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pdfOMB No. 3117‐0016/USITC No. 18‐1‐3872; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
STEEL WHEELS FROM CHINA
This questionnaire must be received by the Commission by April 10, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping duty investigations concerning steel wheels from China (Inv.
Nos. 701‐TA‐602 and 731‐TA‐1412 (Preliminary)). The information requested in the questionnaire is requested under the
authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a
subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced steel wheels (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: WHEEL)
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 ‐ Steel wheels
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on March 27, 2018, by
Accuride Corporation, Evansville, Indiana, and Maxion Wheels Akron LLC, Akron, Ohio. Countervailing
and/or antidumping duties may be assessed on the subject imports as a result of these proceedings if
the Commission makes an affirmative determination of injury, threat, or material retardation, and if the
U.S. Department of Commerce (“Commerce”) makes an affirmative determination of subsidization
and/or dumping. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/steel_wheels_china/preliminary.htm.
Steel wheels covered by these investigations are certain on‐the‐road steel wheels for use with tubeless
tires with a wheel diameter of 22.5 inches and 24.5 inches. Certain on‐the‐road wheels with a wheel
diameter of 22.5 inches and 24.5 inches are generally designed, manufactured, and offered for sale for
use on road and highway surfaces by Class 6, 7, and 8 commercial vehicles, including tractors, semi‐
trailers, dump trucks, garbage trucks, concrete mixers, and buses, and are the current standard wheel
diameters for such applications. The standard widths of certain steel wheels are 7.5 inches, 8.25 inches,
and 9.0 inches, but all certain steel wheels, regardless of width, are covered by the scope. While 22.5
inches and 24.5 inches are standard wheel sizes used by Class 6, 7, and 8 commercial trucks, their
trailers, buses, and other commercial vehicles, and have been for several decades, these petitions are
intended to cover new sizes that may be adopted for use on Class 6, 7, and 8 commercial vehicles.
The scope includes “hub‐piloted” steel wheels and “stud‐piloted” steel wheels and includes rims and
discs for such wheels, whether imported as an assembly or separately. The scope includes wheels, discs,
and rims, of carbon and/or alloy composition, whether cladded or not cladded, whether finished or not
finished, and whether coated or uncoated. All on‐the‐road wheels sold in the United States are subject
to the requirements of the National Highway Traffic Safety Administration and bear markings, such as
the “DOT” symbol, indicating compliance with applicable motor vehicle standards. The scope includes
steel wheels imported with and without the required markings, which may be added after importation.
Steel wheels imported as an assembly with a tire mounted on the wheel or with a valve stem attached
are included. However, if the steel wheels are imported as an assembly with a tire mounted on the
wheel or with a valve stem attached, the tire or valve stem is not covered by the scope.
Excluded from the scope are steel wheels for use with tube‐type tires. Also excluded from the scope are
wheels where steel represents less than fifty percent of the product by weight (e.g., aluminum wheels).
Steel wheels manufactured and offered for sale primarily for off‐highway or off‐the‐road use are also
excluded from the scope. Such wheels are not required to meet the National Highway Traffic Safety
Administration’s requirements. Steel wheels that meet the National Highway Traffic Safety
Administration’s requirements, but can be used off‐road, are included in the scope.
Imports of the subject merchandise are provided for under the following categories of the Harmonized
Tariff Schedule of the United States ("HTSUS"): 8708.70.4530, 8708.70.4560, 8708.70.6030,
8708.70.6060, 8716.90.5045, and 8716.90.5059. Wheels meeting the scope description may also enter
under the following HTSUS subheadings: 4011.20.1015, 4011.20.5020, and 8708.99.4850. While HTSUS
subheadings are provided for convenience and customs purposes, the written description of the subject
merchandise is dispositive.
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 3
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of steel wheels and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
I‐1a.
Page 4
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b. TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
I‐2.
Page 5
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 steel wheels, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐3.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Petition support.‐‐Does your firm support or oppose the petition?
Country
I‐4.
Support
Oppose
Take no position
China ‐ AD
China ‐ CVD
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
I‐5.
I‐6.
Page 6
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing steel wheels from China into the United States or that are
engaged in exporting steel wheels from China to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of steel wheels?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 7
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [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 steel wheels since January 1, 2015.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 8
II‐3a. Alternative production: heavy duty steel wheels for tube‐type tires.‐‐Did your firm produce
heavy duty steel wheels for use with tube‐type tires in 2017 at any U.S. facility (i.e. not limited
to facilities that produce in‐scope steel wheels)?
“Heavy duty steel wheels for tube‐type tires” – Wheels which are 20” to 24.5” in diameter and
used on class 6, 7, and 8 vehicles (by gross vehicle weight rating), and which are used for tube‐
type tires.
No
Yes
If yes‐‐ Complete the table below. (U.S. shipments are inclusive of
commercial U.S. shipments, internal consumption, and transfers to related
firms.)
Quantity (in actual number of wheels) and value (in $1,000)
Calendar year
Item
2017
Production (quantity)
U.S. shipments:
Quantity
Value
II‐3b. Alternative production: heavy duty non‐standard size steel wheels.‐‐Did your firm produce
heavy duty non‐standard size steel wheels for use with tubeless tires in 2017 at any U.S. facility
(i.e. not limited to facilities that produce in‐scope steel wheels)?
“Heavy duty non‐standard steel wheels” – Wheels with wheel diameters other than 22.5” or
24.5” in diameter and used on class 6, 7, and 8 vehicles (by gross vehicle weight rating).
No
Yes
If yes‐‐ Complete the table below. (U.S. shipments are inclusive of
commercial U.S. shipments, internal consumption, and transfers to related
firms.)
Quantity (in actual number of wheels) and value (in $1,000)
Calendar year
Item
2017
Production (quantity)
1
U.S. shipments:
Quantity
Value
1
Please identify the diameter sizes of these non‐standard wheels: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
II‐3c.
Page 9
Alternative production: steel wheels for light and medium class vehicles.‐‐Did your firm
produce steel wheels for light and medium class vehicles in 2017 at any U.S. facility, (i.e. not
limited to facilities that produce in‐scope steel wheels)?
“Steel wheels for light and medium class vehicles” – Steel wheels used on Class 1 through 5
vehicles (by gross vehicle weight rating).
No
Yes
If yes‐‐ Complete the table below. (U.S. shipments are inclusive of
commercial U.S. shipments, internal consumption, and transfers to related
firms.)
Quantity (in actual number of wheels) and value (in $1,000)
Calendar year
Item
Production (quantity)
U.S. shipments:
Quantity
Value
2017
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 10
II‐3d. Alternative production: aluminum wheels.‐‐Did your firm produce aluminum wheels in 2017 at
any U.S. facility, (i.e. not limited to facilities that produce in‐scope steel wheels)?
“Heavy duty aluminum wheels” – Wheels where the primary material in their manufacture is
aluminum (steel represents less than fifty percent of the product by weight) for use on class 6, 7,
or 8 vehicles.
“Light and medium duty aluminum wheels” – Wheels where the primary material in their
manufacture is aluminum (steel represents less than fifty percent of the product by weight) for
use on class 1 to 5 vehicles.
No
Yes
If yes‐‐ Complete the table(s) below. (U.S. shipments are inclusive of
commercial U.S. shipments, internal consumption, and transfers to related
firms.)
Quantity (in actual number of wheels) and value (in $1,000)
Calendar year
Item
2017
Heavy duty aluminum wheels:
Production (quantity)
U.S. shipments:
Quantity
Value
Quantity (in actual number of wheels) and value (in $1,000)
Calendar year
Item
2017
Light and medium duty
aluminum wheels:
Production (quantity)
U.S. shipments:
Quantity
Value
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 11
II‐4a. Production using same machinery.‐‐Please report your firm’s production of products made on
the same equipment and machinery or using the same employees used to produce steel wheels,
and the combined production capacity on this shared equipment and machinery or employees
the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your establishment(s) could
reasonably have expected to attain during the specified periods. Assume normal operating conditions
(i.e., using equipment and machinery in place and ready to operate; normal operating levels (hours per
week/weeks per year) and time for downtime, maintenance, repair, and cleanup).
Note.‐‐If your firm does not produce any out‐of‐scope merchandise on the same machinery and
equipment or using the same employees as scope merchandise (i.e., you have reported no data for the
various out‐of‐scope products in this question) then the "overall production capacity" numbers reported
in this question should be exactly equal to the "average production capacity" numbers reported in
question II‐8. If, however, your firm does produce out‐of‐scope merchandise using the same machinery
and equipment as scope mercandhise, then the "average production capacity" reported in question II‐8
should exclude the portion of "overall production capacity" that was used to produce this out‐of‐scope
merchandise (i.e., "average production capacity" in question II‐8 should be smaller than "overall
production capacity" in this question).
“Production” – All production in your U.S. establishment(s), including production consumed internally
within your firm and production for another firm under a toll agreement.
Note.‐‐Note out‐of‐scope production reported in this table should be limited to such production that is
produced using the same equipment and machinery or using the same employees as in‐scope steel
wheels (unlike data in questions II‐3a through II‐3d which related to all U.S. production regardless of
whether the production used the same machinery and equipment or employees).
Quantity (in actual number of wheels)
Calendar years
Item
Overall production capacity
2016
2017
0
0
0
Heavy duty non‐standard size steel wheels for
use with tubeless tires
Steel wheels for light and medium class vehicles
Aluminum wheels
0
0
0
0
0
0
Production of:
Steel wheels1
Out of scope production:
Heavy duty steel wheels for use with tube‐type
tires
2
Other products
Subtotal, out‐of‐scope
Total
1
2015
Data entered for production of steel wheels will populate here once reported in question II‐8.
2
Please identify these products: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 12
II‐4b. Operating parameters.‐‐The production capacity reported in II‐3a is based on the following
operating paramaters:
Hours per week
II‐4c.
Weeks per year
Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐4d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐4e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between steel wheels and other products
using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐5.
Tolling.‐‐Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of steel wheels?
“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 ‐ Steel wheels
II‐6.
Page 13
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce steel wheels in and/or admit steel
wheels 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 steel wheels into a foreign trade zone (FTZ) for use in distribution of steel wheels
and/or the production of downstream articles?
II‐7.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2015, has your firm imported steel wheels?
“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 ‐ Steel wheels
II‐8.
Page 14
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of steel wheels 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 ‐ Steel wheels
II‐8.
Page 15
Production, shipment, and inventory data.‐‐Continued
Quantity (in actual number of wheels) 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)
Internal consumption:2
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. 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: .
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 ‐ Steel wheels
II‐9.
Page 16
Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution
during the specific periods.
Quantity (in actual number of wheels); Value (in $1,000)
Calendar years
Item
2015
U.S. shipments:
To truck OEMs
Quantity (M)
Value (N)
To trailer OEMs
Quantity (O)
Value (P)
To other OEMs
Quantity (Q)
Value (R)
2016
2017
1
To aftermarket
Quantity (S)
Value (T)
1
This category includes aftermarket or replacement distributors, original equipment service (“OES”) providers (both
product distribution centers and dealer direct shipments), and other aftermarket firms.
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through T) in each time period equal the quantity and value reported for U.S.
shipments (i.e., line D through I) in each time period in question II‐8. If the calculated fields below return values
other than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
2015
2016
2017
Quantity: M + O + Q + S– D – F – H =
zero ("0"), if not revise.
0
0
0
Value: N + P + R + T– E – G – I = zero
("0"), if not revise.
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 17
II‐10. US shipments by product type.‐‐Report your firm’s U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) by type of product during
the specific periods.
Calendar years
Item
2015
U.S. shipments:
Carbon steel: 22.5 diameter
Quantity (U) in units
2016
2017
Weight (V) in kilograms
Value (W) in $1,000
Carbon steel: 24.5 diameter
Quantity (X) in units
Weight (Y) in kilograms
Value (Z) in $1,000
Alloy steel: 22.5 diameter
Quantity (AA) in units
Weight (AB) in kilograms
Value (AC) in $1,000
Alloy steel: 24.5 diameter
Quantity (AD) in units
Weight (AE) in kilograms
Value (AF) in $1,000
RECONCILIATION OF U.S. SHIPMENTS.‐‐Please ensure that the quantities and values reported for U.S. shipments
by product type (i.e., lines U through AF) in each time period equal the quantity and value reported for U.S.
shipments (i.e., line D through I) in each time period in question II‐8. If the calculated fields below return values
other than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
2015
2016
2017
Quantity: U + X + AA + AD– D – F – H
= zero ("0"), if not revise.
0
0
0
Value: W + Z + AC + AF– E – G – I =
zero ("0"), if not revise.
0
0
0
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 18
II‐11. Employment data.‐‐Report your firm’s employment‐related data related to the production of
steel wheels and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2015
2016
2017
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐12. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a 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.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 19
II‐13. Purchases.‐‐Other than direct imports, has your firm otherwise purchased steel wheels 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.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐ Report such purchases below and explain the reasons for your
firms' purchases:
(Quantity in actual number of wheels)
Calendar years
Item
Purchases from U.S.
importers1 of steel wheels
from—
China
2015
2016
2017
Canada
Mexico
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‐14. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 20
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202‐205‐3432,
[email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain
below:
Note.‐‐Please note that we are requesting that firms report their financial data
on a calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include steel wheels:
2. Does your firm prepare profit/loss statements for steel wheels:
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 steel wheels, as well as
specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire ‐ Steel wheels
III‐4.
Page 21
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced steel wheels, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Share of sales
Steel wheels
%
%
%
%
%
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U.S. Producers’ Questionnaire ‐ Steel wheels
III‐6.
Page 22
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of steel wheels 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 detailed.‐‐Please identify the inputs used in the production of
steel wheels that your firm purchases from related suppliers and that are reflected in question
III‐9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation 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 III‐9a (financial results on steel wheels)
in a manner consistent with your firm’s accounting books and records.
Yes
No
If yes‐‐ In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a:
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 23
III‐9a. Operations on steel wheels.‐‐Report the revenue and related cost information requested below
on the steel wheels 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 calendar
years. If your firm was involved in tolling operations (either as the toller or as the tollee), please contact
Charles Yost (202‐205‐3432, [email protected]) before completing this section of the
questionnaire.
Quantity (in actual number of wheels) and value (in $1,000)
Calendar years‐‐
Item
2015
2016
2017
2
Net sales quantities:
Commercial sales (“CS”)
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 COGS
0
0
0
Gross profit or (loss)
0
0
0
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
Net income or (loss) before income taxes
Depreciation/amortization included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 24
III‐9b. Raw materials for steel wheels.‐‐Please indicate the share of total raw material costs reported
in III‐9a in 2017 for the following raw material inputs:
Share of total raw
material costs
Products
(percent)
Steel costs
%
1
Other material inputs
%
Total (should sum to 100 percent)
0.0 %
1
Please indicate any other notable "other" raw materials not expressly identified above
(such as paint or coating materials) and provide the share of the total raw material costs that
they account for:
III‐9c. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes
No
If 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.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 25
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III‐9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III‐9a; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9a, only the allocated value amount included in question III‐9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III‐9a.
Calendar years‐‐
2015
2016
2017
Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in question III‐9a.
specific line item in table III‐9a where the nonrecurring item is
classified.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
Identify:
Explanation:
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 26
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of steel wheels. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for steel wheels in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III‐9a.
Provide data as of the end of your firm’s three most recently completed calendar years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to steel wheels if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Calendar years‐‐
Item
2015
1
Total assets (net)
1
III‐13.
2016
2017
Explain substantial changes
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for steel wheels. Provide data for your
firm’s three most recently completed calendar years.
Value (in $1,000)
Calendar years‐‐
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 on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 27
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported 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.
Calendar years‐‐
Reconciliation
2015
2016
2017
Quantity: Trade data from question
II‐8 (lines D, F, H, and J) less financial
total net sales quantity data from
question III‐9a, = zero ("0").
0
0
0
Value: Trade data from question II‐
8 (lines E, G, I, and K) less financial
total net sales value data from
question III‐9a, = zero ("0").
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 28
III‐15. Effects of imports on investment.‐‐Since January 1, 2015, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of steel wheels from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 29
III‐16. Effects of imports on growth and development.‐‐Since January 1, 2015, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of steel wheels from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 30
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
steel wheels from China?
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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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 31
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202‐205‐3230,
[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.‐‐22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing 60 to 75 lbs.,
inclusive, sold to OEMs.
Product 2.‐‐22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing 60 to 75 lbs.,
inclusive, sold to the aftermarket.
Product 3.‐‐22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing more than
75 lbs., sold to OEMs.
Product 4.‐‐22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing more than
75 lbs., sold to the aftermarket.
Note: Aftermarket includes aftermarket or replacement distributors, original equipment service
(“OES”) providers (both product distribution centers and dealer direct shipments), and other
aftermarket firms.
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 2015‐2017, did your firm produce and sell to unrelated U.S. customers any of the above
listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data table as appropriate.
No.‐‐Skip to question IV‐3.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 32
IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Do not include sales of wheels with tires and/or valve stems already attached.
Report data in number of wheels and actual dollars (not 1,000s).
(Quantity in number of wheels, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value
Product 4
Period of shipment
Quantity
Value
2015:
January‐March
April‐June
July‐September
October‐December
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
What was the average weight (total weight/number of units) of each product reported in the
above table?
Pricing product
Average weight
(pounds per unit)
Product 1
Product 2
Product 3
Product 4
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 33
IV‐2 (c). Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II‐7 in each year?
IV‐2 (d). Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
IV‐3.
Page 34
Price setting.‐‐How does your firm determine the prices that it charges for sales of steel wheels
(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 steel wheels?
Net 60
days
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic steel wheels 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 steel
wheels in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Item
Share of 2017
sales
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
%
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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U.S. Producers’ Questionnaire ‐ Steel wheels
IV‐7.
Page 35
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced steel wheels (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 steel wheels?
Lead time (Average
Source
Share of 2017 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
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U.S. Producers’ Questionnaire ‐ Steel wheels
IV‐9.
Page 36
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced steel wheels 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 steel wheels 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 steel wheels 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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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 37
IV‐11. End uses.‐‐List the end uses of the steel wheels that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by steel wheels and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End use product
Steel wheels
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐12. Substitutes.‐‐ Can other products be substituted for steel wheels?
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 steel wheels?
No Yes
Explanation
1.
2.
3.
IV‐13. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for steel wheels has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Market
Explanation and factors
Within the United States
Outside the United States
IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of steel wheels since January 1, 2015?
No
Yes
If yes, please describe and quantify if possible.
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U.S. Producers’ Questionnaire ‐ Steel wheels
Page 38
IV‐15. Conditions of competition.‐‐
(a) Is the steel wheels market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to steel wheels? If yes,
describe.
Check all that apply.
Please describe.
No
Skip to question IV‐16.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
steel wheels since January 1, 2015?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply steel wheels
since January 1, 2015 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐17. Raw materials.‐‐How have steel wheels raw material prices changed since January 1, 2015?
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 steel
wheels.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 39
IV‐18. Interchangeability.‐‐Are steel wheels 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
United States
China
Canada
Mexico
Other countries
China
Canada
Mexico
For any country‐pair producing steel wheels 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 ‐ Steel wheels
Page 40
IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between steel wheels 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
United States
China
Canada
Mexico
Other countries
China
Canada
Mexico
For any country‐pair for which factors other than price always or frequently are a significant factor
in your firm’s sales of steel wheels, identify the country‐pair and report the advantages or
disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 41
IV‐20. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for steel wheels since January 1, 2015. Indicate the share of the quantity of your
firm’s total shipments of steel wheels that each of these customers accounted for in 2017.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2017
sales
(%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 42
IV‐21. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2015: To avoid losing sales to competitors selling steel
wheels from China, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2015: Did your firm lose sales of steel wheels to imports of
this product from China?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: WHEEL)
IV‐22. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 43
PART V.‐‐ALTERNATIVE PRODUCT INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [email protected]).
In‐scope steel wheels.‐‐As defined on page 2, steel wheels are on‐the‐road steel wheels for use with
tubeless tires with a wheel diameter of 22.5 inches and 24.5 inches. Certain on‐the‐road wheels with a
wheel diameter of 22.5 inches and 24.5 inches are generally designed, manufactured, and offered for
sale for use on road and highway surfaces by Class 6, 7, and 8 commercial vehicles, including tractors,
semi‐trailers, dump trucks, garbage trucks, concrete mixers, and buses, and are the current standard
wheel diameters for such applications. The standard widths of certain steel wheels are 7.5 inches, 8.25
inches, and 9.0 inches, but all certain steel wheels, regardless of width, are covered by the scope. While
22.5 inches and 24.5 inches are standard wheel sizes used by Class 6, 7, and 8 commercial trucks, their
trailers, buses, and other commercial vehicles, and have been for several decades, these petitions are
intended to cover new sizes that may be adopted for use on Class 6, 7, and 8 commercial vehicles.
The scope includes “hub‐piloted” steel wheels and “stud‐piloted” steel wheels and includes rims and
discs for such wheels, whether imported as an assembly or separately. The scope includes wheels, discs,
and rims, of carbon and/or alloy composition, whether cladded or not cladded, whether finished or not
finished, and whether coated or uncoated. All on‐the‐road wheels sold in the United States are subject
to the requirements of the National Highway Traffic Safety Administration and bear markings, such as
the “DOT” symbol, indicating compliance with applicable motor vehicle standards. The scope includes
steel wheels imported with and without the required markings, which may be added after importation.
Steel wheels imported as an assembly with a tire mounted on the wheel or with a valve stem attached
are included. However, if the steel wheels are imported as an assembly with a tire mounted on the
wheel or with a valve stem attached, the tire or valve stem is not covered by the scope.
“Heavy duty aluminum wheels” – Wheels where the primary material in their manufacture is aluminum
(steel represents less than fifty percent of the product by weight) for use on class 6, 7, or 8 vehicles.
“Heavy duty steel wheels for tube‐type tires” – Wheels which are 20” to 24.5” in diameter and used on
class 6, 7, and 8 vehicles (by gross vehicle weight rating), and which are used for tube‐type tires.
Note.‐‐The alternative product comparison question (i.e., V‐1 below) is being asked in multiple
questionnaire types (U.S. producers' and U.S. importers' questionnaires). If your firm is completing
more than one of these questionnaire types in relation to this proceeding, please respond to the
alternative product comparisons question in only one questionnaire type. In general, your firm should
make these comparisons in the questionnaire type that is most relevant to your firm's role in the
market.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
V‐1.
Page 44
Comparability of in‐scope steel wheels to out‐of‐scope heavy duty aluminum wheels and out‐
of‐scope heavy duty steel wheels for tube‐type tires.‐‐ For each of the following indicate
whether in‐scope steel wheels and out‐of‐scope heavy duty aluminum wheels or heavy duty
steel wheels for tube‐type tires are: fully comparable or the same, i.e., have no differentiation
between them; mostly comparable or similar; somewhat comparable or similar; never or not‐at‐
all comparable or similar; or no familiarity with products.
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) Physical Characteristics and End Uses.‐‐The differences and similarities in the physical
characteristics and end uses.
Product‐pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:
In‐scope steel wheels vs out‐of‐
scope heavy duty aluminum
wheels
In‐scope steel wheels vs out‐of‐
scope heavy duty steel wheels for
tube‐type tires
(b) Interchangeability.‐‐The ability to substitute the products in the same application.
Product‐pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:
In‐scope steel wheels vs out‐of‐
scope heavy duty aluminum
wheels
In‐scope steel wheels vs out‐of‐
scope heavy duty steel wheels for
tube‐type tires
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
V‐1.
Page 45
Comparability of in‐scope steel wheels to out‐of‐scope heavy duty aluminum wheels and out‐
of‐scope heavy duty steel wheels for tube‐type tires.‐‐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
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 facilities, production processes, and
production employees:
Product‐pair
Comparison
In‐scope steel wheels vs out‐of‐
scope heavy duty aluminum wheels
In‐scope steel wheels vs out‐of‐
scope heavy duty steel wheels for
tube‐type tires
(d) Channels of distribution.‐‐Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:
Product‐pair
Comparison
In‐scope steel wheels vs out‐of‐
scope heavy duty aluminum wheels
In‐scope steel wheels vs out‐of‐
scope heavy duty steel wheels for
tube‐type tires
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
V‐1.
Page 46
Comparability of in‐scope steel wheels to out‐of‐scope heavy duty aluminum wheels and out‐
of‐scope heavy duty steel wheels for tube‐type tires.‐‐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 the market (e.g., sales/marketing practices).
Product‐pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:
In‐scope steel wheels vs out‐of‐
scope heavy duty aluminum
wheels
In‐scope steel wheels vs out‐of‐
scope heavy duty steel wheels for
tube‐type tires
(f) Price.‐‐Whether prices are comparable or differ between the products.
Product‐pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:
In‐scope steel wheels vs out‐of‐
scope heavy duty aluminum
wheels
In‐scope steel wheels vs out‐of‐
scope heavy duty steel wheels for
tube‐type tires
Business Proprietary
U.S. Producers’ Questionnaire ‐ Steel wheels
Page 47
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2018/steel_wheels_china/preliminary.ht
m.
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: WHEEL
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US producers--Steel wheels (P) |
| Author | jordan.harriman |
| File Modified | 2018-03-29 |
| File Created | 2018-03-29 |