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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3808; Expiration Date: : 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
SODIUM GLUCONATE, GLUCONIC ACID, AND DERIVATIVE PRODUCTS FROM
CHINA AND FRANCE
This questionnaire must be received by the Commission by December 14, 2017
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning sodium gluconate, gluconic acid, and
derivative products (“GNA products”) from China and France (Inv. Nos. 701‐TA‐590 and 731‐TA‐1397‐1398
(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 GNA products (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: GNAP)
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
Email address
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background. ‐‐ This proceeding was instituted in response to a petition filed on November 30, 2017, by
PMP Fermentation Products, Inc., Peoria, Illinois. Countervailing and/or 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/sodium_gluconate_gluconic_acid_and_derivative/p
reliminary.htm
GNA products covered by these investigations are defined as “all grades of sodium gluconate, liquid
gluconate, and gluconic acid, regardless of physical form (including, but not limited to substrates;
solutions; dry granular form or powders, regardless of particle size; or as a slurry). The scope also
includes sodium gluconate, liquid gluconate, and gluconic acid that has been blended or is in solution
with other product(s) where the resulting mix contains 35 percent or more of sodium gluconate, liquid
gluconate, and/or gluconic acid (including glucono delta lactone, in essence dry gluconic acid, commonly
referred to as GDL) by dry weight. Sodium gluconate has a molecular formula of NaC6H11O7; gluconic
acid has a molecular formula of C6H12O7; liquid gluconate is a blend of gluconic acid and sodium
gluconate in an aqueous solution; and GDL has a molecular formula of C6H10O6. Sodium gluconate has a
Chemical Abstract Service (CAS) registry number of 527‐07‐1, and can also be called "sodium salt of
gluconic acid" and/or sodium 2, 3, 4, 5, 6‐pentahydroxy‐hexanoate. Liquid gluconate has CAS registry
numbers of 527‐07‐1, 526‐95‐4, and 7732‐18‐5, and can also be called 2, 3, 4, 5, 6‐Pentahydroxycaproic
acid‐hexanoate. Gluconic acid has a CAS registry number of 526‐95‐4, and can also be called 2, 3, 4, 5, 6‐
Pentahydroxycaproic Acid. GDL has a CAS registry number of 90‐80‐2, and can also be called D‐Glucono‐
1,5‐lactone. The merchandise covered by the scope of this investigation is currently classified in the
Harmonized Tariff Schedule of the United States (HTSUS) at subheadings 2918.16.1000,
2918.16.5010, and 2932.20.5020. Although the HTSUS subheadings and CAS registry numbers are
provided for convenience and customs purposes, the written description of the merchandise is
dispositive.
GNA products are currently imported under statistical reporting numbers 2918.16.10 and 2918.16.50 of
the Harmonized Tariff Schedule of the United States (HTSUS). 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.
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 3
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 GNA products 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
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
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 GNA products, 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 AD
China CVD
France AD
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 – GNA products (Preliminary)
I‐5.
I‐6.
Page 5
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing GNA products from China or France into the United
States or that are engaged in exporting GNA products from China or France to the United
States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of GNA products?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Porscha Stiger (202‐205‐
3241, [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
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of GNA products 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)
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
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 GNA products, 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 dry pounds)
Calendar years
Item
Overall production capacity
Production of:
GNA products1
2
Other products
Total
1
2
2014
2015
January‐September
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
Data entered for production of GNA products 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.
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between GNA products 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 GNA products?
“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.
II‐5.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce GNA products in and/or admit GNA
products 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 firm’s operations in FTZs and identify
the specific FTZ site(s).
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 9
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import GNA products into a foreign trade zone (FTZ) for use in distribution of GNA
products 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 GNA products?
“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 – GNA products (Preliminary)
II‐7.
Page 10
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of GNA products 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.
“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.
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
II‐7.
Page 11
Production, shipment, and inventory data.‐‐Continued
Quantity (in 1,000 dry pounds) and value (in $1,000)
Calendar years
Item
2014
2015
January‐September
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)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
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
1
2014
2015
0
January‐September
2016
0
2016
0
2017
0
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 – GNA products (Preliminary)
II‐8.
Page 12
Channels of distribution.‐‐Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in 1,000 dry pounds)
Calendar years
Item
2014
2015
January‐September
2016
2016
2017
Channels of distribution:
Commercial U.S. shipments:
To distributors (M)
To end users (N)
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‐September
2016
0
2016
0
0
2017
0
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
II‐9.
Page 13
U.S. shipments by market sector.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of GNA
products by market sector. To the degree any your firms' shipments go to distributors, please
attempt to classify those shipments by likely end use sector (i.e., if you know a distributor serves
primarily a certain sector, classify all your firm's shipments to that distributor as for use in that
sector). Do not simply report distribution channel as "other / unknown."
Sector / application
Calendar year 2016
Quantity (1,000 pounds dry weight)
U.S. shipments.‐‐
Agricultural (O)
Construction (P)
Industrial and institution (Q)
Metal cleaning (R)
Food (S)
Chelation (T)
De‐icing (U)
Other / unknown (V)
Total
0
RECONCILIATION OF U.S. SHIPMENTS.‐‐Please ensure that the quantity reported for US shipments by
market sector (i.e., lines O through V) in 2016 equal the quantity reported for U.S. shipments (i.e., lines D,
F, and H) in 2016 in question II‐7. 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
Quantity: O + P + Q + R + S+T+U+V – D – F – H =
zero ("0"), if not revise.
Calendar year
2016
0
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 14
II‐10. 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) of GNA
products by product type.
Quantity (1,000 pounds dry weight), Value (1,000 dollars)
Product type
Calendar year
2016
U.S. shipments of.‐‐
Sodium gluconate
Quantity (W)
Value (X)
Gluconic acid
Quantity (Y)
Value (Z)
GDL
Quantity (AA)
Value (AB)
Liquid gluconate
Quantity (AC)
Value (AD)
1
Blends
Quantity (AE)
Value (AF)
Total
Quantity (AG)
0
Value (AH)
0
1
Describe the reported blends:
RECONCILIATION OF U.S. SHIPMENTS.‐‐Please ensure that the quantities and values reported for US
shipments by product type (i.e., lines W through AF) in 2016 equal the quantity and value reported for
U.S. shipments (i.e., lines D through G) in in 2016 in question II‐7. 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
Quantity: W + Y + AA + AC + AE – D – F – H =
zero ("0"), if not revise.
0
Value: X + Z + AB + AD + AF – E – G –I = zero
("0"), if not revise.
0
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 15
II‐11a. U.S. shipments certified non‐GMO.‐‐Report the share of your firm's U.S. shipments that are
certified to be created through a non‐GMO production process.
U.S. shipments
Share
Certified non‐GMO
%
Not certified
%
Total (should sum to 100.0%)
0.0 %
II‐11b. Non‐GMO.‐‐Is there any physical characteristics of non‐GMO and GMO GNA products that limits
their interchangeability in a given end use (i.e., disregarding purchaser preference)?
No
Yes
If yes, please describe the physical characteristics that limit this
interchangeability between non‐GMO and GMO GNA products.
II‐11c. Importance of non‐GMO GNA products.‐‐Generally, how important is the availability of non‐
GMO certified GNA products for your U.S. customers?
Very important
Somewhat important
Not at all important
Does the importance of the availability of non‐GMO GNA products vary by market sector?
No
Yes
If yes, please the sectors and how the importance of non‐GMO GNA
products varies for those sectors.
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 16
II‐12. Employment data.‐‐Report your firm’s employment‐related data related to the production of
GNA products 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 September periods, calculate similarly and divide by 9.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).”
“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‐September
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‐13. 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.
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 17
II‐14. Purchases.‐‐Other than direct imports, has your firm otherwise purchased GNA products 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 dry pounds)
Calendar years
Item
Purchases from U.S.
importers1 of GNA products
from—
China
2014
2015
January‐September
2016
2016
2017
France
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
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. 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 – GNA products (Preliminary)
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PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202‐205‐3247, [email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
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:
Note.‐‐Please note, that we are requesting that firms report their financial data
on a calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include GNA products:
2. Does your firm prepare profit/loss statements for GNA products:
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, 10Qs,
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 GNA products, as well
as specific statements and worksheets) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
III‐3.
Page 19
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
III‐4.
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 GNA products, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Share of sales
GNA products
%
%
%
%
%
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
III‐6.
Page 20
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of GNA products 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 GNA
products that your firm purchases from related suppliers and that are reflected in question III‐
9c. 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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U.S. Producers’ Questionnaire – GNA products (Preliminary)
III‐8.
Page 21
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in III‐9c (financial results on GNA products)
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 table III‐9c.
III‐9a. By‐products.—Does your firm have any by‐product sales revenue associated with its GNA
products operations? If yes, identify the by‐product(s) in the space below, and complete table
III‐9b. If no, please continue to question III‐9c.
Yes No
III‐9b. By‐product revenue.‐‐Report your firm’s total by‐product sales revenue, net of relevant
processing costs, associated with the GNA products operations of your U.S. establishment(s).
Provide data for the three most recently completed fiscal years, and for the specified interim
periods. Note: the data provided below will appear in question III‐9c as a reduction to COGS.
Value (in $1,000)
Calendar years ended‐‐
Item
By‐product sales revenue1
1
2014
2015
January‐September
2016
2016
2017
Please describe how your firm classifies these by‐product revenues in the normal course of business (e.g.,
included in net sales values, as a reduction to COGS, included in “all other income”).
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
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III‐9c. Operations on GNA products.‐‐Report the revenue and related cost information requested
below on the GNA products operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed calendar years, and for the specified interim periods.
Quantity (in 1,000 dry pounds) and value (in $1,000)
Calendar years ended‐‐
Item
2014
2015
January‐September
2016
2016
2017
2
Net sales quantities:
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
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
Raw materials
Less: by‐product revenue
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
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 – GNA products (Preliminary)
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III‐9d. Raw materials for GNA products.‐‐Please indicate the share of total raw material costs reported
in III‐9c in 2016 for the following raw material inputs:
Share of 2016 total
raw material costs
(percent)
Products
Liquid corn syrup
%
1
Other
%
Total (should sum to 100 percent)
0.0 %
1
Please indicate any other notable "other" raw materials not expressly identified above
and provide the share of the 2016 total raw material costs that they account for:
III‐9e. Financial data reconciliation.‐‐The calculable line items from question III‐9c (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.
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
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III‐10. 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‐9c, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III‐9c 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‐9c; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9c, only the allocated value amount included in question III‐9c 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‐9c.
Calendar years ended‐‐
2014
2015
January‐September
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‐9c.
specific line item in table III‐9c where the nonrecurring item is
classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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‐9c.
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
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III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of GNA products. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for GNA products 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‐9c.
Provide data as of the end of your firm’s three most recently completed calendar 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)
Calendar 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 GNA products. Provide data for your
firm’s three most recently completed calendar years, and for the specified interim periods.
Value (in $1,000)
Calendar years ended‐‐
Item
Capital expenditures
Research and development expenses
1
2014
1
2015
January‐September
2016
2016
2017
2
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
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III‐14. Data consistency and reconciliation.‐‐Please confirm that your firm’s financial data for
questions III‐9c, 12, and 13 are based on a calendar 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 for total net sales in part III of this
questionnaire in each time period. 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 question
II‐7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III‐9c, = zero ("0").
2015
2016
2017
0
0
Value: Trade data from question II‐7
(lines E, G, I, and K) less financial
total net sales value data from
question III‐9c, = zero ("0").
0
0
0
Do these data in question III‐9c 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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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 GNA products from China and France?
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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U.S. Producers’ Questionnaire – GNA products (Preliminary)
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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 GNA products from China and France?
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‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
GNA products from China and France?
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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U.S. Producers’ Questionnaire – GNA products (Preliminary)
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PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Caroline Peters (202‐708‐
1443, [email protected] ) or Cindy Cohen (202‐205‐3230, [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
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.‐‐Sodium gluconate in 50 lb. to 60 lb. bag
Product 2.‐‐Sodium gluconate in 2,000 lb. to 2,500 lb. bag
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‐September 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 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 dry pounds (not 1,000s) and actual dollars (not 1,000s).
(Quantity in dry pounds, value in dollars)
Product 1
Product 2
Sodium gluconate in 2,000 lb. to 2,500 lb. bag
Sodium gluconate in 50 lb. to 60 lb. bag
Quantity
Value
Quantity
Value
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
July‐September
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:
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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 dollars (not $1,000)?
In actual dry pounds (not 1,000 dry pounds)?
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 question II‐7 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.
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
IV‐3.
Page 32
Price setting.‐‐How does your firm determine the prices that it charges for sales of GNA
products (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction
Contracts
IV‐4.
Annual
total
volume
discounts
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced GNA products?
Net 60
days
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic GNA products usually quoted (check
one)?
Delivered
F.o.b.
IV‐6.
If other, describe
No
discount
policy
Net 30
days
Other
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV‐5.
Set
price
lists
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced GNA
products 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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U.S. Producers’ Questionnaire – GNA products (Preliminary)
IV‐7.
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Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced GNA products (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 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 GNA products?
Lead time
(Average
number of
Share of 2016
days)
Source
sales
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
IV‐9.
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Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced GNA products 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 GNA products 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 GNA products 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.
IV‐11. End uses.‐‐List the end uses of the GNA products that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by GNA products and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
GNA products
Other inputs
End use product
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
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IV‐12. Substitutes.‐‐Can other products be substituted for GNA products?
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 GNA products?
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 GNA products 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 GNA products since January 1, 2014?
No
Yes
If yes, please describe and quantify if possible.
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IV‐15. Conditions of competition.‐‐
(a) Is the GNA products market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to GNA products? 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
GNA products since January 1, 2014?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply GNA products
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.
IV‐17. Product quality issues.‐‐Have any of your customers returned GNA products or canceled orders
due to quality issues such as product impurities or caking issues, since January 1, 2014?
No
Yes
If yes, please describe.
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IV‐18. Raw materials.‐‐How have GNA products 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 GNA
products.
IV‐19. Interchangeability.‐‐Are GNA products 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
United States
China
France
China
France
Other countries
For any country‐pair producing GNA products 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‐20. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between GNA products
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
China
France
China
France
Other countries
For any country‐pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of GNA products, identify the country‐pair and report the advantages or disadvantages
imparted by such factors:
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U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 39
IV‐21. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for GNA products since January 1, 2014. Indicate the share of the quantity of your
firm’s total shipments of GNA products 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 – GNA products (Preliminary)
Page 40
IV‐22. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2014: To avoid losing sales to competitors selling GNA
products from China and France, 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 GNA products to imports
of this product from China and France?
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: GNAP)
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 – GNA products (Preliminary)
Page 41
PART V – ALTERNATIVE PRODUCTS
V‐1. Comparability of GNA products‐‐For each of the following product pairs indicate whether the
GNA products produced in the United States are:
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not‐at‐all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and Uses.‐‐The differences and similarities in the physical
characteristics and uses.
Product‐pair
Sodium gluconate (GNA)
Gluconic acid
(GA)
Liquid gluconate
(LG)
Glucono delta
lactone (GDL)
Blends
Gluconic acid (GA)
Liquid gluconate (LG)
Glucono delta lactone (GDL)
For any product‐pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their physical characteristics and uses:
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
V‐1.
Page 42
Comparability of GNA products.‐‐Continued
(b) Interchangeability.‐‐The ability to substitute the products in the same application.
Product‐pair
Sodium gluconate (GNA)
Gluconic acid
(GA)
Liquid gluconate
(LG)
Glucono delta
lactone (GDL)
Blends
Gluconic acid (GA)
Liquid gluconate (LG)
Glucono delta lactone (GDL)
For any product‐pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their interchangeability:
(c) Common manufacturing facilities, production processes, and production employees.‐
‐Whether manufactured in the same facilities, from the same inputs, on the same
machinery and equipment, and using the same employees.
Product‐pair
Sodium gluconate (GNA)
Gluconic acid
(GA)
Liquid gluconate
(LG)
Glucono delta
lactone (GDL)
Blends
Gluconic acid (GA)
Liquid gluconate (LG)
Glucono delta lactone (GDL)
For any product‐pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their manufacturing facilities, production processes, and
production employees:
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 43
V‐1.
Comparability of GNA products.‐‐Continued
(d) Channels of distribution.‐‐Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).
Product‐pair
Sodium gluconate (GNA)
Gluconic acid
(GA)
Liquid gluconate
(LG)
Glucono delta
lactone (GDL)
Blends
Gluconic acid (GA)
Liquid gluconate (LG)
Glucono delta lactone (GDL)
For any product‐pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their channels of distribution:
(e) Customer and producer perceptions.‐‐Perceptions as to the differences and/or
similarities.
Product‐pair
Sodium gluconate (GNA)
Gluconic acid
(GA)
Liquid gluconate
(LG)
Glucono delta
lactone (GDL)
Blends
Gluconic acid (GA)
Liquid gluconate (LG)
Glucono delta lactone (GDL)
For any product‐pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their customer and product perceptions:
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
V‐1.
Page 44
Comparability of GNA products.‐‐Continued
(f) Price.‐‐Whether prices are comparable or differ between the products.
Product‐pair
Sodium gluconate (GNA)
Gluconic acid
(GA)
Liquid gluconate
(LG)
Glucono delta
lactone (GDL)
Blends
Gluconic acid (GA)
Liquid gluconate (LG)
Glucono delta lactone (GDL)
For any product‐pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their price:
Business Proprietary
U.S. Producers’ Questionnaire – GNA products (Preliminary)
Page 45
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/sodium_gluconate_gluconic
_acid_and_derivative/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: GNAP
• 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 - US producers--GNA products (P) |
| Author | robert.casanova |
| File Modified | 2017-12-04 |
| File Created | 2017-12-04 |