U.S. 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.
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U.S. Producers’ Questionnaire – PTFE RESIN
II‐7.
Page 11
Production, shipment, and inventory data.—Continued
Quantity (in 1,000s of pounds in dry weight) and value (in $1,000)
Calendar years
Item
2014
2015
January‐June
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)
End‐of‐period inventories (quantity) (L)
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
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)
To end users (quantity) (N)
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: .
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U.S. Producers’ Questionnaire – PTFE RESIN
II‐7.
Page 12
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 years
Reconciliation
2014
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2015
0
January‐June
2016
0
2016
0
2017
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate: .
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for commercial U.S. shipments (i.e.,
line D) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.
2014
2015
0
January‐June
2016
0
2016
0
0
2017
0
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U.S. Producers’ Questionnaire – PTFE RESIN
II‐8.
Page 13
U.S. shipments by product form.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by product
form.
Quantity (in 1,000s of pounds in dry weight) and value (in $1,000)
Calendar years
Item
2014
U.S. shipments.‐‐
Dispersion:
Quantity (O)
2015
January‐June
2016
2016
2017
Value (P)
Granular:
Quantity (Q)
Value (R)
Other form(s) :
Quantity (U)
Value (V)
Coagulated dispersion (fine powder):
Quantity (S)
Value (T)
1
1
Identify the "other" form(s): .
RECONCILIATION OF SHIPMENTS.‐‐Please ensure that the quantities and values reported for U.S.
shipments by form (i.e., lines O through V) in each time period equal the quantity reported for U.S.
shipments (i.e., lines D through I) 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
2015
January‐June
2016
2016
2017
Quantity: O + Q + S + U – D – F – H =
zero ("0"), if not revise.
0
0
0
0
0
Value: P + R + T + V – E – G – I = zero
("0"), if not revise.
0
0
0
0
0
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U.S. Producers’ Questionnaire – PTFE RESIN
II‐9.
Page 14
U.S. shipments by product type.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by product
type.
Quantity (in 1,000s of pounds in dry weight) and value (in $1,000)
Calendar years
Item
2014
U.S. shipments.‐‐
Unfilled / no additives:
Quantity (W)
Value (X)
2015
January‐June
2016
2016
2017
1
Filled / with additives :
Quantity (Y)
Value (Z)
1
List the additives used in order of importance/ volume:
.
RECONCILIATION OF SHIPMENTS.‐‐Please ensure that the quantities and values reported for U.S.
shipments by form (i.e., lines W through Z) in each time period equal the quantity reported for U.S.
shipments (i.e., lines D through I) 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
2015
January‐June
2016
2016
2017
Quantity: W + Y – D – F – H = zero
("0"), if not revise.
0
0
0
0
0
Value: X + Z– E – G – I = zero ("0"), if
not revise.
0
0
0
0
0
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U.S. Producers’ Questionnaire – PTFE RESIN
Page 15
II‐10. Employment data.‐‐Report your firm’s employment‐related data related to the production of
PTFE resin 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.
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 June periods, calculate similarly and divide by 6.
“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‐June
2016
2016
2017
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
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Page 16
II‐11. 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.
II‐12. Purchases.‐‐Other than direct imports, has your firm otherwise purchased PTFE resin 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 of pounds in dry weight)
Calendar years
Item
2014
2015
January‐June
2016
2016
2017
1
Purchases from U.S. importers of PTFE
resin from—
China
India
All other sources
Purchases from domestic producers
2
Purchases from other sources
1
2
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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Page 17
II‐13. 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. 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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Page 18
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[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 PTFE resin:
2. Does your firm prepare profit/loss statements for PTFE resin:
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 PTFE resin, 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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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 produced in the facilities in which your firm
produced PTFE resin, 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
PTFE resin
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of PTFE resin 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 PTFE resin
that your firm purchases from related suppliers and that are reflected in financial results
reported in question 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 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
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III‐8.
Page 20
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in question III‐9a 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‐9a.
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III‐9a. Operations on PTFE resin.‐‐Report the revenue and related cost information requested below
on the PTFE resin operations of your firm’s U.S. establishment(s).1 Do not report resales of
products. Please note that revenue assigned to 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, and for the specified interim
periods. If your firm was involved in tolling operations (either as the toller or as the tollee),
please contact David Boyland at (202) 708‐4725 before completing this section of the
questionnaire.
Quantity (in 1,000 of pounds in dry weight) and value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
January‐June
2016
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
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.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9b. Financial data reconciliation.‐‐The calculable line items from questions 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.
III‐10. Nonrecurring items (charges and gains) included in PTFE resin financial results.‐‐For each
annual and interim 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 question 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 question III‐9a; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9a, only the allocated value amount included in question 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 question III‐9a.
Fiscal years ended‐‐
2014
2015
January‐June
2016
2016
2017
Nonrecurring item: In this column, please provide a brief
Nonrecurring item: In these columns, please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in question III‐9a.
specific line item in table III‐9a where (e.g., other factory
costs, SG&A expenses, other expenses) the nonrecurring item
Value ($1,000)
is classified.
1. , classified as in table III‐9a.
2. , classified as in table III‐9a.
3. , classified as in table III‐9a.
4. , classified as in table III‐9a.
5. , classified as in table III‐9a.
6. , classified as in table III‐9a.
7. , classified as in table III‐9a.
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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 question 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 question 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 PTFE resin. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for PTFE resin 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
2014
2015
1
Total assets (net)
1
III‐13.
2016
Describe
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for PTFE resin. 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
Capital expenditures
Research and development expenses
1
2
2014
1
2015
January‐June
2016
2016
2017
2
Please describe the nature, focus, and significance of your firm’s capital expenditures on PTFE resin.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to PTFE resin.
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III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, 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 total quantities and revenue values reported in question III‐9a should generally
reconcile with the sum of relevant shipment quantity and value 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 relevant quantities and values
reported for total shipments in part II equal the quantities and values reported for 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 should generally reconcile. If the calculated fields
below do return values other than zero (i.e., “0”) and both are being reported on a calendar basis, please
explain the difference below.
Full year data
Reconciliation
2014
Quantity: Sum of trade data
from question II‐7 (lines D, F,
H, and J) less financial total
net sales quantity data from
question III‐9a, = zero ("0").
2015
0
January‐June
2016
0
2016
0
2017
0
Value: Sum of trade data
from question II‐7 (lines E, G,
I, and K) less financial total net
sales value data from
question III‐9a, = zero ("0").
0
0
0
0
Do these data in question III‐9a reconcile with the sum of relevant data in question II‐7?
Yes
No
If no, please explain.
0
0
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If your responses to any of the items in questions III‐15, III‐16, and III‐17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III‐15. 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 PTFE resin from China and India?
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
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III‐16. 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 PTFE resin from China and India?
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
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III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
PTFE resin from China and India?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐18. 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.
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PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Andrew Knipe (202‐205‐
2390, [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.‐‐Granular PTFE resin, fine cut, bulk density 400‐500g/L, 25‐40um average particle
size, not modified, not filled, in packages of 25kg or greater.
Product 2.‐‐Granular PTFE resin, free flowing, bulk density 500‐850g/L, 290‐700um average
particle size, not modified, not filled, in packages of 25kg or greater.
Product 3.‐‐PTFE fine powder resin, not modified, in packages of 25kg or greater.
Product 4.‐‐PTFE fine powder resin, modified, in packages of 25kg or greater.
Product 5.‐‐PTFE dispersion, general purpose, 50‐65% solid content, packaged in drums of 50
gallons or greater.
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).
IV‐2 (a). During January 2014‐June 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 table(s) as appropriate.
No.‐‐Skip to question IV‐3.
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IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds in dry weight (not 1,000s) and actual dollars (not 1,000s).
Product 1
Quantity
(pounds in dry
Value
weight)
(dollars)
Product 2
Quantity
(pounds in dry
Value
weight)
(dollars)
Product 3
Quantity
(pounds in dry
Value
weight)
(dollars)
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
April‐June
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:
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IV‐2(b). Price data (Continued).‐‐Report below the quarterly price data1 for pricing products2 produced
and sold by your firm.
Report data in actual pounds dry weight (not 1,000s) and actual dollars (not 1,000s).
Product 4
Quantity
(pounds in dry
Value
weight)
(dollars)
Product 5
Quantity
(pounds in dry
Value
weight)
(dollars)
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
April‐June
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 4:
Product 5:
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IV‐2 (c). Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual pounds in dry weight (not 1,000s of pounds in dry weight)?
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in questions II‐7–II ‐8 in each year?
IV‐2 (d). 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.‐‐How does your firm determine the prices that it charges for sales of PTFE resin
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Set
price
lists
Annual
total
volume
discounts
No
discount
policy
Other
Describe
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U.S. Producers’ Questionnaire – PTFE RESIN
IV‐5.
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced PTFE resin?
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 PTFE resin usually quoted (check one)?
Delivered
F.o.b.
IV‐6.
Page 32
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced PTFE
resin 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
%
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
Total
(should
sum to
100.0%)
% 0.0 %
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IV‐7.
Page 33
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced PTFE resin (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Item
Short‐term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long‐term contracts
(multiple deliveries for
more than 12 months)
Average contract
duration
No. of
days
365
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Typical sales
contract provisions
Fixed quantity
and/or price
Meet or release
provision
Not applicable
IV‐8.
Lead times.‐‐What is your firm’s share of sales from inventory vs. 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 PTFE resin?
Share of 2016 Lead time (Average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
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IV‐9.
Page 34
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced PTFE resin 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 PTFE resin 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 PTFE resin 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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IV‐11. End uses.‐‐List the end uses of the PTFE resin that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by PTFE resin vs. other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
PTFE resin
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐12. Substitutes.‐‐Can other products be substituted for PTFE resin?
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 PTFE resin?
No Yes
Explanation
1.
2.
3.
IV‐13. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for PTFE resin 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.
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IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of PTFE resin since January 1, 2014?
No
Yes If yes, please describe and quantify if possible.
IV‐15. Conditions of competition.‐‐
(a)
Is the PTFE resin market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to PTFE resin? If yes,
describe.
Check all that apply.
(b)
Please describe.
No
Skip to question IV‐16.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
If yes, have there been any changes in the business cycles or conditions of competition
for PTFE resin since January 1, 2014?
No
Yes If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply PTFE resin 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, being unable to meet timely shipment commitments, etc.)?
No
Yes If yes, please describe.
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IV‐17. Raw materials.‐‐How have PTFE resin raw material prices changed since January 1, 2014?
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for PTFE
resin.
IV‐18. Interchangeability.‐‐Is PTFE resin produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
India
Germany
Italy
Other countries
United States
China
India
Germany
Italy
For any country‐pair producing PTFE resin that is sometimes or never interchangeable,
identify the country‐pair and explain the factors that limit or preclude interchangeable use:
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IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between PTFE resin produced in
the United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
India
Germany
Italy
Other countries
United States
China
India
Germany
Italy
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of PTFE resin, identify the country‐pair and report the advantages
or disadvantages imparted by such factors:
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IV‐20. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for PTFE resin since January 1, 2014. Indicate the share of the quantity of your firm’s
total shipments of PTFE resin 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
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IV‐21. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2014: To avoid losing sales to competitors selling PTFE
resin from China and/or India, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2014: Did your firm lose sales of PTFE resin to imports of
this product from China and/or India?
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: PTFE)
IV‐22. 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.
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2017/polytetrafluoroethylene_resin_chin
a_and_india/preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: PTFE
• 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 |
| Author | US ITC |
| File Modified | 2017-09-29 |
| File Created | 2017-09-29 |