17-4-3791 Foreign producers' questionnaire

OMB No. 3117-0016/USITC No. 17-4-3791; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ 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-TA1359 (Final)). The information requested in the questionnaire is requested under the authority of the Tariff Act
of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported 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 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
Foreign 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,
purchaser and/or foreign producer 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
Foreign 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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from
Amanda Lawrence (202-205-3185, [email protected]).

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

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”-- Each facility of a firm in China involved in the production or export of cartonclosing staples, including auxiliary facilities operated in conjunction with (whether or not
physically separate from) such facilities. Firms operating more than one establishment in China
should combine the data for all establishments into a single report.

Business Proprietary
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)
I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce carton-closing staples in the United States or other countries?
No

I-4.

2
3
4
5

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

U.S. importers.--Please provide the names, contacts, telephone numbers, and e-mail addresses
of the FIVE largest U.S. importers of your firm’s carton-closing staples in 2016.

Importer’s name
1

Yes--Please name the firm(s) and country below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
carton-closing staples into the United States?
No

I-5.

Page 4

Contact
person

Email

Telephone

Share of your firm’s
2016 U.S. exports (%)

Business Proprietary
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)

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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
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-3.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of carton-closing
staples in the future?
No

II-4a.

Page 6

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 documentation that address this
issue. Include in the response a specific projection of your firm’s
capacity to produce carton-closing staples (in 1,000s staples) for
2017 and 2018.

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.
“Overall production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s) in China, including production consumed
internally within your firm.
Quantity (in pounds)
Calendar years
Item

2014

2015

January-September
2016

2016

2017

Overall production
capacity
Production of:
Carton-closing
staples
Other products1
Total
1

Please identify these products:

0

0

.

Note.--Quantity data requested in this question are based on weight.

0

0

0

Business Proprietary
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)

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II-4b.

Operating parameters.--The production capacity reported in II-4a is based on operating
per week,
weeks per year.

II-4c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-4a, and explain any changes in reported capacity.

II-4d.

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

II-4e.

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).

hours

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.

II-5.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of carton-closing staples?
percent.

II-6.

Firm's estimated share of production in China.--Please estimate the percentage of total production
of carton-closing staples in the country specified on the certification page accounted for by your
firm’s production in 2016.
percent.

II-7.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of carton-closing staples from the country specified on the certification page
accounted for by your firm’s exports in 2016.
percent.

Business Proprietary
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)

II-8.

Third-country trade actions.--Are the carton-closing staples exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?
No

II-9.

Page 8

Yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of carton-closing staples in your establishment(s) in China during the
specified periods. Do not include resales of carton-closing staples that your firm did not
produce in this question; those data to the degree they are exported to the United States should
only be reported in question II-10.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
“Average production capacity” or “capacity”–The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s) in China, including production consumed
internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”--Shipments to destinations outstide of the country indicacted on page 1
(China), 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
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-9.

Page 9

Trade data.--Continued.
Quantity (in 1,000s staples)
Projections1

Actual experience
Calendar year
Item

2014

2015

January-September
2016

2016

Calendar year

2017

2017

2018

2

Average production capacity (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
(D)
Commercial shipments (E)
Exports to the United States (F)
Exports to all other markets3 (G)
Total exports (H)
(should equal F+G)

0

0

0

0

0

0

0

Total shipments (I)
(should equal D+E+F+G)

0

0

0

0

0

0

0

End-of-period inventories (J)
1

Please explain the basis for your firm’s projections.
.
The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity.
.
3
Identify principal other export markets.
.
2

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line J) 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, E, F, and G). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Actual experience
JanuarySeptember

Calendar year
Item

2014

2015

Projections

2016

2016

2017

Calendar year
2017

B+C–D–E–F–G–J=
should equal zero ("0") or
provide an explanation.1
0
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

2018

0

Business Proprietary
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)
II-10.

Page 10

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of carton-closing staples that were produced in China but not by your firm during
the specified periods. Note these data should not be included in question II-9.
Quantity (in 1,000s staples)
Actual experience
JanuarySeptember

Calendar year
Item

2014

2015

Projections

2016

2016

2017

Calendar year
2017

2018

Exports of carton-closing
staples to the United States
not produced by your firm1
1

List the producer(s).

II-11.

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
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)

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

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

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

Business Proprietary
Foreign Producers’ Questionnaire – Carton-Closing Staples from China (Final)

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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/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 your questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm did not produce or export 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, you are 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.