19-1-4025 US producers' questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

LRW (204) - US Producer questionnaire

arge Residential Washers: Monitoring Developments in the Domestic Industry (Inv. no TA-204-013

OMB: 3117-0016

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U.S. PRODUCERS’ QUESTIONNAIRE
LARGE RESIDENTIAL WASHERS
This questionnaire must be received by the Commission by April
See last page for filing instructions.

30, 2019

The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with investigation No. TA-204-013, Large Residential Washers: Monitoring Developments in the Domestic
Industry, under section 204 of the Trade Act of 1974 (19 U.S.C. § 2254). The information requested in the questionnaire
is needed to supplement data available to the Commission from other sources and is requested under the authority of
section 204 of the Tariff Act of 1974. 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 large residential washers (as defined on the next page) at any time since January 1,
2016?

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: LRWS)
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, reviews, or
general fact finding investigations 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

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U.S. Producers’ Questionnaire - Large Residential Washers (204)

Page 2

PART I.—GENERAL INFORMATION
Background.--On January 23, 2018, the President, pursuant to section 203 of the Trade Act of 1974,
issued Proclamation 9694, imposing a safeguard measure on imports of certain residential washers and
parts thereof in the form of a tariff-rate quota, effective February 7, 2018. Section 204 (a) of the Act
requires the Commission to submit a report to the President and Congress on its monitoring of industry
developments at the midpoint of the initial period of relief exceeding three years, including the progress
and specific efforts made by workers and firms in the domestic industry to make a positive adjustment
to import competition. Questionnaires and other information pertinent to this proceeding are available
at

https://www.usitc.gov/investigations/title_7/2019/large_residential_washers_monitoring_developments/safeguard.htm

Products covered by this investigation
Large residential washers.—The products covered by the investigation are all large
residential washers and certain parts thereof.
The term “large residential washers” denotes all automatic clothes washing machines,
regardless of the orientation of the rotational axis, with a cabinet width (measured from
its widest point) of at least 24.5 inches (62.23 cm) and no more than 32.0 inches (81.28
cm), except as noted below.
Covered parts.-- Also covered are certain parts used in large residential washers,
namely: (1) all cabinets, or portions thereof, designed for use in large residential
washers; (2) all assembled tubs 1 designed for use in large residential washers which
incorporate, at a minimum: (a) a tub; and (b) a seal; (3) all assembled baskets 2 designed
for use in large residential washers which incorporate, at a minimum: (a) a side
wrapper; 3 (b) a base; and (c) a drive hub; 4 and (4) any combination of the foregoing
parts or subassemblies.
Products excluded from this investigation
(1) Stacked washers-dryers & commercial washers
Excluded are stacked washer-dryers and commercial washers. The term “stacked
washer-dryers” denotes distinct washing and drying machines that are built on a unitary
frame and share a common console that controls both the washer and the dryer. The
term “commercial washer” denotes an automatic clothes washing machine designed for
the “pay per use” segment meeting either of the following two definitions:

A “tub” is the part of the washer designed to hold water.
A “basket” (sometimes referred to as a “drum”) is the part of the washer designed to hold clothing or other
fabrics.
3
A “side wrapper” is the cylindrical part of the basket that actually holds the clothing or other fabrics.
4
A “drive hub” is the hub at the center of the base that bears the load from the motor.
1
2

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Page 3

(1) (a) it contains payment system electronics; 5 (b) it is configured with an externally
mounted steel frame at least six inches high that is designed to house a coin/token
operated payment system (whether or not the actual coin/token operated payment
system is installed at the time of importation); (c) it contains a push button user
interface with a maximum of six manually selectable wash cycle settings, with no ability
of the end user to otherwise modify water temperature, water level, or spin speed for a
selected wash cycle setting; and (d) the console containing the user interface is made of
steel and is assembled with security fasteners; 6 or
(2) (a) it contains payment system electronics; (b) the payment system electronics are
enabled (whether or not the payment acceptance device has been installed at the time
of importation) such that, in normal operation, 7 the unit cannot begin a wash cycle
without first receiving a signal from a bona fide payment acceptance device such as an
electronic credit card reader; (c) it contains a push button user interface with a
maximum of six manually selectable wash cycle settings, with no ability of the end user
to otherwise modify water temperature, water level, or spin speed for a selected wash
cycle setting; and (d) the console containing the user interface is made of steel and is
assembled with security fasteners.
(2) Top load residential washers with PSC/belt drive/clutch
Also excluded are automatic clothes washing machines that meet all of the following
conditions: (1) have a vertical rotational axis; (2) are top loading; 8 (3) have a drive train
consisting, inter alia, of (a) a permanent split capacitor (PSC) motor, 9 (b) a belt drive, 10
and (c) a flat wrap spring clutch. 11
(3) Front load residential washers with CIM/belt drive
Also excluded are automatic clothes washing machines that meet all of the following
conditions: (1) have a horizontal rotational axis; (2) are front loading; 12 and (3) have a
drive train consisting, inter alia, of (a) a controlled induction motor (CIM), 13 and (b) a
belt drive.

“Payment system electronics” denotes a circuit board designed to receive signals from a payment acceptance
device and to display payment amount, selected settings, and cycle status. Such electronics also capture cycles and
payment history and provide for transmission to a reader.
6
A “security fastener” is a screw with a non-standard head that requires a non-standard driver. Examples include
those with a pin in the center of the head as a “center pin reject” feature to prevent standard Allen wrenches or
Torx drivers from working.
7
“Normal operation” refers to the operating mode(s) available to end users (i.e., not a mode designed for testing
or repair by a technician).
8
“Top loading” means that access to the basket is from the top of the washer.
9
A “PSC motor” is an asynchronous, alternating current (AC), single phase induction motor that employs split
phase capacitor technology.
10
A “belt drive” refers to a drive system that includes a belt and pulleys.
11
A “flat wrap spring clutch” is a flat metal spring that, when engaged, links abutted cylindrical pieces on the input
shaft with the end of the concentric output shaft that connects to the drive hub.
12
“Front loading” means that access to the basket is from the front of the washer.
13
A “controlled induction motor” is an asynchronous, alternating current (AC), polyphase induction motor.
5

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Page 4

(4) “Extra-wide” residential washers
Also excluded are automatic clothes washing machines that meet all of the following
conditions: (1) have a horizontal rotational axis; (2) are front loading; and (3) have
cabinet width (measured from its widest point) of more than 28.5 inches (72.39 cm).
Large residential washers are currently classifiable under subheading 8450.20.00 (statistical reporting
numbers 8450.20.0040 and 8450.20.0080) of the Harmonized Tariff System of the United States
(HTSUS). They may also be imported under HTSUS 8450.11.0040, 8450.11.0080, 8450.90.2000, and
8450.90.6000.14 The HTSUS provisions are for convenience and customs purposes; the written
description of the scope is dispositive.
When reporting U.S. producers’ data—
For the purpose of reporting data for select large residential washers in this U.S. producers’
questionnaire, unless otherwise indicated, please provide data for select residential washers to
include large residential washers and covered subassemblies as well as PSC/belt drive/clutch topload washers and CIM/belt drive front-load washers as defined on pages 2-3 of this document.
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 CFR §§ 206.17(a)(1) and 206.52(c)). 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 confidential business 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 Trade Act of 1974 (19 U.S.C. § 2252(i)) and sections 206.17 and 206.52
of the Commission’s Rules of Practice and Procedure (19 CFR §§ 206.17(a)(1) and 206.52(c)). 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.

14

Large residential washers and parts and certain subassemblies covered by the scope are currently subject to
tariff-rate quotas under a safeguard measure imposed effective February 7, 2018, under subheadings 9903.45.01
and 9903.45.02 (large residential washers) and 9903.45.05 and 9903.45.06 (covered parts) and related legal notes.

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Page 5

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 macroenabled 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.
I-1.

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.

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I-2.

Page 6

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 large residential washers,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
Covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

I-3.

Additional discussion on establishments consolidated in this questionnaire:

Position regarding safeguard measure--Does your firm support or oppose the safeguard
measure applicable to imports of large residential washers?
Support

Oppose

Take no position

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U.S. Producers’ Questionnaire - Large Residential Washers (204)
I-4.

Ownership.--Is your firm owned, in whole or in part, by any other firm?
No

Firm name

I-5.

Page 7

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing large residential washers into the United States or that
are engaged in exporting large residential washers to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire - Large Residential Washers (204)
I-6.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of large residential washers?
No

Yes--List the following information.

Firm name

I-7.

Page 8

Country

Affiliation

Business plan.--In Parts II and IV 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 large residential
washers?

No

Yes

If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.

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Page 9

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nathanael Comly (202-2053174, [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-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of large residential washers since January 1, 2016.

Check as many as appropriate.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)

If checked, please describe; leave blank if not
applicable.

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II-2b

Adjustment plans.--Did your firm submit adjustment plans to the Commission in connection
with the original section 201 investigation, Inv. No. TA-201-76, or indicate to USTR since the
initiation of the original section 201 investigation that it would make adjustments in its large
residential washers operations that would permit it to compete more effectively with imports of
large residential washers after relief expires if it were to receive import relief as a result of that
investigation?

Not known

II-2c.

Page 10

No

Yes

If yes, please supply copies of the specific adjustment plans for your firm as
submitted to the Commission during inv. No. TA-201-76 or to USTR since the
initiation of the original section 201 investigation. Also, please discuss below
the reason(s) why any specific adjustment actions included in the plans have
NOT been implemented (and are therefore not identified in your response to
question II-2d). Please be specific as to the particular adjustment action that is
being discussed.

Significance of relief.--Describe the significance of the tariff-rate quotas imposed by the
President effective on February 7, 2018, in terms of their effect on your firm’s operations in the
following categories. You may wish to compare your firm’s operations before and after the
imposition of the relief. Please explain how you have separated the effects of the safeguard
measure from the effects of other factors, such as closure or re-opening of domestic production
facilities, changes in demand, exchange rate changes, or antidumping and countervailing duties.

Category
Production capacity, production, shipments,
inventories, and employment
Return on investment, ability to generate
capital to finance the modernization of
domestic plant(s) and equipment, or ability to
maintain existing levels of expenditures for
research and development
Changes in your firm’s collective bargaining
agreements (attach copies of all collective
bargaining agreements in effect or otherwise
agreed to by your firm since February 7, 2018)

Please describe the significance of the safeguard
measure.

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II-2d.

Page 11

Efforts since implementation of safeguard measures.--Since February 7, 2018, has your firm
undertaken any efforts to compete more effectively in the U.S. market for large residential
washers?
If yes, please describe (1) any efforts made by your firm and/or its workers since
February 7, 2018 to compete more effectively, (2) the year in which the effort was
made, (3) the expenditure involved (in thousands of dollars), and (4) the specific
competitive advantage acquired (i.e., increased production, cost reduction, quality
improvement, increased market share or sales, etc.).

No

Yes

If you feel that any of these efforts have been made primarily to compete with
imported large residential washers, please indicate and explain. To the extent
possible, furnish the Commission with memoranda, studies, or other
documentation which indicate that such efforts were undertaken primarily to
compete more effectively against imports of large residential washers.

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II-3a.

Page 12

Production using same machinery.-- Please report your firm’s production of products made
using the same equipment, machinery, or employees as used to produce large residential
washers, and the combined production capacity on this shared equipment, machinery, or
employees 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).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-4. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope mercandhise, then the "average production capacity"
reported in question II-4 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“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 units)
Actual experience
Calendar years
Item

Overall production capacity

2016

2017

2018

Projections1

January-March

Calendar years

2018

2019

2019

2020

2

Production of:
Large residential washers
PSC/belt drive TL washers
CIM/belt drive FL washers
Commercial washers
Stacked washers
Extra-wide washers
Other products3
Total production using same
machinery or workers

0

0

0

0

0

Please explain the basis for your firm’s projections:
.
Data reported for capacity (first line) should be greater than data reported for total production (last line).
3
Please identify these products:
.
1
2

0

0

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II-3b.

Page 13

Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
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.

II-3e.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between large residential washers and
other products using the same equipment and/or labor?

No

(ii)

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:

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.

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II-4.

Page 14

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of large residential washers in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your establishment(s)
could reasonably have expected to attain during the specified periods. Assume normal operating
conditions (i.e., using equipment and machinery in place and ready to operate; normal operating
levels (hours per week/weeks per year) and time for downtime, maintenance, repair, and cleanup;
and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed internally
within your firm and production for another firm under a toll agreement.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s length
commercial transaction in the ordinary course of business. Report net values (i.e., gross sales values
less all discounts, allowances, rebates, prepaid freight, and the value of returned goods) in U.S. dollars,
f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. 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 owned, managed, or otherwise controlled; a

firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm that was
solely or jointly owned, managed, or otherwise controlled by a firm that also solely or jointly owned,
managed, or otherwise controlled your firm.
“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.
“Retailers”--Firms that sells large residential washers to the public for use in personal consumption
rather than for resale.
“Distributors”--Firms that purchase large residential washers for the purpose of reselling them to
other firms.
“Buying Groups”--Firms that negotiate prices on behalf of multiple retailers.
“Homebuilders/contractors”--Firms whose business is in the construction of residential dwellings.
“End users/consumers”—Entities who purchase large residential washers for their own personal
consumption.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used
in the preparation of the trade data, as Commission staff may contact your firm regarding questions
on the trade data. The Commission may also request that your company submit copies of the
supporting documents/records (such as production and sales schedules, inventory records, etc.) used to
compile these data.

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II-4.

Page 15

Production, shipment, and inventory data. –Continued
REPORT DATA FOR SELECT LARGE RESIDENTIAL WASHERS, INCLUDING LARGE RESIDENTIAL
WASHERS AND EXCLUDED ITEMS 2, 3, AND 4, AS DEFINED ON PAGES 3-4 OF THIS DOCUMENT.
Quantity (in units) and value (in $1,000)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Average production
capacity1 (quantity) (A)
Beginning-of-period
inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:2
quantity (F)
value (G)
Transfers to related
firms:2
quantity (H)
value (I)
Export shipments:3
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 (use additional pages as necessary).
.

Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide
the data above at fair market value).
2

3

Identify your firm’s principal export markets:

.

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II-4.

Page 16

Production, shipment, and inventory data.--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
B+C–D–F–H–J–L
= should equal zero
("0") or provide an
explanation.1

2016

2017

0

January-March
2018

0

2018

0

2019

0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
1

0

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II-5.

Page 17

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
REPORT DATA FOR SELECT LARGE RESIDENTIAL WASHERS, INCLUDING LARGE RESIDENTIAL
WASHERS AND PSC/BELT DRIVE/CLUTCH TOP-LOAD WASHERS AND CIM/BELT DRIVE FRONTLOAD WASHERS.
Quantity (in units), value (in $1,000)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Commercial U.S. shipments:
To distributors:
Quantity (M)
Value (N)
To retailers:
Quantity (O)
Value (P)
To buying groups:
Quantity (Q)
Value (R)
To home builders / contractors:
Quantity (S)
Value (T)
To end users / consumers:
Quantity (U)
Value (V)
RECONCILIATION OF CHANNELS.--Please ensure that the total quantities and values reported for
channels of distribution (i.e., lines M through V) in each time period equal the quantity and value
reported for commercial U.S. shipments (i.e., lines D and E) in the previous question 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
Reconciliation

2016

2017

January-March
2018

2018

2019

Quantity: M + O + Q + S + U – D =
zero ("0"), if not revise.

0

0

0

0

0

Value: N + P + R + T + V – E = zero
("0"), if not revise.

0

0

0

0

0

Business Proprietary
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II-6.

Page 18

Commercial U.S. shipments by type. Report your firms’ commercial U.S. shipments by type
(covered and select exclusion categories) of washer.
Quantity (in units) and value (in $1,000)
Calendar years
Item

2016

January-March

2017

2018

2018

2019

Commercial U.S. shipments:
Covered large residential
washers
Quantity (W)
Value (X)
Excluded top load residential
washers with PSC/belt
drive/clutch (exclusion 2)1:
Quantity (Y)
Value (Z)
Excluded front load
residential washers with
CIM/belt drive (exclusion 3)1:
Quantity (AA)
Value (AB)
Excluded “Extra-wide”
residential washers (exclusion
4)1:
Quantity (AC)
Value (AD)
1

As defined on pages 3 and 4.
RECONCILIATION OF COMMERCIAL US SHIPMENTS.--Please ensure that the quantities and values
reported for commercial U.S. shipments by type (i.e., lines W through AD) in each time period equal the
quantity reported for commercial U.S. shipments (i.e., lines D and E) in the previous question 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
Reconciliation

2016

2017

January-March
2018

2018

2019

Quantity: W + Y + AA + AC – D = zero
("0"), if not revise.

0

0

0

0

0

Value: X + Z + AB + AD – E = zero ("0"),
if not revise.

0

0

0

0

0

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Page 19

Commercial U.S. shipments by type. Report your firms’ commercial U.S. shipments by type
(top/front, energy star/non-energy star, and with agitator/without agitator).

II-7.

Quantity (in units) and value (in $1,000)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Commercial U.S. shipments:
Front-load.-Energy Star rated.-Quantity (AE)
Value (AF)
Non-Energy Star rated.-Quantity (AG)
Value (AH)
Top-load.-With agitator.-Energy Star rated.-Quantity (AI)
Value (AJ)
Non-Energy Star rated.-Quantity (AK)
Value (AL)
Without agitator.-Energy Star rated.-Quantity (AM)
Value (AN)
Non-Energy Star rated.-Quantity (AO)
Value (AP)
RECONCILIATION OF COMMERCIAL US SHIPMENTS.--Please ensure that the quantities and values reported for
commercial U.S. shipments in this question (i.e., lines AE through AP) equal the quantity and value reported for
commercial U.S. shipments (i.e., lines D and E) in question II-7 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
Reconciliation

2016

2017

January-March
2018

2018

2019

Quantity: AE + AG + AI + AK + AM
+ AO – D = zero ("0"), if not revise.

0

0

0

0

0

Value: AF + AH + AJ + AL + AN +
AP – E zero ("0"), if not revise

0

0

0

0

0

Business Proprietary
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II-8.

Page 20

Commercial U.S. shipments of covered parts. Report your firms’ commercial U.S. shipments of
domestically produced covered parts. Data on these covered parts should not be included in
the data reported in question II-4 through II-7.
Quantity (in units) and value (in $1,000)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Commercial U.S. shipments.-Covered parts.-Quantity
Value
II-9.

Imported covered parts for use in LRW production. Report the covered parts that your firm or a
related firm imported for the production of LRWs in the United States.
Quantity (in units) and value (in $1,000)
Calendar year
Item

2016

2017

U.S. imports of covered parts. -Quantity
1

Value
1

Defined on page 2. Identify the covered parts:

.

January-March
2018

2018

2019

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II-10.

Page 21

Employment data.--Report your firm’s employment-related data related to the production of
large residential washers and out-of-scope PSC/belt drive top-load and CIM/belt drive front-load
washers, 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 March periods, calculate similarly and divide by 3.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
REPORT DATA FOR ALL LARGE RESIDENTIAL WASHERS, INCLUDING PRODUCTS COVERED BY
THE SCOPE AND PSC/BELT DRIVE/CLUTCH TOP-LOAD WASHERS AND CIM/BELT DRIVE FRONTLOAD WASHERS.
Calendar year
Item

2016

Employment data:
Average number of
PRWs (number) (O)
Hours worked by PRWs
(1,000 hours) (P)
Wages paid to PRWs
($1,000) (Q)
Explanation of trends:

2017

January-March
2018

2018

2019

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Page 22

II-11.

Transfers to related firms.--If your firm reported transfers to related firms in question II-4,
please identify the firm(s) and indicate the nature of the relationship between your firm and the
related firms (e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at
market value or by a non-market formula, whether your firm retained marketing rights to all
transfers, and whether the related firms also processed inputs from sources other than your
firm.

II-12.

Purchases.--Has your firm purchased large residential washers produced in the United States or
in other countries since January 1, 2016? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire).
“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.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.

No

Yes

If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases:

Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below.
Quantity (in units)
Calendar years
Item

2016

2017

January-March
2018

2018

2019

Purchases from U.S. importers1
of large residential washers
Purchases from domestic
producers2 of large residential
washers
Purchases from other sources2
of large residential washers
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:
.
1

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II-13.

Page 23

Toll production.--Since January 1, 2016, has your firm been involved in a toll agreement
regarding the production of large residential washers?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

II-14.

Yes

If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce large residential washers in and/or
admit large residential washers into a foreign trade zone (FTZ)?

(a)

“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 designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.

No

Yes

If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import large residential washers into a foreign trade zone (FTZ) for use in distribution of
large residential washers and/or the production of downstream articles?

(b)

No

Yes

If yes--Identify the firms and the FTZs.

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FTZ admissions subsequently reported as imports of large residential washers.—
Report the value of your firm’s admissions into FTZs of any parts for large residential
washers (covered parts as defined on page 2 or any other parts used in the production
of large residential washers) and subsequently reported as an import for consumption
of large residential washers after being used in the production of domestically-produced
large residential washers.

(c)

Value (in 1,000 dollars)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Covered parts
Other parts1
1

Please list the parts:

II-15.

.

Direct imports.--Since January 1, 2016, has your firm imported large residential washers?
“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

II-16.

Other explanations:--If your firm would like to explain further a response to a question in Part II
for which a narrative 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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Page 25

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Emily Kim (202-205-1800, [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:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for which
financial statements are prepared that include large residential washers:

2.
3.

4.

Does your firm prepare profit/loss statements for large residential washers?
Yes
No
How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
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 large residential
washers, as well as specific statements and worksheets) used to compile these data.

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Page 26

III-3.

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 produces in the facilities in which it produces
large residential washers and any PSC/belt drive top-load and CIM/belt drive front-load
washers, and provide the share of net sales accounted for by these products in your firm’s most
recent fiscal year.
Products

Share of sales

large residential washers

%

PSC/belt drive top-load and CIM/belt drive front-load washers

%
%
%
%

Business Proprietary
U.S. Producers’ Questionnaire - Large Residential Washers (204)
III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of large residential washers 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.

Page 27

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of large
residential washers, and any PSC/belt drive top-load and CIM/belt drive front-load washers that
your firm purchases from related suppliers and that are reflected in question III-9a. For “Share
of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
the 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

III-8.

Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in III-9a (financial results on large residential
washers) in a manner consistent with the firm’s accounting books and records.

Yes

No

If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:

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Page 28

III-9a. Operations on large residential washers.--Report the revenue and related cost information
requested below on the large residential washers operations, and any PSC/belt drive top-load
and CIM/belt drive front-load washer 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 fiscal years, and for the specified interim periods. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact Emily
Kim at (202) 205-1800 before completing this section of the questionnaire.
Quantity (in units) and value (in $1,000)
Fiscal years ended-Item

2016

2017

January-March

2018

2018

2019

quantities:2

Net sales
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

values:2

Net sales
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
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.
1

2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

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Page 29

III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

III-9c.

Raw materials.--Please report the share of total raw material costs in 2018 (reported in III-9a)
for the following raw material inputs:
Procurement method

Input

Share of total raw
material costs
(percent)

Primarily
produced by
your firm

Primarily
purchased by
your firm

Steel, stainless
Steel, other than stainless
Plastic
Computer and electric components
Other material inputs1
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 total raw material costs that they account for:

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III-9d. Large residential washers variable and fixed costs.--For the total COGS and total SG&A
expenses reported for the most recently completed annual period in table III-9a please estimate
the share of variable and fixed costs for each category, with the sum adding to 100 percent. The
specified variable and fixed cost shares should be representative of the relevant range of
production that the company could achieve under current capacity constraints.
Item
Share of costs that are.-Variable
Fixed
Total (should sum to 100.0%)

Share of 2018:
COGS (percent)

0.0

Share of 2018:
SG&A (percent)
%
%
%

0.0

%
%
%

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Page 31

III-10. Expenses associated with new large residential washers platforms, upgrades of existing
platforms, and/or other 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-9a, please specify all material (significant) expenses associated with new
platforms and/or upgrades of existing platforms and other nonrecurring items (charges and
gains) in the schedule below, the specific question III-9a line item where the items are included,
a brief description of the relevant items, and the associated values (in $1,000), as reflected in
question III-9a; i.e., if an aggregate item has been allocated to question III-9a, only the allocated
value amount included in question III-9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in question III-9a.
January-March

Fiscal years ended-2016
Item

2017

2018

2018

2019

Value ($1,000)

Item 1
Item 2
Item 3
Item 4
Item 5
Item 6
Item 7

Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III-9a where the nonrecurring item is classified.

Description of the nonrecurring item

Income statement classification of
the nonrecurring item

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

III-11. Classification of identified expenses associated with new large residential washers platforms,
upgrades of existing platforms, and/or other nonrecurring items (charges and gains) in the
accounting books and records of the company.--If nonrecurring items were reported in
question III-10 above, please identify where your company recorded these items in your
accounting books and records in the normal course of business; i.e., just as responses to
question III-10 identify where these items are reported in question III-9a.

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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 large residential washers, and any PSC/belt drive topload and CIM/belt drive front-load washers. If your firm does not maintain some or all of the
specific asset information necessary to calculate total assets for large residential washers in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III-9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

2016

2017

2018

1

Describe

III-13. Capital expenditures and research and development (R&D) expenses.--Report your firm’s
capital expenditures and R&D expenses for large residential washers, and any PSC/belt drive
top-load and CIM/belt drive front-load washers. Provide data for your firm’s three most recently
completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended--

Item

2016

2017

January-March

2018

2018

2019

Capital expenditures1
R&D expenses2
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.
1

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Page 33

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-4 (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 unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended-Reconciliation

2016

2017

January-March
2018

2018

2019

Quantity: Trade data from question
II-4 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II-4
(lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-4?
Yes

No

If no, please explain.

III-15. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative 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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Page 34

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Tana von Kessler (202-2052389, [email protected]).
IV-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 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, 2016 of the following products
your firm imported from all countries:
Product 1.--Front loading, Energy Star rated washer; direct drive; rated DOE capacity
greater than or equal to 3.7 cubic feet but less than 4.2 cubic feet; water
heater included; steam cycle(s) included; no LCD display; white finish.
Product 2.--Front loading, Energy Star rated washer; direct drive; rated DOE capacity
greater than or equal to 4.2 cubic feet but less than 4.7 cubic feet; no water
heater included; no steam cycle(s) included; no LCD display; white finish.
Product 3.--Top loading, Energy Star rated washer; impeller; rated DOE capacity greater
than or equal to 4.7 cubic feet but less than 5.2 cubic feet; no water heater
included; no steam cycle included; lid includes clear or tinted window; white
finish.
Product 4.--Top loading, Energy Star rated; impeller; rated DOE capacity greater than
or equal to 4.7 cubic feet but less than 5.2 cubic feet; water heater included;
steam cycle included; lid includes clear or tinted window; white finish.
Product 5.--Front loading, Energy Star rated washer; direct drive; rated DOE capacity
greater than or equal to 4.2 cubic feet but less than 4.7 cubic feet; water
heater included; steam cycle(s) included; no LCD display; white finish.
Product 6.--Top loading, Energy Star rated washer; direct drive; impeller; rated DOE
capacity greater than or equal to 4.2 cubic feet but less than 4.7 cubic feet;
no water heater included; no steam cycle(s) included; solid opaque lid; white
finish.

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Product 7.--Front loading, Energy Star rated washer; direct drive; rated DOE capacity
greater than or equal to 4.7 cubic feet but less than 5.2 cubic feet; water
heater included; steam cycle(s) included; no LCD display; white finish.
Product 8.--Front loading, Energy Star rated washer; direct drive; rated DOE capacity
greater than or equal to 4.7 cubic feet but less than 5.2 cubic feet; water
heater included; steam cycle(s) included; no LCD display; non-white finish.
Report data for all SKUs/model numbers/product codes that fall under each above definition.
If the DOE rated capacity for a particular SKU/model number/product code changed during the
period, classify the SKU/model number/product code consistent with the capacity being
advertised at the time of sale. Classify a washer as Energy Star if it was being advertised as
Energy Star at the time of sale.
Please report values as follows:
Total dollar values should be f.o.b. factory and should not include U.S.-inland transportation
costs. Report the U.S. f.o.b. sales value and quantity on an invoice basis (i.e., the quantityweighted total of the prices indicated on the invoice for the product in question), and net of
direct and indirect discounts (i.e., all discounts, incentives, allowances, rebates, promotional
amount, cash incentives for retail sales personnel (SPIFFs) or other sales support, and/or any
other form of payment or allowance to a retailer). Exclude any additional equipment
provided (e.g. cold/hot water connection hoses), that may be included in the invoice price.
Direct discounts are tied to sales of the specific large residential washer(s) for which pricing
data are requested, whether or not such discounts are given on the sales price to the customer
or are in the form of a post-sale discount, rebate or other type of sales support after the
customer resells the product to its customer.
Indirect discounts, while not specifically tied to the products in question, are properly allocable
to sales of such products because sales of such products were part of the basis on which the
discount, incentive, allowance, etc. was given. In each case, the basis for the allocation of these
allocated discounts, rebates, etc. should be the value of sales of the pricing product at issue as a
percentage of the value of all the products sold by your firm to a customer that also qualified
for the same discount, rebate, etc. Thus, for example, the value of a discount given to a
customer because it reached an annual large residential washer sales target would be allocated
over large residential washer sales to that customer.
Note: Items such as discounts, allowances, and rebates, which are included as adjustments to
revenue, should be consistent with the company’s accounting procedures; i.e., they should
not include items that are treated separately as costs.

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IV-2a. During January 2016-March 2019, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question IV-3.

IV-2b. Pricing product SKUs.--Identify each SKU/model number/ product code for which you
have reported data and identify the SKU/model number/product code that accounts for
the highest volume of your pricing data by product.
Pricing
product

All included SKU/model number/
product codes1

Highest volume SKU/model
number/product code

Product 1
Product 2
Product 3
Product 4
Product 5
Product 6
Product 7
Product 8
Provide a specification sheet for each that allows the Commission to determine that each
SKU/model number/ product code contains each of the characteristics identified in the product’s
definition.
1

IV-2c. 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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IV-2d. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
(Quantity in units, value in 1,000 dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. factory.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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IV-2d. Price data.—Continued.
(Quantity in units, value in 1,000 dollars)
Product 5
Product 6
Product 7
Quantity
Value
Quantity
Value
Quantity
Value

Product 8
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. factory.
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 5:
Product 6:
Product 7:
Product 8:

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IV-2e. Pricing to OEMs.--Did your firm sell any of the above large residential washer pricing
products to an Original Equipment Manufacturer (OEM), i.e., a firm that marketed and
advertised your firm’s washers under its own brand name?

No

IV-3.

Price setting.--Has your firm changed how it determines the prices that it charges for sales of
large residential washers (transaction-by-transaction, contracts, set price lists, etc.) since
February 7, 2018?
No

IV-4.

If yes, please describe.

Yes

If yes, please describe.

Contract versus spot.--Since February 7, 2018, has the approximate share of your firm’s sales of
its U.S.-produced large residential washers sold on a short-term contract basis, annual contract
basis, long-term contract basis, and spot sales basis changed?
No

IV-6.

Yes

Discount policy.--Has your firm changed its discount policies since February 7, 2018.
No

IV-5.

Yes

If yes, were your sales prices to OEM(s) higher, lower, or mostly the
same as your prices to other customers? Please estimate
approximately how much higher or lower and explain why.

Yes

If yes, please describe.

Lead times.--Has the average lead time between a customer’s order and the date of delivery for
your firm’s sales of its U.S.-produced large residential washers changed since February 7, 2018?
No

Yes

If yes, please describe.

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IV-7.

Geographical shipments.—Has there been any change in the U.S. geographic market area(s) in
which your firm sold its U.S.-produced large residential washers since February 7, 2018?
No

IV-8.

Page 40

Yes

If yes, please describe.

Availability of supply.--Has the availability of large residential washers in the U.S. market
changed since February 7, 2018?
Availability in the U.S.
market

Please explain, noting the countries and reasons for the
No Yes changes.

Changes since February 7, 2018:
U.S.-produced product
Imports from all
countries
IV-9.

Supply constraints.--Has your firm refused, declined, or been unable to supply large residential
washers since February 7, 2018 (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-10. Effect of section 232 investigations of steel and aluminum on raw materials.--Did the
announcement of the section 232 investigations in April 2017 or the subsequent imposition of
tariffs on imported steel and aluminum products beginning in March 2018 impact the raw
material prices for large residential washers?
No
Announcement of the section
232 investigations in April 2017
Imposition of tariffs on imported
steel and aluminum products
beginning in March 2018

Yes

Don’t know If yes, describe impact.

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IV-11. Effect of section 301 investigations on raw materials.--Did the announcement of the section 301
investigations in June 2018 or the subsequent imposition of tariffs on Chinese-origin products
impact the raw material prices for large residential washers?
No

Yes

Don’t know If yes, describe impact.

Announcement of the section
301 investigations in June 2018
Imposition of tariffs on Chineseorigin products
IV-12. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for large residential washers has changed since February 7, 2018, and how you
anticipate demand will change in the future. Explain any trends and describe the principal
factors that have affected, and that you anticipate will affect, these changes in demand.

Overall
increase

Market

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Demand since February 7, 2018
Within the United States
Outside the United States
Anticipated future demand
Within the United States
Outside the United States
IV-13. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of large residential washers since February 7, 2018?
No

Yes

If yes, please describe.

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IV-14.

Page 42

Conditions of competition.--Have there been any changes in the business cycles or conditions
of competition for large residential washers since February 7, 2018?
No

Yes

If yes, describe.

IV-15. Price related factors.—
a. Please indicate whether changes in the following factors have tended to increase, decrease, or
have no effect on the prices of large residential washers in the U.S. market since February 7,
2018.
Factor
Competition between U.S. producers
Level of competition from substitute products
Level of competition from imports
Cost of raw materials
Energy costs
Domestic production capacity
Allocation of production capacity to alternate
products
Productivity of domestic producers
Labor agreements, contracts, etc.
Transportation/delivery cost
Market patterns
Demand in the United States
Demand outside the United States
State and local government incentives
Other

Increased

Decreased

No effect

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b. Please rate the importance of changes in the following factors based on their contribution to the
prices of large residential washers since February 7, 2018.

Factor

Very
important

Somewhat
important

Not
important

Competition between U.S. producers
Level of competition from substitute products
Level of competition from imports
Cost of raw materials
Energy costs
Domestic production capacity
Allocation of production capacity to alternate
products
Productivity of domestic producers
Labor agreements, contracts, etc.
Transportation/delivery cost
Market patterns
Demand in the United States
Demand outside the United States
State and local government incentives
Other
c. Please provide any detailed discussion/elaboration on factors affecting price changes of large
residential washers in the U.S. market since February 7, 2018.

IV-16. Efforts since implementation of safeguard measures.—Has your firm made any efforts to
increase product availability to your customers, either in terms of the quantity of products
available or by increasing your product offerings (e.g., new size ranges, qualities, features,
products, etc.) since February 7, 2018?
No

Yes

If yes, describe.

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IV-17. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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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/title_7/2019/large_residential_washers_monitoring_developments/safeguard.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: LRWS

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
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 (202205-1803). 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.


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