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pdfOMB No. 3117‐0016/USITC No. 18‐1‐3864; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
POLYTETRAFLOUROETHYLENE RESIN (“PTFE RESIN”) FROM CHINA AND INDIA
This questionnaire must be received by the Commission by April 13, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing and antidumping investigations concerning polytetrafluoroethylene resin (“PTFE
resin”) from China and India (Inv. Nos. 701‐TA‐588 and 731‐TA‐1392‐1393 (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 PTFE resin (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: PTFE)
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 – PTFE Resin
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to petitions filed on September 28, 2017, by
The Chemours Company FC LLC, Wilmington, Delaware. Countervailing and 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/polytetrafluoroethylene_ptfe_resin_china_and_india/fina
l.htm.
PTFE resin covered by these investigations is polytetrafluoroethylene (PTFE) resin, including but not
limited to granular, dispersion, or coagulated dispersion (also known as fine powder). PTFE is covered by
the scope of this investigation whether filled or unfilled, whether or not modified, and whether or not
containing co‐polymer additives, pigments, or other materials. Also included is PTFE wet raw polymer.
The chemical formula for PTFE is C2F4, and the Chemical Abstracts Service Registry number is 9002‐84‐
0.
PTFE further processed into micropowder, having particle size typically ranging from 1 to 25 microns,
and a melt‐flow rate no less than 0.1 gram/10 minutes, is excluded from the scope of this investigation.
PTFE is classified in the Harmonized Tariff Schedule of the United States (HTSUS) under subheadings
3904.61.0010 and 3904.61.0090. Subject merchandise may also be classified under HTSUS subheading
3904.69.5000. Although the HTSUS subheadings and CAS Number are provided for convenience and
Customs purposes, the written description of the scope is dispositive.
Reporting of information.‐‐ If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 3
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b.
TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
I‐2a.
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 PTFE resin.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Auxiliary facilities covered.‐‐Provide the city, state, zip code, and brief description of each
auxiliary facility covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table.
“Auxiliary facility”‐‐Each facility of a firm involved in the compounding or processing operations
of PTFE resin that is operated in conjunction with the establishments listed in question I‐2a.
Auxiliary facility
City, State
Zip (5 digit)
Description
covered1
1
I‐3.
1
2
3
4
5
6
Additional discussion on auxiliary facility consolidated in this questionnaire: .
Petition support.‐‐Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
China (AD)
India (AD)
India (CVD)
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
I‐4.
I‐5.
I‐6.
Page 5
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing PTFE resin from China and India into the United States or
that are engaged in exporting PTFE resin from China and India to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of PTFE resin?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Robert Casanova (202‐708‐
2719, [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 PTFE resin since January 1, 2015. (Please specify
whether these changes relate to granular PTFE, fine powder PTFE, or dispersion PTFE).
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
ceased manufacturing certain
in‐scope products
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 7
II‐3a. Production using same machinery.—
(i)
Does your firm produce products other than PTFE resin on the same equipment and
machinery as PTFE resin (any form)? Please explain.
No
Yes
If yes‐‐ Please explain
(ii)
Does your firm produce granular PTFE resin on the same equipment and machinery as
fine powder PTFE resin?
No
Yes
(iii)
If yes‐‐ Please explain
Does your firm produce granular PTFE resin on the same equipment and machinery as
dispersion PTFE resin?
No
Yes
(iv)
If yes‐‐ Please explain
Does your firm produce dispersion PTFE on the same equipment and machinery as fine
powder PTFE resin ?
No
Yes
If yes‐‐ Please explain
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating hours
per week, weeks per year.
II‐3c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity for each type of PTFE resin.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) amongst granular PTFE resin, fine powder
PTFE resin, dispersion PTFE resin, and other products using the same equipment and/or
labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
(iii)
Does your firm operate integrated facilities that manufacture TFE that is used in the
production of PTFE resin and other products such as ETFE, FEP, and PFA?
II‐4.
No
Yes
If yes—Please list the products that you firm manufactures using
internally produced TFE. Also please indicate whether shifting production
among TFE and other products in response to changing market conditions
is your firm’s normal business practice.
Tolling.‐‐Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of any type of PTFE resin?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
II‐5.
Page 9
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce PTFE resin in and/or admit PTFE resin
into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import PTFE resin into a foreign trade zone (FTZ) for use in distribution of PTFE resin
and/or the production of downstream articles?
II‐6.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2015, has your firm imported PTFE resin?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes‐‐ COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
II‐7.
Page 10
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of PTFE resin in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
II‐7.
Page 11
Production, shipment, and inventory data (granular PTFE resin).‐‐Report your firm’s production
capacity, production, shipments, and inventories related to the production of granular PTFE
resin in its U.S. establishment(s) during the specified periods
GRANULAR PTFE RESIN
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
1
2016
2017
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
2
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. 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‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
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
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
II‐8.
Page 12
Channels of distribution (granular PTFE resin).‐‐Report your firm’s U.S. shipments of granular
PTFE resin by channel of distribution.
GRANULAR PTFE RESIN
Quantity (in 1,000 pounds in dry weight)
Calendar years
Item
2015
Channels of distribution:
U.S. shipments:
To distributors (M)
2016
2017
To fillers/further processors (N)
To end users (O)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution (i.e.,
lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in
each time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must
be revised prior to submission to the Commission.
Calendar years
Reconciliation
M+ N + O – D – F – H = zero ("0"), if
not revise.
2015
2016
0
2017
0
0
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
II‐9.
Page 13
U.S. shipments by grade (granular PTFE resin). ‐‐ Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
granular PTFE resin by grade.
GRANULAR PTFE RESIN
Commodity grade.‐‐PTFE resin that does not require any qualifications for the processor or
downstream customer.
Specialty grade.‐‐PTFE resin that necessarily requires qualification for the processor or
downstream product.
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
2016
2017
U.S. shipments. ‐‐
Commodity grade:
Quantity (P)
Value (Q)
Specialty grade :
Quantity (R)
Value (S)
1
1
Please describe the products reported as "specialty grade" and outline the qualifications required for these products:
.
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for U.S. shipments by grade (i.e.,
lines P and R) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in each
time period. Please ensure that the values reported for U.S. shipments by grade (i.e., lines Q and S) in each time
period equal the value reported for U.S. shipments (i.e., lines E, G, and I).If the calculated fields below return
values other than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
Quantity: P + R – D – F – H = zero
("0"), if not revise.
Value: Q + S – E – G – I = zero ("0"), if
not revise.
2015
2016
2017
0
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 14
II‐10. U.S. shipments by type (granular PTFE resin). ‐‐ Report your firm’s U.S. shipments (i.e., inclusive
of commercial U.S. shipments, internal consumption, and transfers to related firms) of granular
PTFE resin by type in 2017.
Modified.‐‐Granular PTFE that is produced by adding a co‐monomer.
Reactor bead.‐‐Unmodified granular PTFE resin that has a much lower value than finished
products.
Fine cut.‐‐Unmodified PTFE that is processed by compression molding.
Free flow.‐‐Unmodified PTFE that is processed by automatic compression molding.
Presintered.‐‐Unmodified PTFE that is processed by ram extrusion.
GRANULAR PTFE RESIN
Quantity (in 1,000 pounds in dry weight)
Item
Calendar year 2017
U.S. shipments. ‐‐
Modified (T)
Unmodified:
Reactor bead (U)
Fine cut (V)
Free flow (W)
Presintered (X)
1
Other forms (Y)
1
Identify the other form(s):
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for U.S. shipments by type (i.e.,
lines T, U, V, W, X, and Y) in 2017 equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in 2017.
If the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised prior Jo
submission to the Commission.
Reconciliation
T + U + V + W + X + Y – D – F – H = zero ("0"), if not revise.
Calendar year 2017
0
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 15
II‐11. Employment data (granular PTFE resin).‐‐Report your firm’s employment‐related data related
to the production of granular PTFE resin 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.
“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.
GRANULAR PTFE RESIN
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:
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 16
II‐12. Production, shipment, and inventory data (fine powder PTFE resin).‐‐Report your firm’s
production capacity, production, shipments, and inventories related to the production of fine
powder PTFE resin in its U.S. establishment(s) during the specified periods
FINE POWDER PTFE RESIN
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
1
2016
2017
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
2
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. 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‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
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
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 17
II‐13. Channels of distribution (fine powder PTFE resin).‐‐Report your firm’s commercial U.S.
shipments of fine powder PTFE resin by channel of distribution.
FINE POWDER PTFE RESIN
Quantity (in 1,000 pounds in dry weight)
Calendar years
Item
2015
Channels of distribution:
U.S. shipments:
To distributors (M)
2016
2017
To fillers/further processors (N)
To end users (O)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution (i.e.,
lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in
each time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must
be revised prior to submission to the Commission.
Calendar years
Reconciliation
M+ N + O – D – F – H = zero ("0"), if
not revise.
2015
2016
0
2017
0
0
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 18
II‐14. U.S. shipments by grade (fine powder PTFE resin). ‐‐ Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
fine powder PTFE resin by grade.
FINE POWDER PTFE RESIN
Commodity grade.‐‐PTFE resin that does not require any qualifications for the processor or
downstream customer.
Specialty grade.‐‐PTFE resin that necessarily requires qualification for the processor or
downstream product.
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
2016
2017
U.S. shipments. ‐‐
Commodity grade:
Quantity (P)
Value (Q)
Specialty grade :
Quantity (R)
Value (S)
1
1
Please describe the products reported as "specialty grade" and outline the qualifications required for these products:
.
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for U.S. shipments by grade (i.e.,
lines P and R) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in each
time period. Please ensure that the values reported for U.S. shipments by grade (i.e., lines Q and S) in each time
period equal the value reported for U.S. shipments (i.e., lines E, G, and I).If the calculated fields below return
values other than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
Quantity: P + R – D – F – H = zero
("0"), if not revise.
Value: Q + S – E – G – I = zero ("0"), if
not revise.
2015
2016
2017
0
0
0
0
0
0
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U.S. Producers’ Questionnaire – PTFE Resin
Page 19
II‐15. U.S. shipments by type (fine powder PTFE resin). ‐‐ Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
fine powder PTFE resin by type in 2017.
Modified.‐‐Fine powder PTFE resin produced by adding a co‐monomer.
Broad specification.‐‐Fine powder PTFE resin that does not fit into one of the other categories.
Ultra‐high molecular weight.‐‐Fine powder PTFE resin with SSG (standard specific gravity) of
less than 2.165 (with no modifier).
FINE POWDER PTFE RESIN
Quantity (in 1,000 pounds in dry weight)
Item
Calendar year 2017
U.S. shipments.‐‐
Modified (T)
Ultra‐high molecular weight (U)
Broad specification (V)
1
Other forms (W)
1
Identify the other form(s):
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for U.S. shipments by type (i.e.,
lines T, U, V ,and W) in 2017 equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in 2017. If
the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised prior Jo
submission to the Commission.
Reconciliation
T + U + V + W – D – F – H = zero ("0"), if not revise.
Calendar year 2017
0
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U.S. Producers’ Questionnaire – PTFE Resin
Page 20
II‐16. Employment data (fine powder PTFE resin).‐‐Report your firm’s employment‐related data
related to the production of fine powder PTFE resin 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.
“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.
FINE POWDER PTFE RESIN
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:
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U.S. Producers’ Questionnaire – PTFE Resin
Page 21
II‐17. Production, shipment, and inventory data (dispersion PTFE resin).— Report your firm’s
production capacity, production, shipments, and inventories related to the production of
dispersion PTFE resin in its U.S. establishment(s) during the specified periods
DISPERSION PTFE RESIN
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
1
2016
2017
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
2
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. 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‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L= should equal zero
("0") or provide an explanation.1
1
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 – PTFE Resin
Page 22
II‐18. Channels of distribution (dispersion PTFE resin).‐‐Report your firm’s commercial U.S. shipments
of dispersion PTFE resin by channel of distribution.
DISPERSION PTFE RESIN
Quantity (in 1,000 pounds in dry weight)
Calendar years
Item
2015
Channels of distribution:
U.S. shipments:
To distributors (M)
2016
2017
To fillers/further processors (N)
To end users (O)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution (i.e.,
lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in
each time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must
be revised prior to submission to the Commission.
Calendar years
Reconciliation
M+ N + O – D – F – H = zero ("0"), if
not revise.
2015
2016
0
2017
0
0
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U.S. Producers’ Questionnaire – PTFE Resin
Page 23
II‐19. U.S. shipments by grade (dispersion PTFE resin). ‐‐ Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
dispersion PTFE resin by grade.
DISPERSION PTFE RESIN
Commodity grade.‐‐PTFE resin that does not require any qualifications for the processor or
downstream customer.
Specialty grade.‐‐PTFE resin that necessarily requires qualification for the processor or
downstream product.
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
2016
2017
U.S. shipments. ‐‐
Commodity grade:
Quantity (P)
Value (Q)
Specialty grade :
Quantity (R)
Value (S)
1
1
Please describe the products reported as "specialty grade" and outline the qualifications required for these products:
.
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for U.S. shipments by grade (i.e.,
lines P and R) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in each
time period. Please ensure that the values reported for U.S. shipments by grade (i.e., lines Q and S) in each time
period equal the value reported for U.S. shipments (i.e., lines E, G, and I).If the calculated fields below return
values other than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
Quantity: P + R – D – F – H = zero
("0"), if not revise.
Value: Q + S – E – G – I = zero ("0"), if
not revise.
2015
2016
2017
0
0
0
0
0
0
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U.S. Producers’ Questionnaire – PTFE Resin
Page 24
II‐20. U.S. shipments by type (dispersion PTFE resin). ‐‐ Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
dispersion PTFE resin by type.
Modified.‐‐Dispersion PTFE resin produced by adding a co‐monomer .
Unmodified.‐‐Dispersion PTFE resin that does include a co‐monomer additive
DISPERSION PTFE RESIN
Quantity (in 1,000 pounds in dry weight)
Item
Calendar year 2017
U.S. shipments. ‐‐
Modified (T)
Unmodified (U)
1
Other forms (V)
1
Identify the other form(s):
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for U.S. shipments by type (i.e.,
lines T, U ,and V) in 2017 equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) in each time
period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised
prior Jo submission to the Commission.
Reconciliation
T + U +V – D – F – H = zero ("0"), if not
revise.
Calendar year 2017
0
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 25
II‐21. Employment data (dispersion PTFE resin).‐‐Report your firm’s employment‐related data related
to the production of dispersion PTFE resin 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.
“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.
DISPERSION PTFE RESIN
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‐22. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a non‐
market formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 26
II‐23. Purchases (granular PTFE resin).‐‐Other than direct imports, has your firm otherwise purchased
granular PTFE resin 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:
GRANULAR PTFE RESIN
(Quantity in 1,000 pounds in dry weight)
Calendar years
Item
Purchases from U.S.
importers1 of granular PTFE
resin from—
China
2015
2016
2017
India
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:
.
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U.S. Producers’ Questionnaire – PTFE Resin
Page 27
II‐24. Purchases (fine powder PTFE resin).‐‐Other than direct imports, has your firm otherwise
purchased fine powder PTFE resin 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:
FINE POWDER PTFE RESIN
(Quantity in 1,000 pounds in dry weight)
Calendar years
Item
Purchases from U.S.
importers1 of fine powder
PTFE resin from—
China
2015
2016
2017
India
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:
.
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U.S. Producers’ Questionnaire – PTFE Resin
Page 28
II‐25. Purchases (dispersion PTFE resin).‐‐Other than direct imports, has your firm otherwise
purchased dispersion PTFE resin 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:
DISPERSION PTFE RESIN
(Quantity in 1,000 pounds in dry weight)
Calendar years
Item
Purchases from U.S.
importers1 of dispersion
PTFE resin from—
China
2015
2016
2017
India
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‐26. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 29
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
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 PTFE resin:
2. Does your firm prepare profit/loss statements for PTFE resin:
Yes
No
3. How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10 Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: GAAP, cash, tax, or other comprehensive
basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes PTFE resin, 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.).
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.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
III‐5.
Page 30
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced PTFE resin, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
III‐6.
Share of sales
Granular PTFE resin
%
Fine Powder PTFE resin
%
Dispersion PTFE resin
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of PTFE resin 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 PTFE resin
that your firm purchases from related suppliers and that are reflected in questions III‐9a
(financial results on Granular PTFE resin), III‐9c (financial results on Fine Powder PTFE resin), and
III‐9e (financial results on Dispersion PTFE resin). For “Share of total COGS” please report this
information by relevant input on the basis of your most recently completed fiscal year. For
“Input valuation” please describe the basis, as recorded in your company’s own accounting
system, of the purchase cost from the related supplier; e.g., the related supplier’s actual cost,
cost plus, negotiated transfer price to approximate fair market value.
a. Granular PTFE resin (corresponding to COGS reported in III‐9a)
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
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U.S. Producers’ Questionnaire – PTFE Resin
Page 31
b. Fine Powder PTFE resin (corresponding to COGS reported in III‐9c)
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
c. Dispersion PTFE resin (corresponding to COGS reported in III‐9e)
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
III‐8.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in questions III‐9a (financial results on
Granular PTFE resin), III‐9c (financial results on Fine Powder PTFE resin), and III‐9e (financial
results on Dispersion PTFE resin) 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 questions III‐9a, III‐9c, and III‐9e.
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U.S. Producers’ Questionnaire – PTFE Resin
Page 32
III‐9a. Operations on Granular PTFE resin.‐‐Report the revenue and related cost information
requested below on the Granular PTFE resin operations of your firm’s U.S. establishment(s).1 Do
not report resales of products. Note that internal consumption and transfers to related firms
must be valued at fair market value. Input purchases from related suppliers should be
consistent with and based on information in the firm’s accounting books and records. Provide
data for your firm’s three most recently completed fiscal years. If your firm was involved in
tolling operations (either as the toller or as the tollee), please contact David Boyland at (202)
708‐4725 before completing this section of the questionnaire.
Quantity (in 1,000 pounds dry weight) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2015
2016
2017
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Internal consumption
Transfers to related firms
0
0
0
Direct labor
Other factory costs
Total net sales quantities
2
Net sales values:
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
All other expense items
All other income items
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – PTFE Resin
Page 33
III‐9b. Granular PTFE resin other factory costs.‐‐For the total other factory costs reported in table III‐
9a, please individually identify primary cost/expense categories, representing 8 percent or more
of total other factory costs, and miscellaneous category, representing remaining total other
factory costs. The annual period sum should equal the corresponding total other factory costs
reported in table III‐9a.
Fiscal years ended‐‐
2015
2016
Other factory costs: In this column please name each primary
cost/expense category which represents 8 percent or more of
total other factory costs. The row designated “miscellaneous”
applies to remaining other factory costs/expenses, not
previously identified as a primary cost/expense. Depending
on how primary costs/expenses are classified, not all rows
may be needed.
2017
Value ($1,000)
Primary other factory costs category 1.
Primary other factory costs category 2.
Primary other factory costs category 3.
Primary other factory costs category 4.
Primary other factory costs category 5.
Primary other factory costs category 6.
Primary other factory costs category 7.
Primary other factory costs category 8.
Primary other factory costs category 9.
Primary other factory costs category 10.
Miscellaneous other factory costs.
Total (should equal total other factory costs reported in III‐9a)
In the space provide below, please describe the costs/expenses included in each identified
primary category, as well as the costs/expenses which are included in the miscellaneous
category. Please describe the extent to which identified costs/expenses changed notably during
the period examined.
Primary other factory costs category 1.
Primary other factory costs category 2.
Primary other factory costs category 3.
Primary other factory costs category 4.
Primary other factory costs category 5.
Primary other factory costs category 6.
Primary other factory costs category 7.
Primary other factory costs category 8.
Primary other factory costs category 9.
Primary other factory costs category 10.
Miscellaneous other factory costs.
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U.S. Producers’ Questionnaire – PTFE Resin
Page 34
III‐9c. Operations on Fine Powder PTFE resin.‐‐Report the revenue and related cost information
requested below on the Fine Powder PTFE resin operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that internal consumption and transfers to related firms
must be valued at fair market value. Input purchases from related suppliers should be
consistent with and based on information in the firm’s accounting books and records. Provide
data for your firm’s three most recently completed fiscal years. If your firm was involved in
tolling operations (either as the toller or as the tollee), please contact David Boyland at (202)
708‐4725 before completing this section of the questionnaire.
Quantity (in 1,000 pounds dry weight) and value (in $1,000)
Fiscal years ended‐‐
Item
2015
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 35
III‐9d. Fine Powder PTFE resin other factory costs.‐‐For the total other factory costs reported in table
III‐9c, please individually identify primary cost/expense categories, representing 8 percent or
more of total other factory costs, and miscellaneous category, representing remaining total
other factory costs. The annual period sum should equal the corresponding total other factory
costs reported in table III‐9c.
Fiscal years ended‐‐
2015
2016
Other factory costs: In this column please name each primary
cost/expense category which represents 8 percent or more of
total other factory costs. The row designated “miscellaneous”
applies to remaining other factory costs/expenses, not
previously identified as a primary cost/expense. Depending
on how primary costs/expenses are classified, not all rows
may be needed.
2017
Value ($1,000)
Primary other factory costs category 1.
Primary other factory costs category 2.
Primary other factory costs category 3.
Primary other factory costs category 4.
Primary other factory costs category 5.
Primary other factory costs category 6.
Primary other factory costs category 7.
Primary other factory costs category 8.
Primary other factory costs category 9.
Primary other factory costs category 10.
Miscellaneous other factory costs.
Total (should equal total other factory costs reported in III‐9c)
In the space provide below, please describe the costs/expenses included in each identified
primary category, as well as the costs/expenses which are included in the miscellaneous
category. Please describe the extent to which identified costs/expenses changed notably during
the period examined.
Primary other factory costs category 1.
Primary other factory costs category 2.
Primary other factory costs category 3.
Primary other factory costs category 4.
Primary other factory costs category 5.
Primary other factory costs category 6.
Primary other factory costs category 7.
Primary other factory costs category 8.
Primary other factory costs category 9.
Primary other factory costs category 10.
Miscellaneous other factory costs.
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Page 36
III‐9e. Operations on Dispersion PTFE resin.‐‐Report the revenue and related cost information
requested below on the Dispersion PTFE resin operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that internal consumption and transfers to related firms
must be valued at fair market value. Input purchases from related suppliers should be
consistent with and based on information in the firm’s accounting books and records. Provide
data for your firm’s three most recently completed fiscal years. If your firm was involved in
tolling operations (either as the toller or as the tollee), please contact David Boyland at (202)
708‐4725 before completing this section of the questionnaire.
Quantity (in 1,000 pounds dry weight) and value (in $1,000)
Fiscal years ended‐‐
Item
2015
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9f. Dispersion PTFE resin other factory costs.‐‐For the total other factory costs reported in table III‐
9e, please individually identify primary cost/expense categories, representing 8 percent or more
of total other factory costs, and miscellaneous category, representing remaining total other
factory costs. The annual period sum should equal the corresponding total other factory costs
reported in table III‐9e.
Fiscal years ended‐‐
2015
2016
Other factory costs: In this column please name each primary
cost/expense category which represents 8 percent or more of
total other factory costs. The row designated “miscellaneous”
applies to remaining other factory costs/expenses, not
previously identified as a primary cost/expense. Depending
on how primary costs/expenses are classified, not all rows
may be needed.
2017
Value ($1,000)
Primary other factory costs category 1.
Primary other factory costs category 2.
Primary other factory costs category 3.
Primary other factory costs category 4.
Primary other factory costs category 5.
Primary other factory costs category 6.
Primary other factory costs category 7.
Primary other factory costs category 8.
Primary other factory costs category 9.
Primary other factory costs category 10.
Miscellaneous other factory costs.
Total (should equal total other factory costs reported in III‐9e)
In the space provide below, please describe the costs/expenses included in each identified
primary category, as well as the costs/expenses which are included in the miscellaneous
category. Please describe the extent to which identified costs/expenses changed notably during
the period examined.
Primary other factory costs category 1.
Primary other factory costs category 2.
Primary other factory costs category 3.
Primary other factory costs category 4.
Primary other factory costs category 5.
Primary other factory costs category 6.
Primary other factory costs category 7.
Primary other factory costs category 8.
Primary other factory costs category 9.
Primary other factory costs category 10.
Miscellaneous other factory costs.
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III‐9g. Financial data reconciliation.‐‐The calculable line items from questions III‐9a, III‐9c, and III‐9e
(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‐10a. Nonrecurring items (charges and gains) included in Granular PTFE resin financial results.‐‐For
each annual period for which financial results are reported in question III‐9a, please specify all
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 report the allocated
value amount in question III‐9a in the schedule below. Note: The Commission’s objective here
is to gather information only on significant nonrecurring items which impacted financial results
reported in question III‐9a.
Fiscal years ended‐‐
2015
Nonrecurring item: In this column, please provide a brief
description of each nonrecurring item and indicate the
specific line item in question III‐9a where the nonrecurring
item is classified.
2016
2017
Nonrecurring item: In these columns, please report the amount of the relevant
nonrecurring item reported in question III‐9a.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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III‐10b. Nonrecurring items (charges and gains) included in Fine Powder PTFE resin financial results.‐‐
For each annual period for which financial results are reported in question III‐9c, please specify
all significant nonrecurring items (charges and gains) in the schedule below, the specific
question III‐9c 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‐
9c; i.e., if an aggregate nonrecurring item has been allocated to question III‐9c, only report the
allocated value amount in question III‐9c in the schedule below. Note: The Commission’s
objective here is to gather information only on significant nonrecurring items which impacted
financial results reported in question III‐9c.
Fiscal years ended‐‐
2015
Nonrecurring item: In this column, please provide a brief
description of each nonrecurring item and indicate the
specific line item in question III‐9c where the nonrecurring
item is classified.
2016
2017
Nonrecurring item: In these columns, please report the amount of the relevant
nonrecurring item reported in question III‐9c.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
III‐10c. Nonrecurring items (charges and gains) included in Dispersion PTFE resin financial results.‐‐
For each annual period for which financial results are reported in question III‐9e, please specify
all significant nonrecurring items (charges and gains) in the schedule below, the specific
question III‐9e 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‐
9e; i.e., if an aggregate nonrecurring item has been allocated to question III‐9e, only report the
allocated value amount in question III‐9e in the schedule below. Note: The Commission’s
objective here is to gather information only on significant nonrecurring items which impacted
financial results reported in question III‐9e.
Fiscal years ended‐‐
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‐9e.
specific line item in table III‐9e where the nonrecurring item is
classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
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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 questions III‐10a, III‐10b,
and/or III‐10c 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
questions III‐10a, III‐10b, and III‐10c identify where these items are reported in questions III‐9a,
III‐9c, and/or III‐9e.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of the specified PTFE resin categories. If your firm does
not maintain some or all of the specific asset information necessary to calculate total assets for
the specified PTFE resin categories 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 questions III‐9a, III‐9c, and III‐9e. Assets that are common to each
PTFE resin category should also be allocated in a manner that is consistent with cost allocations
in III‐9a, III‐9c, and III‐9e. Provide data as of the end of your firm’s three most recently
completed fiscal years. Note: Total assets should reflect net assets after any accumulated
depreciation and allowances deducted. In note 1 to each table, 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.
a. Granular PTFE resin
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Total assets (net)
1
2016
2017
Describe
b. Fine Powder PTFE resin
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Total assets (net)
1
2016
2017
Describe
c. Dispersion PTFE resin
Value (in $1,000)
Fiscal years ended‐‐
Item
1
Total assets (net)
1
Describe
2015
2016
2017
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III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for the PTFE resin categories identified
below. Provide data for your firm’s three most recently completed fiscal years. With respect to
capital expenditures and research and development expenses that are common to all PTFE
categories, please allocate to specified product category using a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in questions III‐9a, III‐9c, and III‐
9e.
a. Granular PTFE resin
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Capital expenditures
2
Research and development expenses
2016
2017
1
Please describe the nature, focus, and significance of your firm’s capital expenditures related to granular
PTFE resin.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to granular PTFE
resin.
b. Fine Powder PTFE resin
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Capital expenditures
2
Research and development expenses
2016
2017
1
Please describe the nature, focus, and significance of your firm’s capital expenditures related to fine powder
PTFE resin.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to fine powder PTFE
resin.
c. Dispersion PTFE resin
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Capital expenditures
2
Research and development expenses
1
2016
2017
Please describe the nature, focus, and significance of your firm’s capital expenditures related to dispersion
PTFE resin.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to dispersion PTFE
resin.
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III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9c, III‐9e, III‐12, and III‐13 are based on a calendar year or on your firm’s
fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a, III‐9c, III‐9e should reconcile
with the corresponding data reported in question II‐7, II‐12, II‐17 (including export shipments) as
long as they are reported on the same calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐ Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
a. Granular PTFE resin
Full year data
Reconciliation
2015
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").
2016
0
2017
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
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
0
0
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b. Fine Powder PTFE resin
Full year data
Reconciliation
2015
Quantity: Trade data from question
II‐12 (lines D, F, H, and J) less
financial total net sales quantity data
from question III‐9c, = zero ("0").
2016
0
2017
0
0
Value: Trade data from question II‐
12 (lines E, G, I, and K) less financial
total net sales value data from
question III‐9c, = zero ("0").
0
0
Do these data in question III‐9c reconcile with data in question II‐12?
Yes
No
0
If no, please explain.
c. Dispersion PTFE resin
Full year data
Reconciliation
2015
Quantity: Trade data from question
II‐17 (lines D, F, H, and J) less
financial total net sales quantity data
from question III‐9e, = zero ("0").
2016
0
2017
0
Value: Trade data from question II‐
17 (lines E, G, I, and K) less financial
total net sales value data from
question III‐9e, = zero ("0").
0
0
Do these data in question III‐9e reconcile with data in question II‐17?
Yes
No
If no, please explain.
0
0
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If your responses to any of the items in questions III‐15, III‐16, and III‐17 differ by country or type of PTFE
(granular, fine powder, or dispersion), please describe these differences and, as applicable, indicate
which country or countries or which products or products your response refers to in the relevant form
fields.
III‐15. Effects of imports on investment.‐‐Since January 1, 2016, 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 PTFE resin from China and India? Specify whether these negative effects relate to
granular, fine powder, or dispersion PTFE.
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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III‐16. Effects of imports on growth and development.‐‐Since January 1, 2016, 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 PTFE resin from China and India? Specify
whether these negative effects relate to granular, fine powder, or dispersion PTFE.
No
Yes‐‐My firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
PTFE resin from China and India? Specify whether these anticipated negative effects relate to
granular, fine powder, or dispersion PTFE.
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 Emily Burke (202‐205‐3191,
[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.‐‐ Commodity grade granular PTFE resin, fine cut, bulk density 400‐500g/L, 25‐40um
average particle size, not modified, not filled, in packages of 25kg or greater.
Product 2.‐‐ Commodity grade granular PTFE resin, free flowing, bulk density 500‐850g/L, 290‐
700um average particle size, not modified, not filled, in packages of 25kg or greater.
Product 3.‐‐ Commodity grade PTFE fine powder resin, not modified, in packages of 25kg or
greater.
Product 4.‐‐ Commodity grade PTFE fine powder resin, modified, in packages of 25kg or greater.
Product 5.‐‐ Commodity grade PTFE dispersion, general purpose, 50‐65% solid content,
packaged in drums or totes of 50 gallons or greater.
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 (a). 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 tables as appropriate.
No.‐‐Skip to question IV‐3.
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IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds in dry weight and actual dollars (not 1,000s).
Product 1
Quantity
(pounds in dry
Value
weight)
(dollars)
Product 2
Quantity
(pounds in dry
Value
weight)
(dollars)
Product 3
Quantity
(pounds in dry
Value
weight)
(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
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide
a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
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IV‐2(b). Price data (Continued).‐‐Report below the quarterly price data1 for pricing products2 produced
and sold by your firm.
Report data in actual pounds dry weight (not 1,000s) and actual dollars (not 1,000s).
Product 4
Quantity
(pounds in dry
Value
weight)
(dollars)
Product 5
Quantity
(pounds in dry
Value
weight)
(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
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the
specified product, provide a description of your firm’s product. Also, please explain any anomalies in your firm’s
reported pricing data.
Product 4:
Product 5:
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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
Value data in actual dollars (not $1,000)
Quantity data in actual pounds dry weight (not 1,000 pounds dry weight)?
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 – II‐8 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.
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If your responses to any of the questions in part IV differ by type of PTEF (granular, fine powder, or
dispersion), please describe those differences in the most appropriate narrative field provided.
IV‐3. Price setting.‐‐How does your firm determine the prices that it charges for sales of PTFE resin
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Annual
total
volume
discounts
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced PTFE resin?
Net 60
days
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic PTFE resin usually quoted (check one)?
Delivered
F.o.b.
IV‐6.
If other, describe
No
discount
policy
Net 30
days
Other
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV‐5.
Set
price
lists
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced PTFE
resin in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2017
sales
%
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced PTFE resin (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Item
Short‐term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long‐term contracts
(multiple deliveries for
more than 12 months)
Average contract
duration
No. of
days
365
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Typical sales
contract provisions
Fixed quantity
and/or price
Meet or release
provision
Not applicable
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 PTFE resin?
Share of 2017
Lead time (Average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
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Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced PTFE resin that is
accounted for by U.S. inland transportation costs? percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of PTFE resin 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 PTFE resin since January 1, 2015 (check all that apply)?
Geographic area
√ if applicable
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
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IV‐11. End uses.
(a)
List the end uses of the granular PTFE resin that your firm manufactures. For each end‐
use product, what percentage of the total cost is accounted for by granular PTFE resin
and other inputs?
Share of total cost in each of the product(s)
Total
accounted for by
(should
sum to
100.0%
Product(s) using granular
across)
PTFE resin
PTFE resin
Other inputs
% +
% =
0.0 %
% +
% =
0.0 %
% +
% =
0.0 %
(b)
List the end uses of the fine powder PTFE resin that your firm manufactures. For each
end‐use product, what percentage of the total cost is accounted for by fine powder
PTFE resin and other inputs?
Share of total cost in each of the product(s)
accounted for by
Product(s) using fine
powder PTFE resin
PTFE resin
Other inputs
Total
(should
sum to
100.0%
across)
% +
% =
0.0 %
% +
% =
0.0 %
% +
% =
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 54
(c)
List the end uses of the dispersion PTFE resin that your firm manufactures. For each
end‐use product, what percentage of the total cost is accounted for by dispersion PTFE
resin and other inputs?
Share of total cost in each of the product(s)
accounted for by
Product(s) using
dispersion PTFE resin
PTFE resin
Other inputs
Total
(should
sum to
100.0%
across)
% +
% =
0.0 %
% +
% =
0.0 %
% +
% =
0.0 %
IV‐12. Substitutes.‐‐ Can other products be substituted for PTFE resin? Please specify if the substitute
applies to only granular, fine powder, or dispersion PTFE.
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for PTFE resin?
No Yes
1.
2.
3.
Explanation
IV‐13. Demand trends.—
(a) Indicate how demand within the United States and outside of the United States (if known)
for PTFE resin has changed since January 1, 2015. Explain any trends and describe the
principal factors that have affected these changes in demand.
Market
Overall
increase
Fluctuate
with no
No
Overall
change decrease clear trend
Explanation and factors
Within the United States
Outside the United States
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 55
(b) Have demand trends since January 1, 2015 been different for different types of PTFE resin
(granular, fine powder, and/or dispersion)? If so, please describe.
No
Yes
If yes, please elaborate on how the demand trends have differed for each
type of PTFE resin.
IV‐14. Product changes.—
(a) Have there been any significant changes in the product range, product mix, or marketing
of PTFE resin since January 1, 2015? Please specify if there have been any changes specific
to granular, fine powder, or dispersion PTFE.
No
Yes
If yes, please describe and quantify if possible.
(b) Please list any specific in‐scope PTFE products that your firm ceased to manufacture and
no longer offered for sale in the U.S. market as of January 1, 2015, specifying whether
cessation of production was due to your firm’s shifting production to other products.
IV‐15. Conditions of competition.‐‐
(a) Is the PTFE resin market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to PTFE resin? If yes,
describe. Please specify if any condition of competition is specific to granular, fine powder,
or dispersion PTFE.
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
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 56
(b) If yes, have there been any changes in the business cycles or conditions of competition for
PTFE resin since January 1, 2015? Please specify if there have been any changes specific to
granular, fine powder, or dispersion PTFE.
No
Yes
If yes, describe.
IV‐16. Supply constraints.—
(a) Has your firm refused, declined, or been unable to supply PTFE resin 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.)? Please specify if
your answer applies to granular, fine powder, or dispersion PTFE.
No
Yes
If yes, please describe.
(b) Has the availability of raw materials used in the production of PTFE changed since January
1, 2015? Please specify if there have been any changes specific to granular, fine powder,
or dispersion PTFE.
No
Yes
If yes, please describe.
IV‐17. Raw materials.‐‐How have PTFE resin raw material prices changed since January 1, 2015? Please
specify if there have been any changes specific to granular, fine powder, or dispersion PTFE.
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for PTFE
resin.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 57
IV‐18. Interchangeability.‐‐Is the same form of PTFE resin (i.e., granular, fine powder, or dispersion)
produced in the United States and in other countries interchangeable (i.e., can they physically be
used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
India
Germany
Italy
Other countries
United States
China
India
Germany
Italy
For any country‐pair producing PTFE resin that is sometimes or never interchangeable,
identify the country‐pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 58
IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between the same form of PTFE
resin (i.e., granular, fine powder, or dispersion) produced in the United States and in other
countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
India
Germany
Italy
Other countries
United States
China
India
Germany
Italy
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of PTFE resin, identify the country‐pair and report the advantages
or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 59
IV‐20a. Interchangeability of grades.—Are certain grades of PTFE resin interchangeable with each other
(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 product‐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 product‐pair
Product‐pair
Specialty grade
Commodity grade
If this product pair is sometimes or never interchangeable, explain the factors that limit or
preclude interchangeable use:
IV‐20b. Interchangeability of forms.—Are certain forms of PTFE resin interchangeable with each other
(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 product‐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 product‐pair
Product‐pair
Filled PTFE
Unfilled PTFE
If this product pair is sometimes or never interchangeable, explain the factors that limit or
preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 60
IV‐21. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for PTFE resin since January 1, 2015. Indicate the share of the quantity of your firm’s
total shipments of PTFE resin that each of these customers accounted for in 2017.
Customer’s name
City
State
Share of 2017 sales (%)
1
2
3
4
5
6
7
8
9
10
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U.S. Producers’ Questionnaire – PTFE Resin
Page 61
IV‐22. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2015: To avoid losing sales to competitors selling PTFE
resin from China and India, did your firm:
Granular
Fine Powder Dispersion
Item
(b)
Yes
No
Yes
No
Yes
No
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2015: Did your firm lose sales of PTFE resin to imports of
this product from China and India?
Item
Granular
Fine
Powder
Dispersion
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.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 62
PART V.‐‐PROCESSORS/FILLERS
Further information on this part of the questionnaire can be obtained from Robert Casanova (202‐708‐
2719, [email protected]). Please contact David Boyland (202‐708‐4725,
[email protected]) regarding questions specific to the financial section of this part of the
questionnaire (questions V‐4, V‐5, and V‐6).
V‐1a. Filling operations.‐‐Since January 1, 2015, has your firm purchased unfilled PTFE resin covered
by the investigations (either domestic or imported) and further processed those purchases into
products that still match the definition of PTFE resin (i.e., filled PTFE)?
No
Yes
If yes—Please describe the nature and extent of the following items in
relation to your firm's filling/further processing operations in the United
States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Costs and activities
V‐1b. Filling operations' complexity and importance.‐‐On a scale of 1 to 5, please provide your firm's
subjective opinion as to the complexity, intensity, and importance of filling/ further processing
activities. 1 being minimally complex, intense or important; 5 being extremely complex, intense,
and important.
1:
Minimally complex,
intense, and
important
2
3
4
Please describe the reason for your rating.
5:
Extremely complex,
intense, and
important
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
V‐2.
Page 63
Production, shipment, and inventory data for filling PTFE resin.‐‐
Filling / Further Processing
Quantity (in 1,000 pounds in dry weight) and value (in $1,000)
Calendar years
Item
2015
1
2016
2017
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity) (B)
Production (quantity) using.—
Purchases of U.S.‐manufactured PTFE resin
(C)
Purchases/imports of PTFE resin from
subject sources (D)
Purchases/imports of PTFE resin from
nonsubject sources (E)
Total production (F)
0
0
0
U.S. shipments:
Commercial shipments:
Quantity (G)
Value (H)
2
Internal consumption:
Quantity (I)
2
Value (J)
2
Transfers to related firms:
Quantity (K)
2
Value (L)
3
Export shipments:
Quantity (M)
Value (N)
End‐of‐period inventories (quantity) (O)
Channels of distribution:
Commercial U.S. shipments:
To distributors (P)
To end users (Q)
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. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
V‐2.
Page 64
Production, shipment, and inventory data for filling PTFE resin.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line O) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., lines C, D, E), less total shipments (i.e., lines G, I, K, and M). 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
2015
2016
B + C + D + E – G – I – K – M – O = should
equal zero ("0") or provide an
explanation.1
2017
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines P and Q) in each time period equal the quantity reported for commercial U.S. shipments (i.e.,
line G) 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
P + Q – G = zero ("0"), if not revise.
2015
2016
0
2017
0
0
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
V‐3.
Page 65
Employment data.‐‐Report your firm’s employment‐related data related to the production of
PTFE resin using unfinished PTFE resin 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.
Filling / Further Processing
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:
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
V‐4.
Page 66
Operations on Filling / further processing PTFE resin.‐‐Report the revenue and related cost
information requested below on the filling / further processing PTFE resin operations of your
firm’s U.S. establishment(s).1 Do not report resales of products. Note that internal consumption
and transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books and
records. Provide data for your firm’s three most recently completed fiscal years. If your firm
was involved in tolling operations (either as the toller or as the tollee), please contact David
Boyland at (202) 708‐4725 before completing this section of the questionnaire.
Filling / Further Processing
Quantity (in 1,000 pounds dry weight) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
2015
2016
2017
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
2
Net sales values:
3
Cost of goods sold (COGS):
Raw materials
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
All other expense items
All other income items
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with commercial sales, internal consumption, and
transfers.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
V‐5.
Page 67
Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
your filling / further processing PTFE operations to include processing/filling, warehousing, and
sale. If your firm does not maintain some or all of the specific asset information necessary to
calculate total assets for filling / further processing PTFE operations in the normal course of
business, please estimate this information, as applicable, based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in questions III‐9a, III‐
9c, and III‐9e. Assets that are common to other PTFE resin categories, as applicable, should also
be allocated in a manner that is consistent with cost allocations in III‐9a, III‐9c, and III‐9e.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
In note 1 to the table, 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.
Filling / Further Processing
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Total assets (net)
1
V‐6.
2016
2017
Describe
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for filling / further processing PTFE resin
operations. Provide data for your firm’s three most recently completed fiscal years.
Filling / Further Processing
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Capital expenditures
2
Research and development expenses
1
2016
2017
Please describe the nature, focus, and significance of your firm’s capital expenditures related to Filling only
PTFE resin operations.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to Filling only PTFE
resin operations.
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 68
PART VI.‐‐ALTERNATIVE PRODUCT INFORMATION
Further information on this part of the questionnaire can be obtained from Robert Casanova (202‐708‐
2719. [email protected]).
VI‐1. Comparability of granular PTFE resin, fine powder PTFE resin, and dispersion PTFE resin.‐‐For
each of the following factors, indicate whether granular PTFE resin, fine powder PTFE resin, and
dispersion PTFE resin are:
F: Fully comparable or the same, i.e., have no differentiation between them;
M: Mostly comparable or similar;
S: Somewhat comparable or similar;
N: Never or not‐at‐all comparable or similar; or
0: No familiarity with products.
(a)
Characteristics and Uses. – The differences and similarities in the physical
characteristics and end uses between granular PTFE, fine powder PTFE, and dispersion
PTFE resin.
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:
Product‐pair
Comparison
Granular PTFE vs Dispersion PTFE
Granular PTFE vs Fine powder
PTFE
Fine powder PTFE vs Dispersion
PTFE
(b)
Interchangeability.‐‐The ability to substitute granular PTFE resin, fine powder PTFE
resin, and dispersion PTFE resin in the same application.
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:
Product‐pair
Comparison
Granular PTFE vs Dispersion PTFE
Granular PTFE vs Fine powder
PTFE
Fine powder PTFE vs Dispersion
PTFE
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
VI‐1.
Page 69
Comparability of granular PTFE resin, fine powder PTFE resin, and dispersion PTFE resin.—
Continued
F: Fully comparable or the same, i.e., have no differentiation between them;
M: Mostly comparable or similar;
S: Somewhat comparable or similar;
N: Never or not‐at‐all comparable or similar; or
0: No familiarity with products.
(c)
Manufacturing facilities, production processes, and production employees.—Whether
granular PTFE resin, fine powder PTFE resin, and dispersion PTFE resin are
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing processes:
Product‐pair
Comparison
Granular PTFE vs Dispersion PTFE
Granular PTFE vs Fine powder
PTFE
Fine powder PTFE vs Dispersion
PTFE
(d)
Channels of distribution.‐‐ Channels of distribution/market situation through which
granular PTFE resin, fine powder PTFE resin, and dispersion PTFE resin are sold (i.e.,
sold direct to end users, through distributors, etc.).
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:
Product‐pair
Comparison
Granular PTFE vs Dispersion PTFE
Granular PTFE vs Fine powder
PTFE
Fine powder PTFE vs Dispersion
PTFE
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
VI‐1.
Page 70
Comparability of granular PTFE resin, fine powder PTFE resin, and dispersion PTFE resin.—
Continued
F: Fully comparable or the same, i.e., have no differentiation between them;
M: Mostly comparable or similar;
S: Somewhat comparable or similar;
N: Never or not‐at‐all comparable or similar; or
0: No familiarity with products.
(e)
Customer and producer perceptions.‐‐Perceptions as to the differences and/or
similarities in granular PTFE resin, fine powder PTFE resin, and dispersion PTFE resin in
the market (e.g., sales/marketing practices).
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
consumer and producer perception:
Product‐pair
Comparison
Granular PTFE vs Dispersion PTFE
Granular PTFE vs Fine powder
PTFE
Fine powder PTFE vs Dispersion
PTFE
(f)
Price.‐‐Whether prices are comparable or differ between granular PTFE resin, fine
powder PTFE resin, and dispersion PTFE resin
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:
Product‐pair
Comparison
Granular PTFE vs Dispersion PTFE
Granular PTFE vs Fine powder
PTFE
Fine powder PTFE vs Dispersion
PTFE
Business Proprietary
U.S. Producers’ Questionnaire – PTFE Resin
Page 71
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/701731/2018/polytetrafluoroethylene_ptfe_resi
n_china_and_india/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: PTFE
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - PRO Q for TESTING ONLY |
| Author | mary.messer |
| File Modified | 2018-03-26 |
| File Created | 2018-03-26 |