Download:
pdf |
pdfOMB No. 3117-0016/USITC No. 17-1-3788; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)
U.S. PRODUCERS’ QUESTIONNAIRE
CARTON-CLOSING STAPLES FROM CHINA
This questionnaire must be received by the Commission by December 20, 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 investigation concerning carton-closing staples from China (Inv. No. 731-TA-1359
(Final)). The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title
VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the
submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced carton-closing staples (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: CART)
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
Email address
Fax:
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 31, 2017, by North
American Steel & Wire, Inc./ISM Enterprises, Butler, PA. 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://www.usitc.gov/investigations/title_7/2017/carton_closing_staples_china/final.htm.
Carton-closing staples may be manufactured from carbon, alloy, or stainless steel wire, and are included
in the scope of the investigation regardless of whether they are uncoated or coated, regardless of the
type of coating.
Carton-closing staples are generally made to American Society for Testing and Materials (ASTM)
specification ASTM D1974/D1974M–16, but can also be made to other specifications. Regardless of
specification, however, all carton-closing staples meeting the scope description are included in the
scope. Carton-closing staples include stick staple products, often referred to as staple strips, and roll
staple products, often referred to as coils. Stick staples are lightly cemented or lacquered together to
facilitate handling and loading into stapling machines. Roll staples are taped together along their
crowns. Carton-closing staples are covered regardless of whether they are imported in stick form or roll
form.
Carton-closing staples vary by the size of the wire, the width of the crown, and the length of the leg. The
nominal leg length ranges from 0.4095 inch to 1.375 inches and the nominal crown width ranges from
1.125 inches to 1.375 inches. The size of the wire used in the production of carton-closing staples varies
from 0.029 to 0.064 inch (nominal thickness) by 0.064 to 0.100 inch (nominal width).
Carton-closing staples subject to this investigation are currently classifiable under subheadings
8305.20.00.00 and 7317.00.65.60 of the Harmonized Tariff Schedule of the United States (‘‘HTSUS’’).
While the HTSUS subheadings and ASTM specification are provided for convenience and for customs
purposes, the written description of the subject merchandise 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.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
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-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 – Carton-Closing Staples from China (Final)
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 carton-closing staples,
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
China
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
I-4.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-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 carton-closing staples from China into the United States
or that are engaged in exporting carton-closing staples from China to the United States?
No
Firm name
I-6.
Page 5
Yes--List the following information.
Country
Affiliation
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of carton-closing staples?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 6
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amanda Lawrence (202-2053185, [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 carton-closing staples 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)
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-3a.
Page 7
Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce carton-closing staples, 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 pounds)
Calendar years
Item
2014
2015
January-September
2016
2016
2017
Overall production
capacity1
Production of:
Carton-closing
staples
Other products2
Total
0
0
0
0
0
1
Overall production capacity, as defined above, should not include capacity for equipment that has been idled
for the majority of the specific periods in question. Please ensure that your firm does not include idled capacity in
its reported data. Additionally, overall production capacity, as defined above should not include running
machinery for more shifts than your firm actually did over the specific periods in question (i.e., do not report
hypothetical non-stop 24/7 capacity if your firm typically runs its machinery for one 8-hour shift a day).
2
Please identify these products:
.
Note.--Quantity data requested in this question are based on weight.
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on operating
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.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
hours
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-3e.
Product shifting.—
(i)
Is your firm able to switch production (capacity) between carton-closing staples and other
products using the same equipment and/or labor?
No
(ii)
II-4.
Page 8
Yes-- (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Tolling.--Since January 1, 2014, has your firm been involved in a toll agreement regarding the
production of carton-closing staples?
“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.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-5.
Page 9
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce carton-closing staples in and/or admit
carton-closing staples 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
(b)
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import carton-closing staples into an FTZ for use in distribution of carton-closing staples
and/or the production of downstream articles?
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 carton-closing staples?
“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
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-7.
Page 10
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of carton-closing staples 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.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-7.
Page 11
Production, shipment, and inventory data.--Continued
Quantity (in 1,000s staples) and value (in $1,000)
Calendar years
Item
2014
2015
January-September
2016
2016
2017
Average production
capacity1 (quantity) (A)
Beginning-of-period
inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related
firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Channels of distribution:
Commercial U.S.
shipments:
To distributors
(quantity) (M)
To end users
(quantity) (N)
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
. Please note average production capacity, as defined above, should not include capacity for
equipment that has been idled for the majority of the specific periods in question. Please ensure that your
firm does not include idled capacity in its reported data. Additionally, average production capacity, as
defined above should not include running machinery for more shifts than your firm actually did over the
specific periods in question (i.e., do not report hypothetical non-stop 24/7 capacity if your firm typically runs
its machinery for one 8-hour shift a day).
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:
.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-7.
Page 12
Production, shipment, and inventory data.--Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar years
Reconciliation
B+C–D–F–H–J–L
= should equal zero
("0") or provide an
explanation.1
2014
January-September
2015
0
2016
0
2016
0
2017
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for commercial U.S. shipments (i.e.,
line D) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N – D = zero ("0"), if not
revise.
2014
2015
0
January-September
2016
0
2016
0
2017
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-8.
Page 13
Total shipments by type.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) and export shipments by
product type.
Calendar years
2014
Item
2015
January-September
2016
2016
2017
Quantity (in 1,000s staples) and value (in $1,000)
U.S. shipments.—
Roll staple products.-Quantity (O)
Value (P)
Staple strip products.-Quantity (Q)
Value (R)
Export shipments.—
Roll staple products.-Quantity (S)
Value (T)
Staple strip products.-Quantity (U)
Value (V)
RECONCILIATION OF TOTAL SHIPMENTS.--Please ensure that the total quantities and values reported for
U.S. shipments and export shipments in this question sum to equal the total quantities and values of U.S.
shipments and export shipments reported in the previous question. If the calculated fields below return
values other than zero (i.e., “0”), the data reported must be revised prior to submission to the
Commission.
Calendar years
Reconciliation
2014
2015
January-September
2016
2016
2017
Quantity reconciliation: O + Q
+ S + U – D – F – H – J = should
equal zero ("0") or provide an
explanation.
0
0
0
0
0
Value reconciliation: P + R + T
+ V – E – G—I – K = zero ("0"),
if not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-9.
Page 14
Employment data.--Report your firm’s employment-related data related to the production of
carton-closing staples 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.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2014
2015
January-September
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.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-11.
Page 15
Purchases.--Other than direct imports, has your firm otherwise purchased carton-closing staples
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 1,000s staples)
Calendar years
Item
2014
2015
January-September
2016
2016
2017
Purchases from
U.S. importers1 of
carton-closing
staples 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:
.
II-12.
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.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 16
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:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include carton-closing staples:
2.
Does your firm prepare profit/loss statements for carton-closing staples:
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,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)
3.
4.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes carton-closing staples,
as well as specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 17
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 carton-closing staples, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products
Share of sales
Carton-closing staples
%
%
%
%
%
III-6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of carton-closing staples 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 cartonclosing staples that your firm purchases from related suppliers and that are reflected in question
III-9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
%
%
%
%
Input valuation as recorded in the firm’s accounting books and records
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
III-8.
Page 18
Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on carton-closing
staples) 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.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 19
III-9a. Operations on carton-closing staples.--Report the revenue and related cost information
requested below on the carton-closing staples operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that internal consumption and transfers to related
firms must be valued at fair market value. Input purchases from related suppliers should be
consistent with and based on information in the firm’s accounting books and records. Provide
data for your firm’s three most recently completed fiscal years and the specified interim periods.
Quantity (in 1,000s staples) and value (in $1,000)
Fiscal years ended-2014
2015
2016
January-September
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
0
0
0
0
0
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
Total COGS
Gross profit or (loss)
Selling, general, and
administrative (SG&A)
expenses:
Selling expenses
General and administrative
expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before
income taxes
Depreciation/amortization
included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the
corresponding shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 20
III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes
No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
III-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
Nonrecurring item: In this column
please provide a brief description of
each nonrecurring item and indicate
the specific line item in table III-9a
where the nonrecurring item is
classified.
1.
, classified as
2.
, classified as
3.
, classified as
4.
, classified as
5.
, classified as
6.
, classified as
7.
, classified as
2015
January-September
2016
2016
2017
Nonrecurring item: In these columns please report the amount of the
relevant nonrecurring item reported in question III-9a.
Value (in $1,000)
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 21
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.
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of carton-closing staples. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for carton-closing
staples 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. In the note provided in table III-12, 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
2014
2015
2016
1
Describe
III-13.
Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for carton-closing staples. 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-September
2016
2016
2017
1
Research and development
expenses2
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 22
III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
January-September
Annual period
Reconciliation
2014
2015
2016
2016
2017
Quantity: Trade data
from part II less financial
data from part III, = zero
("0") except as noted
above.
0
0
0
0
0
Value: Trade data from
part II less financial data
from part III, = zero ("0")
except as noted above.
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 – Carton-Closing Staples from China (Final)
Page 23
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 carton-closing staples from China?
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 – Carton-Closing Staples from China (Final)
Page 24
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 carton-closing staples from China?
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 – Carton-Closing Staples from China (Final)
Page 25
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
carton-closing staples from China?
No
Yes
If yes, my firm anticipates negative effects as follows:
III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
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 – Carton-Closing Staples from China (Final)
Page 26
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Yasnanhia Cabral (202-2052230, [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. distributors since January 1, 2014 of the following products produced by your
firm.
Product 1.--Stick staple, size A 7/8” or equivalent.
Product 2.--Stick staple, size C 5/8” or equivalent.
Product 3.--Roll staple, size GR1 5/8” or equivalent.
Product 4.--Roll staple, size RR1 5/8” or equivalent.
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, including those after the sale has occurred). If discounts or
rebates occurred in a different quarter than the original sale, the deduction for these discounts or
rebates should be made to the quarter of the original sale.
During January 2014-September 2017, did your firm produce and sell to unrelated U.S.
distributors 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 – Carton-Closing Staples from China (Final)
IV-2.
Page 27
Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report quantity in 1,000 staples and value in actual dollars (not $1,000s).
Product 1
Quantity
Value
(Quantity in 1,000 staples, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
Period of shipment
Quantity
Value
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your firm’s U.S.
point of shipment.
2
Pricing product definitions are provided on the first page of Part 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:
Price data checklist.--Please check that the pricing data in question III-2(a) has been correctly reported.
Is the price data reported above:
In actual dollars (not $1,000s)?
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-5 in each year?
√ if Yes
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 28
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 cartonclosing staples (check all that apply)? If your firm issues price lists, please submit sample pages
of a recent list.
Transaction
by
transaction
IV-4.
Set
price
lists
Contracts
Other
If other, describe
Discount policy.—
(a)
Please indicate and describe your firm’s discount policies regarding carton-closing
staples (check all that apply).
Quantity
discounts
(b).
Annual
total
volume
discounts
No
discount
policy
Cash
Describe
Yes–-Please describe.
Does your company provide rebates to customers who were not the company that
issued the purchase order and to whom you issued the invoice?
Yes
(d)
Other
Are carton-closing staples provided at a discount or with rebates to customers that also
purchase stapling machines from your company and/or a related company?
No
(c)
Rebates
No
In what form(s) are discounts and rebates provided to your customers?
Account/Credit
Other
If other, describe
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
IV-4
Discount policy.— Continued
(e)
How are rebates and discounts calculated?
(f)
Which types of customers receive rebates and discount?
Distributors
IV-5.
End users
Other
If other, describe
Pricing terms.-(a)
What are your firm’s typical sales terms for its U.S.-produced carton-closing staples?
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 carton-closing staples usually quoted
(check one)?
Delivered
IV-6.
Page 29
F.o.b.
If f.o.b., specify point
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
carton-closing staples in 2016 were 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
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
%
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
IV-7.
Page 30
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced carton-closing staples (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
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long-term contracts
(multiple deliveries for
more than 12 months)
365
No
Quantity
Fixed quantity
and/or price
Price
Both
Meet or release
provision
Yes
No
Not applicable
IV-8.
Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced carton-closing staples?
Source
Share of 2016
sales
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Lead time (average
number of days)
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
IV-9.
Page 31
Shipping information.-(a)
What is the approximate percentage of the total delivered cost of U.S.-produced cartonclosing staples 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 carton-closing staples 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 carton-closing staples 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 – Carton-Closing Staples from China (Final)
Page 32
IV-11. End uses.--List the end uses of the carton-closing staples that your firm manufactures. For each
end-use product, what percentage of the total cost is accounted for by carton-closing staples
and other inputs?
Share of total cost of end use product
accounted for by
Carton-closing
staples
End use product
Total
(should sum to
100.0% across)
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-12. Substitutes.--Can other products be substituted for carton-closing staples?
No
Substitute
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for carton-closing staples?
No Yes
Explanation
1.
2.
3.
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for carton-closing staples has changed since January 1, 2014. Explain any
trends and describe the principal factors that have affected these changes in demand.
Market
Within the United States
Outside the United States
Overall
increase
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 33
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of carton-closing staples since January 1, 2014?
No
Yes
If yes, please describe and quantify if possible.
IV-15. Conditions of competition.-(a) Is the carton-closing staples market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to cartonclosing staples? 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
carton-closing staples since January 1, 2014?
No
Yes
If yes, describe.
IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply carton-closing
staples since January 1, 2014 (examples include placing customers on allocation or “controlled
order entry,” declining to accept new customers or renew existing customers, delivering less
than the quantity promised, been unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV-17. Raw materials.--How have carton-closing staples raw material prices changed since January 1,
2014?
Fluctuate
Explain, noting how raw material price changes
Overall
No
Overall
with no
have affected your firm’s selling prices for cartonincrease change decrease clear trend
closing staples.
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 34
IV-18. Interchangeability.--Are carton-closing staples produced in the United States and in other
countries interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair
China
Sweden
Other countries
United States
China
Sweden
For any country-pair producing carton-closing staples that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:
IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between carton-closing staples
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair
China
Sweden
Other countries
United States
China
Sweden
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of carton-closing staples, identify the country-pair and report the
advantages or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 35
IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for carton-closing staples since January 1, 2014. Indicate the share of the quantity of
your firm’s total shipments of carton-closing staples that each of these customers accounted for
in 2016.
Customer’s name
1
2
3
4
5
6
7
8
9
10
City
State
Share of 2016 sales (%)
Business Proprietary
U.S. Producers’ Questionnaire – Carton-Closing Staples from China (Final)
Page 36
IV-21. Competition from imports
(a)
Lost revenue.--Since January 1, 2014: To avoid losing sales to competitors selling
carton-closing staples from China, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2014: Did your firm lose sales of carton-closing staples to
imports of this product from China?
No
Yes
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 – Carton-Closing Staples from China (Final)
Page 37
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/title_7/2017/carton_closing_staples_china/final.h
tm
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: CART
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | USITCQUESTIONNAIRE |
| Subject | Title 7 investigations |
| Author | Jones, Lawrence |
| File Modified | 2017-11-07 |
| File Created | 2017-11-07 |