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pdfOMB No. 3117‐0016/USITC No. 18‐1‐3928; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
CRYSTALLINE SILICON PHOTOVOLTAIC CELLS AND MODULES FROM CHINA
This questionnaire must be received by the Commission by September 19, 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 review of the antidumping and countervailing duty orders concerning Crystalline Silicon Photovoltaic
(“CSPV”) Cells and Modules from China (Inv. Nos. 701‐TA‐481 and 731‐TA‐1190 (Review)). 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 CSPV cells and/or modules (as defined on the next page) at any time since January 1,
2012?
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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: CSPV1)
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 or reviews
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 – CSPV Cells and Modules (CSPV1 Review)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐ On December 7, 2012, the Department of Commerce (“Commerce”) issued antidumping
and countervailing duty orders on imports of crystalline silicon photovoltaic (“CSPV”) cells and modules
from China (77 FR 73017–73021). On November 1, 2017, the Commission instituted reviews pursuant to
section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine whether revocation
of the orders would be likely to lead to continuation or recurrence of material injury to the domestic
industry within a reasonably foreseeable time. If both the Commission and Commerce make affirmative
determinations, the orders will remain in place. If either the Commission or Commerce makes negative
determinations, Commerce will revoke the orders. Questionnaires and other information pertinent to
this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/crystalline_silicon_photovoltaic_cells_and_modules
/first_review_full.htm
CSPV Cells and Modules covered by these reviews are defined by Commerce as follows:
The merchandise covered by the order are crystalline silicon photovoltaic cells, and modules,
laminates, and panels, consisting of crystalline silicon photovoltaic cells, whether or not partially
or fully assembled into other products, including, but not limited to, modules, laminates, panels
and building integrated materials.
The order covers crystalline silicon photovoltaic cells of thickness equal to or greater than 20
micrometers, having a p/n junction formed by any means, whether or not the cell has undergone
other processing, including, but not limited to, cleaning, etching, coating, and/or addition of
materials (including, but not limited to, metallization and conductor patterns) to collect and
forward the electricity that is generated by the cell.
Merchandise under consideration may be described at the time of importation as parts for final
finished products that are assembled after importation, including, but not limited to, modules,
laminates, panels, building‐integrated modules, building‐integrated panels, or other finished
goods kits. Such parts that otherwise meet the definition of merchandise under consideration are
included in the scope of the orders.
Excluded from the scope of the order are thin film photovoltaic products produced from
amorphous silicon (a‐Si), cadmium telluride (CdTe), or copper indium gallium selenide (CIGS).
Also excluded from the scope of the order are crystalline silicon photovoltaic cells, not exceeding
10,000 mm2 in surface area, that are permanently integrated into a consumer good whose
function is other than power generation and that consumes the electricity generated by the
integrated crystalline silicon photovoltaic cell. Where more than one cell is permanently
integrated into a consumer good, the surface area for purposes of this exclusion shall be the
total combined surface area of all cells that are integrated into the consumer good.
Additionally, excluded from the scope of this order are panels with surface area from 3,450 mm2
to 33,782 mm2 with one black wire and one red wire (each of type 22 AWG or 24 AWG not more
than 206 mm in length when measured from panel extrusion), and not exceeding 2.9 volts, 1.1
amps, and 3.19 watts. For the purposes of this exclusion, no panel shall contain an internal
battery or external computer peripheral ports.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 3
Modules, laminates, and panels produced in a third‐country from cells produced in China are
covered by the orders; however, modules, laminates, and panels produced in China from cells
produced in a third‐country are not covered by the order.
Merchandise covered by this order is currently classified in the Harmonized Tariff System of the
United States (HTSUS) under subheadings 8501.61.0000, 8507.20.80, 8541.40.6020,
8541.40.6030, and 8501.31.8000. These HTSUS subheadings are provided for convenience and
customs purposes; the written description of the scope of the order is dispositive.
Module.‐‐A joined group of CSPV cells, regardless of the number of cells or the shape of the joined
group, that are capable of generating electricity. The term “module” is frequently used interchangeably
with the term “panel.” A “laminate” is a module that does not have a frame.
Building Integrated Materials.‐‐Materials integrated into the building envelope, such as the façade or
roof, containing CSPV cells. These building integrated materials replace conventional construction
materials, such as glass or roof shingles, taking over the function that conventional materials would
otherwise perform while also producing electricity.
Reporting of information.‐‐If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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 ‐ CSPV Cells and Modules (CSPV1 Review)
Page 4
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.
I‐1.
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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 CSPV cells or the assembly
(full or partial) of CSPV cells into other products (e.g., laminates, panels, modules), including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
Covered1
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I‐3.
Position regarding continuation of orders.‐‐Does your firm support or oppose continuation of
the following antidumping and/or countervailing duty orders currently in place for CSPV cells
and modules?
Country
Support
Oppose
Take no position
China (Antidumping Duty)
China (Countervailing Duty)
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐4.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
I‐5.
Extent of
ownership
(percent)
Address
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing CSPV cells and modules into the United States or that are
engaged in exporting CSPV cells and modules to the United States?
No
Yes‐‐List the following information.
Firm name
Page 6
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of CSPV cells or the assembly (full or partial) of CSPV cells into other
products?
No
Yes‐‐List the following information.
Firm name
I‐7.
Page 7
Country
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for CSPV cells and
modules?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Mary Messer (202‐205‐3193,
[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‐2a. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of CSPV cells or the assembly (full or partial) of CSPV cells
into other products since January 1, 2012.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Bankruptcy
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 9
II ‐2b. Anticipated changes in operations.‐‐Does your firm anticipate any changes in in the character of
its operations or organization relating to the production of CSPV cells or the assembly (full or
partial) of CSPV cells into other products in the future?
II‐3.
No
Yes
If 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 documentations that
address this issue. Include in your response a specific projection of your
firm’s capacity to produce CSPV cells or the assembly (full or partial) of
CSPV cells into other products (in kilowatts) for 2018 and 2019.
Product shifting (CSPV cells).—
(i)
Is your firm able to switch production (capacity) between CSPV cells 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‐4.
Product shifting (CSPV modules).—
(i)
Is your firm able to switch production (capacity) between CSPV modules 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 10
“Integrated producers of CSPV modules” (those U.S. firms that produce CSPV cells to be used in the
production of their CSPV modules) should report data regarding their CSPV cell production in
questions II‐8 through II‐10 (while reporting any cells used in downstream production of
laminates, panels, modules, etc. as "internal consumption") and report data regarding their
CSPV module production in questions II‐9 through II‐13.
“Assemblers of CSPV modules” (those U.S. firms that purchase or import CSPV cells from an unrelated
firm and assemble CSPV modules) should report data regarding their production in questions II‐11
through II‐14 (while indicating the various sources of their CSPV cells in the production data).
“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” or “Assembly” – All production or assembly in your U.S. establishment(s), including
production or assembly of items consumed internally within your firm and production or assembly of
items 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, including CSPV cells used to
assemble other CSPV products, such as modules, panels, and laminates.
“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, including
for example, parent companies, subsidiaries owned by the same parent company, and other affiliates.
Such transactions are valued at fair market value.
“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 ‐ CSPV Cells and Modules (CSPV1 Review)
II‐5.
Page 11
Production, shipment and inventory data: CSPV cells.‐‐Report your firm’s production capacity,
production, shipments, and inventories related to the production of CSPV cells in your U.S.
establishment(s) during the specified periods.
CELLS
Quantity (in kilowatts) and value (in $1,000)
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Average production
capacity1 (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)
value (I)
Export shipments to‐‐
Related firms:3
quantity (J)
Unrelated firms:
quantity (L)
value (M)
value (G)
Transfers to related
firms:2
quantity (H)
value (K)
4
End‐of‐period
inventories (quantity)
(N)
1 The production capacity reported is based on operating
hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, explain any changes in reported capacity, and describe the constraint(s) that set the
limit(s) on your firm’s average production capacity (use additional pages as necessary). .
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 to related firms: .
4 Identify your firm’s principal export markets to unrelated firms: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐5.
Page 12
Production, shipment and inventory data: CSPV cells.‐‐Continued
CELLS
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line N) 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, J, and L). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Calendar year
Item
B + C – D – F – H – J – L
– N = should equal zero
("0") or provide an
explanation.1
1
2012
0
2013
0
2014
0
January‐June
2015
0
2016
0
2017
0
2017
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
2018
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐6.
Page 13
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) of CSPV cells by channel of
distribution.
CELLS
Quantity (in kilowatts)
Calendar year
Item
2012
Channels of distribution:
U.S. shipments:
To module assemblers (O)
2013
2014
2015
January‐June
2016
2017
2017
2018
To distributors (P)
To residential installers (Q)
To commercial installers
(R)
To utilities/developers (S)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines O, P, Q, R, and S) in each time period equal the quantity reported for U.S. commercial
shipments (i.e., lines D, F, and H) in each time period. If the calculated fields below return values other
than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation item
O + P + Q + R + S – D –
F – H = zero ("0"), if not
revise.
2012
0
2013
0
2014
0
January‐June
2015
0
2016
0
2017
0
2017
0
2018
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐7.
Page 14
Employment data.‐‐Report your firm’s employment‐related data related to the production of
CSPV cells and provide an explanation for any trends in these data. If your firm assembles CSPV
modules from its own production of CSPV cells, the employment data reported here should
exclude employment data relating to your firm's assembly operations (so that PRW, hours
worked, and wages paid can be added to those reported in II‐13 to arrive at your firm's total
employment data).
CELLS
“Production 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 dividing that total by 12. For the January to June periods, calculate
similarly and divide by 6.
“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 year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Average number of PRWs
(number) (T)
Hours worked by PRWs
(1,000 hours) (U)
Wages paid to PRWs
($1,000) (V)
Explanation of trends:
II‐8.
CSPV Modules.‐‐Since January 1, 2012, has your firm produced CSPV laminates, panels, or
modules?
No—Skip to question II‐14.
Yes—Continue to question II‐9.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐9.
Page 15
Production, shipment and inventory data: CSPV modules.‐‐Report your firm’s production capacity,
production, shipments, and inventories related to the production of CSPV modules in your U.S.
establishment(s) during the specified periods.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Average production
capacity1 (quantity) (W)
Beginning‐of‐period
inventories (quantity) (X)
Production (quantity) (Y)
U.S. shipments:
Commercial
shipments:
quantity (Z)
Internal
consumption:2
quantity (AB)
value (AC)
Transfers to related
firms:2
quantity (AD)
value (AE)
value (AA)
Export shipments to‐‐
Related firms:3
quantity (AF)
value (AG)
Unrelated firms:4
quantity (AH)
value (AI)
End‐of‐period inventories
(quantity) (AJ)
1 The production capacity reported is based on operating
hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, explain any changes in reported capacity, and describe the constraint(s) that set the
limit(s) on your firm’s average production capacity (use additional pages as necessary). .
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 for related firms: .
4 Identify your firm’s principal export markets for unrelated firms: ..
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐9.
Page 16
Production, shipment and inventory data: CSPV modules.—Continued
MODULES
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line AJ) should be equal to the beginning‐of‐period inventories (i.e., line X),
plus production (i.e., line Y), less total shipments (i.e., lines Z, AB, AD, AF, and AH). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Calendar year
Item
X + Y ‐ Z ‐ AB ‐ AD ‐ AF ‐
AH ‐ AJ = should equal
zero ("0") or provide an
explanation.1
1
2012
0
2013
0
2014
0
January‐June
2015
0
2016
0
2017
0
2017
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
2018
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 17
II‐10. 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) of CSPV modules by channel of
distribution.
MODULES
Quantity (in kilowatts)
Calendar year
Item
2012
Channels of distribution:
U.S. shipments:
To module assemblers
(AK)
2013
2014
2015
January‐June
2016
2017
2017
2018
To distributors (AL)
To residential installers
(AM)
To commercial installers
(AN)
To utilities/developers
(AO)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines AK, AL, AM, AN, and AO) in each time period equal the quantity reported for U.S. shipments
(i.e., line Z, AB, AD) 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 year
Reconciliation item
AK + AL + AM + AN +
AO – Z – AB – AD =
zero ("0"), if not revise.
2012
0
2013
0
2014
0
January‐June
2015
0
2016
0
2017
0
2017
0
2018
0
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 18
II‐11. Sources of inputs used in the production of CSPV modules.‐‐Report your firm’s production of
CSPV modules by source of cells and the cost of those cells for the specified periods.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Calendar years
Item
Production of CSPV modules‐‐
Using own firm's domestically
produced cells.‐‐
Quantity (AP)
Cost (AQ)
Using purchases of domestic
cells.1‐‐
Quantity (AR)
Cost (AS)
Using domestic cells.‐‐
Quantity
Cost
Using imported Chinese‐
origin cells.‐‐
Quantity (AT)
Cost (AU)
Using imported non‐Chinese‐
origin cells.2‐‐
Quantity (AV)
Cost (AW)
Using imported cells.‐‐
Quantity
Cost
Cells from any source.‐‐
Quantity
Cost
2012
2013
2014
January‐June
2015
2016
2017
2017
2018
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1 Please specify the U.S. producers of the puchased U.S.‐origin cells your firm used for these modules:
2 Please specify country of origin of these cells:
RECONCILIATION OF PRODUCTION.‐‐Please ensure that the quantities reported for production by source
of cells (i.e., lines AP, AR, AT, and AV) in each time period equal the quantity reported for production (i.e.,
line Y) 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 year
Reconciliation item
AP + AR + AT + AV – Y =
zero ("0"), if not revise.
2012
0
2013
0
2014
0
January‐June
2015
0
2016
0
2017
0
2017
0
2018
0
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 19
II‐12. US shipments by module configuration.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of CSPV
modules by configuration for the specified periods.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Calendar years
Item
2012
U.S. shipments of CSPV
modules‐‐
60‐cell configuration.‐‐
Quantity (AX)
Value (AY)
72‐cell configuration.‐‐
Quantity (AZ)
Value (BA)
January‐June
2013
2014
2015
2016
2017
2017
2018
1
Other products. ‐‐
Quantity (BB)
Value (BC)
1
Please specify these products: .
RECONCILIATION OF US SHIPMENTS.‐‐Please ensure that the quantities and values reported for US
shipments by cell configuration (i.e., lines AX through BC) in each time period equal the quantity and
value of US shipments (i.e., lines Z through AE) 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 year
Reconciliation item
Quantity: AX + AZ + BB
– Z – AB – AD = zero
("0"), if not revise.
Value: AY + BA + BC –
AA – AC – AE = zero
("0"), if not revise.
2012
2013
2014
January‐June
2015
2016
2017
2017
2018
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 20
II‐13. Employment data.‐‐Report your firm’s employment‐related data related to the production of
CSPV modules and provide an explanation for any trends in these data. If your firm assembles
CSPV modules from its own production of CSPV cells, the employment data reported here
should exclude employment data relating to your firm's assembly operations (so that PRW,
hours worked, and wages paid can be added to those reported in II‐7 to arrive at your firm's
total employment data).
MODULES
“Production 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 dividing
that total by 12. For the January to June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods.
“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 year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Average number of PRWs
(number) (BD)
Hours worked by PRWs
(1,000 hours) (BE)
Wages paid to PRWs
($1,000) (BF)
Explanation of trends:
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐14. Transfers to related firms.‐‐If your firm reported transfers to related firms in questions II‐5 or II‐
9, 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.
II‐15. Purchases: CSPV cells.‐‐Has your firm purchased CSPV cells produced in the United States or in
other countries since January 1, 2012? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire).
“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 in the table below and explain the reasons
for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in kilowatts)
Calendar years
Item
Purchases from U.S.
importers1 of CSPV
cells from—
China
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
All other sources
Purchases from
domestic producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐16. Purchases: CSPV modules.‐‐Has your firm purchased CSPV modules produced in the United
States or in other countries since January 1, 2012? (Do not include imports for which your firm
was the importer of record. These should be reported in an importer questionnaire).
“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 in the table below and explain the reasons
for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below.
(Quantity in kilowatts)
Calendar years
Item
2012
Purchases from U.S.
importers1 of CSPV
modules from—
China2
2013
2014
2015
January‐June
2016
2017
2017
2018
All other sources
Purchases from
domestic producers2
Purchases from other
sources3
2
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
Classify modules made with Chinese origin cells regardless of the country in which the module was assembled
as "China". Classify modules made with non‐Chinese origin cells as "All other sources" even if assembled in China.
3
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐17. Toll production.‐‐Since January 1, 2012, has your firm been involved in a toll agreement
regarding the production of CSPV cells or assembly (full or partial) of CSPV cells into other
products (e.g., laminates, panels, modules)?
“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.
II‐18. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce CSPV cells or assemble (fully or
partially) CSPV cells into other products in and/or admit these items 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 CSPV cells (whether or not partially or fully assembled into other products) into a
foreign trade zone (FTZ) for use in distribution of these items and/or the production of
downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 24
II‐19. Direct imports.‐‐Since January 1, 2012, has your firm imported CSPV cells or modules?
“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
For questions II‐20 and II‐21, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II‐20. Effect of order.‐‐Describe the significance of the existing antidumping and countervailing duty
orders covering imports of CSPV cells and modules from China in terms of its effect on your
firm’s production capacity, production, U.S. shipments, inventories, purchases, employment,
revenues, costs, profits, cash flow, capital expenditures, research and development
expenditures, and asset values. You may wish to compare your firm’s operations before and
after the imposition of the order.
II‐21. Likely impact of revocation.‐‐Would your firm anticipate any changes in in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of CSPV cells
and modules in the future if the antidumping and countervailing duty orders on CSPV cells and
modules from China were to be revoked?
No
Yes
If 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 documentations that
address this issue. Include in your response a specific projection of
your firm’s capacity to produce CSPV cells and modules (in kilowatts)
for 2018 and 2019.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 25
II‐22. Other explanations:‐‐If your firm would like to explain further 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 ‐ CSPV Cells and Modules (CSPV1 Review)
Page 26
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Joanna Lo (202‐205‐1888, [email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain below:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for which
financial statements are prepared that include CSPV cells and/or CSPV modules:
2.
Does your firm prepare profit/loss statements for CSPV cells and/or CSPV modules:
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 CSPV cells and/or CSPV
modules, 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 ‐ CSPV Cells and Modules (CSPV1 Review)
Page 27
“Integrated producers of CSPV modules”.‐‐those U.S. firms that produce CSPV cells to be used in the
production of their CSPV modules) should report data regarding only their CSPV cell operations in
questions questions III‐7, III‐9a, and III‐9b (similar to the instructions provided on page 10 for questions
II‐5 through II‐7 on production of CSPV cells). Report any cells used in downstream production of
laminates, panels, modules, etc. as "internal consumption"). Report data regarding their CSPV module
operations in questions III‐8, III‐9c, and III‐9d, and III‐9e (similar to the instructions provided on page 10
for questions II‐9 through II‐13 on production of CSPV modules).
“Assemblers of CSPV modules”.‐‐those U.S. firms that purchase or import CSPV cells from an unrelated
firm and assemble CSPV modules) should report data regarding their operations in questions III‐9c, III‐
9d, and III‐9e (similar to the instructions provided on page 10 for questions II‐9 through II‐13 on
production of CSPV cells).
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. If your firm is an integrated producer of CSPV
modules, provide the details of your firm’s allocation basis for CSPV cell operations and
confirm that internal consumption has been excluded from your CSPV cell financial data.
III‐5.
Product listing.‐‐Please list the products your firm produces in the facilities in which it produces
CSPV cells and/or CSPV modules, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products
Share of sales
CSPV cells (not including internal consumption)
%
CSPV modules
%
%
%
%
III‐6a. Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CSPV cells 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.
No‐‐Skip to question III‐9a.
III‐6b. Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CSPV modules 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‐8.
No‐‐Skip to question III‐9c.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
III‐7.
Page 28
Inputs from related suppliers for CSPV cells.‐‐Please identify the inputs used in the production
of CSPV cells and/or CSPV modules that your firm purchases from related suppliers and that are
reflected in question III‐9a (Operations on CSPV cells (commercial sales and transfers)). 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
the 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.
III‐9a: Operations on CSPV cells (commercial sales and transfers)
Input1 2
Related supplier
Share of total COGS (percent)
1
What are the cost basis of your firm’s input valuations?
2
Are the input valuations above consistent with the firm’s accounting books and records and
reported in III‐9a? Yes No‐‐Please report the valuation basis of inputs purchased from
related suppliers as reported in question III‐9a:
III‐8.
Inputs from related suppliers for CSPV modules.‐‐Please identify the inputs used in the
production of CSPV modules that your firm purchases from related suppliers and that are
reflected in question III‐9c (Operations on CSPV modules). 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 the 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.
III‐9c: Operations on CSPV modules
Input1 2
Related supplier
Share of total COGS (percent)
1
What are the cost basis of your firm’s input valuations?
2
Are the input valuations above consistent with the firm’s accounting books and records and
reported in III‐9c? Yes No‐‐Please report the valuation basis of inputs purchased from
related suppliers as reported in question III‐9c:
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐9a. Operations on CSPV cells (commercial sales and transfers).‐‐Report the revenue and related
cost information requested below on the CPSV cell operations of your firm’s U.S.
establishment(s).1 Do not report resales of products or internal consumption. Note that
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 and reflect the data reported in question III‐7. Provide data for your firm’s six most
recently completed fiscal years, and for the specified interim periods. Companies whose fiscal
years are not calendar years should report the fiscal years which most closely correspond to
calendar years 2012 through 2017. This table should be completed by integrated producers of
CSPV modules.
Note: The table below should reflect commercial sales and transfers and corresponding
costs/expenses associated with CSPV cells manufactured and sold by your firm as CSPV cells.
CSPV cells manufactured and/or purchased by your firm which were used internally to
produce CSPV modules, if any, should be reported as a component of raw material costs in
table III‐9c (Operations on CSPV modules).
CELLS (commercial sales and transfers only)
Quantity (in kilowatts) and value (in $1,000)
Fiscal years ended‐‐
Item
2012
Net sales quantities:2
2013
2014
2015
January‐June
2016
2017
2017
2018
Commercial sales
Transfers to related firms
0
0
0
0
0
0
0
0
Commercial sales
Transfers to related firms
0
0
0
0
0
0
0
0
Polysilicon, Ingots
Wafers
All other raw material costs (CSPV cells)
Direct labor (CSPV cells)
All other factory costs (CSPV cells)
Total net sales quantities
Net sales values:2
Total net sales values
Cost of goods sold (COGS):3
Total COGS
0
0
0
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
SG&A expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Continued on following page.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐9a. Operations on CSPV cells (commercial sales and transfers).—Continued
Quantity (in kilowatts) and value (in $1,000)
Fiscal years ended‐‐
Item
Other expenses and income:
Interest expense
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
0
0
0
0
0
1
Include only CSPV cells commercial sales and/or transfers (whether domestic or export) and corresponding costs related to your U.S.
manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding CSPV cells shipment
quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CSPV cells commercial sales and transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
III‐9b. CSPV cells (commercial sales and transfers) variable and fixed costs.‐‐For the total COGS and
total SG&A expenses reported for the most recently completed annual period in table III‐9a,
please estimate the share of variable and fixed costs for each category, with the sum adding to
100 percent. The specified variable and fixed cost shares should be representative of the
relevant range of production that the company could achieve under current capacity
constraints.
Share of 2017:
Share of 2017:
COGS
SG&A
Item
(percent)
(percent)
Share of costs that are.‐‐
Variable
%
%
Fixed
%
%
Total (should sum to 100.0%)
0.0
%
0.0
%
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐9c. Operations on CSPV modules.‐‐Report the revenue and related cost information requested
below on the CSPV modules operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption, to the extent applicable, 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 and
reflected the data reported in question III‐8. Provide data for your firm’s six most recently
completed fiscal years, and for the specified interim periods. Companies whose fiscal years are
not calendar years should report the fiscal years which most closely correspond to calendar
years 2012 through 2017. This table should be completed by integrated producers of CSPV
modules and assemblers of CSPV modules.
MODULES
Quantity (in kilowatts) and value (in $1,000)
Item
Fiscal years ended‐‐
2012
Net sales quantities:2
Commercial sales
2013
2014
2015
January‐June
2016
2017
2017
2018
Internal consumption
Transfers to related firms
0
0
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
0
0
0
Direct labor (CSPV modules)
Other factory costs (CSPV modules)
Total COGS
0
0
0
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
0
0
0
0
Total net sales quantities
0
2
Net sales values:
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Raw material costs4
SG&A expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Net income or (loss) before income taxes
Depreciation/amortization included above
Footnotes continued on following page.
0
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐9c. Operations on CSPV modules.—Continued
1 Include CSPV modules commercial sales, internal consumption, and/or transfers (whether domestic or export) and corresponding
costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding CSPV
modules shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CSPV modules commercial sales, internal
consumption, and transfers.
4 Table III‐9d requests a breakout of the total raw material costs and will populate the raw material line item in this table.
Note ‐‐ The table on the previous page contains calculations that will appear when you have entered
data in the MS Word form fields.
III‐9d. Components of total raw material costs of CSPV modules.‐‐Provide a breakout of the relevant
components of total raw material costs reported in question III‐9c (Operations on CSPV
modules). Provide data for your firm’s six most recently completed fiscal years, and for the
specified interim periods. Companies whose fiscal years are not calendar years should report the
fiscal years which most closely correspond to calendar years 2012 through 2017.
MODULES: Raw Materials
Value (in $1,000)
Fiscal years ended‐‐
Item
January‐June
2012
2013
2014
2015
2016
2017
2017
2018
Wafers
All other raw material costs (CSPV cells)
Direct labor (CSPV cells)
All other factory costs (CSPV cells)
0
0
0
0
0
0
0
0
Purchased CSPV cells recognized in III‐9c
raw material costs:
CSPV cells purchased from related suppliers
CSPV cells purchased from unrelated
suppliers
0
0
0
0
0
0
0
0
Internally‐produced CSPV cells recognized in
III‐9c raw material costs:
Polysilicon, ingots
Total cost of internally‐produced CSPV
cells recognized in III‐9c raw material costs
Total cost of purchased CSPV cells
recognized in III‐9c raw material costs
Other raw material costs recognized in III‐9c
raw material costs:
All other raw material costs
1
Total raw material costs (CSPV
0
0
0
0
0
0
0
modules)
1
The total raw material costs calculated in this table will populate the raw material cost line item in table III‐9c.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
0
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐9e. CSPV modules variable and fixed costs.‐‐For the total COGS and total SG&A expenses reported
for the most recently completed annual period in table III‐9c, please estimate the share of
variable and fixed costs for each category with the sum adding to 100 percent. The specified
variable and fixed cost shares should be representative of the relevant range of production that
the company could achieve under current capacity constraints.
Share of 2017:
Share of 2017:
COGS
SG&A
Item
(percent)
(percent)
Share of costs that are.‐‐
Variable
%
%
Fixed
%
%
Total (should sum to 100.0%)
0.0
%
0.0
%
III‐9f. Financial data reconciliation.‐‐The calculable line items from question III‐9a and III‐9c (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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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐10. Nonrecurring items (charges and gains) included in CSPV cells and/or CSPV modules financial
results.‐‐For each annual and interim period for which financial results are reported in question
III‐9a (Operations on CSPV cells (commercial sales and transfers)) and/or III‐9c (Operations on
CSPV modules), please specify all material (significant) nonrecurring items (charges and gains) in
the schedule below, the specific question III‐9a and/or III‐9c line item where the nonrecurring
items are included, a brief description of the relevant nonrecurring items, and the associated
values (in $1,000), as reflected in question III‐9a and/or III‐9c; i.e., if an aggregate nonrecurring
item has been allocated to question III‐9a and/or III‐9c, only the allocated value amount
included in question III‐9a and/or III‐9c 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
and/or III‐9c.
Value ($1,000)
Fiscal years ended‐‐
Item
2012
2017
2018
2015
January‐June
2016
2017
2017
2018
III‐9a‐‐Operations on CSPV cells (commercial sales and transfers):
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III‐9c‐‐Operations on CSPV modules:
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Continued on following page.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐10. Nonrecurring items (charges and gains) included in CSPV cells and/or CSPV modules financial
results.‐‐Continued
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III‐9a and/or III‐9c where the nonrecurring item is
classified.
Description of the nonrecurring item
Income statement classification of
the nonrecurring item
III‐9a‐‐Operations on CSPV cells (commercial sales and transfers):
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III‐9c‐‐Operations on CSPV modules:
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
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 and/or III‐9c.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of CSPV cells and CSPV modules. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for
CSPV cells and/or CSPV modules in the normal course of business, please estimate this
information based upon a method (such as production, sales, or costs) that is consistent with
relevant cost allocations in questions III‐9a and/or III‐9c. Provide data as of the end of your
firm’s six most recently completed fiscal years. Companies whose fiscal years are not calendar
years should report the fiscal years which most closely correspond to calendar years 2012
through 2017.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted. Total assets should be allocated to CSPV products if these assets are also related to
other non‐CSPV products. Assets used in the production of CSPV cells should be further
allocated to CSPV cells for commercial sales and/or transfer and CSPV cells for internal
consumption. In the notes to the table below, please provide a brief explanation if
there were any substantial changes in total asset value during the period; e.g., due to asset
write‐offs, revaluation, and/or major capital equipment purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
2012
CSPV cell assets (net):‐‐
Used for commercial sales & transfers1
Used for internal consumption
2
Total CSPV cell assets (net)
Total CSPV modules (net)3
1
1
2013
2014
2015
2016
2017
Please allocate the total dollar amount of your firm’s CSPV cell assets separately for commercially sold and/or
transferred CSPV cells (reported in question III‐9a) and internally consumed CSPV cells (reported in III‐9c and
III‐9d).
2
Describe assets used for CSPV cells and explain substantial changes:
3
Describe assets used for CSPV modules and explain substantial changes:
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐13. Capital expenditures and research and development (“R&D”) expenses.‐‐Report your firm’s
capital expenditures and R&D for CSPV cells and CSPV modules. Provide data for your firm’s six
most recently completed fiscal years and the specified interim periods. Companies whose fiscal
years are not calendar years should report the fiscal years which most closely correspond to
calendar years 2012 through 2017.
Value (in $1,000)
Fiscal years ended‐‐
Item
CSPV cells:
Capital expenditures1
R&D expenses
2
CSPV modules:
Capital expenditures3
January‐June
2012
2013
2014
2015
2016
2017
2017
2018
4
R&D expenses
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on CSPV cells.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to CSPV cells.
3
Please describe the nature, focus, and significance of your firm’s capital expenditures on CSPV modules.
4
Please describe the nature, focus, and significance of your firm’s R&D expenses related to CSPV modules.
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9c, III‐12, and III‐13 are based on a calendar year or your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a and/or III‐9c should reconcile
with the data reported in question II‐8 and/or II‐11 (including export shipments) as long as they
are reported on the same calendar year basis.
Continued on following page.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐14. Data consistency and reconciliation.‐‐Continued
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II (questions II‐5 and II‐9) equal the quantities and values reported for total
net sales in part III (questions III‐9a and III‐9c) 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.
CSPV cells (commercial sales and transfers only)
Partial year
periods
Full year data
2012
Reconciliation
2013
2014
2015
2016
2017
2017
2018
Quantity: Trade data from question II‐5 less
financial data from question III‐9a, = zero ("0").
0
0
0
0
0
0
0
0
Value: Trade data from question II‐5 less
financial data from question III‐9a, = zero ("0").
0
0
0
0
0
0
0
0
Do these data in question III‐9a (CSPV cells) reconcile with data in question II‐5?
Yes
No
If no, please explain.
CSPV modules (commercial sales, internal consumption, and transfers)
Partial year
periods
Full year data
2012
Reconciliation
2013
2014
2015
2016
2017
2017
2018
Quantity: Trade data from question II‐9 less data
from question III‐9c, = zero ("0").
0
0
0
0
0
0
0
0
Value: Trade data from question II‐9 less
financial data from question III‐9c, = zero ("0").
0
0
0
0
0
0
0
0
Do these data in question III‐9c (CSPV modules) reconcile with data in question II‐9?
Yes
No
If no, please explain.
III‐15. 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 39
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from James Horne (202‐205‐2722,
[email protected]).
IV‐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 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 of the following products produced by your firm.
Product 1.‐‐ 60 cell multicrystalline silicon module, with a the peak power wattage between
240w to 265w, inclusive, p‐max or Wp
Product 2.‐‐ 60 cell multicrystalline silicon module, with a peak power wattage between 266w to
290w, inclusive, P‐max or Wp
Product 3.‐‐ 60 cell monocrystalline silicon module, with a peak power wattage between 250w
to 280w, inclusive, P‐max or Wp
Product 4.‐‐ 60 cell monocrystalline silicon module, with a peak power wattage between 281w
to 310w, inclusive, P‐max or Wp
Product 5.‐‐ 72 cell multicrystalline silicon module, with a peak power wattage between 290w to
315w, inclusive, P‐max or Wp
Product 6.‐‐ 72 cell multicrystalline silicon module, with a peak power wattage between 316w to
340w, inclusive, P‐max or Wp
Product 7.‐‐ 72 cell monocrystalline silicon module, with a peak power wattage between 300w
to 330w, inclusive, P‐max or Wp
Product 8.‐‐ 72 cell monocrystalline silicon module, with a peak power wattage between 331w
to 360w, inclusive, P‐max or Wp
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 40
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).
(a) During January 2012‐June 2018, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were competitive with these
products)?
Yes.‐‐Please complete the following pricing data table(s) as appropriate.
No.‐‐Skip to question IV‐3.
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in kilowatts and actual dollars (not 1,000s).
(Quantity in kilowatts, value in dollars)
Product 1
Product 2
Product 3
Product 4
Period of
shipment
Quantity
Value
Quantity
Value
Quantity
Value
Quantity
Value
2012:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2013:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2014:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2015:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
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 III.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of the 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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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐2(b). Continued
(Quantity in kilowatts, value in dollars)
Product 6
Product 7
Quantity
Value
Quantity
Value
Product 5
Product 8
Period of
Quantity
Value
Quantity
Value
shipment
2012:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2013:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2014:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2015:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
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 III.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 5:
Product 6:
Product 7:
Product 8:
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐2(c). Price data checklist.‐‐Please check that the pricing data in question IV‐2(a) 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‐9 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.
IV‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales CSPV cells and
modules (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction
Contracts
IV‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
IV‐5.
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced CSPV cells and modules?
Net 30
days
Net 60
days
Page 44
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic CSPV cells and modules usually quoted
(check one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced CSPV
cells and modules in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3)
short‐term contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of your
2017 sales
(CSPV cells)
Share of your
2017 sales
(CSPV
modules)
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
%
%
%
%
%
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
IV‐7.
Page 45
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced CSPV cells and modules (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 the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.‐produced CSPV cells and modules?
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 ‐ CSPV Cells and Modules (CSPV1 Review)
IV‐9.
Page 46
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced CSPV cells and
modules that is accounted for by U.S. inland transportation costs? %
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 CSPV cells and modules that
are delivered the following distances from your firm’s 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 CSPV cells and modules since January 1, 2012 (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 ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐11. End uses.‐‐
(a)
Estimate the percent of your total production cost that is accounted for by CSPV cells
and by other inputs (such as labor, energy, and other raw materials) in modules.)?
Share of total cost of end use product
accounted for by
Total
(should sum to 100.0%
across)
End use product
CSPV Cells
Other inputs
Module
(a)
%
%
0.0 %
For products you make using CSPV modules, please estimate the percent of your total
production cost that is accounted for by CSPV modules and by other inputs (such as
labor, energy, and other raw materials).
Share of total cost of end use product
accounted for by
End use product
CSPV Modules
Other inputs
Total
(should sum to 100.0%
across)
Residential system
%
%
0.0 %
Commercial system
%
%
0.0 %
Utility system
%
%
0.0 %
Off grid portable
consumer goods
%
0.0 %
(c)
Have there been any changes in the end uses of CSPV cells and modules since January 1,
2012? Do you anticipate any future changes?
Changes in end
uses
No
Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐12. Substitutes.‐‐
(a) Are thin film solar products considered substitutes for CSPV cells and modules in the
same end use(s)?
Substitutes
Are these
considered
substitutes in the
End use(s) in which
market?
this substitute is
No
Yes
used
Thin film solar
products
Have changes in the price of this
substitute affected the price for CSPV
cells and modules?
No
Yes
Explanation
(b) Can other products not already listed in part "a" of this question be substituted for CSPV
cells and modules?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Other substitutes
Have changes in the price of this substitute
affected the price for CSPV cells and modules?
No Yes
Explanation
1.
2.
3.
(c)
Have there been any changes in the number or types of products that can be
substituted for CSPV cells and modules since January 1, 2012? Do you anticipate any
future changes?
Changes in substitutes No Yes
Changes since
January 1, 2012
Anticipated changes
Explain
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐13. Availability of supply.‐‐Has the availability of CSPV cells and modules in the U.S. market changed
since January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
No Yes
market
changes.
Changes since January 1, 2012:
U.S.‐produced product
Imports from China
Imports from all other
countries
U.S.‐produced product
Imports from China
Imports from all other
countries
Anticipated changes:
IV‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for CSPV cells and modules has changed since January 1, 2012, and how you
anticipate demand will change in the future. Explain any trends and describe the principal
factors that have affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2012
Within the United States
(Residential)
Within the United States
(Utility)
Outside the United States
Anticipated future demand
Within the United States
(Residential)
Within the United States
(Utility)
Outside the United States
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U.S. Producers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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IV‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of CSPV cells and modules since January 1, 2012? Do you anticipate any future
changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
IV‐16. Conditions of competition.‐‐
(a) Are CSPV cells and modules market subject to business cycles (other than general economy‐
wide conditions) and/or other conditions of competition distinctive to CSPV cells and
modules?
Check all that apply.
Please describe.
No
Skip to question IV‐17.
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
CSPV cells and modules since January 1, 2012?
No
Yes
If yes, describe.
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IV‐17. Government Incentives.‐‐
(a)
Indicate how the level or availability of government incentives for CSPV cells and
modules has affected demand for CSPV has changed since January 1, 2012, and how you
anticipate demand will change in the future based on the level or availability of
government incentives? In the last column, list or describe the principal incentive
programs (e.g., Section 1603 program, Renewable Portfolio Standards, or California
Solar Initiative) whose change in level or availability might affect demand.
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Market
Explanation and factors
Demand since January 1, 2012
State and local
government incentives
Federal government
incentives
Anticipated future demand
State and local
government incentives
Federal government
incentives
(b) How have changes in the availability of government incentives affected the price of solar
generated electricity since January 1, 2012? Explain any trends and describe the principal
factors that might affect these changes in price
Fluctuate
with no
Overall
No
Overall
clear
price
Change
price
trend
Explanation and factors
increase
in price decrease
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IV‐18. Impact of the section 201 safeguard on firm and market.—
(a) Did the announcement on January 22, 2018 and subsequent implementation of remedies in
the section 201 safeguard proceeding have any discernible impact on your firm's CSPV cell
and module operations and/or the market as a whole? Include in this discussion the impact
of the 2.5 GW exemption and tariff‐rate quotas for CSPV cells if applicable.
No
Yes‐‐Please specify.
Item
Response
1
Impact on firm
Impact on overall market2
1
Please identify the magnitude and timing of any effects, and compare your firm's operations before and
after the announcement of the safeguard measures on January 22, 2018.
2
Please identify the magnitude and timing of any effects, and compare the overall market before and after
the announcement of the safeguard measures on January 22, 2018.
(b) Assessment of specific impacts of the section 201 safeguard.‐‐Please indicate the impact
that your firm has observed with regards to the announcement on January 22, 2018 and
subsequent implementation of remedies in the section 201 safeguard proceeding.
Item
Fluctuate
with no
Overall
No
Overall
improve change worsen clear trend
Explanation and factors
Overall
demand for
CSPV cells
and modules
in the U.S.
market
Prices for
CSPV cells
and modules
in the U.S.
market
Impact on
your firm's
CSPV cell
and module
operations in
the United
States
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(b) Changes to forward looking outlook due to the section 201 safeguard.‐‐What impact did the
announcement on January 22, 2018 and subsequent implementation of remedies in the
section 201 safeguard proceeding have on your firm's forward‐looking outlook?
Strongly
worsened
Item
Firm's forward looking
outlook
Somewhat
worsened
No change
Somewhat
improved
Strongly
improved
Narrative explanation:
IV‐19. Conventional energy sources.‐‐
(a) How have prices of electricity generated from U.S. conventional energy sources such as
natural gas and coal impacted demand for CSPV cells and modules (whether or not partially
or fully assembled into other products) in each sector below since January 1, 2012? Describe
the principal factors that have affected these changes in demand.
Overall
increase
Market
No
change
Overall
decrease
Fluctuate
with no
clear trend
Factors
Residential
Commercial
Utility
(b) How have changes in the price of electricity generated from U.S. conventional energy
sources affected the price of solar generated electricity since January 1, 2012? Explain any
trends and describe the principal factors that have affected these changes in price.
Overall
No
price
Change in
increase
price
Overall
price
decrease
Fluctuate
with no
clear trend
Explanation and factors
IV‐20. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply CSPV cells and
modules since January 1, 2012 (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.
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IV‐21. Raw materials.‐‐Indicate how CSPV cells and modules raw material prices have changed since
January 1, 2012, and how you expect they will change in the future.
Fluctuate Explain, noting how raw material
price changes have affected your
with no
clear firm’s selling prices for CSPV cells and
Overall
No
Overall
modules.
increase change decrease trend
Raw
materials
prices
Changes since
January 1,
2012
Anticipated
changes
IV‐22. Price comparisons.‐‐Please compare market prices of CSPV cells and modules in U.S. and non‐
U.S. markets, if known. Provide specific information as to time periods and regions for any price
comparisons.
IV‐23. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss CSPV cells and modules supply
(including production capacity and capacity utilization) and demand in (1) the United States, (2)
each of the other major producing/consuming countries, including China, and (3) the world as a
whole. Of particular interest is such data from 2012 to the present and forecasts for the future.
IV‐24. Export constraints.‐‐Describe how easily your firm can shift its sales of CSPV cells and modules
between the U.S. market and alternative country markets. In your discussion, please describe
any contracts, other sales arrangements, or other constraints that would prevent or retard your
firm from shifting cells and modules between the U.S. and alternative country markets within a
12‐month period.
IV‐25. Barriers to trade.‐‐Are your firm’s exports of CSPV cells and modules subject to any tariff or non‐
tariff barriers to trade in other countries?
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IV‐26. Interchangeability.—Are CSPV cells and modules 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
Other countries
China
For any country‐pair producing CSPV cells and modules that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that limit or preclude
interchangeable use:
IV‐27. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between CSPV cells and modules
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
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of CSPV cells and modules, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
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IV‐28. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://usitc.gov/investigations/701731/2017/crystalline_silicon_photovoltaic_cells_an
d_modules/first_review_full.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: CSPV1
• 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--CSPV cells and modules (R1) |
| Author | mary.messer |
| File Modified | 2018-08-06 |
| File Created | 2018-08-06 |