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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3804; Expiration Date: 6/30/2020
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U.S. PRODUCER’S QUESTIONNAIRE
SILICON METAL FROM CHINA
This questionnaire must be received by the Commission by January 19, 2018
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 review of the antidumping duty order concerning silicon metal from China (Inv. No. 731‐TA‐472
(Fourth Review)). 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 silicon metal (as defined on the next page) at any time since January 1, 2012?
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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: SMFC)
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 or reviews
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 – Silicon Metal from China (4R)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐On June 10, 1991, the Department of Commerce (“Commerce”) issued an antidumping
duty order on imports of silicon metal from China. On March 1, 2017, the Commission instituted a
review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine
whether revocation of the order would be likely to lead to continuation or recurrence of material injury
to the domestic industry within a reasonably foreseeable time. If both the Commission and Commerce
make an affirmative determination, the order will remain in place. If either the Commission or
Commerce makes a negative determination, Commerce will revoke the order. Questionnaires and other
information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/silicon_metal_china/fourth_review_full.htm
Silicon Metal covered by the order is silicon metal containing at least 96.00 percent, but less than 99.99
percent of silicon by weight. Also covered by the order is silicon metal containing between 89.00 and
96.00 percent silicon by weight but which contains a higher aluminum content than the silicon metal
containing at least 96.00 percent but less than 99.99 percent silicon by weight (58 FR 27542, May 10,
1993). Silicon metal is currently provided for under subheadings 2804.69.10 and 2804.69.50 of the
Harmonized Tariff Schedule (HTSUS) as a chemical product, but is commonly referred to as a metal.
Semiconductor‐grade silicon (silicon metal containing by weight not less than 99.99 percent of silicon
and provided for in subheading 2804.61.00 of the HTSUS) is not subject to this order. Although the
HTSUS numbers are provided for convenience and customs purposes, the written description remains
dispositive.
Reporting of information.‐‐ If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
Page 3
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.
I‐1.
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.
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
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 silicon metal, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
Covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I‐3.
Position regarding continuation of order.‐‐Does your firm support or oppose continuation of
the following antidumping duty order currently in place for silicon metal?
Country
China
Support
Oppose
Take no position
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
I‐4.
Page 5
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Extent of
ownership
(percent)
Address
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing silicon metal into the United States or that are engaged in
exporting silicon metal to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of silicon metal?
No
Yes‐‐List the following information.
Firm name
I‐7.
Page 6
Country
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for silicon metal?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
Page 7
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202‐205‐
3358, [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 silicon metal since January 1, 2012.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
Page 8
II‐3a. Production using same machinery.‐‐Please report your firm’s production of products made on
the same equipment and machinery used to produce silicon metal, 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 short tons contained silicon)
Calendar years
Item
2014
Overall production capacity
2015
January‐September
2016
2016
2017
0
0
0
0
0
Weight of other elements
Silicon metal on a total
weight basis
0
0
0
0
0
Out‐of‐scope products:
Ferrosilicon
Semiconductor grade
silicon metal
0
0
0
0
0
Production of:
Silicon metal on contained
silicon basis1
All other products
2
Total production using
same equipment
1
2
Data entered for production of silicon metal will populate here once reported in question II‐4.
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.
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
Page 9
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐3e. Product shifting.‐‐
(i)
Is your firm able to switch production (capacity) between silicon metal and other products
using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.
(ii)
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 –Silicon Metal from China (4R)
II‐3f.
Page 10
Details of product shifting.—Did your firm at any time since January 1, 2014 switch production on
the same furnaces from silicon metal production to ferrosilicon production, or the reverse?
No
Yes‐‐then for each instance of a shift please answer the following
questions: (1) identify the specific month and year when the capacity
was shifted ("period"); (2) identify whether the shift was from silicon
metal to ferrosilicon or from ferrosilicon to silicon metal ("direction"),
(3) identify the capacity of the furnaces shifted ("capacity"); (4)
identify how many days it took to make the transition ("days"); (5)
identify the cost of the shift in U.S. dollars ("cost"), and (6) provide a
detailed explanation of the reason or purpose of the capacity shift
("reason").
Item
First (1) shift
Second (2) shift
Period
Direction
Capacity
Days
Costs
Reason
Item
Third (3) shift
Fourth (4) shift
Period
Direction
Capacity
Days
Costs
Reason
Item
Fifth (5) shift
Sixth (6) shift
Period
Direction
Capacity
Days
Costs
Reason
Additional shifts
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
II‐4.
Page 11
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of silicon metal 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.
“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.
“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 –Silicon Metal from China (4R)
II‐4.
Page 12
Production, shipment, and inventory data. ‐‐Continued
Quantity (in short tons contained silicon) and value (in $1,000)
Calendar year
Item
2014
2015
January‐September
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)
2
Internal consumption:
Quantity (F)
Value (G)
2
Transfers to related firms:
Quantity (H)
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity (use additional pages as necessary). .
2
Internal consumption and transfers to related firms should 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‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
B + C – D – F – H – J – L
= 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: .
0
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
II‐5.
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 short tons contained silicon)
Calendar year
Item
2014
U.S. shipments
to Distributors: (M)
2016
2016
2017
To Polysilicon and chemical
producers:(N)
To Primary aluminum producers:
(O)
To Secondary aluminum
producers:(P)
1
To All other end users : (Q)
1
2015
January‐September
Identify 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. commercial shipments
(i.e., lines D, F, and H) in each time period. If the calculated fields below return values other than zero
(i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P + Q – D – F ‐ H = zero
("0"), if not revise.
2014
2015
0
January‐September
2016
0
2016
0
0
2017
0
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
II‐6.
Page 14
Employment data.‐‐Report your firm’s employment‐related data related to the production of
silicon metal 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 September periods, calculate similarly and divide by 9.
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, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
2014
Employment data:
Average number of
PRWs (number)
2015
January‐September
2016
2016
2017
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs
($1,000)
Explanation of trends:
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
II‐7.
Page 15
Transfers to related firms.‐‐If your firm reported transfers to related firms in question II‐4,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non‐market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm. Please identify the
related entities by name and location.
II‐8.
Purchases.‐‐Other than direct imports, has your firm otherwise purchased silicon metal since
January 1, 2014?
No
Yes‐‐ Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity and
value of such purchases below for the specified periods.
“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.
Reason for purchases:
Quantity (in short tons contained silicon)
Calendar years
Item
2014
2015
2016
January‐September
2016
2017
Purchases from U.S.
importers1 of silicon
metal from—
China
All other sources
Purchases from
domestic producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product: .
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
II‐9.
Page 16
Captive production use.‐‐Please report your firm’s internal consumption and/or transfers to
related firms in 2016 by disposition. Identify below the form of the product your firm internally
consumes or transfers to a related firm.
Internal consumption
2016
(short tons
contained silicon)
Products
Sold as silicon metal
1
Unusable/not further processed
2
Processed into other products
Total
Transfers to related firms
2016
(short tons
contained silicon)
N/A
0
0
1
Please describe these products: .
Please identify the top‐5 products silicon metal was processed into by your firm, rank ordered by larger to
smaller quantity: .
2
RECONCILIATION OF INTERNAL CONSUMPTION AND TRANSFERS.—The sum of the data reported above
should be equal to the 2016 data reported for internal consumption and transfers in question II‐4 for
2016. 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
Data in this question minus data in
question II‐4.
Internal consumption
2016
(short tons
contained silicon)
Transfers to related firms
2016
(short tons
contained silicon)
0
0
II‐10. Toll production.‐‐Since January 1, 2012, has your firm been involved in a toll agreement
regarding the production of silicon metal?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
Page 17
II‐11. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce silicon metal in and/or admit silicon
metal into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import silicon metal into a foreign trade zone (FTZ) for use in distribution of silicon
metal and/or the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
II‐12. Direct imports.‐‐Since January 1, 2012, has your firm, or any firm related to you, imported
silicon metal?
“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
II‐13. Effect of order.‐‐Describe the significance of the existing antidumping duty order covering
imports of silicon metal from China in terms of its effect on your firm’s production capacity,
production, U.S. shipments, inventories, purchases, employment, revenues, costs, profits, cash
flow, capital expenditures, research and development expenditures, and asset values. You may
wish to compare your firm’s operations before and after the imposition of the order.
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U.S. Producers’ Questionnaire –Silicon Metal from China (4R)
Page 18
II‐14. Anticipated changes in operations.‐‐Would your firm anticipate any changes in the character of
its operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of silicon
metal in the future? Please consider both anticipated changes if the antidumping duty order on
silicon metal from China was to remain in place and if the order was revoked.
Item
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue. Include in your
response a specific projection of your firm’s capacity to
produce silicon metal (in short tons contained silicon) for 2017
and 2018.
No
Yes
If order
remained in
place
If order is
revoked
II‐15. Other explanations:‐‐If your firm would like to explain further 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 –Silicon Metal from China (4R)
Page 19
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[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:
Note.‐‐Please note that we are requesting that firms report their financial data
on a calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include silicon metal:
2. Does your firm prepare profit/loss statements for silicon metal:
Yes
No
3. 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
4. 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 silicon metal, as well as
specific statements and worksheets) used to compile these data.
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III‐3.
Page 20
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
III‐4.
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced silicon metal, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Share of sales
Silicon metal
%
%
%
%
%
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III‐6.
Page 21
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of silicon metal from any related suppliers (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)?
Yes‐‐Continue to question III‐7.
III‐7.
No‐‐Continue to question III‐9a.
Inputs from related suppliers.‐‐Please identify the inputs used in the production of silicon metal
that your firm purchases from related suppliers and that are reflected in the financial results
reported in question III‐9a (Total market operations on silicon metal). For “Share of total COGS”
please report this information by relevant input for 2016. For “Input valuation” (note 1) 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.
Input1
Related supplier
Share of total III‐9a COGS2
1 With respect to inputs purchased from related suppliers, please describe the relevant input valuation in the
firm’s accounting books and records:
2
As applicable, please describe the extent to which the “share of total COGS” of inputs purchased from
related suppliers is different for III‐9c COGS (Open market operations on silicon metal):
III‐8.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in both III‐9a (Total market operations on
silicon metal) and III‐9c (Open market operations on silicon metal) 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 III‐9a and III‐9c.
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III‐9a. Total market operations on silicon metal.‐‐Report the revenue and related cost information
requested below on the silicon metal total market operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books
and records. Provide data for the requested calendar years, and for the specified interim
periods.
Quantity (in short tons of contained silicon) and value (in $1,000)
Calendar years‐‐
Item
2014
2015
January‐September
2016
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
Electricity
Direct labor
Other factory costs
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers. Electricity costs
specific to the manufacture of silicon metal should be reported in the designated line item.
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. Inputs.‐‐Based on the cost information for your firm’s silicon metal operations as reported in
question III‐9a (Total market operations on silicon metal), report where identified inputs, as
applicable, are classified in question III‐9a COGS (e.g., raw materials, other factory costs), and
their associated cost. Provide data for the requested calendar years, and for the specified
interim periods.
Value (in $1,000)
Calendar years
Item
2014
2015
January‐September
2016
Electrodes (classified in COGS as )
2016
2017
Coal (classified in COGS as )
Natural Gas (classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
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III‐9c. Open market operations on silicon metal.‐‐Report the revenue and related cost information
requested below on the silicon metal open market operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Input purchases from related suppliers
should be consistent with and based on information in the firm’s accounting books and
records. Provide data for the requested calendar years, and for the specified interim periods.
Quantity (in short tons of contained silicon) and value (in $1,000)
Calendar years‐‐
Item
Commercial sales quantities2
2014
2015
January‐September
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
Electricity
Direct labor
Other factory costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
2
Commercial sales values
3
Cost of goods sold (COGS):
Raw materials
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
0
0
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers. Electricity costs
specific to the manufacture of silicon metal should be reported in the designated line item.
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‐9d. Inputs.‐‐Based on the cost information for your firm’s silicon metal operations as reported in
question III‐9c (Open market operations on silicon metal), report where identified inputs, as
applicable, are classified in question III‐9c COGS (e.g., raw materials, other factory costs), and
their associated cost. Provide data for the requested calendar years, and for the specified
interim periods.
Value (in $1,000)
Calendar years
Item
2014
2015
January‐September
2016
Electrodes (classified in COGS as )
2016
2017
Coal (classified in COGS as )
Natural Gas (classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
Other primary non‐electricity inputs
(identify, , classified in COGS as )
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Page 26
III‐9e. Financial data reconciliation.‐‐The calculable line items (i.e., total net sales quantities and
values, total COGS, gross profit or loss, total SG&A, and net income or loss) from question III‐9a
(Total market operations on silicon metal) and III‐9c (Open market operations on silicon metal)
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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Page 27
III‐10a. Nonrecurring items (charges and gains) included in III‐9a (Total market operations on silicon
metal) 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.
Calendar years‐‐
2014
2015
January‐September
2016
2016
2017
Nonrecurring item: In this column please provide a
Nonrecurring item: In these columns please report the amount of the
brief description of each nonrecurring item and indicate relevant nonrecurring item reported in question III‐9a.
the specific line item in table III‐9a where the
nonrecurring item is classified.
Value (in $1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
III‐10b. Nonrecurring items (charges and gains) included in III‐9c (Open market operations on silicon
metal) financial results.—For each annual and interim period for which financial results are
reported in question III‐9c, please specify all material (significant) nonrecurring items (charges
and gains) in the schedule below, the specific question III‐9c 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‐9c; i.e., if an aggregate nonrecurring item has been
allocated to question III‐9c, only the allocated value amount included in question III‐9c 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‐9c.
Calendar years‐‐
2014
2015
January‐September
2016
2016
2017
Nonrecurring item: In this column please provide a
Nonrecurring item: In these columns please report the amount of the
brief description of each nonrecurring item and indicate relevant nonrecurring item reported in question III‐9c.
the specific line item in table III‐9c where the
nonrecurring item is classified.
Value (in $1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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III‐10c. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in questions III‐10a and III‐10b
above, please identify where your company recorded these items in your accounting books and
records in the normal course of business; i.e., just as responses to question III‐10a and III‐10b
identify where these items are reported in questions III‐9a and III‐9c, respectively.
III‐11. Merger or acquisition related to silicon metal operations.‐‐If your company underwent a
merger or acquisition during the period examined, which involved silicon metal operations,
please describe the extent to which U.S. silicon metal operations were affected by the merger or
acquisition, as well as impact (direct or indirect) on silicon metal revenue, COGS, SG&A
expenses, interest expense, other income or expenses, and deprecation. In your response,
please also specify when the merger or acquisition occurred, entities and operations involved,
and objective. As appropriate, please refer to the company’s response to question II‐2 in Part II
of this questionnaire.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of silicon metal. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for silicon metal 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 questions III‐9a
and/or III‐9c. Provide data for the requested calendar 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.
Value (in $1,000)
Calendar years‐‐
Item
1
Total assets (net)
1
2014
2015
2016
Please provide a brief explanation if there were any substantial changes in total asset value during the period; e.g., due to
asset write‐offs, revaluation, and major purchases:
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Page 29
III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for silicon metal. Provide data for the
requested calendar years, and for the specified interim periods.
Value (in $1,000)
Calendar years‐‐
Item
2014
2015
January‐September
2016
1
Capital expenditures
2
Research and development expenses
1
2
2016
2017
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9c, III‐12, and III‐13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the total quantities and values reported in question III‐9a (Total market operations
on silicon metal) 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 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
Quantity: Trade data from part II
less financial data from part III, = zero
("0") except as noted above.
2015
2016
2017
0
0
Value: Trade data from part II less
financial data from part III, = zero
("0") except as noted above.
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
0
0
No
If no, please explain.
0
2016
0
Yes
0
January‐September
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III‐15. 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.
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Page 31
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Jonathan Ruder (202‐205‐
3435, [email protected]).
IV‐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 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 of the following products produced by your firm.
Product 1.‐‐ Sold to primary aluminum producers; silicon metal less than 99.99% pure that
contains a minimum of 98.5% silicon, a maximum of 1.00% iron, a maximum of
0.07% calcium, and no restriction of the aluminum content.
Product 2.‐‐ Sold to secondary aluminum producers; silicon metal less than 99.99% pure that
contains a minimum of 97.0% silicon, a maximum of 2.00% iron, a maximum of 0.4%
calcium, and no restriction of the aluminum content.
Product 3.‐‐ Sold to chemical and polysilicon manufacturers; silicon metal less than 99.99% pure
that contains a minimum of 98.0% silicon, a maximum of 1.50% iron, a maximum of
0.2% calcium, and a maximum of 0.4% aluminum.
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).
(a) During January 2014 – September 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.
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IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in short tons of contained silicon and actual dollars (not 1,000s).
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
(Quantity in short tons of contained silicon, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Quantity
Value
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:
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IV‐2 (c). Price data checklist.‐‐Please check that the pricing data in question IV‐2(a) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II‐4 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.
IV‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales of silicon metal
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
No
Early/cash
Quantity payment discount
policy
discounts discounts
Other
Describe
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IV‐5.
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced silicon metal?
Net 30
days
Net 60
days
Page 34
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic silicon metal usually quoted (check
one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced silicon
metal in 2016 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2016
sales
%
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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IV‐7.
Page 35
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced silicon metal (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
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
Average contract duration
No. of
days
Price renegotiation (during contract period)
Fixed quantity and/or price
Meet or release provision
Indexed to raw material costs1
Indexed to published silicon metal prices2
Not applicable
1
Annual
contracts
(multiple
deliveries
for 12
months)
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
365
Yes
No
Quantity
Price
Both
Yes
No
1
Yes
No
2
Yes
No
Please describe any indexing mechanisms and relevant raw materials:
Please describe any indexing mechanisms and price indices:
2
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IV‐8.
Lead times.‐‐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 silicon metal?
Lead time (Average
Source
Share of 2016 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV‐9.
Page 36
0.0 %
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced silicon metal that is
accounted for by U.S. inland transportation costs? percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of silicon metal that are
delivered the following distances from your firm’s 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 silicon metal since January 1, 2012 (check all that apply)?
Geographic area
√ if applicable
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.
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IV‐11. End uses.‐‐
(a)
List the end uses of the silicon metal that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by silicon metal and other
inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
Silicon metal
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
(b)
Have there been any changes in the end uses of silicon metal since January 1, 2012? Do
you anticipate any future changes?
Changes in end
uses
No
Yes
Explain
Changes since
January 1, 2012
Anticipated
changes
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IV‐12. Substitutes.‐‐
(a)
Can other products be substituted for silicon metal?
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 silicon metal?
No Yes
Explanation
1.
2.
3.
(b)
Have there been any changes in the number or types of products that can be
substituted for silicon metal since January 1, 2012? Do you anticipate any future
changes?
Changes in
substitutes
No Yes
Explain
Changes since
January 1, 2012
Anticipated
changes
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IV‐13. Availability of supply.‐‐Has the availability of silicon metal in the U.S. market changed since
January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2012:
U.S.‐produced product
Imports from China
Imports from all other
countries
U.S.‐produced product
Imports from China
Imports from all other
countries
Anticipated changes:
IV‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for silicon metal has changed since January 1, 2012, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors that
have affected, and that you anticipate will affect, these changes in demand.
Market
Overall
increase
No
change
Fluctuate
Overall
with no
decrease clear trend
Explanation and factors
Demand since January 1, 2012
Within the United States‐
Overall demand
Polysilicon / chemical user
demand
Other sectors
Outside the United States
Anticipated future demand
Within the United States‐
Overall demand
Polysilicon / chemical user
demand
Other sectors
Outside the United States
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IV‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of silicon metal since January 1, 2012? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
IV‐16. Conditions of competition.‐‐
(a) Is the silicon metal market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to silicon metal?
Check all that apply.
Please describe.
No
Skip to question IV‐17.
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
silicon metal since January 1, 2012?
No
Yes
If yes, please describe.
(c) Has the 2015 market entrance of silicon metal producer Mississippi Silicon LLC impacted
conditions of competition?
No
Yes
If yes, please describe.
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IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply silicon metal
since January 1, 2012 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐18. Raw material and electricity costs.‐‐
(a) Indicate how silicon metal raw material prices have changed since January 1, 2012, and how
you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no
Explain, noting how raw material
clear
price changes have affected your
Overall
No
Overall
trend
firm’s selling prices for silicon metal.
increase change decrease
Changes since
January 1,
2012
Anticipated
changes
(b) Indicate how your firm’s electricity costs have changed since January 1, 2012, and how you
expect they will change in the future.
Electricity
prices
Fluctuate
with no Explain, noting how electricity price
changes have affected your firm’s
clear
Overall
No
Overall
selling prices for silicon metal.
trend
increase change decrease
Changes since
January 1,
2012
Anticipated
changes
IV‐19. Price comparisons.‐‐Please compare market prices of silicon metal in U.S. and non‐U.S. markets,
if known. Provide specific information as to time periods and regions for any price comparisons.
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IV‐20. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss silicon metal supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China, and (3) the world as a whole.
Of particular interest is such data from 2012 to the present and forecasts for the future.
IV‐21. Export constraints.‐‐Describe how easily your firm can shift its sales of silicon metal between
the U.S. market and alternative country markets. In your discussion, please describe any
contracts, other sales arrangements, or other constraints that would prevent or retard your firm
from shifting silicon metal between the U.S. and alternative country markets within a 12‐month
period.
IV‐22. Barriers to trade.‐‐Are your firm’s exports of silicon metal subject to any tariff or non‐tariff
barriers to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2012, or that are expected to occur in the future.
IV‐23. Interchangeability.‐‐Is silicon metal 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
United States
China
China
Other countries
For any country‐pair producing silicon metal that is sometimes or never interchangeable,
identify the country‐pair and explain the factors that limit or preclude interchangeable use:
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IV‐24. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between silicon metal 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
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of multilayered wood flooring, identify the country‐pair and report
the advantages or disadvantages imparted by such factors:
IV‐25. 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.
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2017/silicon_metal_china/fourth_review
_full.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: SMFC
• 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 Type | application/pdf |
| File Title | Microsoft Word - US producers--Silicon metal (R4) |
| Author | lawrence.jones |
| File Modified | 2017-11-29 |
| File Created | 2017-11-29 |