Form 18-1-3820 US producers' questionnaire

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

US producers--Citric Acid (F)

Citric acid and certain citrate salts from Belgium, Colombia, and Thailand (701-TA-581 and 731-TA-1374-1376)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 18-1-3820; Expiration Date: : 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
CITRIC ACID AND CERTAIN CITRATE SALTS (“CACCS”)
FROM BELGIUM, COLOMBIA, AND THAILAND
This questionnaire must be received by the Commission by March 5, 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 antidumping and countervailing duty investigations concerning CACCS from Belgium, Colombia, and
Thailand (Inv. Nos. 701-TA-581 and 731-TA-1374-1376 (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 CACCS (as defined on next page) at any time since January 1, 2015?

(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: CBCT)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my knowledge and belief
and understand that the information submitted is subject to audit and verification by the Commission. By means of this certification I also grant
consent for the Commission, and its employees and contract personnel, to use the information provided in this questionnaire and throughout
this proceeding in any other import-injury proceedings conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this proceeding or other
proceedings may be disclosed to and used:(i) by the Commission, its employees and Offices, and contract personnel (a) for developing or
maintaining the records of this or a related proceeding, or (b) in internal investigations, audits, reviews, and evaluations relating to the
programs, personnel, and operations of the Commission including under 5 U.S.C. Appendix 3; or (ii) by U.S. government employees and contract
personnel, solely for cybersecurity purposes. I understand that all contract personnel will sign appropriate nondisclosure agreements
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Email address

Business Proprietary
U.S. Producers’ Questionnaire – CACCS (Final)

Page 2

PART I.--GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 2, 2017, by Archer
Daniels Midland Company, Decatur, Illinois; Cargill, Incorporated, Minneapolis, Minnesota; and Tate &
Lyle Ingredients Americas, LLC, Hoffman Estates, Illinois. Countervailing/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/dumping. Questionnaires and other
information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2017/citric_acid_and_certain_citrate_salts_belgium/final.htm.
CACCS covered by these investigations is all grades and granulation sizes of citric acid, sodium citrate,
and potassium citrate in their unblended forms, whether dry or in solution, and regardless of packaging
type. The scope also includes blends of citric acid, sodium citrate, and potassium citrate; as well as
blends with other ingredients, such as sugar, where the unblended form(s) of citric acid, sodium citrate,
and potassium citrate constitute 40 percent or more, by weight, of the blend.
The scope also includes all forms of crude calcium citrate, including dicalcium citrate monohydrate, and
tricalcium citrate tetrahydrate, which are intermediate products in the production of citric acid, sodium
citrate, and potassium citrate.
The scope includes the hydrous and anhydrous forms of citric acid, the dihydrate and anhydrous forms
of sodium citrate, otherwise known as citric acid sodium salt, and the monohydrate and monopotassium
forms of potassium citrate. Sodium citrate also includes both trisodium citrate and monosodium citrate
which are also known as citric acid trisodium salt and citric acid monosodium salt, respectively.
The scope does not include calcium citrate that satisfies the standards set forth in the United States
Pharmacopeia and has been mixed with a functional excipient, such as dextrose or starch, where the
excipient constitutes at least 2 percent, by weight, of the product.
Citric acid and sodium citrate are classifiable in subheadings 2918.14.00 and 2918.15.10 of the HTSUS,
respectively. Potassium citrate and crude calcium citrate are classifiable in subheading 2918.15.50 and,
if included in a mixture or blend, subheading 3824.99.92 (statistical reporting number 3824.99.9295) of
the HTSUS. Blends that include citric acid, sodium citrate, and potassium citrate are also imported under
statistical reporting number 3824.99.9295 of the HTSUS. Although the HTSUS subheadings are provided
for convenience and customers purposes, the written description of the merchandise is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)

Page 3

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.

I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes

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U.S. Producers’ Questionnaire – CACCS (Final)
I-2.

Page 4

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment” – Each facility of a firm involved in the production of CACCS, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

I-3.

Additional discussion on establishments consolidated in this questionnaire:

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

Belgium
Colombia
Thailand (AD)
Thailand (CVD)

Support

Oppose

Take no position

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)
I-4.

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

Firm name

I-5.

Page 5

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing CACCS from Belgium, Colombia, and/or Thailand into the
United States or that are engaged in exporting CACCS from Belgium, Colombia, and/or Thailand
to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – CACCS (Final)
I-6.

Page 6

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – CACCS (Final)

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amelia Shister (202-2052047, [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 CACCS since January 1, 2015.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

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U.S. Producers’ Questionnaire – CACCS (Final)
II-3a.

Page 8

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce CACCS, 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).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise (i.e., you have reported no data for "other products" in this
question) then the "overall production capacity" numbers reported in this question should be
exactly equal to the "average production capacity" numbers reported in question II-9. If,
however, your firm does produce out-of-scope merchandise using the same machinery and
equipment as scope merchandise (i.e., you have reported data for "other products" in this
question), then the "average production capacity" reported in question II-9 should exclude the
portion of "overall production capacity" that was used to produce this out-of-scope
merchandise (i.e., "average production capacity" in question II-9 should be smaller than "overall
production capacity" in this question).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in 1,000 dry pounds)
Calendar years
Item

2015

2016

2017

Overall production capacity
Production of:
Citric acid and certain citrate salts1

Other products

Total, using same machinery
1

Data entered for production of citric acid and certain citrate salts will populate here once reported in
question II-7.
2
Please identify these products:
.

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U.S. Producers’ Questionnaire – CACCS (Final)

Page 9

II-3b.

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

II-3c.

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

II-3d.

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

II-3e.

Product shifting.-(i)

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

(ii)

hours

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

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

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U.S. Producers’ Questionnaire – CACCS (Final)
II-4.

Page 10

Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of CACCS?
“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.

II-5.

Decline in capacity utilization in 2017.--Was your firm’s capacity utilization lower in 2017
compared to 2016? If yes, please describe how your firm supplied CACCS to your U.S. customers
in 2017 (e.g., drawing down inventories of domestically produced CACCS, providing resales of
CACCS produced by another US producer or imported, or just lost sales).
No

II-6a.

Yes

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

Yes

If yes, please describe.

Production processes.--Please identify the production process your firm utilizes for production
of citric acid?
Deep tank method
Shallow pan method
Other (please specify:

II-6b.

Raw materials.--Please identify the raw materials your firm utilizes for production of citric acid?
Corn
Sugar beets
Other (please specify:

II-6c.

)

Operation costs.--Based on a.) and b.), please discuss how that affects your operation costs.

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U.S. Producers’ Questionnaire – CACCS (Final)
II-7.

Page 11

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

(a)

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

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

(b)

II-8.

Yes

If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Yes

If yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2015, has your firm imported CACCS?
“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

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)
II-9.

Page 12

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of CACCS in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” – Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” – Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” – A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” – Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories” – Finished goods inventory, not raw materials or work-in-progress.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)
II-9.

Page 13

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

2015

2016

2017

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity).-Using corn substrates (C)
Using sugar substrates (D)
Using tapioca substrates (E)
2

Using all other substrates (F)

Total production (G)

U.S. shipments:
Commercial shipments:
Quantity (H)
Value (I)
3

Internal consumption:
Quantity (J)
2

Value (K)
Transfers to related firms:
Quantity (L)

Value (M)
Export shipments:
Quantity (N)

Value (O)
End-of-period inventories (quantity) (P)

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
Identify the other substrates used in CACCS production:
.
3
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:
4
Identify your firm’s principal export markets:
.
5
Please describe any end-of-period inventory trends:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line P) should be equal to the beginning-of-period inventories (i.e., line B), plus production
(i.e., lines C through F), less total shipments (i.e., lines H, J, L, and 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 years

Reconciliation
B + C + D + E +F – H – J – L – N – P =
should equal zero ("0") or provide an
explanation.1
1

2015

2016

2017

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

0
.

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U.S. Producers’ Questionnaire – CACCS (Final)
II-10.

Page 14

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in 1,000 dry pounds)
Calendar years
Item

2015

2016

2017

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (Q)
To food & beverage end users (R)
To industrial end users (S)
To other end users (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 commercial U.S. shipments (i.e., line 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
Q + R + S + T – H = zero ("0"), if not
revise.

2015

2016
0

2017
0

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U.S. Producers’ Questionnaire – CACCS (Final)
II-11.

Page 15

U.S. shipments by GMO classification.--Please report your firm's U.S. shipments (i.e., inclusive
of commercial U.S. shipments, internal consumption, and transfers to related firms) by GMO
classification from 2015-17.
GMO.--In the context of U.S. producers' U.S. shipments of CACCS, GMO stands for CACCS that
was produced using inputs (i.e., the substrates) that were genetically engineered or
bioengineered.
Quantity (1,000 dry pounds) and Value (in $1,000)
Calendar years
Product type

2015

2016

2017

U.S. shipments.-GMO:
Quantity (U)
Value (V)
Non-GMO but not certified or
verified by any independent
organization:
Quantity (W)
Value (X)
"Non-GMO Project" verified:
Quantity (Y)
Value (Z)
Verified or certified as non-GMO
other than "Non-GMO Project"
verified1:
Quantity (AA)
Value (AB)
1

List the organization(s) that provide this certification and/or verification:
RECONCILIATION OF SHIPMENT DATA.--Please ensure that the quantity and value of U.S.
shipments reported above (i.e., lines U through AB) equal the quantity and value of U.S.
shipments in in each period as reported the main trade grid, question II-8 (i.e., lines H through
M). If the calculated field below returns a value other than zero (i.e., “0”), the data reported
must be revised prior to submission to the Commission.
Calendar years
Reconciliation

2015

2016

2017

Quantity: U + W + Y + AA– H –
J - L= zero ("0"), if not revise.

Value: V + X + Z +AB – I – K – M
= zero ("0"), if not revise.

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U.S. Producers’ Questionnaire – CACCS (Final)
II-12.

Page 16

U.S. shipments by product type.--Please report your firm's U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by product
type.
Quantity (1,000 dry pounds) and Value (in $1,000)
Calendar years

Product type

2015

2016

2017

U.S. shipments.-Citric acid:
Quantity (AA)
Value (AB)
Sodium citrate:
Quantity (AC)
Value (AD)
Potassium citrate:
Quantity (AE)
Value (AF)
Crude calcium citrate:
Quantity (AG)
Value (AH)
Blends:1
Quantity (AI)
Value (AJ)
1

Describe the blends reported:

RECONCILIATION OF SHIPMENT DATA.--Please ensure that U.S. shipments reported above equal
U.S. shipments as reported in question II-7. 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

2015

2016

2017

Quantity: AA + AC + AE + AG + AI
– H – J - L= zero ("0"), if not revise.

Value: AB + AD + AF + AH + AJ– I –
K – M = zero ("0"), if not revise.

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U.S. Producers’ Questionnaire – CACCS (Final)
II-13.

Page 17

Commercial U.S. shipments by sale type.--Please report your firm's commercial U.S. shipments
by type of sale.
Spot sales.--Single delivery shipments (Such sales can involve a purchase agreement or contract,
but which does not include provisions for multiple deliveries).
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.
Quantity (1,000 dry pounds) and Value (in $1,000)
Calendar years

Product type

2015

2016

2017

Commercial U.S. shipments.-Spot sales:
Quantity (AK)
Value (AL)
Short term contract sales:
Quantity (AM)
Value (AN)
Annual contract sales:
Quantity (AO)
Value (AP)
Long-term contract sales:
Quantity (AQ)
Value (AR)
1

Describe the blends reported:
RECONCILIATION OF COMMERCIAL SHIPMENT DATA.--Please ensure that commercial U.S. shipments reported
above equal commercial U.S. shipments as reported in question II-7. 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

2015

2016

2017

Quantity: AK + AM + AO+ AQ – H
= zero ("0"), if not revise.

Value: AL + AN + AP + AR – I =
zero ("0"), if not revise.

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U.S. Producers’ Questionnaire – CACCS (Final)
II-14.

Page 18

Employment data.--Report your firm’s employment-related data related to the production of
CACCS and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) – 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.
“Hours worked” – 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

2015

2016

2017

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

II-15.

Related firms.--If your firm reported transfers to related firms in question II-7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

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U.S. Producers’ Questionnaire – CACCS (Final)
II-16.

Page 19

Purchases.--Other than direct imports, has your firm otherwise purchased CACCS since January
1, 2015?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
No

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

(Quantity in 1,000 dry pounds)
Calendar years
Item

2015

2016

2017

Purchases from U.S.
importers1 of citric acid and
certain citrate salts from-Belgium
Colombia
Thailand
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1

Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.

II-16.

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

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[email protected]).
III-1.

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 CACCS:

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

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

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III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

III-4.

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

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced CACCS, and provide the share of net sales accounted for by these products in 2017.
Products
CACCS

Share of sales in 2017
%
%
%
%
%

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III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CACCS 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.

Page 22

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of CACCS 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 calendar year
2017. 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 in 2017

Input valuation as recorded in the firm’s accounting books and records (e.g., the related supplier’s
actual cost, cost plus, negotiated transfer price to approximate FMV, etc.)

III-8.

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 CACCS) 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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III-9a. Operations on CACCS.--Report the revenue and related cost information requested below on
the CACCS 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.
Quantity (in 1,000 dry pounds) and value (in $1,000)
Calendar year
Item

2015

2016

2017

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

Total COGS

Gross profit or (loss)

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

Direct labor
Other factory costs

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

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

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

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

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

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

2015

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

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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 CACCS. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for CACCS 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.
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)
Calendar years

Item
Total assets (net)

2015

2016

2017

Describe

III-13.

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for CACCS.
Value (in $1,000)
Calendar years

Item
Capital expenditures

2015

2016

2017

1
2

Research and development expenses
1

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

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

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III-14. Data consistency and reconciliation.--Please note the quantities and values reported in
question III-9a should reconcile with the data reported in question II-7 (including export
shipments).
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period. If the calculated fields below return values other than zero (i.e., “0”),
please reconcile the tables or provide an explanation for the discrepancy below.
Full year data
Reconciliation

2015

2016

2017

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

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").

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

If no, please explain.

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If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2015, 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 CACCS from Belgium, Colombia, and/or Thailand?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

(please describe)

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III-16. Effects of imports on growth and development.--Since January 1, 2015, 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 CACCS from Belgium, Colombia, and/or
Thailand?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the issue
of stocks or bonds
Ability to service debt

Other

(please describe)

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III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
CACCS from Belgium, Colombia, and/or Thailand?
No

Yes

If yes, my firm anticipates negative effects as follows:

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.

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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Fernando Gracia
([email protected], 202-205-2747).
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

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, 2015 of the following products produced by your
firm.

NOTE.--All values and quantities should be reported in an anhydrous equivalent basis.
For purposes of this section, the terms “spot/short term” and “annual contract” sales are defined as
follows:
“Spot/short term” are any sales made pursuant to agreements of a length for less than one year.
“Annual contract” are any sales made pursuant to an annual contract (i.e., a one-year contract).
Product 1.--Citric acid, granular, in dry form in 25 kilogram and 50 pound bags, spot/short term sales.
Product 2.--Citric acid, granular, in dry form in 25 kilogram and 50 pound bags, annual contract sales.
Product 3.--Citric acid, fine granular, in dry form in 25 kilogram and 50 pound bags, spot/short term
sales.
Product 4.--Citric acid, fine granular, in dry form in 25 kilogram and 50 pound bags, annual contract
sales.
Product 5.--Citric acid, granular, in dry form packed in bulk sacks (“supersacks”), spot/short term sales.
Product 6.--Citric acid, granular, in dry form packed in bulk sacks (“supersacks”), annual contract sales.
Product 7.--Sodium citrate, granular, in dry form in 25 kilogram and 50 pound bags, spot/short term
sales.
Product 8.--Sodium citrate, granular, in dry form in 25 kilogram and 50 pound bags, annual contract
sales.
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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IV-2a. During January 2015-December 2017, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were directly 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 actual dry pounds (not 1,000s of pounds) and actual dollars (not 1,000s of dollars).

Period of shipment
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December

Product 1
Quantity
Value

(Quantity in dry 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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IV-2b. Price data.--Continued.
Report data in actual dry pounds (not 1,000s of pounds) and actual dollars (not 1,000s of dollars).

(Quantity in dry pounds, value in dollars)
Product 5
Product 6
Product 7
Quantity
Value
Quantity
Value
Quantity
Value

Product 8
Quantity
Value

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IV-2c.

Page 33

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

√ if Yes

In actual dollars (not $1,000)
In actual dry pounds (not 1,000s of dry pounds)
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-9 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.

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IV-3.

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

IV-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

IV-5.

Page 34

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

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

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

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

F.o.b.

If f.o.b., specify point

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IV-6.

Page 35

Bundling.--For each year, please provide the quantity of shipments that were bundled sales.
“Bundling” is defined as an instance in which you sold CACCS together with any other product(s)
to the same customer pursuant to the same purchase agreement/contract.
Report data in actual dry pounds (not 1,000s of pounds).
2015

2016

2017

(a) What products are bundled with CACCS sales?
(b) How does your firm assign value to CACCS in its reported pricing data given the existence of any
bundled sales?
IV-7.

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced CACCS (or check “not applicable” if your firm does not sell on a long-term, shortterm and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

Short-term contracts
(multiple deliveries
for less than 12
months)

Annual contracts
(multiple
deliveries for 12
months)

No
Quantity
Price
Both

Meet or release
provision

Yes

Indexed to raw
material prices1

Yes

Not applicable
1

Please describe method, raw material, and price index source:

365

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

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IV-8.

Page 36

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 CACCS?

Source

Share of 2017
sales

From inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

Lead time (average
number of days)

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IV-9.

Page 37

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced CACCS that is
accounted for by U.S. inland transportation costs?
percent

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(c)

Indicate the approximate percentage of your firm’s sales of CACCS that are delivered the
following distances from its production facility.
Distance from production facility

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 CACCS since January 1, 2015 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

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

CACCS

Total
(should sum to
100.0% across)

Other inputs
%

0.0 %

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

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for CACCS?
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 CACCS has changed since January 1, 2015. Explain any trends and describe
the principal factors that have affected these changes in demand.

Market
Within the United States
Outside the United States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of CACCS since January 1, 2015?
No

Yes

If yes, please describe and quantify if possible.

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

Please describe.

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
CACCS since January 1, 2015?
No

Yes

If yes, describe.

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IV-16. Certifications.-(a) Does your firm sell CACCS that have any of the following certifications?
If yes, indicate the
share of your firm’s
2017 sales that
were certified
No Yes
(percent)

Certification

Explain (including name of certifying
organization and time to certify)

Halal
Kosher
Non-GMO but not certified
or verified by any
independent organization
“Non-GMO Project” verified
Verified or certified nonGMO by other than “NonGMO Project” verified1
Other:
Other:
1

Please describe the criteria, process, and documentation that your firm considers for non-GMO
product:
(b) Has your firm’s ability to supply CACCS that have certifications changed since January 2015?
Yes
No

Increased

Decreased

If yes, please identify specific
certifications and explain.

(c) Does your firm anticipate applying to The Non-GMO Project in 2018 or 2019 or to any other
organization that certifies CACCS as non-GMO, or changes in certification status?

Yes

If yes, please describe the changes, reasons why you anticipate applying for
non-GMO certification, and certifying organization.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply CACCS since
January 1, 2015 (examples include placing customers on allocation or “controlled order entry,”

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Page 41

declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, inability to supply nonGMO CACCS, etc.)?
No

Yes

If yes, please describe.

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IV-18. Raw materials.--How have CACCS raw material prices changed since January 1, 2015?
Fluctuate
Overall
No
Overall
with no
Explain, noting how raw material price changes
increase change decrease clear trend have affected your firm’s selling prices for CACCS.

IV-19. Interchangeability.--Is CACCS 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

Belgium

Colombia

Thailand

Canada

Other countries

United
States
Belgium
Colombia
Thailand
Canada
For any country-pair producing CACCS which is sometimes or never interchangeable, please
identify the country-pair and explain the factors that limit or preclude interchangeable use:

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IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between CACCS 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

Belgium

Colombia

Thailand

Canada

Other countries

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IV-21. Customer identification.--List the names and contact information for your firm’s 5 largest U.S.
customers for CACCS since January 1, 2015. Indicate the share of the quantity of your firm’s
total shipments of CACCS that each of these customers accounted for in 2017.
Customer’s name

City

State

Share of 2017 sales
(%)

1
2
3
4
5

Customer identification.—Continued. List the names and contact information for your firm’s 5 largest
U.S. customers for non-GMO CACCS since January 1, 2015. Indicate the share of the quantity of
your firm’s total shipments of non-GMO CACCS that each of these customers accounted for in
2017.
Customer’s name
1
2
3
4
5

City

State

Share of 2017 sales
(%)

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U.S. Producers’ Questionnaire – CACCS (Final)

Page 45

IV-22. Competition from imports.-(a)

Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling CACCS
from Belgium, Colombia, and/or Thailand, did your firm:
Item

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2015: Did your firm lose sales of CACCS to imports of this
product from Belgium, Colombia, and/or Thailand?
No

Yes

IV-23. Other explanations.--If your firm would like to further explain a response to a question in Part IV
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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U.S. Producers’ Questionnaire – CACCS (Final)

Page 46

PART V.—ALTERNATIVE PRODUCT INFORMATION (non-GMO CACCS)
Further information on this part of the questionnaire can be obtained from Amelia Shister (202-2052047, [email protected]).
The Commission is requesting information on the comparability of non-GMO CACCS and GMO CACCS.
V-1.

Comparability of GMO CACCS vs. non-GMO CACCS.--For each of the following indicate whether
non-GMO CACCS and GMO CACCS are: fully comparable or the same, i.e., have no
differentiation between them; mostly comparable or similar; somewhat comparable or similar;
never or not-at-all comparable or similar; or no familiarity with products.
(a) Characteristics and Uses.--The differences and similarities in the physical characteristics
and end uses for non-GMO CACCS versus GMO CACCS.

Fully comparable

Mostly
comparable

Somewhat
comparable

Not at all
comparable

NA/no familiarity

Please provide a narrative discussion for the comparability ratings you provided in terms of their
characteristics and uses:

(b) Interchangeability.--The ability to substitute non-GMO CACCS with GMO CACCS for the
same application.
Fully
interchangeable

Mostly
interchangeable

Somewhat
interchangeable

Not at all
interchangeable

NA/no
familiarity

Please provide a narrative discussion for the comparability ratings you provided in terms of
their interchangeability:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)
V-1.

Page 47

Comparability of non-GMO CACCS vs. GMO CACCS.--Continued
(c) Manufacturing facilities, production processes, and production employees.-- Whether
non-GMO CACCS and GMO CACCS are manufactured in the same facilities, from the same
inputs, on the same machinery and equipment, and using the same employees.

Fully the same

Mostly the same

Somewhat the
same

Not at all the
same

NA/no familiarity

Please provide a narrative discussion for the comparability ratings you provided in terms of their
manufacturing processes:

(d) Channels of distribution.--Channels of distribution/market situation through which nonGMO CACCS and GMO CACCS are sold (i.e., sold direct to end users, through distributors,
etc.).

Fully comparable

Mostly
comparable

Somewhat
comparable

Not at all
comparable

NA/no familiarity

Please provide a narrative discussion for the comparability ratings you provided in terms of their
channels of distribution:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)
V-1.

Page 48

Comparability of non-GMO CACCS vs. GMO CACCS.--Continued
(e) Customer and producer perceptions.--Perceptions as to the differences and/or similarities
in non-GMO CACCS versus GMO CACCS in the market (e.g., sales/marketing practices).

Fully comparable

Mostly
comparable

Somewhat
comparable

Not at all
comparable

NA/no familiarity

Please provide a narrative discussion for the comparability ratings you provided in terms of their
customer and producer perceptions:

(f)

Price.--Whether prices are comparable or differ for non-GMO CACCS and versus GMO
CACCS.

Fully comparable

Mostly
comparable

Somewhat
comparable

Not at all
comparable

NA/no familiarity

Please provide a narrative discussion for the comparability ratings you provided in terms of their
prices:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – CACCS (Final)

Page 49

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/citric_acid_and_certain_citrate_salts_bel
gium/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: CBCT

• E-mail.--E-mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.--If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	US producer questionnaire
Subject	Title 7 investigations
Author	Carlson, Carolyn
File Modified	2018-01-18
File Created	2018-01-18