18-3-3910 US purchasers' questionnaire

OMB No. 3117-0016/USITC No. 18-3-3910; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
STEEL RACKS FROM CHINA
This survey must be received by the Commission by July 5, 2018
See last page for filing instructions.
The information called for in this survey is for use by the United States International Trade Commission in connection
with its countervailing duty and antidumping investigations concerning steel racks from China (Inv. Nos. 701-TA-608 and
731-TA-1420 (Preliminary)). The information requested in the survey 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 possession (19 U.S.C. § 1333(a)). Further information on this survey can
be obtained from Jon Ruder (202-205-3435, [email protected]).
Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased steel racks (as defined on next page) at any time since January 1, 2015?

NO

(Sign the certification below and promptly return only this page of the survey to the Commission)

YES

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

Title of Authorized Official

Date

Signature

Phone

Email address

Business Proprietary
Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 20, 2018, by Bulldog
Rack Company, Weirton, West Virginia; Hannibal Industries, Inc., Los Angeles, California; Husky Rack and
Wire, Denver, North Carolina; Ridg-U-Rak, Inc., North East, Pennsylvania; SpaceRAK, A Division of
Heartland Steel Products, Inc., Marysville, Michigan; Speedrack Products Group, Ltd., Sparta, Michigan;
Steel King Industries, Inc., Stevens Point, Wisconsin; Tri-Boro Shelving & Partition Corp., Farmville,
Virginia; and UNARCO Material Handling, Inc., Springfield, Tennessee. 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. U.S. producers of steel racks have provided the USITC with allegations about sales or revenue
that they have lost due to competition from imports of steel racks from China. One or more domestic
producer(s) have named your firm in such an allegation. Questionnaires and other information pertinent
to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/steel_racks_china/preliminary.htm.
Steel racks covered by these investigations are steel racks and parts thereof, assembled or
unassembled. Steel racks are racks made of steel of dimensions and configurations that can be adjusted
as required, with or without locking tabs or slots, and with or without bolted, clamped, or welded
connections, including any of the following: uprights, posts, columns, braces, frames, beams, arms,
locking devices, and rails.
A steel rack is a structure typically made from cold-formed or hot-rolled steel structural members and
includes, but is not limited to, components such as plates, rods, angles, shapes, sections, tubes and the
like. Welding, bolting, and clipping are the typical methods of assembly. Connections may also be made
with locking devices such as clips, end plates, and beam connectors. Steel racks may be made to ANSI
MH16.1 or ANSI MH16.3. All steel racks and parts thereof meeting the physical description set out
herein are covered by the scope of this investigation, whether or not produced according to a particular
standard.
The vertical components of steel racks may be referred to as posts, columns, or uprights, and may be
connected with horizontal or diagonal braces to form upright frames. A typical storage configuration
comprises upright frames perpendicular to the aisles, independently adjustable, positive locking beams
parallel to the aisle and spanning between the upright frames, and braces designed to support unit loads
between the beams. A cantilever rack consists of uprights running parallel to the aisle and cantilever
beams or arms connected to the uprights and running perpendicular to the aisle rather than spanning
two upright frames.
The scope includes all steel racks and parts thereof meeting the description above, regardless of: (1)
dimensions, weight, strength, gauge, or load rating; (2) vertical upright or frame type (including
structural, roll-form, or other); (3) horizontal support or beam / brace type (including but not limited to
structural, roll-form, slotted, unslotted, Z-beam, C-beam, L-beam, step beam, cantilever beam, and
cargo rack); (4) number of supports; (5) number of levels; (6) surface coating, if any (including but not
limited to paint, epoxy, powder coating, zinc, and other metallic coating); (7) shape (including but not
limited to rectangular, square, corner, and cantilever); (8) the method by which the vertical and
horizontal supports connect (including but not limited to locking tabs or slots, bolting, clamping, and

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Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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welding); and (9) the inclusion or not of moving components (including but not limited to rails, wheels,
rollers, tracks, channels, carts, and conveyors).
Steel racks may be referred to as pallet racks, storage racks, stacker racks, retail racks, pick modules, or
cantilever racks. Steel racks that incorporate moving components may also be referred to as pallet flow
racks, carton flow racks, push back racks, movable shelf racks, drive-in racks, and drive-through racks.
Subject merchandise includes material matching the above description that has been finished,
assembled, or packaged in a third country, including by coating, painting, assembling, attaching to, or
packaging with another product, or any other finishing, assembly, or packaging that would not
otherwise remove the merchandise from the scope of the investigation if performed in the country of
manufacture of the steel racks and parts thereof.
Steel racks and parts thereof are covered whether or not imported attached to, or in conjunction with,
other parts and accessories such as wire decking, nuts, and bolts. If steel racks and parts thereof are
imported attached to, or in conjunction with, such non-subject merchandise, only the steel racks and
parts thereof are covered by the scope.
Specifically excluded from the scope of this investigation are any products covered by the existing
antidumping and countervailing duty orders on boltless steel shelving units prepackaged for sale from
the People’s Republic of China. See Boltless Steel Shelving Units
Prepackaged for Sale From the People’s Republic of China: Antidumping Duty Order, 80 Fed. Reg. 63,741
(October 21, 2017); Boltless Steel Shelving Units Prepackaged for Sale From the
People’s Republic of China: Amended Final Affirmative Countervailing Duty Determination and
Countervailing Duty Order, 80 Fed. Reg. 63,745 (October 21, 2017).
Merchandise covered by this investigation is currently classified in the Harmonized Tariff Schedule of the
United States (HTSUS) under the following subheadings: 7326.90.86881 and 9403.20.0080.2 Subject
merchandise may also enter under subheadings 7308.90.3000, 7308.90.6000, 7308.90.9590, and
9403.20.0090. The HTSUS subheadings set forth above are provided for convenience and U.S. Customs
purposes only. The written description of the scope is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates.
Confidentiality.--The data furnished in response to this survey 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.

Prior to January 1, 2017, such merchandise was classified under HTS statistical reporting number 7326.90.8588.
From July 1, 2015 through December 31, 2017, such merchandise was classified under HTS statistical reporting
number 9403.20.0080. Prior to July 1, 2015 such merchandise was classified under HTS statistical reporting
number 9403.20.0020.
1
2

Business Proprietary
Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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Release of information.--The information provided by your firm in response to this survey, 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. Please also retain a copy of the final document that you submit.
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.

Business Proprietary
Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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PURCHASE INFORMATION
II-1.

Purchases and imports.--Report separately your firm’s domestic purchases and imports of steel
racks.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
Quantity (in pounds)
Calendar years
Item

2015

January-March

2016

2017

2017

2018

Purchases of steel racks
produced in—
United States
China
All other countries1
Sources unknown
Total purchases

0

0

0

0

0

0

0

0

0

0

Imports of steel racks
from—
China
All other countries1
Total imports
1

Please identify these countries:

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Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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2. Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of steel
racks from different sources have changed since January 1, 2015.
Source of
purchases

Did not
purchase

Decreased Increased

Constant

Fluctuated

Explanation for trend

United States

China

All other
countries
Sources
unknown

3. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase steel racks. For example, load rating, price, color,
warranty, reliability of supplier, delivery time, terms, etc.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

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Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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4. Purchasing subject imports rather than domestic products.—
(a)

Since January 2015, did your firm purchase imports of steel racks from China instead of
U.S.-produced steel racks?
Source

Yes
(also respond to parts (b) and (c))

No
(If “No” skip to question 5)

China
(b)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source

Yes

No

China
(c)

If you responded “Yes” to part (a), was price a primary reason for purchasing subject
imports rather than domestic product?

Source

China

Yes

If Yes, estimate the quantity
of imports purchased instead
of domestic product since
January 2015
(in pounds)

No

If No, please indicate the
reason your firm purchased
imports instead of domestic
product

Business Proprietary
Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)
5.

Page 8

U.S. producers and import competition.—
(a)

Since January 1, 2015, in connection with a sale or offer to sell steel racks to your firm,
did U.S. producers reduce their prices of domestically produced steel racks in order to
compete with lower-priced imports of steel racks from the subject countries?
Source

Yes (also respond to
question part (b))

No (If “No”, skip to question 6)

Don’t know

China
(b)

If your firm responded “yes” to any of the above countries, please provide an estimate
of the reduction in U.S. producers’ prices, and any additional explanations, such as
timing (e.g., months/years), frequency of price reductions, or other market/competitive
factors.

Source
China

Estimated
reduction in U.S.
prices
(percent)

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

%

6. Method of purchase--Please provide a general description of your firm’s method(s) of purchase
(e.g., individual purchase, contract, bids, Internet purchases, etc.) for steel racks.

7. Other explanations--Please provide any additional comments in this box.

Business Proprietary
Lost Sales and Lost Revenue Survey- Steel racks (Preliminary)

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OMB INFORMATION
8. OMB statistics.--Please report the actual number of hours required and the cost to your firm of
completing this survey.
Hours

Dollars

The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey along with a scanned copy of the signed
certification page (page 1) through the Commission’s secure upload facility:
o
o
o

Web address: https://dropbox.usitc.gov/oinv/
Enter Investigation: Select “Steel racks from China” in the drop down menu
Pin: SRACK

• E-mail.—E-mail the MS Word survey to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.