19-1-4028 Foreign producers' questionnaire

OMB No. 3117-0016/USITC No. 19-1-4028; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ 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.
Name of firm
Address
Website
Has your firm produced or exported large residential washers (as defined on 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)

Data reported in this questionnaire relate to (Check one):
Canada

China

Korea

Thailand

Vietnam

Other:

Mexico
________(please list country)

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 investigations, 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

Phone:
Signature

Fax:

Email address

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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 an 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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(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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(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.
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.
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
Nathanael Comly ([email protected]; 202-205-3174).
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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I-1.

Page 5

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
30 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2.

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 in a country involved in the production or export of
large residential washers, including auxiliary facilities operated in conjunction with (whether or
not physically separate from) such facilities. Firms operating more than one establishment in a
single country should combine the data for all establishments in that country into a single
report.

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I-3.

Page 6

U.S. importers.--Please provide the names, contacts, email addresses, and telephone numbers
of the FIVE largest U.S. importers of your firm’s large residential washers in 2018.

No.

Importer’s name

Contact person

Email address

Share of
Area code
your firm’s
and
2018 U.S.
telephone
exports
number
(%)

1
2
3
4
5
I-4.

U.S. or other country production.--Does your firm or any related firm produce, have the
capability to produce, or have any plans to produce large residential washers in the United
States or other countries?
No

I-5.

Yes--Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire.

U.S. importation.--Does your firm or any related firm import or have any plans to import large
residential washers into the United States?
No

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

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I-6.

Page 7

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 future market conditions for large
residential washers?
No

Yes--Please provide the requested documents. If you are not providing the
requested documents, please explain why not.

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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
Fax

II-2.

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

Anticipated changes in operations.--Does your firm anticipate any changes in in the character of
its operations or organization relating to the production of large residential washers in the
future?

No

II-2c.

Page 9

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. Include in your
response a specific projection of your firm’s capacity to
produce large residential washers (in units) for 2019 and 2020.

Significance of safeguard measure.--Describe the significance of the safeguard measure
imposed by the President effective on February 7, 2018, in terms of its effect on your firm’s
production, production capacity, home market shipments, exports to the United States and
other markets, and inventories. You may wish to compare your firm’s operations before and
after the imposition of the relief.

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II-3a.

Page 10

Production using same machinery.-- Please report your firm’s production of products made on
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 for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” --All production in your establishment(s), including production consumed
internally within your firm.
Quantity (in units)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Overall production capacity
Production of:
Large residential washers1

0

0

0

0

0

0

0

0

0

0

PSC/belt drive TL washers
CIM/belt drive FL washers
Commercial washers
Stacked washers
Extra-wide washers
Other products2
Total

Data entered for production of large residential washers will populate here once reported in
question II-9.
2
Please identify these products:
.
1

II-3b.

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

hours

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II-3e.

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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-- (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.

II-4.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of large residential washers?
percent.

II-5.

Firm's estimated share of production in country.--Please estimate the percentage of total
production of large residential washers in the country specified on the certification page accounted
for by your firm’s production in 2018.
percent.

II-6.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of large residential washers from the country specified on the certification
page accounted for by your firm’s exports in 2018.
percent.

II-7.

Third country trade actions.--Are the large residential washers exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings in third
countries?
No

II-8.

Yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

Other export markets.--Identify export markets (other than the United States) that your firm
has developed or where it has increased its sales of large residential washers since January 1,
2016. Please identify and discuss below.

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II-9.

Page 12

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of large residential washers in your establishment(s) during the
specified periods. Do not include resales of large residential washers that your firm did not
produce in this question; those data to the degree they are exported to the United States should
only be reported in question II-10.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
Do not submit data on multiple countries combined. The establishments reported here should
all be located in the country corresponding to the box checked on the certification page.
Multinational companies with production in multiple subject countries should submit separate
foreign producer questionnaire responses for each subject country.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s), including production consumed
internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s). Quantities
reported should be net of returns. 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.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firmsin the market in which your establishments are located.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in the market in which your establishments are located, including product
consumed internally by your firm.
“Export shipments”--Shipments to destinations outside the country indicated on page 1,
including shipments to related firms.
“Inventories”--Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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Trade data.--Continued.

II-9.

Quantity (in units)
Actual experience

Projections1

Calendar year
Item

2016

2017

January-March
2018

2018

Calendar year

2019

2019

2020

Average production capacity (A)
2

Beginning-of-period inventories
(B)
Production (C)
Home market shipments:
Internal consumption/
transfers (D)
Commercial shipments (E)
Export shipments:
to the United States (F)
to the European Union3 (G)
to Asia4 (H)
to all other markets5 (I)
Total exports (J)

0

0

0

0

0

0

0

Total shipments (K)

0

0

0

0

0

0

0

End-of-period inventories (L)
Please explain the basis for your firm’s projections.
.
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:
.
3
Identify your firm’s principal European Union export markets:
.
4
Identify your firm’s principal Asian export markets:
.
5
Identify your firm’s principal other export markets:
.
1
2

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line R) 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, J, L,
and N). 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
Item

B + C – D – E – F – G – H – I – 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-10.

Page 14

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of large residential washers that was produced in the country identified by your
firm on page 1 but not by your firm during the specified periods. Note these data should not be
included in question II-9.
Quantity (in units)
Calendar year
Item

2016

2017

January-March
2018

2018

2019

Exports of large residential washers to the
United States not produced by your firm.1
1

List the producer(s).

II-11.

Other explanations.--If your firm would like to further explain 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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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
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm did not produce or export 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.