Form 18-1-3868 US producers' questionnaire

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

US producers--UGW Paper (F)

Uncoated groundwood paper from Canada (701-TA-584 and 731-TA-1382)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 18-1-3868; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
UNCOATED GROUNDWOOD PAPER FROM CANADA
This questionnaire must be received by the Commission by May 2, 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 investigations concerning uncoated groundwood paper (“UGW
paper”) from Canada (Inv. Nos. 701-TA-584 and 731-TA-1382 (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 UGW paper (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: UGWP)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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

Page 2

PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on August 9, 2017, by North
Pacific Paper Company (“NORPAC”), Longview, Washington. Countervailing and/or antidumping duties
may be assessed on the subject imports as a result of these proceedings if the Commission makes an
affirmative determination of injury, threat, or material retardation, and if the U.S. Department of
Commerce (“Commerce”) makes an affirmative determination of subsidization and/or dumping.
Questionnaires and other information pertinent to this proceeding are available
at https://usitc.gov/investigations/701731/2018/uncoated_groundwood_paper_canada/final.htm.
UGW paper covered by these investigations include certain paper that has not been coated on either
side and with 50 percent or more of the cellulose fiber content consisting of groundwood pulp, including
groundwood pulp made from recycled paper, weighing not more than 90 grams per square meter.
Groundwood pulp includes all forms of pulp produced from a mechanical pulping process, such as
thermo-mechanical process (TMP), chemi-thermo mechanical process (CTMP), bleached chemi-thermo
mechanical process (BCTMP), or any other mechanical pulping process. The scope includes paper
shipped in any form, including but not limited to both rolls and sheets.
Certain uncoated groundwood paper includes but is not limited to standard newsprint, high bright
newsprint, book publishing, and printing and writing papers. The scope includes paper that is white, offwhite, cream, or colored.
Specifically excluded from the scope are imports of certain uncoated groundwood paper printed with
final content of printed text or graphic. Also excluded are papers that otherwise meet this definition, but
which have undergone a supercalendering process. Additionally, excluded are papers that otherwise
meet this definition, but which have undergone a creping process over the entire surface area of the
paper.
Also excluded are uncoated groundwood construction paper and uncoated groundwood manila drawing
paper in sheet or roll format. Excluded uncoated groundwood construction paper and uncoated
groundwood manila drawing paper: (a) Have a weight greater than 61 grams per square meter; (b) have
a thickness greater than 6.1 caliper, i.e., greater than .0061” or 155 microns; (c) are produced using at
least 50 percent thermomechanical pulp; and (d) have a shade, as measured by CIELAB, as follows: L*
less than or 75.0 or b* greater than or equal to 25.0.
Also excluded is uncoated groundwood directory paper that: (a) Has a basis weight of 34 grams per
square meter or less; and (b) has a thickness of 2.6 caliper mils or 66 microns or less.
Certain uncoated groundwood paper is classifiable in the Harmonized Tariff Schedule of the United
States (HTSUS) in several subheadings, including 4801.00.0120, 4801.00.0140, 4802.61.1000,
4802.61.2000, 4802.61.3110, 4802.61.3191, 4802.61.6040, 4802.62.1000, 4802.62.2000, 4802.62.3000,
4802.62.6140, 4802.69.1000, 4802.69.2000, and 4802.69.3000. Subject merchandise may also be
imported under several additional subheadings including 4805.91.5000, 4805.91.7000, and
4805.91.9000.
Newsprint.—UGW paper designed exclusively for newspapers and similar publications commonly
disposed within a day. Standard newsprint has a weight typically ranging from 40 grams per square
meter (gsm) to 48.8 gsm and has brightness levels ranging from 56 to 62.
Directory paper.—Any paper that meets the definition of certain uncoated groundwood paper (defined
above) with basis weight of 36 grams per square meter or less and ISO brightness of 56 or less.

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

Page 3

High bright paper. – Any paper that meets the definition of certain uncoated groundwood paper
(defined above) with ISA brightness of 65 or greater.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
I-1a.

Page 4

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.

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

I-2.

No

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

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
I-3.

Page 5

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

Support

Oppose

Take no position

Canada (AD)
Canada (CVD)
I-4.

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

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

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

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
I-6.

Page 6

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

Yes--List the following information.
Country

Affiliation

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

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Calvin Chang (202-2053062, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax

II-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of UGW paper since January 1, 2015.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

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

Page 8

II-2b.

Effect of changes in operations on UGW paper products.--Please describe the effect of any
change in your firm’s operations on the production and shipment of UGW paper.

II-2c.

Effect of changes in operations on export markets.--Please describe the effect of any change in
your firm’s operations on exports of UGW paper.

II-2d.

Change in ownership or corporate structure.—Did your firm experience a change in ownership
or corporate structure during the POI?
No

II-3.

Yes–Supply details as to the time, nature, and significance of such

changes.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of UGW paper in the
future?
No

Yes–Supply details as to the time, nature, and significance of such changes and
provide underlying assumptions, along with relevant portions of business
plans or other supporting documentation that address this issue. Include
in the response a specific projection of your firm’s capacity to produce
UGW paper (in metric tons) for 2018 and 2019.

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
II-4a.

Page 9

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce UGW paper, and the combined production
capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in metric tons)
Calendar years
Item

2015

2016

2017

Overall production capacity
Production of:
UGW paper1

0

0

0

0

0

0

23

Other products
Total
1

Data entered for production of UGW paper will populate here once reported in question II-8.
Please identify the other types of paper products your firm can produce on your paper making
.
machinery:
3
Describe any production trends away from UGW paper:
.
2

II-4b.

Operating parameters.--The production capacity reported in II-4a is based on operating
per week,
weeks per year.

II-4c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-4a, 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 of UGW paper.

hours

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
II-4e.

Product shifting.—
(i)

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

(ii)

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

Does your firm produce newsprint and other UGW paper products on the same equipment
and/or labor?
No

(iii)

II-5.

Page 10

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

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

Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of UGW paper?
“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 – UGW Paper (Final)
II-6.

Page 11

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

(a)

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

No

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

(b)

No

II-7.

Yes

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

Yes

If yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2015, has your firm imported UGW paper?
“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 – UGW Paper (Final)
II-8.

Page 12

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of UGW paper 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 – UGW Paper (Final)
II-8.

Page 13

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

2015

2016

2017

1

Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2

Internal consumption:
Quantity (F)
2

Value (G)
Transfers to related firms:
Quantity (H)

2

2

Value (I)
Export shipments:
Quantity (J)

3

Value (K)
4

End-of-period inventories (quantity) (L)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your
firm uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and
.
provide value data using that basis for each of the periods noted above:
3
Identify your firm’s principal export markets:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar years

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

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 – UGW Paper (Final)
II-9.

Page 14

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

2015

2016

2017

Channels of distribution:
Commercial U.S. shipments:
To national distributors (M)
To regional distributors (N)
To publishers/newspapers (O)
To other end users (P)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M and N) in each time period equal the quantity reported for commercial U.S. shipments (i.e., line D) in
each time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must
be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P – D = zero ("0"), if not
revise.

2015

2016
0

2017
0

0

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
II-10.

Page 15

Commercial U.S. shipments by product type.--Report your firm’s commercial U.S. shipments of
UGW paper, by product type, during the specified periods.
Quantity (in metric tons); Value (in $1,000)
Calendar years
Item

2015

2016

2017

Commercial U.S. shipments:
Newsprint
40 gsm or less
Quantity (Q)
Value (R)
More than 40 gsm but less than
45 gsm
Quantity (S)
Value (T)
45 gsm
Quantity (U)
Value (V)
More than 45 gsm
Quantity (W)
Value (X)
High bright paper
Quantity (Y)
Value (Z)
Directory paper
Quantity (AA)
Value (AB)
Other UGW paper1
Quantity (AC)
Value (AD)
1

Please list the other UGW paper products:

Reconciliation
Quantity: Q + S + U + W + Y + AA +
AC – D should equal zero ("0"), revise
if not.
Value: R + T + V + X + Z + AB + AD – E
should equal zero ("0"), revise if not.

Calendar years
2016

2015

2017

0

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
II-11.

Page 16

Commercial U.S. shipments by geographical region.--Report your firm’s commercial U.S.
shipments of UGW paper in 2017 by geographical region.
Quantity (in metric tons); Value (in $1,000)
Calendar year 2017
Item

Newsprint

Other than newsprint

All UGW paper

Northeast.–CT, ME, MA, NH, NJ,
NY, PA, RI, and VT.
Quantity (AE)

0

Value (AF)

0

Central.–IL, IN, IA, KS, MI, MN,
MO, NE, ND, OH, SD, and WI.
Quantity (AG)

0

Value (AH)

0

South.–AL, AR, DE, DC, FL, GA, KY,
LA, MD, MS, NC, OK, SC, TN, TX,
VA, and WV.
Quantity (AI)

0

Value (AJ)

0

West.–AZ, CA, CO, ID, MT, NV, NM,
OR, UT, WA, and WY.
Quantity( AK)

0

Value (AL)

0

Other.–All other markets in the
United States not previously listed,
including AK, HI, PR, and VI.
Quantity (AM)

0

Value (AN)

0

Entire US market
Quantity (AO)

0

0

0

Value (AP)

0

0

0

Reconciliation

Other UGW paper

Quantity: AO (in last column) – D (in 2017) = zero ("0"), if not revise.

0

Value: AP (in last column) – E (in 2017) = zero ("0"), if not revise.

0

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
II-12.

Page 17

Employment data.--Report your firm’s employment-related data related to the production of
UGW paper 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.
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-13.

Related firms.--If your firm reported transfers to related firms in question II-8, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
II-14.

Page 18

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

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

(Quantity in metric tons)
Calendar years
Item

2015

2016

2017

Purchases from U.S.
importers1 of UGW paper
from-Canada – White Birch
Canada – Resolute
Canada – All other firms
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-15.

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 – UGW Paper (Final)

Page 19

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202-2053432, [email protected]).
III-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
Fax

III-2.

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

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

B.1.

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

2.

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

3.

4.

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

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III-4.

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

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced UGW paper, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products

Share of sales

UGW paper

%
%
%
%
%

III-6.

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

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
III-8.

Page 21

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on UGW paper) in
a manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III-9a.

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III-9a. Operations on UGW paper.--Report the revenue and related cost information requested below
on the UGW paper operations of your firm’s U.S. establishment(s).1 Do not report resales of
products. Note that internal consumption and transfers to related firms must be valued at fair
market value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three most
recently completed fiscal years, and for the specified interim periods. If your firm was involved
in tolling operations (either as the toller or as the tollee), please contact CHARLES YOST at (202)
205-3432 before completing this section of the questionnaire.
Quantity (in metric tons) 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”)
Total net sales quantities

0

0

0

0

0

0

Total COGS

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor
Other factory costs

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

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

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

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III-9b. Raw materials for uncoated groundwood.--Please indicate the share of total raw material costs
reported in III-9a in 2017 for the following raw material inputs:

Products
Own production of pulp cost
Purchased pulp cost
Other material inputs1
Total (should sum to 100 percent)

Share of total raw
material costs
(percent)
%
%
%
0.0 %

1

Please indicate any other notable "other" raw materials not expressly identified above
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 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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III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to question
III-9a, only the allocated value amount included in question III-9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.
Fiscal years ended-Item

Nonrecurring item: In this column please
provide a brief description of each nonrecurring
item and indicate the specific line item in table
III-9a where the nonrecurring item is classified.
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

2015

2016

2017

Nonrecurring item: In these columns please report the
amount of the relevant nonrecurring item reported in
question III-9a.
Value ($1,000)

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. Explain and provide detail about nonrecurring items.
Identify:
Explanation:

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III-12a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of UGW paper. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for UGW paper in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9a. Provide data as
of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

2015

2016

2017

1

Explain changes in asset values (e.g., writeoffs, impairments, etc.)

III-12b. Integrated ownership structure.—Does your firm own all of the capital assets used in the
production of UGW? If not, please identify the most important capital assets that are owned by
another party:
Yes
No
If no, please identify the capital assets owned by another party

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III-12c. Wastewater treatment.--Does your firm own the facility that treats wastewater effluent? If not,
please identify the owner:
Yes

No

If no, please identify the owner and describe the manner by which you
contract and pay for wastewater effluent treatment servies.

If you pay another company for the treatment of wastewater effluent, please indicate whether
there have been interruptions or failures in treatment operations, and, if so specifiy the dates
that treatment was stopped and started. Also, please indicate how costs associated with any
interruptions are accounted for in the data reported in question III-9a or elsewhere in Part III of
this questionnaire.

III-13.

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for UGW paper. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Item

Fiscal years ended--

2015
Capital expenditures

2016

2017

1
2

Research and development expenses
1

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject
product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject
product.

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III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12a, 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.
Full year data
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-8?
Yes

No

If no, please explain.

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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 UGW paper from Canada?
No

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

(please describe)

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III-16. Effects of imports on growth and development.--Since January 1, 2015, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of UGW paper from Canada?
No

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

Lowering of credit rating

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

Other

(please describe)

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III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
UGW paper from Canada?
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 Amelia Preece (202-2053250, [email protected]).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2015 of the following products produced by your
firm.
Product 1.--Newsprint, 45.0 gsm (27.7 lb. newsprint weight), with ISO Brightness of 55-62, in rolls.
Sold in the Northeast (CT, ME, MA, NH, NJ, NY, PA, RI, and VT).
Product 2.--Newsprint, 45.0 gsm (27.7 lb. newsprint weight), with ISO Brightness of 55-62, in rolls.
Sold in the Central U.S. (IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI).
Product 3.--Newsprint, 45.0 gsm (27.7 lb. newsprint weight), with ISO Brightness of 55-62, in rolls.
Sold in the South (AL, AR, DE, DC, FL, GA, KY, LA, MD, MS, NC, OK, SC, TN, TX, VA, and WV).
Product 4.--Newsprint, 45.0 gsm (27.7 lb. newsprint weight), with ISO Brightness of 55-62, in
rolls. Sold in the West (AZ, CA, CO, ID, MT, NV, NM, OR, UT, WA, and WY).
Product 5.--65 Bright, 44.0-46.0 gsm (27-28 lb. newsprint weight) with ISO brightness of 65, in rolls.
Product 6.--80 Bright, 51.5-52.5 gsm (35.0 lb. book weight), with ISO brightness of 80, in rolls.
Product 7.--Directory, 34.0 gsm (20.9 lb. directory weight), with ISO brightness of 56 in rolls.

Please note that values should be delivered and should 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 in
the United States by your firm.
Report data in kilograms (not metric tons) and actual dollars (not 1,000s).
Product 1
Quantity
Value

(Quantity in kilograms, value in dollars)
Product 2
Product 3
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, and the value of returned goods), delivered.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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IV-2(b). Price data (continued).--Report below the quarterly price data1 for pricing products2 produced
and sold in the United States by your firm.
.

Report data in kilograms (not metric tons) and actual dollars (not 1,000s).
(Quantity in kilograms, value in dollars)
Product 5
Product 6
Quantity
Value
Quantity
Value

Product 7
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, and the value of returned goods), delivered.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 5:
Product 6:
Product 7:

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

√ if Yes

In actual dollars (not $1,000)?
In kilograms (not metric tons)?
Delivered price (i.e., includes 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-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.

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
IV-3.

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

IV-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

IV-5.

Page 35

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

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

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

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

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
IV-6.

Page 36

Pricing factors.—
(a) Rate and describe the effect of the following factors on your firm’s ability to price UGW
paper.
Rating of the factor
No/minimal effect
Factor

1

Substantial effect

2

3

4

Not
applicable

5

The decline in print media
Other factors causing demand
for paper products to decline
Availability of substitute
products
Competition from U.S.
producers
Availability of subject imports
Please describe:
(b) Are there any internal benchmarks you use to determine prices of UGW paper, e.g., pricing
UGW paper at a certain percentage of another paper’s price? Please explain.
No

IV-7.

Yes

Explain.

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

Share of 2017
sales

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire – UGW Paper (Final)
IV-8.

Page 37

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity
Price
Both

Meet or release
provision

Yes
No

Not applicable
IV-9.

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 UGW paper?

Source

Share of 2017 sales

Newsprint
From inventories

%

Produced to order

%

UGW paper other than newsprint
From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Lead time
(Average number
of days)

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IV-10. Warehouses.--Does your firm hold inventories at warehouses located in a different state than
your production? Where are these warehouses located? What products do you hold in these
warehouses?

No

Yes

If yes, list the State(s) in which
these warehouse(s) is/are
located

Products held in these warehouses
Newsprint

High Directory
bright
paper

Other

IV-11. Shipping information.-(a)

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

(b)

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

(c)

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

Share

Within 500 miles

%

501 to 1,000 miles

%

1,001 to 1,500 miles

%

1,501 to 2,000 miles

%

Over 2,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-12. End uses.--List the end uses of the UGW paper that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by UGW paper and other inputs?
Other inputs include: labor (salaries and benefits for printers, writers, editors, etc.); energy;
other raw materials; and overhead (depreciation, marketing, and finance).
Share of total cost of end use product
accounted for by
End use product
Newspaper publication

UGW paper

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

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IV-13. Substitutes.--Can other products be substituted for UGW paper?
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 UGW paper?
No Yes

Explanation

1.
2.
3.
IV-14. Demand trends.-(a)

Indicate how demand within the United States and outside of the United States (if
known) for UGW paper has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.

Overall
increase

Market

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within the United States
Outside the United States
(b)

Has demand for UGW paper been affected by purchasers shifting between different
types of paper?

No

Yes

If yes, specify the types of papers that have shifted and if this shift has
increased or reduced your overall demand for UGW paper

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IV-15. Factors affecting UGW paper demand.--For each factor, rate how it has affected the overall
demand for UGW paper since January 1, 2015 and discuss the effect of each factor.
Impact on demand in the U.S. market for UGW paper products
Decreased demand in U.S. for
UGW paper

Factor

Substantial Moderate

Minimal

No
impact

Do not
Increased demand in U.S. for UGW
know/
paper
no
Minimal Moderate Substantial opinion

Demand shift
between UGW
paper and other
paper
Decline in demand
for print media/
periodical
Use of digital media
Shift to lighter
weight newsprint
Narrative discussion of each factor
Demand shift between
UGW paper and other
paper (please report
the type of other
paper)
Decline in demand for
print media/ periodical
Use of digital media
Shift to lighter weight
newsprint

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IV-16. Substitutability by product type.--Please compare the substitutability of various UGW papers
with each other (i.e., can they be substituted for each another)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products being compared are always substitutable with each other in the same
end uses
F = the products are frequently substitutable
S = the products are sometimes substitutable
N = the products are never substitutable
0 = no familiarity with products from a specified product-pair
Product-pair

Directory paper

High bright

Other

Newsprint
Directory paper
High bright
For any product comparison that is sometimes or never substitutable, identify the factors that limit or
preclude substitutability between those products.

IV-17. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of UGW paper since January 1, 2015?
No

Yes

If yes, please describe and quantify if possible.

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

Page 42

IV-18. Conditions of competition.-(a) Is the UGW paper market (or any specific type of UGW paper) subject to business cycles
(other than general economy-wide conditions) and/or other conditions of competition
distinctive to UGW paper? If yes, describe.
Check all that apply.

Please describe.

No

Skip to question IV-9.

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
UGW paper since January 1, 2015?
No

Yes

If yes, describe.

IV-19. Supply constraints.--Has your firm refused, declined, or been unable to supply UGW paper 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-20. Decision to cease or curtail production.—Does your firm have plans, or has your firm
announced plans, to eliminate or significantly reduce production of a particular weight of
newsprint?
No

Yes

If yes, please describe product weights and plans.

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

Page 43

IV-21. Raw materials.--How have UGW paper raw material prices changed since January 1, 2015?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for UGW
paper.

IV-22. Interchangeability.--Is UGW paper produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair

Country-pair

Canada

Other countries

United States
Canada
For any country-pair producing UGW paper that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

If this differs between the types of UGW paper you purchase please report the products and
the interchangeability of each different product by country.

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

Page 44

IV-23. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between UGW paper produced
in the United States and in other countries a significant factor in your firm’s sales of the
products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair

Country-pair

Canada

Other countries

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

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

Page 45

IV-24. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for UGW paper since January 1, 2015. Indicate the share of the quantity of your
firm’s total shipments of UGW paper that each of these customers accounted for in 2017.

4
5
6
7
8
9
10

Other

3

Directory
paper

2

State

High bright

1

City

Newsprint

Customer’s name

Share
of 2017
sales
(%)

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

Page 46

IV-25. Competition from imports
(a) Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling UGW
paper from Canada, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2015: Did your firm lose sales of UGW paper to imports of
this product from Canada?
No

Yes

IV-26. 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 – UGW Paper (Final)

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://usitc.gov/investigations/701731/2018/uncoated_groundwood_paper_canad
a/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: UGWP

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


File Typeapplication/pdf
File TitleUS producer questionnaire
SubjectTitle 7 investigations
AuthorPreece, Amelia
File Modified2018-04-02
File Created2018-04-02

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