Form 17-1-3765 US producers' questionnaire

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

US producers--PET Resin (P)

Polyethylene terephthalate (PET) resin from Brazil, Indonesia, Korea, Pakistan, and Taiwan (731-TA-1387-1391)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 17-1-3765; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
POLYETHYLENE TEREPHTHALATE RESIN FROM BRAZIL, INDONESIA, KOREA,
PAKISTAN, AND TAIWAN
This questionnaire must be received by the Commission by October 10, 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 antidumping investigations concerning polyethylene terephthalate resin (“PET resin”) from Brazil,
Indonesia, Korea, Pakistan, and Taiwan (Inv. Nos. 731-TA-1387-1391 (Preliminary)). 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 PET Resin (as defined on next page) 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: PETR)
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. Producers’ Questionnaire –PET resin

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on September 26, 2017, by
DAK Americas LLC, Charlotte, NC; Indorama Ventures USA, Inc., Decatur, AL; M&G Polymers USA, LLC,
Houston, TX; and Nan Ya Plastics Corporation, America Lake City, SC. 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 dumping. Questionnaires and other
information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2017/polyethylene_terephthalate_resin_brazil_indonesia/prel
iminary.htm
PET resin covered by these investigations is polyethylene terephthalate (PET) resin having an intrinsic
viscosity of at least 70, but not more than 88, milliliters per gram (0.70 to 0.88 deciliters per gram). The
scope includes blends of virgin PET resin and recycled PET resin containing 50 percent or more virgin
PET resin content by weight, provided such blends meet the intrinsic viscosity requirements above. The
scope includes all PET resin meeting the above specifications regardless of additives introduced in the
manufacturing process.
PET resin is currently imported under statistical reporting numbers 3907.61.0000 and 3907.69.0000 of
the Harmonized Tariff Schedule of the United States (HTSUS). Prior to January 1, 2017, PET resin was
imported under statistical reporting number 3907.60.0030. 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.
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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of PET Resin and your responses to the questions in Part I of

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U.S. Producers’ Questionnaire – PET resin

Page 3

the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
I-1a.

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

Dollars

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

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

No

Business Proprietary
U.S. Producers’ Questionnaire – PET resin
I-2.

Page 4

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 PET resin, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

I-3.

Additional discussion on establishments consolidated in this questionnaire:

.

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

Brazil
Indonesia
Korea
Pakistan
Taiwan

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire – PET resin
I-4.

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

Firm name

I-5.

Page 5

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 PET resin from Brazil, Indonesia, Korea, Pakistan, and
Taiwan into the United States or that are engaged in exporting PET resin from Brazil, Indonesia,
Korea, Pakistan, and Taiwan to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – PET resin
I-6.

Page 6

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – PET resin

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Calvin Chang (202-2053062, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the
following changes in relation to the production of PET resin since January 1, 2014.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

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U.S. Producers’ Questionnaire – PET resin
II-3a.

Page 8

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce PET resin, and the combined production
capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready
to operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in 1,000 pounds)
Calendar years
Item

2014

2015

January-June
2016

2016

2017

Overall production capacity
Production of:
PET resin1
Other products
Total
1
2

0

0

0

0

0

0

0

0

0

0

2

Data entered for production of PET resin will populate here once reported in question II-7.
Please identify these products:
.

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on operating
hours per week,
weeks per year.

II-3c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.

II-3d.

Hot fill PET resin production. – What percentage of your firm’s total PET resin production was
hot fill PET resin in 2016?
percent.

II-3e.

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

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U.S. Producers’ Questionnaire – PET resin
II-3f.

Page 9

Product shifting.—
(i)

Is your firm able to switch production (capacity) between PET resin and other products
using the same equipment and/or labor?
No

(ii)

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

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

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U.S. Producers’ Questionnaire – PET resin
II-4.

Page 10

Tolling.--Since January 1, 2014, has your firm been involved in a toll agreement regarding the
production of PET resin?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

II-5.

Yes

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

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

(a)

“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.

No

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

(b)

No

II-6.

Yes

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, 2014, has your firm imported PET resin?
“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

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U.S. Producers’ Questionnaire – PET resin
II-7.

Page 11

Production, shipment, and inventory data.--Report your firm’s production capacity,
production, shipments, and inventories related to the production of PET resin in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready
to operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –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.

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. Producers’ Questionnaire – PET resin
II-7.

Page 12

Production, shipment, and inventory data.--Continued
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item

2014

2015

January-June
2016

2016

2017

1

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)

2

2

Value (G)
Transfers to related firms:
Quantity (H)

2

2

Value (I)
Export shipments:
Quantity (J)

3

Value (K)
End-of-period inventories (quantity) (L)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, 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:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod 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

2014

2015

0

January-June
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:

0
.

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U.S. Producers’ Questionnaire – PET resin
II-8.

Page 13

Channels of distribution.--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.
Quantity (in 1,000 pounds)
Calendar years
Item

2014

2015

January-June
2016

2016

2017

Channels of distribution:
U.S. shipments:
To distributors (quantity) (M)
To end users.Bottle producers (N)
Carpeting manufacturers
(O)
Sheet, packaging, and
strapping manufacturers (P)
Other end users1 (Q)
1

Please describe the other end users.

.

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M through Q) 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 + O + P + Q – D – F – H = zero
("0"), if not revise.

2014

2015
0

January-June
2016

0

2016
0

2017
0

0

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U.S. Producers’ Questionnaire – PET resin
II-9.

Page 14

Employment data.--Report your firm’s employment-related data related to the production of
PET resin 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, regardless of whether the interim
periods are Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).
“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, oldage 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

2014

2015

January-June
2016

2016

2017

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

II-10.

Related firms.--If your firm reported transfers to related firms in question II-7, 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 nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

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U.S. Producers’ Questionnaire – PET resin
II-11.

Page 15

Purchases.--Other than direct imports, has your firm otherwise purchased PET resin since
January 1, 2014?
“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.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer
of record or consignee.
No

Yes--Report such purchases below and explain the reasons for your firms'
purchases:

(Quantity in 1,000 pounds)
Calendar years
Item

2014

2015

January-June
2016

2016

2017

Purchases from U.S.
importers1 of PET resin fromBrazil
Indonesia
Korea
Pakistan
Taiwan
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:
.

Business Proprietary
U.S. Producers’ Questionnaire – PET resin
II-11.

Purchases.—Continued
(b)

Do any of the data reported in questions II-7 (production, shipments, and inventories)
or question III-9a (Operations on certain PET resin) include data sourced from the
purchases reported above?
No

II-12.

Page 16

Yes—PLEASE REVISE the data in questions II-7 and III-9a to exclude
data for resales of PET resin not produced by your firm prior
to submission of this questionnaire response to the
Commission.

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

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U.S. Producers’ Questionnaire – PET resin

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, [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

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 PET resin:

2.
3.

4.

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

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

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U.S. Producers’ Questionnaire – PET resin

Page 18

III-3.

Cost accounting system/Inventories.--Briefly describe your firm’s cost accounting system (e.g.,
standard cost, job order cost) and your firm’s basis for valuing raw material inventories (e.g.,
FIFO, LIFO, weighted average) related to PET resin operations, as well as the average number of
weeks of MEG and PTA inventories maintained for normal operations.

III-4.

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

III-5.

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

Share of sales
%
%
%
%
%

Business Proprietary
U.S. Producers’ Questionnaire – PET resin
III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of PET resin from any related sources (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)?
Yes--Continue to question III-7.

III-7.

Page 19

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of PET resin
that your firm purchases from related sources and that are reflected in question III-9a. For
“Share of total COGS” please report this information by relevant input on the basis of your
most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input

Related supplier

Share of total COGS

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

III-8.

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related sources, as identified in III-7, were reported in III-9a (financial results on PET resin) in a
manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III-9a.

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U.S. Producers’ Questionnaire – PET resin

Page 20

III-9a. Operations on PET resin.--Report the revenue and related cost information requested below
on the PET resin 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 sources should be consistent with and based
on information in the firm’s accounting books and records. Provide data for your firm’s three
most recently completed fiscal years, and for the specified interim periods.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended-Item

2014

2015

January-June

2016

2016

2017

2

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

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials

3

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
1

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

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

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III-9b. Raw materials for PET resin.--Please indicate the share of total raw material costs reported in
III-9a in 2016 for the following raw material inputs:

Products
PTA
MEG
Other1
Total (should sum to 100 percent)

Share of total raw
material costs
(percent)
%
%
%
0.0 %

1

Please indicate any other notable "other" raw materials not expressly identified above
and provide the share of the total raw material costs that they account for:

III-9c.

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

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

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U.S. Producers’ Questionnaire – PET resin

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III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a,
please specify all material (significant) nonrecurring items (charges and gains) in the schedule
below, the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to
question III-9a, only the allocated value amount included in question III-9a should be reported
in the schedule below. Note: The Commission’s objective here is to gather information only
on material (significant) nonrecurring items which impacted the reported financial results of
the subject product in question III-9a.
Fiscal years ended--

2014

2015

January-June

2016

2016

2017

Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in question III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
Value ($1,000)
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

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

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III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of PET resin. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for PET resin in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9a. Provide data
as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

III-13.

2014

2015

2016

1

Describe

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

2014

2015

January-June

2016

2016

2017

1
2

Research and development expenses
1

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

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

Fiscal year

Specify fiscal year

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

2014

2015

Partial year periods
2016

2016

2017

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

0

0

0

0

0

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

0

0

0

0

0

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

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 25

If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2014, 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 PET resin from Brazil, Indonesia, Korea, Pakistan, and Taiwan?
No

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)

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

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III-16. Effects of imports on growth and development.--Since January 1, 2014, 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 PET resin from Brazil, Indonesia,
Korea, Pakistan, and Taiwan?
No

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)

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 27

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports
of PET resin from Brazil, Indonesia, Korea, Pakistan, and Taiwan?
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 that did not provide a narrative 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. Producers’ Questionnaire – PET resin

Page 28

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Joanne Guth (202-2053264, [email protected]).
IV-1.

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

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, 2014 of the following products produced by your
firm.
Product 1.--PET resin, being either a clear homo- or co-polymer, and having an intrinsic
viscosity of 0.72 IV to 0.84 IV, in the solid stated form. This PET resin product is
typically used in water bottle applications.
Product 2.--PET resin, being either a clear homo- or co-polymer, and having an intrinsic
viscosity of 0.72 IV to 0.84 IV, in the solid stated form. This PET resin product is
typically used in sheet and strapping.
Product 3.--PET resin, being either a clear homo- or co-polymer, and having an intrinsic
viscosity of 0.78 IV to 0.86 IV, in the solid stated form. This PET resin product is
typically used in carbonated soft drink applications.
Product 4.--PET resin, being mainly a co-polymer, and having an intrinsic viscosity of 0.75 IV to
0.86 IV, in the solid stated form. This PET resin product is typically used in heat set
or hot fill applications; food, household, and other products.

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-2 (a). During January 2014-June 2017, 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.

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 29

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

(Quantity in pounds, 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
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:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

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

√ if Yes

In actual dollars (not $1,000)?
In actual pounds (not 1,000 of pounds)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-2 (d). 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.

Business Proprietary
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Page 31

IV-3a. Price setting.-- How does your firm determine the prices that it charges for sales of PET resin
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction

Set
price
lists

Contracts

Other

If other, describe

IV-3b. Do your firm’s contracts set prices based on a comparison to raw material costs or raw material
price indexes?
No

IV-4.

If yes, please briefly describe each pricing mechanism

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

Quantity
discounts

IV-5.

Yes

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced PET resin?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic PET resin usually quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – PET resin
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced PET
resin in 2016 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?

Share of 2016
sales
IV-7.

Page 32

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced PET resin (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
Not applicable

No
Quantity
Price
Both
Yes
No

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 – PET resin
IV-8.

Page 33

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

Share of 2016
sales

Source
From inventory

%

Produced to order

%

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

Lead time
(Average number
of days)

0.0 %

Shipping information.-(a)

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

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced PET resin 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.

√ if applicable

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 34

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

PET resin

Other inputs

Total
(should sum to
100.0% across)

Bottled water/soda.-Excluding liquid
contents (e.g., just
the bottle)

%

%

0.0 %

Inclusive of liquid
contents (e.g., final
bottled product)

%

%

0.0 %

Carpet

%

%

0.0 %

Roll of PET sheet

%

%

0.0 %

PET strapping

%

%

0.0 %

Other:

%

%

0.0 %

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

Substitute
1.
2.
3.

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 PET resin?
No Yes

Explanation

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U.S. Producers’ Questionnaire – PET resin

Page 35

IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for PET resin 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:
Overall demand
Bottler sector
All other sectors
Outside the United States

IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of PET resin since January 1, 2014?
No

Yes

If yes, please describe and quantify if possible.

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

Please describe.

No

Skip to question IV-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition
for PET resin since January 1, 2014?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply PET resin since
January 1, 2014 (examples include placing customers on allocation or “controlled order entry,”

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 36

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 PET resin 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 PET
resin.

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 37

IV-18. Interchangeability.--Is PET resin 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
Countrypair

Brazil

Indonesia

Korea

Pakistan

Taiwan

Canada Mexico

Other
countries

United
States
Brazil
Indonesia
Korea
Pakistan
Taiwan
Canada
Mexico
For any country-pair producing PET resin 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 – PET resin

Page 38

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

Brazil

Indonesia

Korea

Pakistan

Taiwan

Canada Mexico

Other
countries

United
States
Brazil
Indonesia
Korea
Pakistan
Taiwan
Canada
Mexico
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of PET resin, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 39

IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for PET resin since January 1, 2014. Indicate the share of the quantity of your firm’s
total shipments of PET resin that each of these customers accounted for in 2016.

Customer’s name
1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share of
2016 sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 40

IV-21. Competition from imports
(a)

Lost revenue.--Since January 1, 2014: To avoid losing sales to competitors selling PET
resin from Brazil, Indonesia, Korea, Pakistan, and Taiwan, did your firm:
No
Yes
Reduce prices
Roll back announced price increases

(b)

Lost sales.--Since January 1, 2014: Did your firm lose sales of PET resin to imports of
this product from Brazil, Indonesia, Korea, Pakistan, and Taiwan?
No

(c)

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost
revenues worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the
Commission may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: PETR)

IV-22. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – PET resin

Page 41

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://usitc.gov/investigations/701731/2017/polyethylene_terephthalate_resin_brazil
_indonesia/preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: PETR

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned
copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of
the completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary
(202-205-1803). 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 Typeapplication/pdf
File TitleUSITCQUESTIONNAIRE
SubjectTitle 7 investigations
AuthorChang, Hangyul
File Modified2017-10-03
File Created2017-10-03

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