Form 19-1-4105 U.S. producers' questionnaire

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

US producers--Magnesium

Magnesium from Israel (Inv. nos. 701-TA-614 and 731-TA-1431)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 19-1-4105; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
MAGNESIUM FROM ISRAEL
This questionnaire must be received by the Commission by September 23, 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 investigations concerning magnesium from Israel (Inv. Nos.
701-TA-614 and 731-TA-1431 (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 magnesium (as defined on next page) at any time since January 1, 2016?

(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: MAGN)
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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on October 24, 2018, by US
Magnesium LLC. 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 dumping. Questionnaires and other information pertinent to this
proceeding are available at
https://www.usitc.gov/investigations/701731/2019/magnesium_israel/final.htm.
Magnesium covered by these investigations are primary and secondary pure and alloy magnesium
metal, regardless of chemistry, raw material source, form, shape, or size. Magnesium is a metal or alloy
containing by weight primarily the element magnesium. Primary magnesium is produced by
decomposing raw materials into magnesium metal. Secondary magnesium is produced by recycling
magnesium-based scrap into magnesium metal. The magnesium covered by this investigation also
includes blends of primary magnesium, scrap, and secondary magnesium.
The subject merchandise includes the following pure and alloy magnesium metal products made from
primary and/or secondary magnesium, including, without limitation, magnesium cast into ingots, slabs,
t-bars, rounds, sows, billets, and other shapes, and magnesium ground, chipped, crushed, or machined
into raspings, granules, turnings, chips, powder, briquettes, and other shapes: (1) products that contain
at least 99.95 percent magnesium, by weight (generally referred to as “ultra-pure” or “high purity”
magnesium); (2) products that contain less than 99.95 percent but not less than 99.8 percent
magnesium, by weight (generally referred to as “pure” magnesium); and (3) chemical combinations of
magnesium and other material(s) in which the magnesium content is 50 percent or greater, but less
than 99.8 percent, by weight, whether or not conforming to an “ASTM Specification for Magnesium
Alloy.”
The scope of these investigations excludes: (1) magnesium that is in liquid or molten form; and (2)
mixtures containing 90 percent or less magnesium in granular or powder form by weight and one or
more of certain non-magnesium granular materials to make magnesium-based reagent mixtures,
including lime, calcium metal, calcium silicon, calcium carbide, calcium carbonate, carbon, slag
coagulants, fluorspar, nephaline syenite, feldspar, alumina (A1203), calcium aluminate, soda ash,
hydrocarbons, graphite, coke, silicon, rare earth metals/mischmetal, cryolite, silica/fly ash, magnesium
oxide, periclase, ferroalloys, dolomite lime, and colemanite.
Magnesium is currently imported under statistical reporting numbers 8104.11.00, 8104.19.00, and
8104.30.00 of the Harmonized Tariff Schedule of the United States (HTSUS). 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,
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.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 3

Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
I-1a.

Page 4

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.

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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

I-2a.

Page 5

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 magnesium, 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

Additional discussion on establishments consolidated in this questionnaire:

I-2b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-2c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:

Lead attorney(s):

I-3.

Petitioner status.--Is your firm the 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

Israel AD
Israel CVD

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
I-5.

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

Firm name

I-6.

Page 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 magnesium from Israel into the United States or that are
engaged in exporting magnesium from Israel to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
I-7.

Page 7

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

Yes--List the following information.

Firm name

Country

Affiliation

I-8a.

Magnesium production process.--Please explain your firm’s production process.

I-8b.

Magnesium production.—Identify the nature of your firm’s magnesium operations (check all
that apply):
Item
Primary magnesium producer
Secondary magnesium producer (i.e. diecaster, recycler, etc.)
Grinder only

Check all that apply

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 8

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Andres Andrade (202-2052078, [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 magnesium 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)

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 9

II-3a.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-3b.

Product shifting.—
(i)

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

(ii)

Yes

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

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-3c.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between pure magnesium and alloy
magnesium using the same equipment and/or labor?
No

(ii)

II-4.

Page 10

Yes

Please describe the factors that affect your firm’s ability to shift production capacity
between pure magnesium and alloy magnesium?

Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of magnesium (i.e., in which upstream raw materials were provided to a toller that
then produces magnesium on behalf of a tollee)?
“Toll agreement”--Agreement between two firms whereby the first firm (“TOLLEE”) furnishes
the raw materials and the second firm (“TOLLER”) 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--For all such agreements entered into by your firm, please indicate whether your firm
was the Toller (the producer of magnesium) or tollee (the firm that furnished the
inputs to the Toller).
Our firm
Toller

Other firm(s)
Please name the tollee(s):

Special instruction
For production produced through
a tolling agreement, please
respond to the data requested in
Part V of this questionnaire. Data
for other production for merchant
market sales, if any, should be
reported in Parts II, III, IV.
Tollee1
Please name the toller(s):
Please respond to data requested
in Parts II, III, and IV, and skip data
requested in Part V.
1
Identify the raw material input(s) that your firm provided the toller(s):

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-5.

Page 11

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce magnesium in and/or admit magnesium
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 designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.

(b)

Yes

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import magnesium into a foreign trade zone (FTZ) for use in distribution of magnesium
and/or the production of downstream articles?
No

II-6.

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

Yes

If yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2016, has your firm imported magnesium?
“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
https://www.usitc.gov/investigations/701731/2018/magnesium_israel/preliminary.htm

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-7a.

Page 12

Production, shipment, and inventory data: primary and secondary magnesium producer.-Report your firm’s production capacity, production, shipments, and inventories related to the
production of primary, secondary, and granular magnesium in its U.S. establishment(s) during
the specified periods.
“Theoretical capacity” –Often referred to as “nameplate” or “rated” capacity. The level of
production your firm could obtain if all avaliable steel shells were producing magnesium.
“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” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” – Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” – A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” – Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
“Primary magnesium” – Primary magnesium is produced by decomposing raw materials into
magnesium metal.
“Secondary magnesium” – Secondary magnesium is produced by recycling magnesium-

based scrap into magnesium metal.
“Granular magnesium” – Granular magnesium is production by grinding magnesium ingots or
atomizing molten magnesium.
“Alloy magnesium” – Chemical combinations of magnesium and other materials(s) in which the
magnesium content is 50 percent of greater, but less than 99.8 percent, by weight, whether or
not conforming to as ASTM specificatrion for magnesium alloy.
“Pure magnesium” – Products that contain not less than 99.8 percent magnesium, by weight,
including “ultra pure magnesium” products that contain at least 99.95 percent magnesium, by
weight.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 13

II-7a. Production, shipment, and inventory data.—Continued
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-7a.

Page 14

Production, shipment, and inventory data.—Continued

Primary and secondary magnesium producer
Quantity (in metric tons) and value (in $1,000)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Capacity measures.-Theoretical capacity1
Average production capacity2 (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value3 (G)
Transfers to related firms:3
Quantity (H)
Value3(I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1

Please provide the number of steel shells used to calculate theoretical capacity
.
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
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.
4
Identify your firm’s principal export markets:
.
2

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

Reconciliation
B + C – D – F – H – J – L = should equal zero ("0")
or provide an explanation.1
1

2016

2017

January-June
2018

2018

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

2019

0
.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-7b.

Page 15

Channels of distribution: primary and secondary magnesium producers.--Report your firm’s
U.S. shipments (i.e. inclusive of commercial U.S. shipments, internal consumption, and transfers
to related firms) by channel of distribution.

Primary and secondary magnesium producer
Quantity (in metric tons)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., line 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 – D – F – H = zero ("0"), if not
revise.

2016

2017
0

January-June
2018

2018
0

2019
0

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-7c.

Page 16

U.S. shipments by product type. – Report the quantity and value of your firm’s U.S. shipment
(i.e. inclusive of commercial U.S. shipments, internal consumption, and transfers to related
firms) by product type in the specified periods.

Quantity (in metric tons); value (in $1,000)
Calendar Year
Item

2016

2017

January-June
2018

2018

2019

Alloy magnesium solid
forms:
Quantity (O)
Value (P)
Pure magnesium solid
forms:
Quantity (Q)
Value (R)
Granular forms:
Quantity (S)
Value (T)
RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for US
shipments by product type here (i.e., lines O through T) in each time period equal the quantities and
values reported for U.S. shipments (i.e., lines D through I) in each time period. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to submission to
the Commission.
Calendar year
Item

2016

2017

January-June
2018

2018

2019

Quantity: O + Q + S - D
- F - H = zero ("0"), if
not revise.

Value: P + R + T - E - G
- I = zero ("0"), if not
revise.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
II-7d.

Page 17

Employment data: primary and secondary magnesium producers.--Report your firm’s
employment-related data related to the production of magnesium 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.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods.
“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

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

2016

2017

January-June
2018

2018

2019

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U.S. Producers’ Questionnaire – Magnesium (Final)

Page 18

II-8a. Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to granular only magnesium production during the specified periods.
See definitions on page 12.

Granular only magnesium producer
Quantity (in metric tons) and value (in $1,000)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Average production capacity1 (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity)
Using domestic magnesium (C)
Using magnesium from Israel (D)
Using magnesium from other sources (E)
Total grinding production (F)
U.S. shipments:
Commercial shipments:
Quantity (H)
Value (I)
Internal consumption:3
Quantity (J)
Value3 (K)
Transfers to related firms:3
Quantity (L)
Value3(M)
Export shipments:4
Quantity (N)
Value (O)
End-of-period inventories (quantity) (P)
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:
.

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U.S. Producers’ Questionnaire – Magnesium (Final)

Page 19

Reconciliation

2016

B + F – H – J – L – N – P = should equal zero
("0") or provide an explanation.1
1

2017

January-June
2018

2018

2019

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

0
.

II-8b. Grinding operations.--Since January 1, 2016, has your firm purchased cast magnesium covered by
the investigations (either domestic or imported) and further processed those purchases through
grinding operations into products that still match the definition of magnesium (e.g., granular or
powder magnesium)?

Yes

If yes—Please describe the nature and extent of the following items in
relation to your firm's grinding operations in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Any other costs and
activities

II-8c.

Grinding operations' complexity and importance.--On a scale of 1 to 5, please provide your
firm's subjective opinion as to the complexity, intensity, and importance of grinding operations.
1 being minimally complex, intense or important; 5 being extremely complex, intense, and
important.

1:
Minimally
complex, intense,
and important

Please describe the reason for your rating:

5:
Extremely
complex, intense,
and important

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

II-8d.

Page 20

Channels of distribution: granular magnesium producers.--Report your firm’s U.S. shipments
(i.e. inclusive of commercial U.S. shipments, internal consumption, and transfers to related
firms) by channel of distribution.

Granular only magnesium producer
Quantity (in metric tons)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (Q)
To end users (R)
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., line 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
Q + R – H – J – L = zero ("0"), if not
revise.

2016

2017
0

January-June
2018

2018
0

2019
0

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U.S. Producers’ Questionnaire – Magnesium (Final)

II-8e.

Page 21

Employment data: granular magnesium producers.--Report your firm’s employment-related
data related to the production of magnesium 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.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods.
“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

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

2016

2017

January-June
2018

2018

2019

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Page 22

II-9.

Related firms.--If your firm reported transfers to related firms in questions II-7 and II-8a, please
indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non-market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.

II-10.

Purchases.--Has your firm purchased magnesium 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.

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 metric tons)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Purchases from U.S. importers of
magnesium from—
Israel
Canada
Russia
Taiwan
Turkey
All other sources
Purchases from domestic producers2
Purchases from other sources2
1

Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.

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U.S. Producers’ Questionnaire – Magnesium (Final)

II-11.

Page 23

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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U.S. Producers’ Questionnaire – Magnesium (Final)

Page 24

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Emily Kim (202-205-1800, [email protected]).
III-1.

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 magnesium:

Does your firm prepare profit/loss statements for magnesium?
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes magnesium, 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.).

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.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
III-5.

Page 25

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

Share of sales

Pure magnesium (solid)

Alloy magnesium (solid)

Granular magnesium

%
%
%
%

III-6.

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

No--Continue to question III-8.

III-7a. Inputs from related suppliers detailed.--Please identify the inputs used in the production of
magnesium that your firm purchases from related suppliers and that are reflected in question
III-9a/9b. 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

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

Share of total COGS

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U.S. Producers’ Questionnaire – Magnesium (Final)

Page 26

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

Yes

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

III-8a. By-products.—Does your firm have any by-product sales revenue associated with its magnesium
operations (e.g., silvanite, chlorine, scrap)? If yes, identify the by-product(s) in the space below,
and complete the table in question III-8b. If no, please continue to question III-9a.
Yes

III-8b. By-product revenue.--Report your firm’s total by-product sales revenue, net of relevant
processing costs, associated with the magnesium operations of your U.S. establishment(s).
Provide data for the three most recently completed fiscal years, and for the specified interim
periods. Note: the data provided below will appear in question III-9a/9b as a reduction to
COGS.
Value (in $1,000)
Fiscal years ended--

Item

2016

2017

January-June

2018

2019

By-product sales revenue1
1

Please describe how your firm classifies these by-product revenues in the normal course of business (e.g.,
included in net sales values, as a reduction to COGS, included in “all other income”).

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Page 27

III-9a. Operations on magnesium: Primary and secondary magnesium producer.--Report the revenue
and related cost information requested below on the magnesium operations of your firm’s U.S.
establishment(s).1 If your firm produces granular magnesium only, please skip this question and
provide the revenue and related cost information on the granular magnesium operations in
question III-9b. Do not report resales of products. Note that internal consumption and transfers
to related firms must be valued at fair market value. Input purchases from related suppliers
should be consistent with and based on information in the firm’s accounting books and records.
Provide data for your firm’s three most recently completed fiscal years, and for the specified
interim periods. If your firm was involved in tolling operations (either as the toller or as the tollee),
please report the revenue and related cost information on tolling in Part V.
Quantity (in metric tons) and value (in $1,000)
Fiscal years ended-Item

2016

2017

January-June

2018

2019

Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

Total COGS

Gross profit or (loss)

Net sales values:2
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Direct labor
Other factory costs
Less: by-product revenue

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income or (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight (f.o.b. your facility). The quantities and values should approximate the
corresponding shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

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

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Page 28

III-9b. Operations on granular magnesium ONLY producer.--Report the revenue and related cost
information requested below on the granular magnesium operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books and
records. Provide data for your firm’s three most recently completed fiscal years, and for the
specified interim periods. If your firm was involved in tolling operations (either as the toller or as
the tollee), please report the revenue and related cost information on tolling in Part V.
Quantity (in metric tons) and value (in $1,000)
Fiscal years ended-Item

2016

2017

January-June
2018

2018

2019

Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

Total COGS

Gross profit or (loss)

Net sales values:2
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Raw materials.—
Using domestic magnesium
Using magnesium from Israel
Using magnesium from other sources
Other raw materials
Total raw materials
Direct labor
Other factory costs

Selling, general, and administrative (SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income or (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight (f.o.b. your facility). The quantities and values should approximate the
corresponding shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

III-9c.

Page 29

Financial data reconciliation.--The calculable line items from question III-9a/9b (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

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.

III-9d. Raw materials.--Please report the share of total raw material costs in 2018 (reported in III9a/9b) for the following raw material inputs:

Input

Share of total raw material
costs (percent)

Magnesium chloride, magnesium-containing ore, or other
magnesium containing mined materials
Processed magnesium1
R134a and other cover gases, and other material inputs 2
Total (should sum to 100 percent)
1

Processed magnesium includes primary or secondary magnesium products, magnesium scrap, slag,
or other recycled content.
2
Please identify any other notable "other" raw materials not expressly requested above and provide
the share of the total raw material costs that they account for:

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Page 30

III-9e. Magnesium variable and fixed costs.--For the total COGS and total SG&A expenses reported for
the most recently completed annual period in table III-9a/b please estimate the share of
variable and fixed costs for each category, with the sum adding to 100 percent. The specified
variable and fixed cost shares should be representative of the relevant range of production that
the company could achieve under current capacity constraints.
Share of 2018:
COGS (percent)

Item
Share of costs that are.-Variable
Fixed
Total (should sum to 100.0%)

0.0

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

0.0

%
%
%

III-10a. Expenses associated with cleanup/litigation activities related to U.S. Environmental Protection
Agency’s classification of U.S. Magnesium as a Superfund site included in the subject product
financial results.--For each annual and interim period for which financial results are reported in
question III-9a/9b, please specify all material (significant) expenses associated with
cleanup/litigation activities related to U.S. Environmental Protection Agency’s classification of
U.S. Magnesium as a Superfund site in the schedule below, the specific question III-9a/9b line
item where expenses are included, a brief description of the relevant expenses, and the
associated values (in $1,000), as reflected in question III-9a/9b; i.e., if an aggregate expense has
been allocated to question III-9a/9b, only the allocated value amount included in question III9a/9b should be reported in the schedule below. Note: The Commission’s objective here is to
gather information only on material (significant) items which impacted the reported financial
results of the subject product in question III-9a/9b.
Fiscal years ended--

2016

2017

Item

January-June

2018

2019

Value ($1,000)

Expense 1
Expense 2
Expense 3
Expense 4
Expense 5

Expense: In this table please provide a brief description of each expense reported above and indicate the specific
line item in table III-9a/9b where the item is classified.
Description of expense
Expense 1
Expense 2
Expense 3
Expense 4
Expense 5

Income statement classification of expense

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Page 31

III-10b. 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/9b,
please specify all material (significant) nonrecurring items (charges and gains) in the schedule
below, the specific question III-9a/9b 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/b; i.e., if an aggregate nonrecurring item has been allocated to
question III-9a/9b, only the allocated value amount included in question III-9a/9b 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/9b.
Fiscal years ended--

2016
Item

2017

January-June

2018

2019

Value ($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/9b where the nonrecurring item is classified.
Description of the
nonrecurring item

Income statement classification of the nonrecurring item

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

III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10a/10b 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-10a/10b identify where
these items are reported in question III-9a/9b.

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III-12. Asset values.--Report the total assets, i.e., both current (cash, accounts receivable, inventories,
for example) and long-term assets (property, plant, and equipment, net of depreciation, for
example) associated with the production, warehousing, and sale of magnesium. If your firm
does not maintain some or all of the specific asset information necessary to calculate total
assets for magnesium 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/9b. 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

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for magnesium. 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

2019

R&D expenses2
1

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.

Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.

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Page 33

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a/9b, 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 and III-9b should reconcile with
the data reported in question II-7a and II-8a (including export shipments) as long as they are
reported on the same calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended-Reconciliation

2016

2017

January-June
2018

2018

2019

Quantity: Trade data from question II-7a
and II-8a (lines D, F, H, and J) less
financial total net sales quantity data
from question III-9a and III-9b, = zero
("0").

Value: Trade data from question II-7a
and II-8a (lines E, G, I, and K) less
financial total net sales value data from
question III-9a and III-9b, = zero ("0").

Do these data in question III-9a and III-9b reconcile with data in question II-7a and II-8a?
Yes

If no, please explain.

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Page 34

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 magnesium from Israel?
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)

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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 magnesium from Israel?
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)

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Page 36

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
magnesium from Israel?
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.

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Page 37

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King
([email protected], 202-205-2049).
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-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products produced by your
firm.
Product 1.-- Pure magnesium ingots containing at least 99.95 percent magnesium (“high purity
magnesium”).
Product 2.-- Pure magnesium ingots containing at least 99.8 percent magnesium, but less than
99.95 percent magnesium (“pure magnesium”).
Product 3.-- Alloy magnesium ingots containing less than 99.8 percent magnesium, meeting
ASTM specifications for alloy magnesium.

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-2a. 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.

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

Product 3
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
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:

IV-2c.

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

√ if Yes

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U.S. Producers’ Questionnaire – Magnesium (Final)
IV-2d.

Page 39

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.
IV-3.

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

IV-4.

Contracts

Other

If other, describe

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

Quantity
discounts

IV-5.

Set
price
lists

Annual
total
volume
discounts

No
discount
policy

Other

Describe

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

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
IV-6.

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

Item
Share of 2018
sales
IV-7.

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

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

Spot sales
(for a single
delivery)

Total (should
sum to
100.0%)
0.0

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced magnesium (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

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Page 40

Please identify the indexes used:

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

Annual contracts
(multiple
deliveries for 12
months)
365

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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
IV-8.

Lead times.--What is your firm’s share of sales from inventory vs. 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 magnesium?

Source

Share of 2018 sales

From inventory

Produced to order

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

Page 41

0.0

Lead time (Average
number of days)

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced magnesium 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 magnesium that are
delivered the following distances from its production facility.
Distance from production facility

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 magnesium 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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 42

IV-11. End uses.--List the end uses of the magnesium that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by magnesium and other inputs?
Share of total cost of end use product
accounted for by
End-use product

Magnesium

Total
(should sum to
100.0% across)

Other inputs
%

0.0 %

IV-12. Substitutes.--Can other products be substituted for magnesium?
No

Substitute

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 magnesium?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for magnesium has changed since January 1, 2016. Explain any trends and
describe the principal factors (including any changes in downstream markets such as aluminum)
that have affected these changes in demand for magnesium.

Market
Within the United
States
Outside the United
States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 43

IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of magnesium since January 1, 2016?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a)

Is the magnesium market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to magnesium? If yes,
describe.

Check all that apply.

Please describe.

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 magnesium since January 1, 2016?
No

(c)

Yes

If yes, describe.

Has the closure of ATI’s titanium sponge facility had an impact on the market for
magnesium?

Don’t know

Yes

If yes, describe.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 44

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply magnesium 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.

IV-17. Raw materials.--How have magnesium raw material prices changed since January 1, 2016?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

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

IV-18. Interchangeability.--Is magnesium 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

Israel

Canada

Russia

Taiwan

Turkey

Other
countries

United States
Israel
Canada
Russia
Taiwan
Turkey
For any country-pair producing magnesium that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 45

IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between magnesium 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

Israel

Canada

Russia

Taiwan

Turkey

Other
countries

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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 46

IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for magnesium since January 1, 2016. Indicate the share of the quantity of your firm’s
total shipments of magnesium that each of these customers accounted for in 2018.

Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2018 sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 47

IV-21. Competition from imports.-(a)

Lost revenue.--Since January 1, 2016: To avoid losing sales to competitors selling
magnesium from Israel, did your firm:
Item

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2016: Did your firm lose sales of magnesium to imports of
this product from Israel?
No

Yes

IV-22. 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.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 48

PART V.—TOLLER OPERATIONS
Address questions on this part of the questionnaire to Andres Andrade (202-205-2078,
[email protected]) and Emily Kim (202-205-1800, [email protected]).
V-1.

Trade data on operations by TOLLER.—If your firm performed tolling operations on behalf of
another firm (produced for the tollee), report your firm’s production capacity, production,
shipments returned to the tollee, and employment related to the production of strontium
chromate in your firm’s U.S. establishment(s) during the specified periods. (See definition of
toller/tollee in II-4).
Quantity (in metric tons) and value (in $1,000)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Average production capacity (quantity) (A)
Production (quantity) (B)
U.S. shipments returned to the tollee:
Quantity (C)
Tolling fee(s) received (value) (D)
Employment data:
Average number of PRWs (number)
Hours worked by PRWs (actual hours)
Wages paid to PRWs (value)
1

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
V-2.

Page 49

Tolling operations by TOLLER.-- If your firm performed tolling operations on behalf of another
firm (produced for the tollee), report the operating income or (loss) and related cost
information requested below on the magnesium tolling operations of your firm’s U.S.
establishment(s) during the specified periods.

Item

Quantity (in metric tons) and value (in $1,000)
Fiscal years ended-2016
2017
2018

January-June
2018
2019

Tolling operations:1
Net quantity tolled
Net tolling revenue
Total revenue from
tolling operations
Cost of tolling services:
Raw materials NOT
supplied by tollee
Direct labor
Other factory costs
Total cost of tolling
services
Gross profit or (loss)
Selling, general, and
administrative (SG&A)
expenses:
Operating income or (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
The quantities and values should approximate the corresponding shipment quantities and values reported in
the trade data on tolling operations

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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
V-3.

Page 50

Financial data reconciliation.--The calculable line items from question V-2 (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

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)
V-4.

Page 51

Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
question V-2 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 V-2 should reconcile with the data
reported in question V-1 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 U.S. shipments returned to the tollee in V-1 equal the quantities and values reported for total net
sales in V-2 of this questionnaire in each time period unless the financial data from V-2 are reported on a
fiscal year basis, in which case only the interim periods must reconcile. If the calculated fields below
return values other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain
the discrepancy below.
Fiscal years ended--

Reconciliation

2016

2017

January-June

2018

2017

2018

Quantity: Trade data from question V-1
(line C) less financial total net sales
quantity data from question V-2 = zero
("0").

Value: Trade data from question V-1
(line D) less financial total net sales value
data from question V-2 = zero ("0").

Do these data in question V-2 reconcile with data in question V-1?
Yes

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire – Magnesium (Final)

Page 52

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/magnesium_israel/final.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: MAGN

• E-mail.—E-mail the MS Word questionnaire to Andres Andrade ([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.

File Type	application/pdf
File Title	Microsoft Word - US producers--Magnesium (F)
Author	andres.andrade
File Modified	2019-08-13
File Created	2019-08-13