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pdfOMB No. 3117‐0016/USITC No. 18‐2‐3953; Expiration Date: 6/30/2020
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U.S. IMPORTERS’ QUESTIONNAIRE
UTILITY SCALE WIND TOWERS FROM CHINA AND VIETNAM
This questionnaire must be received by the Commission by October 31, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its review of the countervailing and antidumping duty orders concerning utility scale wind towers
(“wind towers”) from China and Vietnam (Inv. Nos. 701‐TA‐486 and 731‐TA‐1195‐1196 (Review)). The information
requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This report is
mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of records
or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm imported wind towers (as defined on the next page) from any country at any time since
January 1, 2012?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: WIND)
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 investigations or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone:
Email address
Business Proprietary
U.S. Importers’ Questionnaire ‐ Wind towers (R1)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐On February 15, 2013, the Department of Commerce (“Commerce”) issued countervailing
and antidumping duty orders on imports of wind towers from China and Vietnam. On January 2, 2018,
the Commission instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. §
1675(c)) (the Act) to determine whether revocation of the orders would be likely to lead to continuation
or recurrence of material injury to the domestic industry within a reasonably foreseeable time. If both
the Commission and Commerce make an affirmative determination, the orders will remain in place. If
either the Commission or Commerce makes a negative determination, Commerce will revoke the orders.
Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/utility_scale_wind_towers_china_and_vietnam/full
_review.htm.
Wind towers covered by these investigations are certain wind towers, whether or not tapered, and
sections thereof. Certain wind towers are designed to support the nacelle and rotor blades in a wind
turbine with a minimum rated electrical power generation capacity in excess of 100 kilowatts and with a
minimum height of 50 meters measured from the base of the tower to the bottom of the nacelle (i.e.,
where the top of the tower and nacelle are joined) when fully assembled.
A wind tower section consists of, at a minimum, multiple steel plates rolled into cylindrical or conical
shapes and welded together (or otherwise attached) to form a steel shell, regardless of coating, end‐
finish, painting, treatment, or method of manufacture, and with or without flanges, doors, or internal or
external components (e.g., flooring/decking, ladders, lifts, electrical buss boxes, electrical cabling,
conduit, cable harness for nacelle generator, interior lighting, tool and storage lockers) attached to the
wind tower section. Several wind tower sections are normally required to form a completed wind tower.
Wind towers and sections thereof are included within the scope whether or not they are joined with
nonsubject merchandise, such as nacelles or rotor blades, and whether or not they have internal or
external components attached to the subject merchandise.
Specifically excluded from the scope are nacelles and rotor blades, regardless of whether they are
attached to the wind tower. Also excluded are any internal or external components which are not
attached to the wind towers or sections thereof.
Wind towers are currently imported under statistical reporting numbers 7308.20.00201 or
8502.31.00002 of the Harmonized Tariff Schedule of the United States (HTSUS). Prior to 2011, subject
merchandise was classified in the HTSUS under statistical reporting number 7308.20.0000 and may
continue to be to some degree. The HTSUS provisions are for convenience and customs purposes; the
written description of the scope is dispositive.
Unit.—A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections would
be equal to ¼ or 0.25 wind towers).
1
Wind towers are classified under HTSUS 7308.20.0020 when imported as a tower or tower section(s) alone.
Wind towers may also be classified under HTSUS 8502.31.0000 when imported as part of a wind turbine (i.e.,
accompanying nacelles and/or rotor blades).
2
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 3
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,
purchaser and/or foreign producer 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.
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.
Valid number error messages.‐‐If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Keysha
Martinez (202‐205‐2136, [email protected]).
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 4
I‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
I‐2.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”‐‐Each facility of a firm involved in the importation of wind towers, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
I‐3.
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. Importers’ Questionnaire – Wind towers (R1)
Page 5
I‐4.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing wind towers into the United States or that are engaged in
exporting wind towers to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
I‐5.
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wind towers?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Importing operations.‐‐Please indicate the nature of your firm’s importing operations on wind
towers. More than one answer may be applicable.
Importer of record
Takes title to the
imported product(s)
Consignee of the
imported products(s)
Customs broker or
freight forwarder
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 6
I‐7.
Consignees.‐‐If your firm is an importer of record of wind towers but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).
I‐8.
Firm name
Address
Contact person and
phone number
FTZ, TIB, or bonded warehouses.‐‐Please indicate whether your firm enters wind towers into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports wind towers under the TIB (temporary importation under bond)
program.
“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, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re‐export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby, imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule (HTS).
Item
No
Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 7
I‐9.
Business plan.‐‐In Parts II and III of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for wind towers?
No
Yes–Please provide the requested documents. If you are not providing the
requested documents, please explain why not.
I‐10.
Other trade actions.‐‐To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No
Yes–Please specify.
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202‐205‐
2136, [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 importation of wind towers since January 1, 2012.
Check as many as appropriate.
If checked, please describe, including the month and
year of the event; leave blank if not applicable.
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 9
II‐2b Anticipated changes in operations.‐‐Does your firm anticipate any changes in in the character of
its operations or organization relating to the importation of wind towers in the future?
II‐3.
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.
Arranged imports.‐‐Has your firm imported or arranged for the importation of wind towers for
delivery after June 30, 2018?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No
Yes–Fill out the table below.
Quantity (in units)
Period/Source
China
Vietnam
1
All other sources:
1
Jul‐Sept 2018
Apr‐Jun 2019
Reasons for importing if producer.‐‐If your firm also produces wind towers in the United States,
please indicate the reasons for importing this product. If your firm’s reasons differ by source,
please elaborate.
Jan‐Mar 2019
Identify your other sources:
II‐4.
Oct‐Dec 2018
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 10
Definitions
“Imports” ‐‐Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” ‐‐Quantities reported should be net of returns.
“Import values”‐‐Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial shipments”‐‐ Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” ‐‐Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” ‐‐Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” ‐‐A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments”‐‐ Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories” ‐‐Finished goods inventory, not raw materials or work in progress.
“Unit"‐‐A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of
multiple sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four
sections would be equal to ¼ or 0.25 wind towers).
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. Importers’ Questionnaire – Wind towers (R1)
Page 11
II‐5a. Imports from China.‐‐ Report your firm’s imports and your firm’s shipments and inventories of
wind towers imported from China during the specified periods.
A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections
would be equal to ¼ or 0.25 wind towers).
**If your firm reports internal consumption (lines F and G below), please complete a U.S.
PURCHASERS’ questionnaire.**
CHINA
Quantity (in units), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
2
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please list the 10‐digit HTS statistical reporting numbers used for Customs classification purposes: .
Please identify the foreign producers, if known: .
2
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each period identified above: .
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
II‐5a. Imports from China.–Continued
Page 12
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐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
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar year
January‐June
Reconciliation
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2012
2013
0
2014
0
0
2015
0
2016
0
2017
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐5b. Channels of distribution: CHINA‐‐ Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by channel of
distribution.
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Quantity (in units)
Channels of distribution:
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 K and L) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N – D – F – H = zero
("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 13
II‐6a. Imports from Vietnam.‐‐ Report your firm’s imports and your firm’s shipments and inventories
of wind towers imported from Vietnam during the specified periods.
A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections
would be equal to ¼ or 0.25 wind towers).
**If your firm reports internal consumption (lines F and G below), please complete a U.S.
PURCHASERS’ questionnaire.**
VIETNAM
Quantity (in units), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
2
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please list the 10‐digit HTS statistical reporting numbers used for Customs classification purposes: .
Please identify the foreign producers, if known: .
2
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each period identified above: .
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
II‐6a. Imports from Vietnam.–Continued
Page 14
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐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
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar year
January‐June
Reconciliation
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2012
2013
0
2014
0
0
2015
0
2016
0
2017
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐6b. Channels of distribution: VIETNAM‐‐ Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by channel of
distribution.
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Quantity (in units)
Channels of distribution:
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 K and L) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N – D – F – H = zero
("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
Page 15
II‐7a. Imports from all other sources.‐‐ Report your firm’s imports and your firm’s shipments and
inventories of wind towers imported from all other sources combined during the specified
periods.
A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections
would be equal to ¼ or 0.25 wind towers).
**If your firm reports internal consumption (lines F and G below), please complete a U.S.
PURCHASERS’ questionnaire.**
ALL OTHER SOURCES COMBINED
(list sources:
)
Quantity (in units), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
Value2 (I)
2
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please list the 10‐digit HTS statistical reporting numbers used for Customs classification purposes: .
Please identify the foreign producers, if known: .
2
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each period identified above: .
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (R1)
II‐7a. Imports from all other sources.–Continued
Page 16
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐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
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar year
January‐June
Reconciliation
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐7b. Channels of distribution: All other sources‐‐ Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by channel of
distribution.
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Quantity (in units)
Channels of distribution:
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 K and L) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N – D – F – H = zero
("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
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U.S. Importers’ Questionnaire – Wind towers (R1)
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For questions II‐8 and II‐9, if your firm’s response differs for particular orders, please indicate and
explain the particular effect of imposition and/or revocation of specific orders.
II‐8. Effect of order(s).‐‐Describe the significance of the existing countervailing and antidumping duty
orders covering imports of wind towers from China and Vietnam in terms of its effect on your
firm’s imports, U.S. shipments of imports, and inventories. You may wish to compare your firm’s
operations before and after the imposition of the order.
II‐9.
Likely impact of revocation. ‐‐Would your firm anticipate any changes in in the character of its
operations or organization, including its imports, U.S. shipments of imports, or inventories of
wind towers in the future if the countervailing and antidumping duty orders on wind towers
from China and Vietnam were to be revoked?
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.
II‐10. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative response box was not provided, 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. Importers’ Questionnaire – Wind towers (R1)
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PART III.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202‐205‐3230,
[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. Price setting.‐‐ How does your firm determine the prices that it charges for sales of wind towers
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
III‐3.
Set
price
lists
Other
If other, describe
Discount policy.‐‐ Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
III‐4.
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of imported wind towers from China and
Vietnam usually quoted? (check one)
Delivered
F.o.b.
If f.o.b., specify point
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U.S. Importers’ Questionnaire – Wind towers (R1)
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III‐5. Contract versus spot.‐‐ Approximately what share of your firm’s sales of wind towers imported
from China and Vietnam in 2017 was on a (1) long‐term contract basis, (2) annual contract basis,
(3) short‐term contract basis, and (4) spot sales basis?
Type of sale
Short‐term
Long‐term
Annual
Total
contracts
Spot sales
contracts
contracts
(should
(multiple
(for a single
(multiple
(multiple
sum to
deliveries for
delivery)
deliveries for 12 deliveries for less
100.0%)
more than 12
than 12 months)
months)
months)
Share of your
%
%
%
% 0.0 %
2017 sales
III‐6. Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
wind towers from China and Vietnam (or check “not applicable” if your firm does not sell on a
long‐term, short‐term, and/or contract basis).
Short‐term contracts Annual contracts Long‐term contracts
(multiple deliveries
(multiple
Typical sales
(multiple deliveries
Item
for more than 12
deliveries for 12
contract provisions
for less than 12
months)
months)
months)
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
1
Please identify the indexes used:
365
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U.S. Importers’ Questionnaire – Wind towers (R1)
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III‐7. Long‐term arrangements.—Please list any long‐term contracts or supply agreements that your
firm has with purchasers of wind towers. Briefly describe these agreements, including the name
of the purchaser, dates, any minimum purchase quantities, and any dedicated capacity.
Purchaser
name
III‐8.
Dates
covered
Minimum
purchase
quantities
(units)
Dedicated
capacity
(units)
Brief description
Lead times.‐‐ What is your firm’s share of sales of wind towers imported from China and
Vietnam 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 wind towers?
Source
Lead time
(average number of days)
From inventory
%
From foreign manufacturers’ inventory
%
Produced to order
%
0.0
%
Total (should sum to 100.0%)
Share of 2017
sales
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III‐9. Shipping information.‐‐
(a)
What is the approximate percentage of the cost of wind towers imported from China
and Vietnam that is accounted for by U.S. inland transportation costs? %
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
(c)
When your firm sells wind towers imported from China and Vietnam, from where is it
shipped?
Point of importation Storage facility (check one)
(d)
Indicate the approximate percentage of your sales of wind towers imported from China
and Vietnam that are delivered the following distances from your firm’s U.S. point of
shipment.
Distance from your firm’s U.S. point of shipment
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
III‐10. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold wind
towers imported from subject countries since January 1, 2012 (check all that apply)? Also,
please indicate the share of your firms’ 2017 shipments that were shipped to each region.
Shipments since Share of shipments in
January 1, 2012
2017
Geographic area
China Vietnam China
Vietnam
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.
0.0
0.0
Total (columns should individually sum to 100.0%)
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III‐11. End uses.‐‐ Have there been any changes in the end uses of wind towers since January 1, 2012?
Do you anticipate any future changes?
Changes in end
uses
No
Yes
Explain
Changes since
January 1, 2012
Anticipated
changes
III‐12. Substitutes.‐‐ Have there been any changes in the number or types of products that can be
substituted for wind towers since January 1, 2012? Do you anticipate any future changes?
Changes in
substitutes
No Yes
Explain
Changes since
January 1, 2012
Anticipated
changes
III‐13. Availability of supply.‐‐Has the availability of wind towers in the U.S. market changed since
January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2012:
U.S.‐produced product
Imports from China and
Vietnam
Imports from all other
countries
U.S.‐produced product
Imports from China and
Vietnam
Anticipated changes:
Imports from all other
countries
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U.S. Importers’ Questionnaire – Wind towers (R1)
Page 23
III‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for wind towers has changed since January 1, 2012, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors (for
example, federal or state government policies and natural gas prices) that have affected, and
that you anticipate will affect, these changes in demand.
Market
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2012
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States
III‐15. Product changes.‐‐ Have there been any significant changes in the product range, product mix,
or marketing of wind towers since January 1, 2012? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
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U.S. Importers’ Questionnaire – Wind towers (R1)
Page 24
III‐16. Conditions of competition.‐‐
(a) Is the wind tower market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to wind towers?
Check all that apply.
Please describe.
No
Skip to question III‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
wind towers since January 1, 2012?
No
Yes
If yes, describe.
III‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply wind towers
since January 1, 2012 (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, inability to meet
certain specifications, etc.)?
No
Yes
If yes, please describe.
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U.S. Importers’ Questionnaire – Wind towers (R1)
Page 25
III‐18. Raw materials.‐‐
(a) Indicate how wind towers’ raw material prices have changed since January 1, 2012, and
how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no Explain (including if applicable, the
clear effect of section 232 and antidumping
Overall
No
Overall
increase change decrease trend duty tariffs on steel products).
Changes since
January 1,
2012
Anticipated
changes
(b) Have raw material price changes affected your firm’s selling prices for wind towers?
No
Yes
If yes, please describe.
III‐19. Price comparisons.‐‐Please compare market prices of wind towers in U.S. and non‐U.S. markets
if known. Provide information as to time periods and regions for any price comparisons.
III‐20. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss wind towers supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China and Vietnam, and (3) the world
as a whole. Of particular interest is such data from 2012 to the present and forecasts for the
future.
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U.S. Importers’ Questionnaire – Wind towers (R1)
Page 26
III‐21. Interchangeability.‐‐Is wind towers 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
Vietnam
Other countries
United States
China
Vietnam
For any country‐pair producing wind towers which is sometimes or never interchangeable,
please identify the country‐pair and explain the factors that limit or preclude interchangeable
use:
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U.S. Importers’ Questionnaire – Wind towers (R1)
Page 27
III‐22. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wind towers 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
Vietnam
Other countries
United States
China
Vietnam
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of wind towers, identify the country‐pair and report the advantages
or disadvantages imparted by such factors:
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U.S. Importers’ Questionnaire – Wind towers (R1)
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If your firm imported wind towers from China or Vietnam for internal use (i.e., you reported internal
consumption in question II‐5a or II‐6a), please answer question III‐23. If not, skip to question III‐24.
III‐23. Additional costs for your firm’s direct imports of wind towers for your firm’s internal use.
(a) Please identify the factors (other than costs already included in landed duty paid values)
that add to your cost of importing directly since January 1, 2012. Estimate the share of the
cost of the landed duty‐paid value accounted for by these factors.
Estimated share of landed duty‐
Factors
paid value (percent)
(b) To which source(s) does your firm compare costs in determining your additional transaction
costs to directly import?
U.S. importers
U.S. producers
Both
Neither
(c) Briefly identify the benefits of directly importing wind towers instead of purchasing wind
towers from a U.S. importer or from a U.S. producer.
(d) Please provide the estimated margin saved by having directly imported wind towers instead
of purchasing from a U.S. importer. percent of landed duty‐paid value.
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U.S. Importers’ Questionnaire – Wind towers (R1)
Page 29
III‐24. Impact of the section 301 investigation.— This question concerns the section 301 investigation
and tariffs on wind towers that have been proposed and implemented by the United States in
response to Chinese trade practices.
(a) Did the announcement in March, 2018 and subsequent implementation of tariff remedies in
the section 301 investigation impact, or do you anticipate that it will impact, your firm's
wind tower business and/or the U.S. wind tower market as a whole?
Yes—Please fill out table below and
answer part (b)
No
Don’t know
Item
Response
1
Impact on your firm
1
Impact on overall U.S. market
1
Please identify the magnitude and timing of any effects, and compare your firm's
operations/overall market before and after the announcement of the section 301 measures.
(b) Assessment of specific impacts of the section 301 investigation.‐‐Please indicate the impact
of the announcement and subsequent implementation of remedies in the section 301
investigation and tariff actions regarding wind towers.
Item
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Overall demand for
wind towers in the
U.S. market
Prices for wind towers
in the U.S. market
III‐25. Other explanations.‐‐ If your firm would like to further explain a response to a question in Part
III for which a narrative response box was not provided, 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. Importers’ Questionnaire – Wind towers (R1)
Page 30
Correcting Valid number error messages.‐‐If you are completing a Commission
questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set‐up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)
When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.
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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/701731/2018/utility_scale_wind_towers_china_a
nd_vietnam/full_review.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: WIND
• 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 import 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 - Importers questionnaire |
| Author | keysha.martinez |
| File Modified | 2018-09-18 |
| File Created | 2018-09-18 |