Form 19-1-4093 US producers' questionnaire

OMB No. 3117-0016/USITC No. 19-1-4093 ; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
VERTICAL METAL FILE CABINETS FROM CHINA
This questionnaire must be received by the Commission by August 28, 2019
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping duty investigations concerning vertical metal file cabinets
(“VMFCs”) from China (Inv. No. 701-TA-623 and 731-TA-1449 (Final)). The information requested in the questionnaire is
requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed
can result in a subpoena or other order to compel the submission of records or information in your firm’s possession (19
U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced vertical metal file cabinets (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)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: FILE)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Signature

Title of Authorized Official

Phone

Date

Email address

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 2

PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on April 30, 2019, by Hirsh
Industries LLC, West Des Moines, Iowa. Countervailing and antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2019/vertical_metal_file_cabinets_china/preliminary.htm
Vertical metal file cabinets “VMFCs” covered by these investigations are freestanding vertical metal file
cabinets containing two or more extendable file storage elements and having an actual width of 25
inches or less.
The subject vertical metal file cabinets have bodies made of carbon and/or alloy steel and or other
metals, regardless of whether painted, powder coated, or galvanized or otherwise coated for corrosion
protection or aesthetic appearance. The subject vertical metal file cabinets must have two or more
extendable elements for file storage (e.g., file drawers) of a height that permits hanging files of either
letter (8.5” x 11”) or legal (8.5” x 14”) sized documents.
An “extendable element” is defined as a movable load-bearing storage component including, but not
limited to, drawers and filing frames. Extendable elements typically have suspension systems, consisting
of glide blocks or ball bearing glides, to facilitate opening and closing.
The subject vertical metal file cabinets typically come in models with two, three, four, or five-file
drawers. The inclusion of one or more additional non-file-sized extendable storage elements, not sized
for storage files (e.g., box or pencil drawers), does not remove an otherwise in-scope product from the
scope as long as the combined height of the non-file-sized extendable storage elements does not exceed
six inches. The inclusion of an integrated storage area that is not extendable (e.g., a cubby) and has an
actual height of six inches or less, also does not remove a subject vertical metal file cabinet from the
scope. Accessories packaged with a subject vertical file cabinet, such as separate printer stands or shelf
kits that sit on top of the in-scope vertical file cabinet are not considered integrated storage.
“Freestanding” means the unit has a solid top and does not have an open top or a top with holes
punched in it that would permit the unit to be attached to, hung from, or otherwise used to support a
desktop or other work surface. The ability to anchor a vertical file cabinet to a wall for stability or to
prevent it from tipping over does not exclude the unit from the scope.
The addition of mobility elements such as casters, wheels, or a dolly does not remove the product from
the scope. Packaging a subject vertical metal file cabinet with other accessories, including, but not
limited to, locks, leveling glides, caster kits, drawer accessories (e.g., including but not limited to
follower wires, follower blocks, file compressors, hanger rails, pencil trays, and hanging file folders),
printer stand, shelf kit and magnetic hooks, also does not remove the product from the scope. Vertical
metal file cabinets are also in scope whether they are imported assembled or unassembled with all
essential parts and components included.
Excluded from the scope are lateral metal file cabinets. Lateral metal file cabinets have a width that is
greater than the body depth, and have a body with an actual width that is more than 25 inches wide.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 3

Also excluded from the scope are pedestal file cabinets. Pedestal file cabinets are metal file cabinets
with body depths that are greater than or equal to their width, are under 31 inches in actual height, and
have the following characteristics: (1) an open top or other the means for the cabinet to be attached to
or hung from a desktop or other work surface such as holes punched in the top (i.e., not freestanding);
or (2) freestanding file cabinets that have all of the following: (a) at least a 90 percent drawer extension
for all extendable file storage elements; (b) a central locking system; (c) a minimum weight density of 9.5
lbs./cubic foot; and (d) casters or leveling glides.
“Percentage drawer extension” is defined as the drawer travel distance divided by the inside depth
dimension of the drawer. Inside depth of drawer is measured from the inside of the drawer face to the
inside face of the drawer back. Drawer extension is the distance the drawer travels from the closed
position to the maximum travel position which is limited by the out stops. In situations where drawers
do not include an outstop, the drawer is extended until the drawer back is 3-l/2 inches from the closed
position of inside face of the drawer front. The “weight density” is calculated by dividing the cabinet’s
actual weight by its volume in cubic feet (the multiple of the product’s actual width, depth, and height).
A “central locking system” locks all drawers in a unit.
Also excluded from the scope are fire proof or fire-resistant file cabinets that meet Underwriters
Laboratories (UL) fire protection standard 72, class 350, which covers the test procedures applicable to
fire-resistant equipment intended to protect paper records.
The merchandise subject to the investigation is classified under Harmonized Tariff Schedule of the
United States (HTSUS) subheading 9403.10.0020. The subject merchandise may also enter under HTSUS
subheadings 9403.10.0040, 9403.20.0080, and 9403.20.0090. While HTSUS subheadings are provided
for convenience and customs purposes, the written description of the scope of the investigation is
dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.-- The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 4

Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from
Lawrence Jones (202-205-3358, [email protected]).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a 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-1a.

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes

I-2.

Page 5

No

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 VMFCs, 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:

Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No

I-4.

.

Yes

Petition support.--Does your firm support or oppose the petition?
Country

China – AD
China – CVD

Support

Oppose

Take no position

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
I-5.

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

Firm name

I-6.

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 VMFCs from China into the United States or that are
engaged in exporting VMFCs from China to the United States?
No
Firm name

I-7.

Page 6

Yes--List the following information.
Country

Affiliation

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

Yes--List the following information.
Country

Affiliation

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of VMFCs 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)

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-3a.

Page 8

Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce VMFCs, 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-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-7 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)
Calendar years
Item

2016

Overall production capacity

2017

January-June
2018

2018

2019

1

Production of:
VMFCs2

0

0

0

0

0

0

0

0

0

0

Out-of-scope products.-Lateral metal file cabinets
Pedestal metal file cabinets
Other products3
Total production using same
machinery or workers
1

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of VMFCs will populate here once reported in question II-7.
3
Please identify these products:
.
2

II-3b.

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

Weeks per year

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 9

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 VMFCs and other products using
the same equipment and/or labor?

No

(ii)

II-4.

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.

Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of VMFCs?
“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

Yes

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

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-5.

Page 10

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce VMFCs in and/or admit VMFCs into a
foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.

No

(b)

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 VMFCs into a foreign trade zone (FTZ) for use in distribution of VMFCs and/or the
production of downstream articles?
No

II-6.

Yes

Yes

If yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2016, has your firm imported VMFCs?
“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

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-7.

Page 11

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of VMFCs in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Commercial shipments made within the United States as a result
of an arm’s length 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 / including for own firm’s retail sales” – Product consumed internally by
your firm, which includes merchandise that your firm transferred to your own firm's retail
locations. Such transactions are valued at fair market value (i.e., not the total value of final
downstream processed merchandise (in the case of internal consumption), nor the retail sale
value (in the case of your firm owning and operating its own retail locations); rather, these
transactions should be recorded at the fair market wholesale value of the merchandise used for
further processing or for retail level sale). These should not include transfers among related
retail establishments.
“Transfers to related firms” –Shipments made to related 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.

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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-8.

Page 12

Production, shipment, and inventory data.--Continued
Quantity (in units) and value (in 1,000s of dollars)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

1

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including for own
firm’s retail sales:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (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
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

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

2016

2017
0

January-June
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:

0
.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-9.

Page 13

Channels of distribution.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption including VMFCs for your own firm’s retail sales) by channel of
distribution.
Quantity (in units)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers (N)
To end users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D – F – H = zero ("0"),
if not revise.

2016

2017
0

January-June
2018

0

2018
0

2019
0

0

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

II-11.

Page 14

Employment data.--Report your firm’s employment-related data related to the production of
VMFCs 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 June periods, calculate
similarly and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs (1,000 dollars)
Explanation of trends:

II-12.

Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and/or 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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-13.

Page 15

Purchases.--Has your firm purchased VMFCs 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-June
2018

2018

2019

1

Purchases from U.S. importers of
VMFCs from—
China
Mexico
All other sources
Purchases from domestic producers2
Purchases from other sources2
1

Please list the names 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 names of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.

II-14.

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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

II-15.

Page 16

Instructions.--Please check that the data in part II have been correctly reported.
Is the data reported in those questions:
In $1,000 dollars (not actual dollars)? (i.e., reporting 15 would represent
fifteen thousand dollars)
Inclusive of data limited to only in-scope VMFCs as defined on pages 2-3?
Net of all discounts, rebates, returns, etc.?
Properly accounted for based on the definitions on page 11?
Reconciled in the reconciliation tables above?

√ if Yes

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 17

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Samuel Varela-Molina (202-205-3429,
[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 VMFCs:

2.

Does your firm prepare profit/loss statements for VMFCs:
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,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

3.

4.

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 VMFCs, as well as
specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 18

III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced VMFCs, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
VMFCs

Share of sales
%
%
%
%
%

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of VMFCs 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 19

No--Continue to question III-9a.

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
VMFCs 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 your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input

Related supplier

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records

III-8.

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on VMFCs) in a
manner consistent with your 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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 20

III-9a. Operations on VMFCs.--Report the revenue and related cost information requested below on
the VMFCs 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.
Quantity (in units) and value (in $1,000)
Fiscal years ended-Item

2016

2017

January-June

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
Steel

(COGS):3

Other raw materials4
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
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 Please list major other raw materials:
.

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

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 21

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

III-9c.

No

If 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.

Based on data reported in III-9a, did your firm’s unit raw material costs increase since January 1,
2016?

No

Yes

If yes.--Please describe the primary cost drivers of this increase in per unit
raw material costs.

III-9d. Based on data reported in III-9a, was your firm able to increase its average unit net sales prices
in line to cover any increase in unit raw materials (i.e., was your firm able to pass increased raw
materials costs to your customers) over the period?

Yes

No

If no (i.e., your firm was unable to pass the entirety of increased raw
materials costs to your customers).--Please indicate the reasons your firm
was unable to do so.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 22

III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring 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.
Fiscal years

2016
Item

2017

January-June

2018

2018

2019

Value (in $1,000)

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

Income statement classification of the nonrecurring item

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 23

III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of VMFCs. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for VMFCs 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

III-13.

2016

2017

2018

1

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for VMFCs. 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
Capital expenditures

2016

2017

January-June

2018

2018

2019

1

Research and development
expenses2
1
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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 24

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 on 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-7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period 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.
January-June

Fiscal years ended-Reconciliation

2016

2018

2017

2018

2019

Quantity: Trade data from question II-6
(lines D, F, H, and J) less financial total
net sales quantity data from question III9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II-6
(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-7?
Yes

No

If no, please explain.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 25

III-15. Effects of imports on investment.--Since January 1, 2016, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of VMFCs from China?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

(please describe)

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 26

III-16. Effects of imports on growth and development.--Since January 1, 2016, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of VMFCs from China?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the
issue of stocks or bonds
Ability to service debt

Other

(please describe)

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 27

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
VMFCs from China?
No

Yes

If yes, my firm anticipates negative effects as follows.

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 28

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Pamela Davis (202-2052218, [email protected]).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone

PRICE DATA
IV-2a. 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 produced by your
firm.
Product 1.-- Vertical metal file cabinet, 17.75” — 20.25” deep, two file drawers, letter size (14.0”
— 16.25” wide), containing a lock, not containing casters
Product 2.-- Vertical metal file cabinet, 20.75” — 24.25” deep, two file drawers, letter size (14.0”
— 16.25” wide), containing a lock, not containing casters
Product 3.-- Vertical metal file cabinet, 27.75” — 29.25” deep, two file drawers, letter size (14.0”
— 16.25” wide), containing a lock, not containing casters
Product 4.-- Vertical metal file cabinet, 17.75” — 20.25” deep, two file drawers and one pencil
drawer, letter size (14.00” — 16.25” wide), containing a lock, not containing casters
Product 5.-- Vertical metal file cabinet, 17.75” — 20.25” deep, three file drawers, letter size
(14.00” — 16.25” wide), containing a lock, not containing casters
Product 6.-- Vertical metal file cabinet, 25.75” — 27.25” deep, four file drawers, letter size (14.00”
— 16.25” wide), containing a lock, not containing casters
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV-2b. During January 2016-June 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 table as appropriate.
No.--Skip to question IV-3.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 29

IV-2c. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in units and actual dollars (not 1,000s).
Product 1

(Quantity in units, value in dollars)
Product 2
Value
Quantity
Value

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

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 30

IV-2a. Price data. --Continued Report below the quarterly price data1 for pricing products2 produced
and sold by your firm.
Report data in units and actual dollars (not 1,000s).
Product 4

(Quantity in units, value in dollars)
Product 5
Value
Quantity
Value

Product 6
Period of shipment
Quantity
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
April-June
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
Product 6:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 31

IV-2b. Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Is the price data reported above:

√ if Yes

In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
IV-3.

Price setting.--How does your firm determine the prices that it charges for sales of VMFCs
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction

IV-4.

Contracts

Annual
total
volume
discounts

Online
price
lists

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of domestic VMFCs usually quoted (check
one)?
Delivered

IV-6.

Set
price
lists

Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).

Quantity
discounts

IV-5.

Page 32

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
VMFCs in 2018 was on a (1) short-term contract basis, (2) annual contract basis, (3) long-term
contract basis, and (4) spot sales basis?

Item
Share of 2018
sales

Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

Short-term
contracts
(multiple
deliveries for
less than 12
months)
%

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
IV-7.

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced VMFCs (or check “not applicable” if your firm does not sell on a short-term,
annual and/or long-term contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

Short-term contracts
(multiple deliveries
for less than 12
months)

No
Quantity

Indexed/adjusted to
raw material costs1

Price
Both
Yes
No

Not applicable
1

Page 33

Please identify the indexes/adjustments used:

Annual contracts
(multiple
deliveries for 12
months)
365

Long-term contracts
(multiple deliveries
for more than 12
months)

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)
IV-8.

Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced VMFCs?

Source

Share of 2018 sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)
IV-9.

Page 34

0.0

Lead time (Average
number of days)

%

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced VMFCs that is
accounted for by U.S. inland transportation costs?
percent

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(c)

Indicate the approximate percentage of your firm’s sales of VMFCs that are delivered
the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced VMFCs since January 1, 2016 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 35

IV-11. Substitutes.—
(a)

Specific substitutes.--Are these specific products considered as substitutes for VMFCs in
the same end use(s)?

Specific substitutes

Are these
considered
substitutes in the
Have changes in the price of this
End use(s) in which
market?
substitute affected the price of VMFCs?
this substitute is
No
Yes
used
No
Yes
Explanation

Lateral metal file
cabinets
Pedestal metal file
cabinets
Filing cabinets not
made of metal
Desks or other office
furniture with storage
capacity
Electronic document
storage
(b)

Other substitutes.--Can other products not already listed in part “a” of this question be
substituted for VMFCs?
No

Other substitutes
1.
2.
3.
4.

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for VMFCs?
No Yes

Explanation

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 36

IV-12. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for VMFCs has changed since January 1, 2016. Explain any trends and describe
the principal factors that have affected these changes in demand for your firm and the overall
VMFCs market (e.g., general economic growth, office vacancy rates, etc.).

Market

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

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 VMFCs since January 1, 2016?
No

Yes

If yes, please describe and quantify if possible.

IV-14. Product characteristics. –
(a) Please list product characteristics or features (e.g., steel gauge or type of steel, color, finish,
design, safety, etc.) that would cause your firm to sell two products with similar dimensions
at different prices.

(b) Please list firm-specific product characteristics or features (e.g., steel gauge or type of steel,
color, finish, design, safety, etc.) of the VMFCs that would cause two products with similar
dimensions to be sold at different prices.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 37

IV-15. Conditions of competition.-(a) Is the VMFCs market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to VMFCs? If yes, describe.
Check all that apply.

Please describe.

No

Skip to question IV-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
VMFCs since January 1, 2016?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply VMFCs since
January 1, 2016 (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.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 38

IV-17. Raw materials.—

(a) How have VFMC raw material prices changed since January 1, 2016?

Item

Overall
No
Overall
increase change decrease

Fluctuate
with no
clear trend

Explain, noting how raw
material price changes
have affected your firm’s
selling prices for
#abbrproduct.

Cost of raw materials
(b) Effect of 232 duties on raw material prices.--Did the announcement of the 232
investigation in April 2017 or the subsequent imposition of tariffs on imported steel
products beginning in March 2018 have an impact on the raw material prices for
VMFCs?
Yes—Please indicate the impact
in the table below.

Item
Raw material costs
for VMFCs in the
U.S. market
Prices for VFMCs in
the U.S. market

No

Fluctuate
with no
No
clear
Increase change Decrease trend

Don’t know

Explanation and factors

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 39

IV-18. Impact of the section 301 investigation.-- This question concerns the section 301

investigation and subsequent announcement of additional tariffs that include VMFCs
proposed and implemented by the United States in response to Chinese trade practices.
(a)

Has the implementation of tariff remedies in the section 301 investigation impact, or do
you anticipate that it will impact, your firm's VMFCs business and/or the U.S. VMFCs
market as a whole?
Yes—Please answer b and c.

(b)

No

Don’t know

Please indicate the impact of implementation of remedies in the section 301
investigation and tariff actions regarding VMFCs on each of the following factors.

Impact on

Overall
Increase

No change

Overall
Decrease

Fluctuate with
no clear trend

Demand for VMFCs in the
U.S. market
Supply of VMFCs imported
from China in the U.S.
market
Supply of VMFCs imported
from sources other than
China in the U.S. market
Prices for VMFCs in the
U.S. market
Raw materials costs for
VMFCs in the U.S. market
(c)

Describe the impact of the 301 tariffs on your firm and the overall market for VMFCs.
Please identify the magnitude and timing of the reported effects, and compare your
firm’s operations/overall market before and after the implementation of tariffs.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 40

IV-20. Interchangeability.--Are VMFCs produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

China

Mexico

Other countries

United States
China
Mexico
For any country-pair producing VMFCs that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 41

IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between VMFCs produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

China

Mexico

Other countries

United States
China
Mexico
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of VMFCs, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 42

IV-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for VMFCs since January 1, 2016. Indicate the share of the quantity of your firm’s
total shipments of VMFCs that each of these customers accounted for in 2018.
Customer’s name

City

State

Share of 2018
sales (%)

1
2
3
4
5
6
7
8
9
10

IV-24. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Vertical metal file cabinets (Final)

Page 43

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2019/vertical_metal_file_cabinets_china/
preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: FILE

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.--If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (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.