17-2-3758 US Importers' questionnaire

OMB No. 3117-0016/USITC No. 17-2-3758; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
TOOL CHESTS AND CABINETS FROM CHINA AND VIETNAM
This questionnaire must be received by the Commission by October 16, 2017
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 and antidumping investigations concerning tool chests and cabinets from China and
Vietnam (Inv. Nos. 701-TA-575 and 731-TA-1360-1361 (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 imported tool chests and cabinets; tool chests and cabinets not prepackaged for retail sale; or
industrial tool chests and cabinets (as defined on next page) from any country at any time since January 1, 2014?

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: TOOL)
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

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets

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PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on April 11, 2017, by
Waterloo Industries Inc., Sedalia, Missouri. Countervailing and/or 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/701731/2017/tool_chests_and_cabinets_china_and_vietnam/fina
l.htm.
Tool chests and cabinets All metal tool chests and cabinets, including top chests, intermediate chests,
tool cabinets and side cabinets, storage units, mobile work benches, and work stations and that have
the following physical characteristics:
(1) a body made of carbon, alloy, or stainless steel and/or other metals;
(2) two or more drawers for storage in each individual unit;
(3) a width (side to side) exceeding 15 inches for side cabinets and exceeding 21 inches for all
other individual units but not exceeding 60 inches;
(4) a depth (front to back) exceeding 10 inches but not exceeding 24 inches; and
(5) prepackaged for retail sale.
For purposes of this scope, the width parameter applies to each individual unit, i.e., each individual top
chest, intermediate top chest, tool cabinet, side cabinet, storage unit, mobile work bench, and work
station.
Prepackaged for retail sale means the units are packaged in a cardboard box or other container suitable
for retail display and sale. Subject tool chests and cabinets are covered whether imported in assembled
or unassembled form. Subject merchandise includes tool chests and cabinets produced in China or
Vietnam but assembled, prepackaged for sale, or subject to other minor processing in a third country
prior to importation into the United States. Similarly, it would include tool chests and cabinets produced
in China or Vietnam that are later found to be assembled, prepackaged for sale, or subject to other
minor processing after importation into the United States.
Subject tool chests and cabinets may also have doors and shelves in addition to drawers, may have
handles (typically mounted on the sides), and may have a work surface on the top. Subject tool chests
and cabinets may be uncoated (e.g., stainless steel), painted, powder coated, galvanized, or otherwise
coated for corrosion protection or aesthetic appearance.
Subject tool chests and cabinets may be packaged as individual units or in sets. When prepackaged in
sets, they typically include a cabinet with one or more chests that stack on top of the cabinet. Tool
cabinets act as a base tool storage unit and typically have rollers, casters, or wheels to permit them to
be moved more easily when loaded with tools. Work stations and work benches are tool cabinets with a
work surface on the top that may be made of rubber, plastic, metal, wood, or other materials.
Top chests are designed to be used with a tool cabinet to form a tool storage unit. The top chests may
be mounted on top of the base tool cabinet or onto an intermediate chest. They are often packaged as a
set with tool cabinets or intermediate chests, but may also be packaged separately. They may be
packaged with mounting hardware (e.g. bolts) and instructions for assembling them onto the base tool
cabinet or onto an intermediate tool chest which rests on the base tool cabinet. Smaller top chests
typically have handles on the sides, while the larger top chests typically lacks handles. Intermediate tool

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets

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chests are designed to sit on top of the floor standing tool cabinet and to be used underneath the top
tool chest. Although they may be packaged or used separately from the tool cabinet, intermediate
chests are designed to be used in conjunction with tool cabinets. Intermediate chests typically do not
have handles, but the intermediate and top chests may have the capability of being bolted together.
Side cabinets are designed to be bolted or otherwise attached to the side of the base storage cabinet to
expand the storage capacity of the base tool cabinet.
Subject tool chests and cabinets also may be packaged with a tool set included. Packaging a subject tool
chest and cabinet with a tool set does not remove an otherwise covered subject tool chest and cabinet
from the scope. When this occurs the tools are not part of the subject merchandise.
All tool chests and cabinets that meet the above definition are included in the scope unless otherwise
specifically excluded.
Excluded from the scope of the investigations are tool boxes, chests, and cabinets with bodies made of
plastic, carbon fiber, wood, or other non-metallic substances. Also excluded from the scope of the
investigations are industrial grade steel tool chests and cabinets. The excluded industrial grade steel tool
chests and cabinets are those:
(1) having a body that is over 60 inches wide; or
(2) having each of the following physical characteristics:
(a) a body made of steel that is 0.047 inches or more in thickness;
(b) a body depth (front to back) exceeding 21 inches; and
(c) a unit weight that exceeds the maximum unit weight shown below for each width
range:
Weight to Width Ratio Tool Chests
Inches
Maximum Pounds
> 21 ≤25
90
> 25 ≤28
115
> 28 ≤30
120
> 30 ≤32
130
> 32 ≤34
140
> 34 ≤36
150
> 36 ≤38
160
> 38 ≤40
170
> 40 ≤42
180
> 42 ≤44
190
> 44 ≤46
200
> 46 ≤48
210
> 48 ≤50
220
> 50 ≤52
230
> 52 ≤54
240
> 54 ≤56
250
> 56 ≤58
260
> 58 ≤60
270

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Weight to Width Ratio Tool Cabinets
Inches
Maximum Pounds
> 21 ≤25
155
> 25 ≤28
170
> 28 ≤30
185
> 30 ≤32
200
> 32 ≤34
215
> 34 ≤36
230
> 36 ≤38
245
> 38 ≤40
260
> 40 ≤42
280
> 42 ≤44
290
> 44 ≤46
300
> 46 ≤48
310
> 48 ≤50
320
> 50 ≤52
330
> 52 ≤54
340
> 54 ≤56
350
> 56 ≤58
360
> 58 ≤60
370
Also excluded from the scope of the investigations are service carts. The excluded service carts have all
of the following characteristics:
(1) casters, wheels, or other similar devices which allow the service cart to be rolled from place
to place;
(2) a flat top or flat lid on top of the unit that opens;
(3) a space or gap between the casters, wheels, or other similar devices, and the bottom of
the enclosed storage space (e.g., drawers) of at least 10 inches; and
(4) a total unit height, including casters, of less than 48 inches.
Also excluded from the scope of the investigations are work benches having each of the following
characteristics:
(1) a solid top working surface;
(2) no drawers, one drawer, or two drawers in a side-by side configuration; and
(3) the unit is supported by legs and the unit has no solid front, side, or back panels enclosing
the body of the unit.
Also excluded from the scope of the investigations are metal filing cabinets that are configured to hold
hanging file folders and are classified in the Harmonized Tariff Schedule of the United States (HTSUS) at
subheading 9403.10.0020.
Merchandise subject to the investigation is classified under HTSUS categories 9403.20.0021,
9403.20.0026, 9403.20.0030 and 7326.90.86881 but may also be classified under HTSUS category
7326.90.3500. While HTSUS subheadings are provided for convenience and Customs purposes, the
written description of the scope of this investigation is dispositive.

1

On January 1, 2017, HTSUS subheading 7326.90.85 was re-designated as HTSUS subheading 7326.90.86.

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Other tool chests and cabinets.--Other tool chests and cabinets include the following items:
1. Tool chests and cabinets not prepackaged for retail sale
This includes all metal tool chests and cabinets, including top chests, intermediate chests, tool
cabinets and side cabinets, storage units, mobile work benches, and work stations and that have
the following physical characteristics:
(1) a body made of carbon, alloy, or stainless steel and/or other metals;
(2) two or more drawers for storage in each individual unit;
(3) a width (side to side) exceeding 15 inches for side cabinets and exceeding 21 inches for
all other individual units but not exceeding 60 inches;
(4) a depth (front to back) exceeding 10 inches but not exceeding 24 inches; and
(5) not prepackaged for retail sale.
2. Industrial tool chests and cabinets
The excluded industrial grade steel tool chests and cabinets are those:
(1) Having a body that is over 60 inches wide; or
(2) having each of the following physical characteristics:
(a) a body made of steel that is 0.047" or more in thickness;
(b) a body depth (front to back) exceeding 21 inches; and
(c) a unit weight that exceeds the maximum unit weight shown below for each
width range:
Weight to Width Ratio Tool Chests
Inches
Maximum Pounds
> 21 ≤25
90
> 25 ≤28
115
> 28 ≤30
120
> 30 ≤32
130
> 32 ≤34
140
> 34 ≤36
150
> 36 ≤38
160
> 38 ≤40
170
> 40 ≤42
180
> 42 ≤44
190
> 44 ≤46
200
> 46 ≤48
210
> 48 ≤50
220
> 50 ≤52
230
> 52 ≤54
240
> 54 ≤56
250
> 56 ≤58
260
> 58 ≤60
270

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Weight to Width Ratio Tool Cabinets
Inches
Maximum Pounds
> 21 ≤25
155
> 25 ≤28
170
> 28 ≤30
185
> 30 ≤32
200
> 32 ≤34
215
> 34 ≤36
230
> 36 ≤38
245
> 38 ≤40
260
> 40 ≤42
280
> 42 ≤44
290
> 44 ≤46
300
> 46 ≤48
310
> 48 ≤50
320
> 50 ≤52
330
> 52 ≤54
340
> 54 ≤56
350
> 56 ≤58
360
> 58 ≤60
370
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary,
in importing tool chests and cabinets (as defined above) into the United States from a foreign
manufacturer or through its selling agent.
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.

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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 Abu B. Kanu (202-205-2597,
[email protected]).

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets
I-1.

Page 8

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

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of tool chests and cabinets,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets
I-3a.

Ownership.-- Is your firm owned, in whole or in part, by any other firm? Please include any firms
that produced tool chests and cabinets not packaged for retail sale or industrial tool chests and
cabinets (“other tool chests and cabinets”).
No

Yes--List the following information

Firm name

I-3b.

Page 9

Address

Extent of
ownership
(percent)

Changes in ownership.-- Has your firm experienced any change in ownership since January 1,
2014?
No

Yes

Please provide details regarding the change in ownership include the names of the new owner
and previous owner, the date of the change in ownership, and the motivations for the change in
ownership.

I-3c.

Impact.--What is the impact of this change in ownership on your firm’s operations regarding inscope tool chests and cabinets and other tool chests and cabinets, e.g. (projected products,
brands owned or produced for, etc.)? Please respond separately regarding in-scope tool chests
and cabinets and other tool chests and cabinets.

I-3d.

Market outlook.—If your firm responded yes to question II-3, please provide any market
forecasts or other document relating to market outlook for in-scope tool chests and cabinets or
other tool chests and cabinets as an attachment to this questionnaire.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
I-4.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing tool chests and cabinets from China and Vietnam into the
United States or that are engaged in exporting tool chests and cabinets from China and Vietnam
to the United States? Please include any firms that produced tool chests and other tool chests
and cabinets.
No

Yes--List the following information.

Firm name

I-5.

Country

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of tool chests and cabinets? Please include any firms that produced
tool chests and other tool chests and cabinets.
No

Yes--List the following information.

Firm name

I-6.

Page 10

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on tool
chests and cabinets. More than one answer may be applicable.
Importer of record

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets
I-7.

Consignee.--If your firm is an importer of record of tool chests and cabinets but is not the
consignee, please list the consignees below (firm name, address, telephone number, and
individual to contact).

Firm name

I-8.

Page 11

Contact person
and phone
number

Address

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters tool chests and
cabinets into, or withdraws such merchandise from, foreign trade zones or bonded warehouses.
Also indicate whether your firm imports tool chests and cabinets under the TIB (temporary
importation under bond) program.
“Foreign trade zone” is a designated location in the United States where firms utilize special
procedures that allow delayed or reduced customs duty payments on foreign merchandise, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States(HTS).
No

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes–Please specify.

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Abu B. Kanu (202-205-2597,
[email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the importation of tool chests and cabinets since January 1, 2014.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-3.

Page 13

Arranged imports.--Has your firm imported or arranged for the importation of tool chests and
cabinets for delivery after September 30, 2017?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes–Fill out the table below.
Quantity (in units)

Period/Source

Oct-Dec 2017

Jan-Mar 2018

Apr-Jun 2018

Jul-Sep 2018

China
Vietnam
Other sources
II-4.

Reasons for importing if producer.--If your firm also produces tool chests and cabinets in the
United States, please indicate the reasons for importing this product. If your firm’s reasons differ
by source, please elaborate.

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial shipments”— Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Transfers for retail sale by your firm” –Tool chests and cabinets that were directly imported
by your firm for the purpose of sale to end users using your firm’s own retail establishments.
Report the shipment of these imports to their initial location for retail sale (i.e., as transfers)
with the shipments valued at fair market value.
“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.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-5a.

Page 15

Imports from China.–Report your firm’s imports and your firm’s shipments and inventories of
tool chests and cabinets imported from China by your firm during the specified periods.

China

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

2014

2015

January-September
2016

2016

2017

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial U.S. shipments:
To distributors:
Quantity (D)
Value (E)
To end users:
Quantity (F)
Value (G)
To unrelated retailers:
Quantity (H)
Value (I)
Transfers for retail sale by your firm:2
Quantity (J)
Value (K)
Internal consumption:2
Quantity (L)
Value2 (M)
Transfers to related firms:2
Quantity (N)
Value2 (O)
Export shipments:3
Quantity (P)
Value (Q)
End-of-period inventories (quantity) (R)
1

Please identify the foreign producers, if known:
.
Shipments destined for retail sale by your firm, sales to related firms, and internal consumption must be valued at fair market
value. In the event that your firm uses a different basis for valuing these sales within your company, please specify that basis (e.g.,
cost, cost plus, etc.) and provide value data using that basis for each of the periods noted above:
.
3
Identify your firm’s principal export markets:
.
2

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RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line R) should be equal to the beginning-of-period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, J, L, N, and P). 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
A+B–D–F–H–J–L–N–P–R =
should equal zero ("0") or provide an
explanation.1
1

2014

2015

0

January-September
2016

0

2016

0

2017

0

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

II-5b.

0
.

Monthly U.S. imports: China.-- Report your firm’s monthly U.S. imports of tool chests and
cabinets from China from January 2016 through September 2017.

China

U.S. imports
Year and month
2016.-January (AA)
February (AB)
March (AC)
April (AD)
May (AE)
June (AF)
July (AG)
August (AH)
September (AI)
October (AJ)
November (AK)
December (AL)
2017.-January (AA)
February (AB)
March (AC)
April (AD)
May (AE)
June (AF)
July (AG)
August (AH)
September (AI)

Quantity
(units)

Value
(1,000 dollars)

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U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-5c.

Page 17

U.S. shipments by product type: China.-- Report your firm’s U.S. shipments of tool chests and
cabinets by type of product made predominantly (i.e. body) of carbon steel and stainless steel
for calendar year 2016.

China

Quantity (in units) and value (in $1,000)
Calendar year 2016
Item

Carbon steel

Stainless steel

All steel types

U.S. shipments:
Prepackaged sets:
Quantity (S)

0

Value (T)

0

Top chests:
Quantity (U)

0

Value (V)

0

Intermediate chests:
Quantity (W)

0

Value (X)

0

Tool cabinets:
Quantity (Y)

0

Value (Z)

0

Side cabinets:
Quantity (AA)

0

Value (AB)

0
1

All other in-scope products:
Quantity (AC)

0

Value (AD)

0

1

Please identify these products (e.g. mobile work benches, work stations, metal storage units with two
or more drawers, etc.):
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
shipments by product type (i.e., lines S through AD) in each time period equal the quantities and values
reported for U.S. shipments in part a (i.e., D through O) 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.
Reconciliation

Calendar year 2016

Quantity: S + U + W + Y + AA + AC – D – F – H – J – L – N = zero ("0"),
if not revise.

0

Value: T + V + X + Z + AB + AD – E – G – I –K – M – O = zero ("0"), if
not revise.

0

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-6a.

Page 18

Imports from Vietnam.–Report your firm’s imports and your firm’s shipments and inventories of
tool chests and cabinets imported from Vietnam by your firm during the specified periods.

Vietnam

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

2014

2015

January-September
2016

2016

2017

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial U.S. shipments:
To distributors:
Quantity (D)
Value (E)
To end users:
Quantity (F)
Value (G)
To unrelated retailers:
Quantity (H)
Value (I)
Transfers for retail sale by your firm:2
Quantity (J)
Value (K)
Internal consumption:2
Quantity (L)
Value2 (M)
Transfers to related firms:2
Quantity (N)
Value2 (O)
Export shipments:3
Quantity (P)
Value (Q)
End-of-period inventories (quantity) (R)
1

Please identify the foreign producers, if known:
.
Shipments destined for retail sale by your firm, sales to related firms, and internal consumption must be valued at fair market
value. In the event that your firm uses a different basis for valuing these sales within your company, please specify that basis (e.g.,
cost, cost plus, etc.) and provide value data using that basis for each of the periods noted above:
.
3
Identify your firm’s principal export markets:
.
2

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 19

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line R) should be equal to the beginning-of-period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, J, L, N, and P). 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
A+B–D–F–H–J–L–N–P–R =
should equal zero ("0") or provide an
explanation.1
1

2014

2015

0

January-September
2016

0

2016

0

2017

0

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

II-6b.

0
.

Monthly U.S. imports: Vietnam.-- Report your firm’s monthly U.S. imports of tool chests and
cabinets from Vietnam from January 2016 through September 2017.

Vietnam

U.S. imports
Year and month
2016.-January (AA)
February (AB)
March (AC)
April (AD)
May (AE)
June (AF)
July (AG)
August (AH)
September (AI)
October (AJ)
November (AK)
December (AL)
2017.-January (AA)
February (AB)
March (AC)
April (AD)
May (AE)
June (AF)
July (AG)
August (AH)
September (AI)

Quantity
(units)

Value
(1,000 dollars)

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-6c.

Page 20

U.S. shipments by product type: Vietnam.-- Report your firm’s U.S. shipments of tool chests
and cabinets by type of product made predominantly (i.e. body) of carbon steel and stainless
steel for calendar year 2016.

Vietnam

Quantity (in units) and value (in $1,000)
Calendar year 2016
Item

Carbon steel

Stainless steel

All steel types

U.S. shipments:
Prepackaged sets:
Quantity (S)

0

Value (T)

0

Top chests:
Quantity (U)

0

Value (V)

0

Intermediate chests:
Quantity (W)

0

Value (X)

0

Tool cabinets:
Quantity (Y)

0

Value (Z)

0

Side cabinets:
Quantity (AA)

0

Value (AB)

0
1

All other in-scope products:
Quantity (AC)

0

Value (AD)

0

1

Please identify these products (e.g. mobile work benches, work stations, metal storage units with two
or more drawers, etc.):
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
shipments by product type (i.e., lines S through AD) in each time period equal the quantities and values
reported for U.S. shipments in part a (i.e., D through O) 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.
Reconciliation

Calendar year 2016

Quantity: S + U + W + Y + AA + AC – D – F – H – J – L – N = zero ("0"),
if not revise.

0

Value: T + V + X + Z + AB + AD – E – G – I –K – M – O = zero ("0"), if
not revise.

0

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-7

Page 21

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of tool chests and cabinets imported from all other sources by your firm during the
specified periods.

All other sources

(list sources:

)
Quantity (in units), value (in $1,000)
Calendar years

Item

2014

2015

January-September
2016

2016

2017

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial U.S. shipments:
To distributors:
Quantity (D)
Value (E)
To end users:
Quantity (F)
Value (G)
To unrelated retailers:
Quantity (H)
Value (I)
Transfers for retail sale by your firm:2
Quantity (J)
Value (K)
Internal consumption:2
Quantity (L)
Value2 (M)
Transfers to related firms:2
Quantity (N)
Value2 (O)
Export shipments:3
Quantity (P)
Value (Q)
End-of-period inventories (quantity) (R)
1

Please identify the foreign producers, if known:
.
Shipments destined for retail sale by your firm, sales to related firms, and internal consumption must be valued at fair market
value. In the event that your firm uses a different basis for valuing these sales within your company, please specify that basis (e.g.,
cost, cost plus, etc.) and provide value data using that basis for each of the periods noted above:
.
3
Identify your firm’s principal export markets:
.
2

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 22

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line R) should be equal to the beginning-of-period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, J, L, N, and P). 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
A+B–D–F–H–J–L–N–P–R =
should equal zero ("0") or provide an
explanation.1
1

2014

2015

0

January-September
2016

0

2016

0

2017

0

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

II-7b.

0
.

Monthly U.S. imports: All other sources.-- Report your firm’s monthly U.S. imports of tool
chests and cabinets from all other sources from January 2016 through September 2017.

All other sources

U.S. imports
Year and month
2016.-January (AA)
February (AB)
March (AC)
April (AD)
May (AE)
June (AF)
July (AG)
August (AH)
September (AI)
October (AJ)
November (AK)
December (AL)
2017.-January (AA)
February (AB)
March (AC)
April (AD)
May (AE)
June (AF)
July (AG)
August (AH)
September (AI)

Quantity
(units)

Value
(1,000 dollars)

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-7c.

Page 23

U.S. shipments by product type: All other sources.-- Report your firm’s U.S. shipments of tool
chests and cabinets by type of product made predominantly (i.e. body) of carbon steel and
stainless steel for calendar year 2016.

All other sources

Quantity (in units) and value (in $1,000)
Calendar year 2016
Item

Carbon steel

Stainless steel

All steel types

U.S. shipments:
Prepackaged sets:
Quantity (S)

0

Value (T)

0

Top chests:
Quantity (U)

0

Value (V)

0

Intermediate chests:
Quantity (W)

0

Value (X)

0

Tool cabinets:
Quantity (Y)

0

Value (Z)

0

Side cabinets:
Quantity (AA)

0

Value (AB)

0
1

All other in-scope products:
Quantity (AC)

0

Value (AD)

0

1

Please identify these products (e.g. mobile work benches, work stations, metal storage units with two
or more drawers, etc.):
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
shipments by product type (i.e., lines S through AD) in each time period equal the quantities and values
reported for U.S. shipments in part a (i.e., D through O) 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.
Reconciliation

Calendar year 2016

Quantity: S + U + W + Y + AA + AC – D – F – H – J – L – N = zero ("0"),
if not revise.

0

Value: T + V + X + Z + AB + AD – E – G – I –K – M – O = zero ("0"), if
not revise.

0

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
II-8.

Page 24

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

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 25

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (303-2053250, [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
Fax

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 26

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2014 of the following products your firm imported
from China and Vietnam:

Product 1.--26-27 inch wide top chest sold in combination with a 26-27 inch wide rolling cabinet, each
with a body of cold-rolled carbon steel, having 9 to 10 total drawers (across both units) with ball
bearing drawer slides, a minimum chest depth (front to back) of 15 inches, a minimum cabinet
depth of 18 inches and a combined unit weight (not shipping weight) of 150 to 180 lbs.
Product 2.--40-46 inch wide top chest sold in combination with a 40-46 inch wide rolling cabinet, each
with a body of cold-rolled carbon steel, having 16 to 21 drawers (across both units) with ball
bearing slides, a chest depth of and cabinet depth of 16 to 19 inches; and combined unit weight
(not shipping weight) of less than 420 lbs.
Product 3.--45 to 56 inch wide workstation or mobile workbench, with a body of cold-rolled carbon
steel, having 8 to 11 drawers or doors with ball bearing slides, a top work surface, a unit depth
of 17-24 inches, and a unit weight (not shipping weight) of less than 175 lbs. This category
specifically excludes work stations or mobile workbenches in which the body is made of stainless
steel but includes tool chests and cabinets in which the drawers or door fronts are made of
stainless steel.
Product 4.--45 to 56 inch wide workstation or mobile workbench, with a body of cold-rolled carbon
steel, having 8 to 11 drawers or doors with ball bearing slides, a top work surface, a unit depth
of 17-24 inches, and a unit weight (not shipping weight) of less than 175 lbs. This category
specifically excludes work stations or mobile workbenches in which the body is made of stainless
steel but includes tool chests and cabinets in which the drawers or door fronts are made of
stainless steel. Do not include workstation or mobile workbench sold with tools, stereos, or
refrigerators.
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).
During January 2014-September 2017, did your firm import from China and/or Vietnam and sell
to unrelated U.S. nonretail customers any of the above listed products (or any products that
were competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-2d.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 27

III-2a. Price data.--Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.

China

Report data in actual units and actual dollars (not 1,000s).

Product 1
Quantity
Value

(Quantity in units, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

Product 4
Period of shipment
Quantity
Value
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
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 III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 28

III-2b. Price data.--Report below the quarterly price data1 for pricing products2 imported from Vietnam
and sold by your firm.

Vietnam

Report data in actual units and actual dollars (not 1,000s).
Product 1
Quantity
Value

(Quantity in units, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

Period of shipment
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
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 III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
III-2c.

Page 29

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.
III-2d. Imports for retail/own use. –During January 2014-December 2016, did your firm import any of
the products listed at III-2 from China and/or Vietnam for retail/own use.
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question III-2h.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 30

III-2e. Imports for retail/own use.--Report below the import data1 for pricing products2 imported from
China and used for sales in your firm’s retail locations or internally consumed.

China

Report data in actual units and actual dollars (not 1,000s).
(Quantity in units, LDP value in dollars)
Product 1
Quantity
Value

Product 2
Product 3
Product 4
Period of shipment
Quantity
Value
Quantity
Value
Quantity
Value
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
1
LDP value (i.e., landed duty-paid values) represents the cost paid to foreign supplier(s) plus any freight and insurance costs paid for
international transportation as well as all Customs duties and fees. LDP value represents the f.o.b. value of your firm’s imports at the U.S. port
of entry after clearing Customs.
2
Pricing product definitions are provided on the first page of Part III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
III-2f.

Page 31

Imports for retail/own use.--Report below the import data1 for pricing products2 imported from
Vietnam and used for sales in your firm’s retail locations or internally consumed.

Vietnam

Report data in actual units and actual dollars (not 1,000s).
(Quantity in units, LDP value in dollars)
Product 1
Quantity
Value

Product 2
Product 3
Product 4
Period of shipment
Quantity
Value
Quantity
Value
Quantity
Value
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
1
LDP value (i.e., landed duty-paid values) represents the cost paid to foreign supplier(s) plus any freight and insurance costs paid for
international transportation as well as all Customs duties and fees. LDP value represents the f.o.b. value of your firm’s imports at the U.S. port
of entry after clearing Customs.
2
Pricing product definitions are provided on the first page of Part III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 32

III-2g. Additional costs for your direct imports of tool chests and cabinets for your firm’s retail/own
use.
(i) If your firm reported direct import purchase costs (questions III-2e, and/or 2f), please identify
the factors that add to your cost of importing directly since January 1, 2014, estimate the share
of the cost of the landed duty paid value, and explain the specific costs associated with each
category.

Factors
Logistical or supply chain costs
Warehousing costs
Currency conversion costs
Other

Estimated share of landed
duty paid value
(percent)

Explanation

(ii) To which source does your firm compare costs in determining your additional transaction costs
to directly import?
U.S. importers

(iii)

U.S. producers

Both

Neither

(A) If your firm reported data above (question III-2e and/or 2f), briefly identify the benefits
of directly importing tool chests and cabinets instead of purchasing tool chests and cabinets
from a U.S. importer or from a U.S. producer.

(B) Please provide the estimated margin saved by having directly imported tool chests and
cabinets instead of purchasing from a U.S. importer:
percent of landed duty-paid
value.
(C) Explain any variation in the margin saved since January 1, 2014.

(iv)

What is the approximate percentage of the total cost of tool chests and cabinets you
directly imported from China and Vietnam that is accounted for by U.S. inland
transportation or other logistics costs from the port of importation to your distribution
network or retail store?
Country

Percent

China

%

Vietnam

%

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 33

III-2h. Product specifications.--If your firm provided pricing information please report their
characteristics in the following table. If you sold different SKUs under any individual pricing
product, report the characteristics of the most common SKU you sold within that pricing
product.
Item
The product in question included only one
SKU?

Product 1
Yes

No

Product 2
Yes

No

Product 3
Yes

No

Product 4
Yes

No

If you answered "no" above, please estimate
the percent share that the largest SKU (as
described below) accounted for of product in
question

Overall cabinet and chest (or for product 4, work station/bench)
Largest SKU reported in
Item

Product 1

Product 2

Product 3

Product 4

Cabinet width (inches)
Cabinet height (inches)
Cabinet depth (inches)
Cabinet total weight capacity (pounds)
Chest width (inches)
Chest height (inches)
Chest depth (inches)
Chest total weight capacity(pounds)
Combined unit weight(pounds)
Steel thickness (inches)

Paint
Largest SKU reported in
Item

Product 1

Product 2

Product 3

Product 4

Electric coat (check = yes)
Powder coat (check = yes)
Number of colors available

Casters/wheels
Largest SKU reported in
Item
Size of casters/wheels (inches)

Product 1

Product 2

Product 3

Product 4

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 34

III-2h. Product specifications.--Continued
Drawers
Largest SKU reported in
Item

Product 1

Product 2

Product 3

Product 4

Total number of drawers
Each drawer supports (pounds)
Number of ball bearings per glide
Type of drawer latching mechanism
Soft closing drawer slides (check = yes)
Drawer liners included (check = yes)
Drawer support brackets (check = yes)

Construction factors
Largest SKU reported in
Item

Product 1

Product 2

Product 3

Product 4

Double wall construction (check = yes)
Seamless construction (check = yes)
Roll formed inner panels (check = yes)
Reinforced inner panels (check = yes)
Gas struts for lid (check = yes)
Stainless steel hinges (check = yes)
Uses aluminum rivets (check = yes)
Add-ons

Largest SKU reported in
Item

Product 1

Includes power strip
Includes USB port(s)
Includes Bluetooth enabled electronic locking
Other (please describe)

Other clarifications regarding product specifications.--.

Product 2

Product 3

Product 4

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 35

III-2i.

If your firm is a direct importer for retail sales or your own use please check here
question III-11.

III-3.

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

III-4.

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for tool chests and cabinets imported from
China and Vietnam?
Net 30
days

(b)

Net 60
days

2/10 net 30
days

Other

Other (specify)

On what basis are your firm’s prices of imported tool chests and cabinets from China
and Vietnam usually quoted (check one)?
Delivered

III-6.

Other

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

Quantity
discounts

III-5.

Contracts

Set
price
lists

and skip to

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of tool chests and cabinets
imported from China and Vietnam in 2016 was on a wholesale (1) long-term contract basis,
(2) annual contract basis, (3) short-term contract basis, (4) spot sales basis or on a retail basis?

Share of 2016
sales

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

Type of sale
Annual
contracts
(multiple
deliveries for
12 months)

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

Spot sales
(for a single
delivery)

%

%

%

Total (should
sum to
100.0%)
0.0

%

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
III-7.

Page 36

Contract provisions.—Please fill out the table regarding your firm’s typical sales contracts for
tool chests and cabinets from China and Vietnam (or check “not applicable” if your firm does not
sell on a long-term, short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price
Meet or release
provision

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

Annual contracts
(multiple deliveries
for 12 months)

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

365

No
Quantity
Price
Both
Yes
No

Not applicable
III-8.

Lead times.--What is your firm’s share of sales of tool chests and cabinets imported from China
and Vietnam from inventory and produced to order and what is the typical lead time between a
customer’s order and the date of delivery for your firm’s sales of tool chests and cabinets?

Source

Share of 2016
sales

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Lead time
(average number
of days)

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
III-9.

Page 37

Shipping information.—
(a)

What is the approximate percentage of the total delivered cost of tool chests and
cabinets imported from China and Vietnam 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)

When your firm sells tool chests and cabinets imported from China and Vietnam, from
where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of tool chests and cabinets
imported from China and Vietnam that are delivered the following distances from your
firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold tool chests
and cabinets imported from subject countries since January 1, 2014 (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.

China

Vietnam

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 38

III-11. End uses.--List the end uses of the tool chests and cabinets that your firm imports from China
and Vietnam.
End uses for tool chests and cabinets
1
2
3
III-12. Substitutes.--Can other products be substituted for tool chests and cabinets?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

Have changes in the price of this substitute
affected the price for tool chests and
cabinets?
No Yes

Explanation

1.
2.
3.
III-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for tool chests and cabinets has changed since January 1, 2014. Explain any
trends and describe the principal factors that have affected these changes in demand.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within the United States
Outside the United States

III-14. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of tool chests and cabinets since January 1, 2014?
No

Yes

If yes, please describe.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 39

III-15. Conditions of competition.—
(a) Is the tool chests and cabinets market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to tool chests
and cabinets?
Check all that apply.

Please describe.

No

Skip to question III-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
tool chests and cabinets since January 1, 2014?
No

Yes

If yes, describe.

(c) Have financial dificutlies of any particularly large retailer (e.g., Sears, other) affected your
firms tool chests and cabenets business?
No

Yes

If yes, describe.

(d) Have changes to the brick and mortar retail sector and increases in online retail affected
your firm's tool chests and cabinets business?
No

Yes

If yes, describe.

III-16. Supply constraints.--Has your firm refused, declined, or been unable to supply tool chests and
cabinets since January 1, 2014 (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, been unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 40

III-17. Customer preferences.--Have customers requested customizations or product specifications of
specific tool chests and cabinets that your firm has been unable or unwilling to provide since
January 1, 2014?
No

Yes

If yes, please describe.

III-18. Raw materials.--How have tool chests and cabinets raw material prices changed since January 1,
2014?
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 tool
chests and cabinets.

III-19. Brands.-(a) Please list the top 5 brands of tool chests and cabinets that your firm imports.

(b) Please list what purchasers require for your firm to be eligible to import for a new brand
for a purchaser.

(c) Please estimate the number of days it would take for your firm to become eligible to
import a new brand.
to

days

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 41

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

China

Vietnam

Other countries

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

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 42

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

China

Vietnam

Other countries

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

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 43

III-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for tool chests and cabinets since January 1, 2014. Indicate the share of the quantity
of your firm’s total shipments of tool chests and cabinets that each of these customers
accounted for in 2016.

Customer’s name

City

State

Share of 2016 sales (%)

1
2
3
4
5
6
7
8
9
10

III-23. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 44

PART IV – PURCHASING FACTORS
IV-1.

If your firm is not an importer for retail sales or your own use then please check here
question IV-2.

skip

IV-2.

If your firm is a retailer please check here
and fill out a purchaser questionnaire available at:
https://www.usitc.gov/investigations/701731/2017/tool_chests_and_cabinets_china_and_vietn
am/final.htm. In the purchaser questionnaire you may skip the questions that do not apply to
you because you are a retailer and you may also skip any question you have already responded
to in the importer questionnaire.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 45

PART V – ALTERNATIVE PRODUCT
Other tool chests and cabinets include the following items:

1. Tool chests and cabinets not prepackaged for retail sale.
This includes all metal tool chests and cabinets, including top chests, intermediate chests, tool
cabinets and side cabinets, storage units, mobile work benches, and work stations and that have
the following physical characteristics:
(1) a body made of carbon, alloy, or stainless steel and/or other metals;
(2) two or more drawers for storage in each individual unit;
(3) a width (side to side) exceeding 15 inches for side cabinets and exceeding 21 inches for
all other individual units but not exceeding 60 inches;
(4) a depth (front to back) exceeding 1 0 inches but not exceeding 24 inches; and
(5) not prepackaged for retail sale.
2. Industrial tool chests and cabinets.
The excluded industrial grade steel tool chests and cabinets are those:
(1) Having a body that is over 60 inches wide; or
(2) having each of the following physical characteristics:
(a) a body made of steel that is 0.047" or more in thickness;
(b) a body depth (front to back) exceeding 21 inches; and
(c) a unit weight that exceeds the maximum unit weight shown below for each
width range:
Weight to Width Ratio Tool Chests
Inches
Maximum Pounds
> 21 ≤25
90
> 25 ≤28
115
> 28 ≤30
120
> 30 ≤32
130
> 32 ≤34
140
> 34 ≤36
150
> 36 ≤38
160
> 38 ≤40
170
> 40 ≤42
180
> 42 ≤44
190
> 44 ≤46
200
> 46 ≤48
210
> 48 ≤50
220
> 50 ≤52
230
> 52 ≤54
240
> 54 ≤56
250
> 56 ≤58
260
> 58 ≤60
270

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
Weight to Width Ratio Tool Cabinets
Inches
Maximum Pounds
> 21 ≤25
155
> 25 ≤28
170
> 28 ≤30
185
> 30 ≤32
200
> 32 ≤34
215
> 34 ≤36
230
> 36 ≤38
245
> 38 ≤40
260
> 40 ≤42
280
> 42 ≤44
290
> 44 ≤46
300
> 46 ≤48
310
> 48 ≤50
320
> 50 ≤52
330
> 52 ≤54
340
> 54 ≤56
350
> 56 ≤58
360
> 58 ≤60
370

Page 46

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
V-1.

Page 47

Comparability of in-scope tool chests and cabinets to out-of-scope other tool chests and
cabinets -- For each of the following factors, indicate whether in-scope tool chest and cabinets
compared to select out-of-scope products are:
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and Uses.--The differences and similarities in the physical
characteristics and end uses.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:

In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets
(b) Interchangeability.--The ability to substitute the products in the in the same application.

Product-pair
In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
V-1.

Page 48

Comparability of in-scope tool chests and cabinets to select out-of-scope products--Continued
(c) Manufacturing facilities, production processes, and production employees.--Whether the
products are manufactured in the same facilities, from the same inputs, on the same
machinery and equipment, and using the same employees.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:

In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets
(d) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).

Product-pair
In-scope tool chests and
cabinets vs out-of-scope other
tool chests and cabinets

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
V-1.

Page 49

Comparability of in-scope tool chests and cabinets to select out-of-scope products--Continued
(e) Customer and producer perceptions.--Perceptions as to the differences and/or similarities
in the products in the market (e.g., sales/marketing practices).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and producer perceptions:

In-scope tool chests and
cabinets vs other tool chests
and cabinets
(f) Price.--Whether prices are comparable or differ between the products.

Product-pair
In-scope tool chests and
cabinets vs other tool chests
and cabinets

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
prices:

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
V-2a.

Page 50

Imports from all sources.–Report your firm’s imports and your firm’s shipments and inventories
of other tool chests imported from all foreign sources by your firm during the specified periods.

All sources

(list sources:

)
Quantity (in units), value (in $1,000)
Calendar years

Item

2014

2015

January-September
2016

2016

2017

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial U.S. shipments:
To distributors:
Quantity (D)
Value (E)
To end users:
Quantity (F)
Value (G)
To unrelated retailers:
Quantity (H)
Value (I)
Transfers for retail sale by your firm:2
Quantity (J)
Value (K)
Internal consumption:2
Quantity (L)
Value2 (M)
Transfers to related firms:2
Quantity (N)
Value2 (O)
Export shipments:3
Quantity (P)
Value (Q)
End-of-period inventories (quantity) (R)
1

Please identify the foreign producers, if known:
.
Shipments destined for retail sale by your firm, sales to related firms, and internal consumption must be valued at fair market
value. In the event that your firm uses a different basis for valuing these sales within your company, please specify that basis (e.g.,
3
Identify your firm’s
cost, cost plus, etc.) and provide value data using that basis for each of the periods noted above:
principal export markets:
.
2

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
V-2a.

Page 51

Imports from all sources.--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line R) should be equal to the beginning-of-period inventories (i.e., line A),
plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, J, L, N, and P). 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

2014

2015

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

January-September
2016

0

2016

0

0

2017

0

0

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

V-2b.

.

U.S. shipments data by product category.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, transfers for retail sale by your own firm, internal consumption, and
transfer to related parties) of imports of other tool chest and cabinets from all sources by
product category.

Items
U.S shipments:
Tool chests and cabinets not
prepackaged for retail sale:
Quantity (S)
Value (T)
Other:
Quantity (U)
Value (V)

Calendar Years
2015

2014

January-September
2015
2016

2016

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
shipments by product category (i.e., lines S through V) in each time period equal the quantities and
values reported for U.S. shipments in table V-2a (i.e., D through O) 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

2014

2015

January-September
2016

2016

2017

Quantity: S + U –D -F – H – J – L - N =
should equal zero ("0") or provide
an explanation.1

0

0

0

0

0

Value: T + V –E -G – I – K – M - O =
should equal zero ("0") or provide
an explanation.1

0

0

0

0

0

1

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

.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets
V-3.

Page 52

U.S. shipments by product type.--Report your firm’s U.S. shipments of other tool chests and
cabinets by type of product made predominantly (i.e., body) of carbon steel and stainless steel
for calendar year 2016.

Other tool chests and cabinets
Quantity (in units) and value (in $1,000)
Calendar year 2016
Item

Carbon steel

Stainless steel

All steel types

U.S. shipments:
Prepackaged sets:
Quantity (W)

0

Value (X)

0

Top chests:
Quantity (AA)

0

Value (AB)

0

Intermediate chests:
Quantity (AC)

0

Value (AD)

0

Tool cabinets:
Quantity (AE)

0

Value (AF)

0

Side cabinets:
Quantity (AG)

0

Value (AH)

0

1

Others:
Quantity (AI)

0

Value (AJ)

0

1

Please identify these products:

.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
shipments by product type (i.e., lines W through AJ) in each time period equal the quantities and values
reported for U.S. shipments in table V-a2 (i.e., D through O) 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.
Reconciliation

Calendar year 2016

Quantity: W + Y + AA + AC +AE + AG + AI – D – F – H – J – L – N = zero
("0"), if not revise.

0

Value: X + Z + AB + AD + AF + AH + AJ – E – G – I –K – M – O = zero
("0"), if not revise.

0

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 53

Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than
one. Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.

Business Proprietary
U.S. Importers’ Questionnaire - Tool Chests and Cabinets

Page 54

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/701731/2017/tool_chests_and_cabinets_china_a
nd_vietnam/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: TOOL

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