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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3796; Expiration Date: 06/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
ALUMINUM FOIL FROM CHINA
This questionnaire must be received by the Commission by December 15, 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 countervailing and antidumping duty investigations concerning aluminum foil from China (Inv. Nos.
701‐TA‐570 and 731‐TA‐1346 (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 aluminum foil, small reels of aluminum foil, or single‐backed aluminum foil (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: FOIL)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements
Name of Authorized Official Title of Authorized Official
Date
Phone:
Signature
Fax:
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 2
PART I.‐‐GENERAL INFORMATION
Background. ‐‐This proceeding was instituted in response to a petition filed on March 9, 2017 by The
Aluminum Association Trade Enforcement Working Group and its individual members. Countervailing
and/or antidumping duties may be assessed on the subject imports as a result of these proceedings if
the Commission makes an affirmative determination of injury, threat, or material retardation, and if the
U.S. Department of Commerce (“Commerce”) makes an affirmative determination of subsidization
and/or dumping. Questionnaires and other information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2017/aluminum_foil_china/final.htm.
Aluminum foil.‐‐ The merchandise covered by this investigation is aluminum foil having a thickness of
0.2 mm or less, in reels exceeding 25 pounds, regardless of width. Aluminum foil is made from an
aluminum alloy that contains more than 92 percent aluminum. Aluminum foil may be made to ASTM
specification ASTM B479, but can also be made to other specifications. Regardless of specification,
however, all aluminum foil meeting the scope description is included in the scope.
Excluded from the scope of this investigation is aluminum foil that is backed with paper, paperboard,
plastics, or similar backing materials on only one side of the aluminum foil, as well as etched capacitor
foil and aluminum foil that is cut to shape.
Where the nominal and actual measurements vary, a product is within the scope if application of either
the nominal or actual measurement would place it within the scope based on the definitions set forth
above. The products under investigation are currently classifiable under Harmonized Tariff Schedule of
the United States (HTSUS) subheadings 7607.11.3000, 7607.11.6000, 7607.11.9030, 7607.11.9060,
7607.11.9090, and 7607.19.6000. Further, merchandise that falls within the scope of this proceeding
may also be entered into the United States under HTSUS subheadings 7606.11.3060, 7606.11.6000,
7606.12.3045, 7606.12.3055, 7606.12.3090, 7606.12.6000, 7606.91.3090, 7606.91.6080, 7606.92.3090,
and 7606.92.6080. Although the HTSUS subheadings are provided for convenience and customs
purposes, the written description of the scope of this proceeding is dispositive.
Ultra‐thin. ‐‐ Aluminum foil less than 0.000315 inch (8 microns) thickness.
Thin. ‐‐ Aluminum foil greater than or equal to 0.000315 inch (8 microns) and less than 0.00039 inch (10
microns) thickness.
Standard. ‐‐ Aluminum foil greater than or equal to 0.00039 inch (10 microns) and less than or equal to
0.001 inch (25 microns) thickness.
Heavy. ‐‐ Aluminum foil greater than 0.001 inch (25 microns) thickness and less than 0.00177 inch (45
microns) thickness.
Extra heavy. ‐‐ Aluminum foil greater than or equal to 0.00177 inch (45 microns) thickness.
Certain fin stock aluminum foil.‐‐Certain fin stock is defined as flat‐rolled aluminum of greater than or
equal to 45 microns (0.045 mm; 0.00177 inches) and less than or equal to 200 microns (0.2 mm, 0.00787
inches) in thickness, containing 1 percent or more, by weight, of manganese.
Other in‐scope fin stock aluminum foil.‐‐Any other types of fin stock your firm sells to U.S. customers
that meets the definition of "aluminum foil" but not "certain fin stock" (e.g., fin stock made from 1000
and 7000 series alloys).
Single‐backed aluminum foil.‐‐ aluminum foil that is backed with paper, paperboard, plastics, or similar
backing materials on only one side of the aluminum foil.
Small reels of aluminum foil.—Aluminum foil in reels weighing 25 pounds, or less.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 3
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
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?
No
Yes
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 aluminum foil, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐3.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Petition support.‐‐Does your firm support or oppose the petition?
Country
I‐4.
Support
Oppose
Take no position
China AD
China CVD
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
I‐5.
I‐6.
Page 5
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing aluminum foil from China into the United States or that
are engaged in exporting aluminum foil from China to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of aluminum foil?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Justin Enck (202‐205‐3363,
[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 aluminum foil since January 1, 2014.
(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)
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 7
II‐3a. Production using same machinery.‐‐ Please report your firm’s production of products made on
the same equipment and machinery used to produce aluminum foil, 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)
Calendar years
Item
Overall production capacity
Production of:
Aluminum foil1
Aluminum sheet and plate
products
2
Other products
Total
1
2
2014
2015
January‐September
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
Data entered for production of aluminum foil will populate here once reported in question II‐7.
Please identify these products: .
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating hours
per week, weeks per year.
II‐3c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between aluminum foil 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.
II‐3f.
II‐3g.
Type of Annealing Furnace.‐‐ Please check the box corresponding to the type of annealing
furnace your firm uses to produce aluminum foil.
Electric
Gas/Diesel/Other petroleum
Maximum width.‐‐ Please report the maximum width of your firm’s finishing foil mill (in inches):
II‐3h. Separator/Slitter.—Does your firm produce aluminum foil using a positive air‐pressure chamber
separator/slitter?
No
Yes
II‐4. Tolling.‐‐Since January 1, 2014, has your firm been involved in a toll agreement regarding the
production of aluminum foil?
“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 – Aluminum Foil
II‐5.
Page 9
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce aluminum foil in and/or admit
aluminum foil 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 aluminum foil into a foreign trade zone (FTZ) for use in distribution of aluminum
foil and/or the production of downstream articles?
II‐6.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2014, has your firm imported aluminum foil?
“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 – Aluminum Foil
II‐7.
Page 10
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of aluminum foil 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 to produce small reels,
aluminum foil backed on one side, or other downstream aluminum foil products. Such
transactions are valued at fair market value.
For example, regarding “small reels” (retail packages or other reels of aluminum foil
weighing 25 pounds or less), your firms' U.S. production of aluminum foil considered to fall
within the scope of these proceedings (i.e., in reels weighing more than 25 pounds) that is used
to produce small reels (weighing less than 25 pounds) should be reported as follows: 1) report
the “aluminum foil" (in reels weighing more than 25 pounds) that was used to produce the small
reels as U.S. production of aluminum foil in this questionnaire (in questions II‐3a and II‐7) and 2)
report the use/shipment of that production as internal consumption (in questions II‐7, II‐9, and
III‐9).
“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 – Aluminum Foil
II‐7.
Page 11
Production, shipment, and inventory data.‐‐Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
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)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
2
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 .
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above: .
3
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐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
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
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
II‐8.
Page 12
Channels of distribution.‐‐Report your firm’s U.S. shipments by channel of distribution in the
specified periods.
“Consumer Packaging /Convertor”‐‐Shipments to end users in the business of packaging foods,
cosmetics, pharmaceuticals and to other chemical products; these end users are otherwise
known as convertors in the industry.
“Household use/spoolers”‐‐ Shipment to end users for eventual retail sale as aluminum foil used
for short‐term wrapping, mostly in households, catering and food and floristry retail businesses
after further processing into small reels (e.g., in the context of internal consumption).
“Industrial applications”‐‐ Shipments to end users in the business of using the foil in thermal
insulation, cables, and electronics, among other industrial end uses.
Quantity (in short tons)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To distributors (M)
2014
2015
January‐September
2016
2016
2017
To consumer packaging/
converter (quantity) (N)
To household use/spoolers
(quantity) (O)
To industrial applications
(quantity) (P)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through P) in each time period equal the quantity reported for U.S. 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 – D – F – H = zero ("0"),
if not revise.
2014
2015
0
January‐September
2016
0
2016
0
0
2017
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 13
II‐9a. U.S. shipments by thickness.‐‐Report your firm’s U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) of aluminum foil produced
by your firm.
Ultra‐thin. ‐‐ Aluminum foil less than 0.000315 inch (8 microns) thickness.
Thin. ‐‐ Aluminum foil greater than or equal to 0.000315 inch (8 microns) and less than 0.00039
inch (10 microns) thickness.
Standard. ‐‐ Aluminum foil greater than or equal to 0.00039 inch (10 microns) and less than or
equal to 0.001 inch (25 microns) thickness.
Heavy. ‐‐ Aluminum foil greater than 0.001 inch (25 microns) thickness and less than 0.00177
inch (45 microns) thickness.
Extra heavy. ‐‐ Aluminum foil greater than or equal to 0.00177 inch (45 microns) thickness.
Quantity (in short tons); value ($1,000)
Calendar year
Item
2014
U.S. shipments.—
Ultra‐thin
Quantity (Q)
January – September
2015
2016
2016
2017
Value (R)
Thin
Quantity (S)
Value (T)
Standard
Quantity (U)
Value (V)
Heavy
Quantity (W)
Value (X)
Extra‐heavy
Quantity (Y)
Value (Z)
RECONCILIATION OF U.S. SHIPMENTS BY THICKNESS.— Please ensure that the data reported for U.S.
shipments by thickness (i.e., lines Q through Z) in each time period equal the data reported for U.S.
shipments (i.e., lines D through I) in table II‐7 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
January ‐ September
Reconciliation
2014
2015
2016
2016
2017
Quantity: Q + S + U + W + Y – D –
F – H = should equal zero ("0")
0
0
0
0
0
Value: R + T + V + X + Z – E – G – I
= should equal zero ("0")
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 14
II‐9b. Changes in U.S. shipments by thickness.‐‐Since January 1, 2014, has your firm increased or
decreased its production and/or shipments of specific thickness categories? And if so why?
Category
No
Yes
Explanation
Ultra‐thin
Thin
Standard
Heavy
Extra‐heavy
II‐10. Aluminum foil by product type.‐‐Report your firms' U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) for each period.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
U.S. shipments:
Certain fin stock (from part V):1
Quantity2 (AA)
2
Value (AB)
2015
January‐September
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
3
Other in‐scope fin stock:
Quantity (AC)
Value (AD)
All other non‐fin stock aluminum foil
products:
With a manganese content similar
to that provided for certain fin
stock:4
Quantity (AE)
Value (AF)
Without a manganese content
similar to that provided for certain
fin stock:5
Quantity (AG)
Value (AH)
1
Defined on page 2.
These data will be populated by data reported in part V of this questionnaire.
3
Any other types of fin stock your firm sells to U.S. customers that meets the definition of "aluminum foil" but not
"certain fin stock" (e.g., fin stock made from 1000 and 7000 series alloys). Please describe these products and compare
and contrast them to "certain fin stock":
4
Please describe these high manganese content non‐fin stock products and compare and contrast them to the fin
stocks reported above.
5
Please describe these low manganese content non‐fin stock products and compare and contrast them to the fin
stocks reported above.
2
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 15
RECONCILIATION OF U.S. SHIPMENTS BY PRODUCT TYPE.— Please ensure that the data reported for U.S. shipments
by product type (i.e., lines AA through AH) in each time period equal the data reported for U.S. shipments (i.e., lines
D through I) in table II‐7 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
Quantity: AA + AC + AE + AG– D –
F – H = should equal zero ("0")
2014
2015
0
January ‐ September
2016
0
2016
0
2017
0
0
Value: AB + AD + AF + AH – E – G –
I = should equal zero ("0")
0
0
0
0
0
II‐11. Employment data.‐‐Report your firm’s employment‐related data related to the production of
aluminum foil 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:
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 16
II‐12. 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 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.
II‐13. Purchases.‐‐Other than direct imports, has your firm otherwise purchased aluminum foil 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 short tons)
Calendar years
Item
Purchases from U.S.
importers1 of aluminum foil
from‐‐
China
2014
2015
January‐September
2016
2016
2017
Purchases from domestic
producers2
Purchases from other
sources2
All other sources
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 – Aluminum Foil
Page 17
II‐14. Captive production use.—Please report your firm’s internal consumption and/or transfers to
related firms in 2016 by disposition.
Internal consumption
Transfers to related firms
2016
2016
Products
(short tons)
(short tons)
Sold as scope merchandise
1
Unusable/not further processed
2
Processed into other products
N/A
0
0
Total
1
Please describe the eventual disposition of these products:
.
Please identify the top‐5 products that the aluminum foil 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‐7 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
Internal consumption
2016
(short tons)
Data in this question minus data in
question II‐7.
Transfers to related firms
2016
(short tons)
0
0
II‐15. Double sided aluminum foil.‐‐Has your firm produced any aluminum foil that has been backed
with paper, paperboard, plastics, or similar backing materials on both sides of the foil at any
time since January 1, 2014?
No
Yes‐‐Report such the following data related to your firm's production and
U.S. shipments of this merchandise (such data should be reported as
part of commercial U.S. shipments in II‐7 using the same valuation
basis)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
2015
January‐September
2016
2016
2017
Production (quantity)
U.S. shipments:
Quantity
Value
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 18
II‐16. Ultra‐thin aluminum foil.‐‐Has your firm produced any ultra‐thin aluminum foil at any time
since January 1, 2014?
No
Yes‐‐Report such the following data related to your firm's production and
U.S. shipments of this merchandise (such data should be reported as
part of commercial U.S. shipments in II‐7 using the same valuation
basis)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2014
2015
January‐September
2016
2016
2017
Production (quantity)
U.S. shipments:
Quantity
Value
II‐17. 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 – Aluminum Foil
Page 19
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202‐205‐3188,
[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 aluminum foil:
2. Does your firm prepare profit/loss statements for aluminum foil:
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, 10 Qs,
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 aluminum foil, 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.).
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U.S. Producers’ Questionnaire – Aluminum Foil
III‐4.
Page 20
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 aluminum foil, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
III‐6.
Share of sales
Aluminum foil
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of aluminum foil 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 aluminum
foil 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 method (e.g., the related supplier’s actual cost, cost plus, negotiated transfer
price to approximate FMV, etc.)
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U.S. Producers’ Questionnaire – Aluminum Foil
III‐8.
Page 21
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 aluminum foil)
in a manner consistent with your firm’s accounting books and records.
Yes
No‐‐In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III‐9a.
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 22
III‐9a. Operations on aluminum foil.‐‐Report the revenue and related cost information requested
below on the aluminum foil 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 for the specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
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
Total net sales quantities
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
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
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.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 23
III‐9b. Operations on aluminum foil – U.S. commercial sales and exports only (“open market sales”).‐
‐Report the revenue and related cost information requested below on the aluminum foil
operations of your firm’s U.S. establishment(s).1 Include both domestic and export commercial
sales of aluminum foil, but do not report resales of purchased aluminum foil. 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 in chronological order from left to right and for the specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales quantities from III‐9a
2014
2015
January‐September
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
2
Net sales values:
Commercial sales values from III‐9a
Cost of goods sold (COGS):3
Raw materials
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
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 commercial sales.
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 24
III‐9c. Financial data reconciliation.‐‐The calculable line items from question III‐9a and III‐9b (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
2015
January‐September
2016
2016
2017
Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in question III‐9a.
specific line item in table III‐9a where the nonrecurring item is
classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 25
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of aluminum foil. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for aluminum foil in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III‐9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
2015
1
Total assets (net)
1
III‐13.
2016
Describe
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for aluminum foil. 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
2014
1
Capital expenditures
2016
2016
2017
2
Research and development expenses
1
2015
January‐September
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 – Aluminum Foil
Page 26
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 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 question
II‐7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III‐9a, = zero ("0").
2015
0
Partial year periods
2016
0
2016
0
Value: Trade data from question II‐7
(lines E, G, I, and K) less financial
total net sales value data from
question III‐9a, = zero ("0").
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
2017
0
0
0
0
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 27
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 aluminum foil from China?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
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
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 28
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 aluminum foil from China?
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 29
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
aluminum foil from China?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐18. Active management of energy costs.—Does your firm actively manage its energy costs used in
the production of aluminum foil?
No
Yes
If yes, please describe.
III‐19. Active management of aluminum costs.—Does your firm actively manage its metal costs (i.e.,
the price of acquiring aluminum to roll) used in the production of aluminum foil?
No
Yes
If yes, please describe.
III‐20. 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 – Aluminum Foil
Page 30
PART IV.‐‐ PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Craig Thomsen (202‐205‐
3226, [email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2014 of the following products produced by your
firm.
Product 1.‐‐Aluminum in the 1000 series, standard tempers, 0.00025 inch to less than 0.000315
inch thickness, width 30‐70", matte/bright.
Product 2.‐‐Aluminum in the 1000 series, standard tempers, 0.000315‐0.0005 inch thickness,
inclusive, width 30‐70", matte/bright.
Product 3.‐‐Aluminum in the 8000 series, standard tempers, 0.00039‐0.001 inch thickness, width
12‐18", mill finish.
Product 4.‐‐Aluminum in the 8000 series, standard tempers, 0.002‐0.0039 inch thickness, width
11” to 31.375”, mill finish.
Product 5.‐‐Aluminum in the 8000 series, standard tempers, 0.004‐0.0078 inch thickness, width
11” to 31.375”, mill finish.
Product 6.‐‐Aluminum in the 3000 series, standard tempers, 0.002‐0.0033 inch thickness, width
0.5‐2", mill finish.
Product 7.‐‐ Aluminum in the 3000 series, standard tempers, 0.0034‐0.0078 inch thickness,
width 0.5‐10", mill finish.
Product 8.‐‐ Aluminum certain fin stock, 65 to 110 microns (0.00256 to 0.00433 inches) thick, 15
to 100 mm (0.59 to 3.94 inches) wide, and containing 1.2 to 2.0 percent, by weight,
of manganese.
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).
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 31
IV‐2a. 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 tables as appropriate.
No.‐‐Skip to question IV‐3.
IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds (not short tons) and actual dollars (not 1,000s).
Period of
shipment
2014:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2015:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
1
Product 1
Quantity
Value
(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
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:
Product 4:
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U.S. Producers’ Questionnaire – Aluminum Foil
Page 32
IV‐2b. Price data.—Continued.
Report data in pounds (not short tons) and actual dollars (not 1,000s).
Period of
shipment
2014:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2015:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Product 5
Quantity
Value
1
(Quantity in pounds, value in dollars)
Product 6
Product 7
Quantity
Value
Quantity
Value
Product 8
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 5:
Product 6:
Product 7:
Product 8:
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U.S. Producers’ Questionnaire – Aluminum Foil
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IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000)
In pounds (not short tons)?
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?
Equal to or less than reported commercial shipments in question II‐7 in each
year?
IV‐2d. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 34
Please note: If your response to any question relates to certain fin stock aluminum foil, or differs with
respect to certain fin stock aluminum foil compared with aluminum foil other than certain fin stock,
please note this in your response to that question, or in your response to question IV‐22.
IV‐3. Price setting.‐‐How does your firm determine the prices that it charges for sales of aluminum
foil (check all that apply)? If your firm issues price lists, please submit sample pages of a recent
list.
Transaction
by
transaction
Contracts
IV‐4.
Annual
total
volume
discounts
If other, describe
No
discount
policy
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced aluminum foil?
Net 30
days
Other
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV‐5.
Set
price
lists
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic aluminum foil usually quoted (check
one)?
Delivered
Net 60
days
F.o.b.
If f.o.b., specify point
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U.S. Producers’ Questionnaire – Aluminum Foil
IV‐6.
Page 35
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced
aluminum foil 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
IV‐7.
%
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
0.0
%
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced aluminum foil (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Item
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)
Average contract
duration
No. of
days
365
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Typical sales
contract provisions
Fixed quantity
and/or price
Meet or release
provision
Not applicable
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
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 aluminum foil?
Share of 2016
Lead time (Average
Source
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 total delivered cost of U.S.‐produced
aluminum foil 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 aluminum foil 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 aluminum foil since January 1, 2014 (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.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 37
IV‐11. End uses.‐‐List the top end uses of the aluminum foil that your firm manufactures. For each
end‐use product, what percentage of the total cost is accounted for by aluminum foil and other
inputs (such as labor, energy, and other raw materials)?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
Aluminum foil
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
IV‐12. Substitutes.‐‐Can other products be substituted for aluminum foil?
No
Yes‐‐Please fill out the table.
0.0 %
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for aluminum foil?
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 aluminum foil has changed since January 1, 2014. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Overall
No
Overall
increase change decrease
Fluctuate
with no
clear trend
Explanation and factors
Within the United States
Outside the United States
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 38
IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of aluminum foil since January 1, 2014?
No
Yes
If yes, please describe the changes, the supplier(s) making the changes,
and quantify if possible.
IV‐15. Conditions of competition.‐‐
(a) Is the aluminum foil market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to aluminum foil? 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
aluminum foil since January 1, 2014?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply aluminum foil
since January 1, 2014 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, been unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 39
IV‐17. Raw materials.‐‐
(a)
How have aluminum foil raw material prices changed since January 1, 2014?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for
aluminum foil.
Are your firm’s selling price for aluminum foil indexed to raw material costs?
(b)
Type of sale
No
Yes
Please explain.
By contract
Spot market
IV‐18. Interchangeability.‐‐Is aluminum foil 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
Armenia
Germany
Russia
Other countries
United States
China
Armenia
Germany
Russia
For any country‐pair producing aluminum foil which is sometimes or never interchangeable,
please identify the country‐pair and explain the factors that limit or preclude interchangeable
use:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 40
IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between aluminum foil
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
Armenia
Germany
Russia
Other countries
United States
China
Armenia
Germany
Russia
or any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of aluminum foil, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 41
IV‐20. Customer identification.‐‐ List the names and contact information for your firm’s 5 largest U.S.
customers for ceratin fin stock and other aluminum foil since January 1, 2014. Indicate the share
of the quantity of your firm’s total shipments of aluminum foil that each of these customers
accounted for in 2016.
Aluminum foil other than certain fin stock
Customer’s name
City
State
Share of 2016
sales (%)
1
2
3
4
5
Certain fin stock aluminum foil
Customer’s name
City
State
Share of 2016
sales (%)
1
2
3
4
5
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 42
IV‐21. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2014: To avoid losing sales to competitors selling
aluminum foil from China, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2014: Did your firm lose sales of aluminum foil 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 – Aluminum Foil
Page 43
PART V.‐‐ALTERNATIVE PRODUCT INFORMATION
Further information on this part of the questionnaire can be obtained from Justin Enck (202‐205‐3363),
[email protected]) and/or Jennifer Brinckhaus (202‐205‐3188, [email protected]).
V‐1. Comparability of certain types of aluminum foils‐‐For each of the following indicate whether
the products being compared are:
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not‐at‐all comparable or similar; or
0: no familiarity with products.
Note.‐‐ Please limit comparison of small reels of aluminum foil to larger reels of aluminum foil with
otherwise similar properties.
(a)
Physical Characteristics and Uses.‐‐The differences and similarities in the physical
characteristics and uses.
Product‐pair
All other
aluminum foil
Certain fin stock
aluminum foil
Aluminum foil
backed on only one
side
Small reels of
aluminum foil
weighing 25
pounds or less
Ultra‐thin
aluminum foil
Please provide a narrative discussion for the comparability ratings you provided in terms of their physical
characteristics and uses:
(b)
Interchangeability.‐‐The ability to substitute the products in the same application.
Product‐pair
All other
aluminum foil
Certain fin stock
aluminum foil
Aluminum foil
backed on only one
side
Small reels of
aluminum foil
weighing 25
pounds or less
Ultra‐thin
aluminum foil
Please provide a narrative discussion for the comparability ratings you provided in terms of their
interchangeability:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐1.
Page 44
Comparability of certain types of aluminum foils ‐‐Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not‐at‐all comparable or similar; or
0: no familiarity with products.
(c)
Common manufacturing facilities, production processes, and production employees.‐
‐Whether manufactured in the same facilities, from the same inputs, on the same
machinery and equipment, and using the same employees.
Product‐pair
Certain fin stock
aluminum foil
Aluminum foil
backed on only one
side
Small reels of aluminum
foil weighing 25 pounds or
less
Ultra‐thin
aluminum foil
All other
aluminum foil
Please provide a narrative discussion for the comparability ratings you provided in terms of their
manufacturing facilities, production processes, and production employees:
(d)
Channels of distribution.‐‐Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).
Product‐pair
Certain fin stock
aluminum foil
Aluminum foil
backed on only one
side
Small reels of aluminum
foil weighing 25 pounds or
less
Ultra‐thin
aluminum foil
All other
aluminum foil
Please provide a narrative discussion for the comparability ratings you provided in terms of their
channels of distribution:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐1.
Page 45
Comparability of certain types of aluminum foils ‐‐Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not‐at‐all comparable or similar; or
0: no familiarity with products.
(e)
Customer and producer perceptions.‐‐Perceptions as to the differences and/or
similarities.
Product‐pair
Certain fin stock
aluminum foil
Aluminum foil
backed on only one
side
Small reels of aluminum
foil weighing 25 pounds or
less
Ultra‐thin
aluminum foil
All other
aluminum foil
Please provide a narrative discussion for the comparability ratings you provided in terms of their
customer and product perceptions:
(f)
Price.‐‐Whether prices are comparable or differ between the products.
Product‐pair
Certain fin stock
aluminum foil
Aluminum foil
backed on only one
side
Small reels of aluminum
foil weighing 25 pounds or
less
Ultra‐thin
aluminum foil
All other
aluminum foil
Please provide a narrative discussion for the comparability ratings you provided in terms of their price:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐2.
Page 46
Production using same machinery.‐‐Please report your firm’s production of products made on
the same equipment and machinery used to produce in‐scope fin‐stock aluminum foil, 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)
Calendar years
Item
Overall production capacity
2014
2015
January‐September
2016
2016
2017
0
0
0
0
0
0
0
0
0
0
Out‐of‐scope products.‐‐
Out‐of‐scope fin stock aluminum
foil or sheet
Other aluminum sheet and plate
products
0
0
0
0
0
0
0
0
0
0
Production of:
Certain fin stock aluminum foil1
Other in‐scope aluminum foil
In‐scope products on certain fin
stock machinery
2
Other products
Out‐of‐scope products on
certain fin stock machinery
Total
1
2
Data entered for production of certain fin stock aluminum foil will populate here once reported in question V‐3.
Please identify these products: .
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐3.
Page 47
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of certain fin stock aluminum foil in its U.S.
establishment(s) during the specified periods.
CERTAIN FIN STOCK ALUMINUM FOIL
Quantity (in short tons) 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: .
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 48
V‐3. 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 year
Reconciliation 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
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐4.
Page 49
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) of certain fin stock aluminum
foil by channel of distribution.
CERTAIN FIN STOCK ALUMINUM FOIL
“Consumer Packaging /Convertor”‐‐Shipments to end users in the business of packaging foods,
cosmetics, pharmaceuticals and to other chemical products; these end users are otherwise
known as convertors in the industry.
“Household use/spoolers”‐‐ Shipment to end users for eventual retail sale as aluminum foil used
for short‐term wrapping, mostly in households, catering and food and floristry retail businesses
after further processing into small reels (e.g., in the context of internal consumption).
“Industrial applications”‐‐ Shipments to end users in the business of using the foil in thermal
insulation, cables, and electronics, among other industrial end uses.
Quantity (in short tons)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To distributors (M)
2014
2015
January‐September
2016
2016
2017
To consumer packaging/
converter (quantity) (N)
To household use/spoolers
(quantity) (O)
To industrial applications
(quantity) (P)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through R) in each time period equal the quantity reported for U.S. 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 – D – F – H = zero ("0"),
if not revise.
2014
2015
0
January‐September
2016
0
2016
0
0
2017
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐5.
Page 50
Employment data.‐‐Report your firm’s employment‐related data related to the domestic (U.S.)
production of certain fin stock aluminum foil and provide an explanation for any trends in these
data.
“Production 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 domestic (U.S.) production operations. Do not report employment data for
production occurring outside of the United States or employment data for U.S. sales of products
manufactured outside the United States.
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.
CERTAIN FIN STOCK ALUMINUM FOIL
Calendar year
Employment data
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:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐6.
Page 51
Operations on certain fin stock.‐‐ Report the revenue and related cost information requested
below on the certain fin stock aluminum foil 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 for the specified interim
periods. If your firm was involved in tolling operations (either as the toller or as the tollee),
please contact Jennifer Brinckhaus (202‐205‐3188, [email protected]). before
completing this section of the questionnaire.
CERTAIN FIN STOCK ALUMINUM FOIL
Quantity (in short tons) and value (in $1,000)
January‐September
Fiscal years ended‐‐
Item
2014
2015
2016
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms
(“Transfers”)
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
Direct labor
Other factory costs
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
0
0
0
0
0
0
0
0
0
0
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
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.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment
quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 52
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in V‐3 the quantities and values reported total net sales in V‐6 in each time period
unless the financial data from part V‐6 are reported on a fiscal year basis, in which case only the interim
periods must reconcile.
Full year data
Reconciliation
Quantity: Trade data from question
V‐3 (lines D, F, H, and J) less financial
total net sales quantity data from
question V‐6, = zero ("0").
2014
2015
0
Partial year periods
2016
0
2016
0
2017
0
0
Value: Trade data from question V‐3
(lines E, G, I, and K) less financial
total net sales value data from
question V‐6, = zero ("0").
0
0
0
0
0
V‐7. Asset values.‐‐As applicable, report the total assets (i.e., both current and long‐term assets)
associated with the production, warehousing, and sale of in‐scope certain fin stock aluminum
foil. If your firm does not maintain some or all of the specific asset information necessary to
calculate total assets related to operations on certain fin stock 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 table V‐6. 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. As reported in this table, total assets
should be allocated if they are also related to the operations of other products.) In the note to
table V‐7, 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.
CERTAIN FIN STOCK ALUMINUM FOIL
Value (in $1,000)
Fiscal years ended‐‐
2014
1
Total assets (net)
1
Describe
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐8.
Page 53
Capital expenditures and R&D expenses.‐‐Report your firm’s capital expenditures and R&D
expenses for in‐scope certain fin stock aluminum foil. Provide data for your firm’s three most
recently completed fiscal years, and for the specified interim periods. The manner in which
capital expenditures and R&D expenses are assigned to operations on certain fin stock should be
consistent with the manner in which capital expenditures and R&D expenses were assigned to
operations on aluminum foil (III‐13).
CERTAIN FIN STOCK ALUMINUM FOIL
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
1
Capital expenditures
2
R&D expenses
1
2015
January‐September
2016
2016
Please describe the nature, focus, and significance of your firm’s capital expenditures on certain fin stock:
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to operations on certain fin
stock:
2017
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
V‐9.
Page 54
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of small reel aluminum foil in its U.S.
establishment(s) during the specified periods.
SMALL REEL ALUMINUM FOIL
Quantity (in short tons) 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) –
Using firm’s own production of
aluminum foil (C)
Using purchases of domestically
produced aluminum foil (D)
Using imports of aluminum foil
from subject sources (E)
Using imports of aluminum foil
from nonsubject sources (F)
Total production (G)
0
0
0
0
0
U.S. shipments:
Commercial shipments:
quantity (H)
value (I)
2
Internal consumption:
quantity (J)
value (K)
2
Transfers to related firms:
quantity (L)
value (M)
3
Export shipments:
quantity (N)
value (O)
End‐of‐period inventories
(quantity) (P)
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: .
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 55
V‐9. 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 P) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line G), less total shipments (i.e., lines H, J, L, N). 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
Reconciliation item
B + G – H – J – L – N – P =
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
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 56
V‐10. 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) of small reel aluminum foil by
channel of distribution.
SMALL REEL ALUMINUM FOIL
“Consumer Packaging /Convertor”‐‐Shipments to end users in the business of packaging foods,
cosmetics, pharmaceuticals and to other chemical products; these end users are otherwise
known as convertors in the industry.
“Household use/spoolers”‐‐ Shipment to end users for eventual retail sale as aluminum foil used
for short‐term wrapping, mostly in households, catering and food and floristry retail businesses.
“Industrial applications”‐‐ Shipments to end users in the business of using the foil in thermal
insulation, cables, and electronics, among other industrial end uses.
Quantity (in short tons)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To distributors (Q)
2014
2015
January‐September
2016
2016
2017
To consumer packaging/
converter (quantity) (R)
To household use/spoolers
(quantity) (S)
To industrial applications
(quantity) (T)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines Q through T) in each time period equal the quantity reported for U.S. shipments (i.e., lines H, J,
and L) 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
Q + R + S + T – H – J – L = zero ("0"), if
not revise.
2014
2015
0
January‐September
2016
0
2016
0
0
2017
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 57
V‐11. Employment data.‐‐Report your firm’s employment‐related data related to the domestic (U.S.)
production of small reel aluminum foil and provide an explanation for any trends in these data.
“Production 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 domestic (U.S.) production operations. Do not report employment data for
production occurring outside of the United States or employment data for U.S. sales of products
manufactured outside the United States.
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.
SMALL REEL ALUMINUM FOIL
Calendar year
Employment data
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:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 58
V‐12. Operations on small reels.‐‐ Report the revenue and related cost information requested below
on small reel aluminum foil 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.
SMALL REEL ALUMINUM FOIL
Quantity (in short tons) and value (in $1,000)
January‐September
Fiscal years ended‐‐
Item
2014
Net sales quantities:2
Commercial sales (“CS”)
2015
2016
2016
2017
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Cost of foil ‐‐ Internally produced or
purchases of domestically produced
(domestic)
Cost of foil – Imports or purchases of
imports from subject sources (subject)
Cost of foil – Imports or purchases of
imports from non subject sources
(nonsubject)
0
0
0
0
0
0
0
0
0
0
Direct labor
Other factory costs
0
0
0
0
0
0
0
0
0
0
Total cost of foil
Other raw materials
Total raw materials
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
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.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 59
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in V‐9 the quantities and values reported total net sales in V‐12 in each time period
unless the financial data from part V‐12 are reported on a fiscal year basis, in which case only the interim
periods must reconcile.
Full year data
Reconciliation
2014
Quantity: Trade data from question
V‐9 (lines H, J, L, and N) less financial
total net sales quantity data from
question V‐12, = zero ("0").
2015
0
Partial year periods
2016
0
2016
0
2017
0
0
Value: Trade data from question V‐9
(lines I, K, M, and O) less financial
total net sales value data from
question V‐12, = zero ("0").
0
0
0
0
0
V‐13. Asset values.‐‐As applicable, report the total assets (i.e., both current and long‐term assets)
associated with the production, warehousing, and sale of small reel aluminum foil. If your firm
does not maintain some or all of the specific asset information necessary to calculate total
assets related to operations on small reels 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 table V‐6. 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. As reported in this table, total assets
should be allocated if they are also related to the operations of other products.) In the note to
table V‐7, 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.
SMALL REEL ALUMINUM FOIL
Value (in $1,000)
Fiscal years ended‐‐
2014
1
Total assets (net)
1
Describe
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 60
V‐14. Capital expenditures and R&D expenses.‐‐Report your firm’s capital expenditures and R&D
expenses for small reel aluminum foil. Provide data for your firm’s three most recently
completed fiscal years, and for the specified interim periods. The manner in which capital
expenditures and R&D expenses are assigned to operations on small reels should be consistent
with the manner in which capital expenditures and R&D expenses were assigned to operations
on aluminum foil (III‐13).
SMALL REEL ALUMINUM FOIL
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
1
Capital expenditures
2
R&D expenses
1
2015
January‐September
2016
2016
2017
Please describe the nature, focus, and significance of your firm’s capital expenditures on small reels:
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to operations on small reels:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 61
V‐15. Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of single sided aluminum foil in its U.S.
establishment(s) during the specified periods.
SINGLE‐BACKED ALUMINUM FOIL
Quantity (in short tons) 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) –
Using firm’s own production of
aluminum foil (C)
Using purchases of domestically
produced aluminum foil (D)
Using imports of aluminum foil
from subject sources (E)
Using imports of aluminum foil
from nonsubject sources (F)
Total production (G)
0
U.S. shipments:
Commercial shipments:
quantity (H)
value (I)
0
0
0
0
2
Internal consumption:
quantity (J)
value (K)
2
Transfers to related firms:
quantity (L)
value (M)
3
Export shipments:
quantity (N)
value (O)
End‐of‐period inventories
(quantity) (P)
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: .
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 62
V‐15. 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 P) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line G), less total shipments (i.e., lines H, J, L, N). 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
Reconciliation item
B + G – H – J – L – N – P =
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
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 63
V‐16. 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) of single‐backed aluminum foil
by channel of distribution.
SINGLE‐BACKED ALUMINUM FOIL
“Consumer Packaging /Convertor”‐‐Shipments to end users in the business of packaging foods,
cosmetics, pharmaceuticals and to other chemical products; these end users are otherwise
known as convertors in the industry.
“Household use/spoolers”‐‐ Shipment to end users for eventual retail sale as aluminum foil used
for short‐term wrapping, mostly in households, catering and food and floristry retail businesses.
“Industrial applications”‐‐ Shipments to end users in the business of using the foil in thermal
insulation, cables, and electronics, among other industrial end uses.
Quantity (in short tons)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To distributors (Q)
2014
2015
January‐September
2016
2016
2017
To consumer packaging/
converter (quantity) (R)
To household use/spoolers
(quantity) (S)
To industrial applications
(quantity) (T)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines Q through T) in each time period equal the quantity reported for U.S. shipments (i.e., lines H, J,
and L) 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
Q + R + S + T – H – J – L = zero ("0"), if
not revise.
2014
2015
0
January‐September
2016
0
2016
0
0
2017
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 64
V‐17. Employment data.‐‐Report your firm’s employment‐related data related to the domestic (U.S.)
production of single‐backed aluminum foil and provide an explanation for any trends in these
data.
“Production 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 domestic (U.S.) production operations. Do not report employment data for
production occurring outside of the United States or employment data for U.S. sales of products
manufactured outside the United States.
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.
SINGLE‐BACKED ALUMINUM FOIL
Calendar year
Employment data
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:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 65
V‐18. Operations on single‐backed aluminum foil.‐‐ Report the revenue and related cost information
requested below on single‐backed aluminum foil 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.
SINGLE‐BACKED ALUMINUM FOIL
Quantity (in short tons) and value (in $1,000)
January‐September
Fiscal years ended‐‐
Item
2014
Net sales quantities:2
Commercial sales (“CS”)
2015
2016
2016
2017
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Cost of foil ‐‐ Internally produced or
purchases of domestically produced
(domestic)
Cost of foil – Imports or purchases of
imports from subject sources (subject)
Cost of foil – Imports or purchases of
imports from non subject sources
(nonsubject)
0
0
0
0
0
0
0
0
0
0
Direct labor
Other factory costs
Total cost of foil
Other raw materials
Total raw materials
Total COGS
Gross profit or (loss)
0
0
0
0
0
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
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.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 66
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in V‐15 the quantities and values reported total net sales in V‐18 in each time period
unless the financial data from part V‐18 are reported on a fiscal year basis, in which case only the interim
periods must reconcile.
Full year data
Reconciliation
Quantity: Trade data from question
V‐15 (lines H, J, L, and N) less
financial total net sales quantity data
from question V‐18, = zero ("0").
2014
2015
0
Partial year periods
2016
0
2016
0
2017
0
0
Value: Trade data from question V‐
15 (lines I, K, M, and O) less financial
total net sales value data from
question V‐18, = zero ("0").
0
0
0
0
0
V‐19. Asset values.‐‐As applicable, report the total assets (i.e., both current and long‐term assets)
associated with the production, warehousing, and sale of single‐backed aluminum foil. If your
firm does not maintain some or all of the specific asset information necessary to calculate total
assets related to operations on single‐backed aluminum foil 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 table V‐6. 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. As reported in this table, total assets
should be allocated if they are also related to the operations of other products.) In the note to
table V‐7, 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.
SINGLE‐BACKED ALUMINUM FOIL
Value (in $1,000)
Fiscal years ended‐‐
2014
1
Total assets (net)
1
Describe
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 67
V‐20. Capital expenditures and R&D expenses.‐‐Report your firm’s capital expenditures and R&D
expenses for single‐backed aluminum foil. Provide data for your firm’s three most recently
completed fiscal years, and for the specified interim periods. The manner in which capital
expenditures and R&D expenses are assigned to operations on small reels should be consistent
with the manner in which capital expenditures and R&D expenses were assigned to operations
on aluminum foil (III‐13).
SINGLE‐BACKED ALUMINUM FOIL
Value (in $1,000)
Fiscal years ended‐‐
Item
2014
1
Capital expenditures
2
R&D expenses
1
2015
January‐September
2016
2016
2017
Please describe the nature, focus, and significance of your firm’s capital expenditures on single‐backed aluminum foil:
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to operations on single‐backed
aluminum foil:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil
Page 68
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://usitc.gov/investigations/701731/2017/aluminum_foil_china/final.htm.
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: FOIL
• 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--Al foil (final) |
| Author | justin.enck |
| File Modified | 2017-11-21 |
| File Created | 2017-11-21 |