Form 18-1-3824 US producers' questionnaire

OMB No. 3117-0016/USITC No. 18-1-3824; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
LARGE DIAMETER WELDED PIPE (LDWP)
FROM CANADA, CHINA, GREECE, INDIA, KOREA, AND TURKEY
This questionnaire must be received by the Commission by January 31, 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 duty and antidumping duty investigations concerning large diameter welded pipe
(“LDWP”) from Canada, China, Greece, India, Korea, and Turkey (Inv. Nos. 701-TA-593-596 and 731-TA-1401-1406
(Preliminary)). 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 LDWP (as defined on next page) at any time since January 1, 2015?

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: PIPE)
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 – LDWP (Prelim)

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PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on January 17, 2018, by
American Cast Iron Pipe Company (Birmingham, Alabama), Berg Steel Pipe Corp. (Panama City, Florida),
Berg Spiral Pipe Corp. (Mobile, Alabama), Dura-Bond Industries, Inc. (Export, Pennsylvania), Skyline Steel
(Newington, Virginia), and Stupp Corporation (Baton Rouge, Louisiana). 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/701731/2018/large_diameter_pipe_canada_china_greece_india/prelim
inary.htm.
LDWP covered by these investigations is welded carbon and alloy steel pipe, more than 406.4 mm (16
inches) in nominal diameter (large diameter welded pipe), regardless of wall thickness, length, surface
finish, grade, end finish, or stenciling. Large diameter welded pipe may be used to transport oil, gas,
steam, slurry, or other liquids. It may also be used for structural purposes, including piling. Specifically
not included is large diameter welded pipe produced only to specifications of the American Water
Works Association ("AWWA") for water and sewage pipe.
Large diameter welded pipe used to transport oil, gas, or natural gas liquids is normally produced to the
American Petroleum Institute (“API”) specification 5L. Large diameter welded pipe may also be
produced to American Society for Testing and Materials (“ASTM”) standards A500, A252, or A53. Large
diameter welded pipe can be produced to comparable foreign specifications or to proprietary grades, or
can be non-graded material. All pipe meeting the physical description set forth above is covered by the
scope of these investigations, whether or not produced according to a particular standard.
Subject merchandise also includes large diameter welded pipe that has been further processed in a third
country, including but not limited to coating, painting, notching, beveling, cutting, punching, welding, or
any other processing that would not otherwise remove the merchandise from the scope of the
investigation if performed in the country of manufacture of the in-scope large diameter welded pipe.
The large diameter welded pipe that is subject to these investigations is currently classifiable in the
Harmonized Tariff Schedule of the United States (HTSUS) under subheadings 7305.11.1030,
7305.11.1060, 7305.11.5000, 7305.12.1030, 7305.12.1060, 7305.12.5000, 7305.19.1030, 7305.19.1060,
7305.19.5000, 7305.31.4000, 7305.31.6090, 7305.39.1000, and 7305.39.5000. While the HTSUS
subheadings are provided for convenience and customs purposes, the written description of the scope
of this investigation 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.

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U.S. Producers’ Questionnaire – LDWP (Prelim)

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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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of LDWP and your responses to the questions in Part I of the
producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for use
in connection with (and only in connection with) its requirement pursuant to section 702(c)(4)/732(c)(4)
of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning the extent of
industry support for the petition requesting this proceeding. Any information provided to Commerce
will be transmitted under the confidentiality and release guidelines set forth above. Your response to
these questions constitutes your consent that such information be provided to Commerce under the
conditions described above.

Business Proprietary
U.S. Producers’ Questionnaire – LDWP (Prelim)
I-1a.

Page 4

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

I-2.

No

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 LDWP, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

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U.S. Producers’ Questionnaire – LDWP (Prelim)
I-3.

Page 5

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

Support

Oppose

Take no position

Canada AD
China AD
China CVD
Greece AD
India AD
India CVD
Korea AD
Korea CVD
Turkey AD
Turkey CVD
I-4.

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

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing LDWP from Canada, China, Greece, India, Korea, and
Turkey into the United States or that are engaged in exporting LDWP from Canada, China,
Greece, India, Korea, and Turkey to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – LDWP (Prelim)
I-6.

Page 6

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – LDWP (Prelim)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Abu B. Kanu (202-205-2597,
[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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of LDWP 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 – LDWP (Prelim)
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 LDWP, 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-7. If,
however, your firm does produce out-of-scope merchandise using the same machinery and
equipment as scope mercandhise (i.e., you have reported data for "other products" in this
question), then the "average production capacity" reported in question II-7 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-7 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 short tons)
Calendar years
Item

2015

2016

2017

Electric resistance welding (“ERW”)
ERW overall production capacity
ERW production of:
LDWP1
Other products1
Total
Table continued on next page.

0

0

0

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-3a.

Page 9

Production using same machinery.--Continued
Quantity (in short tons)
Calendar years
Item

2015

2016

2017

Helical (Spiral) submerged arc welding (“HSAW”)
HSAW overall production capacity
HSAW production of:
LDWP1
Other products2
Total

0

0

0

Longitudinal submerged arc welding (“LSAW”)
LSAW overall production capacity
LSAW production of:
LDWP1
Other products3
Total

0

1

0

Please identify these products made on ERW machinery:
Please identify these products made on HSAW machinery:
3
Please identify these products made on LSAW machinery:
2

.

0

.
.

RECONCILIATION OF PRODUCTION.--Please ensure that the quantities reported for production of LDWP (i.e., ERW,
HSAW, and LSAW combined) in this table in each time period equal the quantity reported for production of LDWP
(i.e., line C) in question 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
ERW + HSAW + LSAW – C = zero ("0"), if
not revise.

2015

2016
0

2017
0

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.

0
hours

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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 LDWP and other products using
the same equipment and/or labor?
No

(ii)

II-4.

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

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

Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of LDWP?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

Yes

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

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-5.

Page 11

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce LDWP in and/or admit LDWP 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.

No

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

(b)

No

II-6.

Yes

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

Yes

If yes--Identify the firms and the FTZs.

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

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-7.

Page 12

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of LDWP 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.

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-7.

Page 13

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

2015

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)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
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. Does your firm use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide
the data above at fair market value).
3
Identify your firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod 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

2015

2016
0

2017
0

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

0
.

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-8.

Page 14

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in short tons)
Calendar years
Item

2015

2016

2017

Channels of distribution:
Commercial U.S. shipments:
To distributors (M)
To end users (N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e., lines
M and N) in each time period equal the quantity reported for commercial U.S. shipments (i.e., line D) in each time
period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised
prior to submission to the Commission.

Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.

2015

2016
0

2017
0

0

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-9.

Page 15

U.S. shipments by grade.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by grade. Classify LDWP that is
certified to multiple specifications or standards according to the most demanding specification
or standard.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item

2015

2016

2017

U.S. shipments:
API 5L / grade B:
Quantity (O)
Value (P)
X-40-49:
Quantity (Q)
Value (R)
X-50-59:
Quantity (S)
Value (T)
X-60-69:
Quantity (U)
Value (V)
X-70-79:
Quantity (W)
Value (X)
X-80 and above:
Quantity (Y)
Value (Z)
Other line pipe:
Quantity (AA)
Value (AB)
ASTM (A500, A252, A53):
Quantity (AC)
Value (AD)
Other:1
Quantity (AE)
Value (AF)
US shipments:
Quantity
Value
1

Please describe these products:

0

0

0

0

0

0

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-9.

Page 16

US shipments by grade.--Continued

RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities and values US shipments by grade and
manufacture (i.e., lines O through AF) in each period in this question equal the quantities and values reported for
U.S. shipments (i.e., lines D through I) in each period 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: O + Q + S + U + W + Y + AA
+ AC + AE– D – F – H = zero ("0"), if
not revise.

0

0

0

Value: P + R + T + V + X + Z + AB + AD
+ AF– E – G – I = zero ("0"), if not
revise.

0

0

0

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-10.

Page 17

U.S. shipments by diameter sizes and type of manufacture.--Report your firm’s U.S. shipments
(i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to related
firms) by diameter size and type of manufacture.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2015

2016

2017

U.S. shipments:
ERW:
>16 in OD <= 24 inch OD:
Quantity (AG)
Value (AH)
>24 in OD <= 48 inch OD:
Quantity (AI)
Value (AJ)
>48 in OD:
Quantity (AK)
Value (AL)
HSAW:
>16 in OD <= 24 inch OD:
Quantity (AM)
Value (AN)
>24 in OD <= 48 inch OD:
Quantity (AO)
Value (AP)
>48 in OD:
Quantity (AQ)
Value (AR)
LSAW:
>16 in OD <= 24 inch OD:
Quantity (AS)
Value (AT)
>24 in OD <= 48 inch OD:
Quantity (AU)
Value (AV)
>48 in OD:
Quantity (AW)
Value (AX)
US shipments:
Quantity
Value

0

0

0

0

0

0

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-10.

Page 18

U.S. shipments by diameter sizes and type of manufacture.--Continued

RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities and values reported for U.S. shipments in this
question (i.e., lines AG through AX) in each time period equal the quantities and values reported for U.S. shipments
(i.e., lines D through I) 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

2015

2016

2017

Quantity: AG + AI + AK + AM + AO + AQ
+ AS + AU + AW – D – F – H = zero ("0"),
if not revise.

0

0

0

Value: AH + AJ + AL + AN + AP + AR + AT
+ AV + AX – E – G – I = zero ("0"), if not
revise.

0

0

0

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U.S. Producers’ Questionnaire – LDWP (Prelim)
II-11.

Page 19

Employment data.--Report your firm’s employment-related data related to the production of
LDWP 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.
“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

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-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 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 – LDWP (Prelim)
II-14.

Page 20

Purchases.--Other than direct imports, has your firm otherwise purchased LDWP 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 short tons)
Calendar years
Item

2015

2016

2017

Purchases from U.S.
importers1 of LDWP from—
Canada
China
Greece
India
Korea
Turkey
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1

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

II-12.

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

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U.S. Producers’ Questionnaire – LDWP (Prelim)

Page 21

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Joanna Lo (202-205-1888, [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

III-2.

Accounting system.--Briefly describe your firm’s financial accounting system.
A.

When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:

Note.--Please note that we are requesting that firms report their financial data
on a calendar year basis.
B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include LDWP:

2.

Does your firm prepare profit/loss statements for LDWP:
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,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

3.

4.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes LDWP, 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 – LDWP (Prelim)

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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 LDWP, and provide the share of net sales accounted for by these products in calendar
year 2017.
Products

Share of sales in 2017

LDWP

%
%
%
%
%

III-6.

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

Input valuation basis as recorded in the firm’s accounting books and records

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U.S. Producers’ Questionnaire – LDWP (Prelim)
III-8.

Page 23

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 LDWP) 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 question III-9a.

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III-9a. Operations on LDWP.--Report the revenue and related cost information requested below on the
LDWP 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 recent
calendar years. If your firm was involved in tolling operations (either as the toller or as the
tollee), please contact Joanna Lo at (202) 205-1888 or [email protected] before completing
this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2015

2016

2017

2

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

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor (J)
Other factory costs (K)
Total COGS (L)
Gross profit or (loss) (M)
Selling, general, and administrative (SG&A)
expenses:
Selling expenses (N)
General and administrative expenses (O)
Total SG&A expenses (P)
Operating income (loss) (Q)
Other expenses and income:
Interest expense (R)
All other expense items (S)
All other income items (T)
Net income or (loss) before income taxes (U)
Depreciation/amortization included above (V)
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

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III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities (row D) and values (row H), total COGS (row L), gross profit (or loss) (row M), total
SG&A (P), operating income (or loss) (row Q), and net income (or loss) (row U)) 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 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 III9a; 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
description of each nonrecurring item and indicate the
relevant nonrecurring item reported in question III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

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U.S. Producers’ Questionnaire – LDWP (Prelim)

Page 26

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 (allocated to LDWP).--Report the total assets (i.e., both current and long-term
assets) associated with the production, warehousing, and sale of LDWP. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for
LDWP 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 recent calendar years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject LDWP only 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)
1

III-13.

2015

2016

2017

1

Describe

Capital expenditures and research and development expenses (allocated to LPWP).--Report
your firm’s capital expenditures and research and development expenses for LDWP. Provide
data for your firm’s three most recent calendar years.
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.

2

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 indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on calendar years:
Yes

No

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period. 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

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").

0

0

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.

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Page 28

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 LDWP from Canada, China, Greece, India, Korea, and/or Turkey?
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 LDWP from Canada, China, Greece, India, Korea,
and/or Turkey?
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
LDWP from Canada, China, Greece, India, Korea, and/or Turkey?
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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Page 31

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Aimee Larsen (202-2053179, [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

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.
Product 1.—Line pipe, 42” OD, 0.600”- 1.000” wall, API 5L X52-X70, regardless of length
Product 2.—Line pipe, 32”- 36” OD, 0.350”- 0.800” wall, API 5L X52-X70, regardless of length
Product 3.—Line pipe, 26”- 30” OD, 0.350”- 0.800” wall, API 5L X52-X70, regardless of length
Product 4.—Structural pipe, 18”- 24” OD, 0.375”- 0.750” wall, ASTM A252, A1035, or similar,
regardless of length
Product 5.—Structural pipe, >24”- 32” OD, 0.500”- 1.000” wall, ASTM A252, A1035, or similar,
regardless of length
Product 6.—Line pipe, 20”- 24” OD, 0.300”- 0.500” wall, API 5L X60-X70, regardless of length

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).
IV-2

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 competitive with these
products)?
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire – LDWP (Prelim)
IV-2.

Page 32

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Period of shipment
Quantity
Value
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
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Sales by type of manufacture.--Please also indicate the percentage of your firm’s total sales by the type of manufacture method
(ERW, HSAW, LSAW) for each pricing product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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U.S. Producers’ Questionnaire – LDWP (Prelim)
IV-2.

Page 33

Price data.--Continued
Report data in short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Period of shipment
Quantity
Value
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
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Sales by type of manufacture.--Please also indicate the percentage of your firm’s total sales by the type of manufacture method
(ERW, HSAW, LSAW) for each pricing product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
Product 6:

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IV-2 (c). 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)?
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-7 in each year?
IV-2 (d). Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

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

Business Proprietary
U.S. Producers’ Questionnaire – LDWP (Prelim)
IV-3.

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

IV-4.

Contracts

Other

If other, describe

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 LDWP?
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 LDWP usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 35

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced LDWP
in 2017 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term contract
basis, and (4) spot sales basis?

Share of 2017
sales

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

Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

%

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U.S. Producers’ Questionnaire – LDWP (Prelim)
IV-7.

Page 36

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced LDWP (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)

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

365

No
Quantity

Meet or release
provision

Price
Both
Yes
No

Not applicable
IV-8.

Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced LDWP?

Source

Share of 2017
sales

Lead time (Average
number of days)

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

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U.S. Producers’ Questionnaire – LDWP (Prelim)
IV-9.

Page 37

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced LDWP 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 LDWP 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 LDWP 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 LDWP that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by LDWP and other inputs?
Share of total cost of end use product
accounted for by
End use product

LDWP

Total
(should sum to
100.0% across)

Other inputs
%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Substitutes.--Can other products be substituted for LDWP?
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 LDWP?
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 LDWP 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 LDWP since January 1, 2015?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a) Is the LDWP market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to LDWP? 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
LDWP since January 1, 2015?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply LDWP since
January 1, 2015 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

IV-17. Raw materials.--How have LDWP raw material prices changed since January 1, 2015?
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 LDWP.

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IV-18. Interchangeability.--Is LDWP 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

Canada

China

Greece

India

Korea

Turkey

Other
countries

United States
Canada
China
Greece
India
Korea
Turkey
For any country-pair producing LDWP that is sometimes or never interchangeable, identify the countrypair and explain the factors that limit or preclude interchangeable use:

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IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between LDWP 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

Canada

China

Greece

India

Korea

Turkey

Other
countries

United States
Canada
China
Greece
India
Korea
Turkey
For any country-pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of LDWP, identify the country-pair and report the advantages or disadvantages
imparted by such factors:

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IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for LDWP since January 1, 2015. Indicate the share of the quantity of your firm’s total
shipments of LDWP that each of these customers accounted for in 2017.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2017
sales
(%)

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IV-21. Competition from imports
(a)

Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling LDWP
from Canada, China, Greece, India, Korea, and Turkey, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2015: Did your firm lose sales of LDWP to imports of this
product from Canada, China, Greece, India, Korea, and Turkey?
No

(c)

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: PIPE)

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.

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2017/tool_chests_and_cabinets_china_a
nd_vietnam/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: PIPE

• 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.