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pdfOMB No. 3117-0016/USITC No. 18-1-3904; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
SILICOMANGANESE FROM CHINA AND UKRAINE
This questionnaire must be received by the Commission by July 27, 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 reviews of the antidumping duty order concerning silicomanganese from China and Ukraine (Inv.
Nos. 731-TA-672-673 (Fourth 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 silicomanganese (as defined on the next page) at any time since January 1, 2012?
NO
(Si gn the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Compl ete 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: SIMN)
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 - Silicomanganese
Page 2
PART I.—GENERAL INFORMATION
Background.--On December 22, 1994, the Department of Commerce (“Commerce”) issued an
antidumping duty order on imports of silicomanganese from China, and on September 17, 2001,
Commerce issued an antidumping duty order on imports of silicomanganese from Ukraine. On October
2, 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 an affirmative determination, the orders will remain
in place. If either the Commission or Commerce makes a negative determination, Commerce will revoke
the orders. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/silicomanganese_china_and_ukraine_fourth_revie
w/full_review.htm.
Silicomanganese.--Silicomanganese, which is sometimes called ferrosilicon manganese, is a ferroalloy
composed principally of manganese, silicon and iron, and normally contains much smaller proportions of
minor elements, such as carbon, phosphorus, and sulfur. Silicomanganese generally contains by weight
not less than 4 percent iron, more than 30 percent manganese, more than 8 percent silicon, and not
more than 3 percent phosphorus. All compositions, forms, and sizes of silicomanganese are included
within the scope of the order, including silicomanganese slag, fines, and briquettes. Silicomanganese is
used primarily in steel production as a source of both silicon and manganese.
Silicomanganese is currently classifiable under subheading 7202.30.00 of the Harmonized Tariff
Schedule of the United States (“HTSUS”). Some silicomanganese may also currently be classifiable under
HTSUS subheading 7202.99.80. The orders cover all silicomanganese, regardless of its tariff
classification. Although the HTSUS subheadings are provided for convenience and customs purposes, the
written description of the orders remain dispositive.
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
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 3
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.
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 macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 4
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, me ani ngful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2.
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 silicomanganese, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
Covered1
City, State
Zip (5 digit)
1
2
3
4
5
6
1 Additional
discussion on establishments consolidated in this questionnaire:
Description
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U.S. Producers’ Questionnaire - Silicomanganese
I-3.
Page 5
Position regarding continuation of orders.--Does your firm support or oppose continuation of
the following antidumping duty orders currently in place for silicomanganese?
Country
Support
Oppose
Take no position
China
Ukraine
I-4.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-5.
Yes--List the following information.
Address
Extent of
ownership
(percent)
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing silicomanganese into the United States or that are
engaged in exporting silicomanganese to the United States?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
I-6.
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of silicomanganese?
No
Yes--List the following information.
Firm name
I-7.
Page 6
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 silicomanganese?
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 - Silicomanganese
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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Julie Duffy (202-708-2579,
[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 silicomanganese since January 1, 2012.
Check as many as appropriate.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
If checked, please describe; leave blank if not
applicable.
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U.S. Producers’ Questionnaire - Silicomanganese
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 silicomanganese in the future?
No
II-3a.
Page 8
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 silicomanganese (in short tons) for 2018 and 2019.
Production using same machinery.-- Please report your firm’s production of products made on
the same equipment, machinery, or employees as used to produce #abbrproduct, and the
combined production capacity on this shared equipment, machinery, or employees in the
periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in short tons)
Item
Overall production capacity
Production of:
Silicomanganese1
Out-of-scope production.-Ferromanganese
2015
Calendar year
2016
January-June
2017
2018
2017
0
0
0
0
0
0
0
0
0
0
Ferrosilicon
All other products2
Subtotal, out-of-scope
production
Total
1 Data
entered for production of silicomanganese will populate here once reported in question II-4.
these products:
.
2 Please identify
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on operating
per week,
weeks per year.
hours
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Page 9
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II-3e.
Product shifting.--Is your firm able to switch production (capacity) between silicomanganese and
other products using the same equipment and/or labor?
No
II-3f.
Yes-- (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.
Product shifting factors.--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 - Silicomanganese
II-4.
Page 10
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of silicomanganese in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions
are valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-4a.
Page 11
Production, shipment, and inventory data. --Continued
Quantity (in short tons) and value (in $1,000)
Item
2015
Calendar year
2016
2017
January-June
2017
2018
Average production capacity
(quantity) (A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
1
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:2
quantity (F)
value (G)
Transfers to related firms:2
quantity (H)
value (I)
Export shipments:3
quantity (J)
value (K)
End-of-period inventories
(quantity) (L)
Channels of distribution:
U.S. shipments—
to distributors (M)
to steel producers (N)
to other end users (O)
1 The
production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity (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, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide the data
above at fair market value).
3 Identify your firm’s principal export markets:
.
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U.S. Producers’ Questionnaire - Silicomanganese
II-4a.
Page 12
Production, shipment, and inventory data.--Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
January-June
Item
2015
2016
2017
2017
2018
B+ C– D– F–H –J– L
= should equal zero
("0") or provide an
explanation.1
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
0
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for commercial U.S. shipments
(i.e., line D) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
Item
M + N + O– D = zero
("0"), if not revise.
2015
2016
0
January-June
2017
0
2017
0
2018
0
0
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Page 13
II-5. U.S. shipments by grade. – Report the quantity and value of your firm’s U.S. shipments by grade
during the specified review periods (including commercial U.S. shipments, internal consumption,
and transfers, but not including exports).
Quantity (in short tons); value (in $1,000)
Item
Calendar Year
2016
2015
January-June
2017
2018
2017
ASTM A:
Quantity (P)
Value (Q)
ASTM B:
Quantity (R)
Value (S)
ASTM C:
Quantity (T)
Value (U)
High phosphorus not
meeting ASTM standard
(more than 0.2% of
phosphorus content):
Quantity (V)
Value (W)
Other1:
Quantity (X)
Value (Y)
U.S. Shipments:
Quantity (Z)
Value (AA)
1
0
0
0
0
0
0
0
0
0
0
Indicate the included product(s):
RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for US
shipments by product type here (i.e., lines P through AA) in each time period equal the quantities and
values reported for U.S. shipments (i.e., lines D through I) in each time period. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to submission to
the Commission.
Item
Calendar year
2016
2015
January-June
2017
2018
2017
Quantity: P + R + T + V
+ X - D - F - H = zero
("0"), if not revise.
0
0
0
0
0
Value: Q + S + U + W +
Y - E - G - I = zero ("0"),
if not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
II-6.
Historical U.S. shipment data. --Report the quantity and value of your firm’s U.S. shipments
(including commercial U.S. shipments, internal consumption, and transfers, but not including
exports) of silicomanganese produced in your U.S. establishment(s) during the specified periods.
Item
U.S. shipments
Quantity
Value
Page 14
Quantity (in short tons); value (in $1,000)
2012
2013
2014
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U.S. Producers’ Questionnaire - Silicomanganese
II-7.
Page 15
Employment data.--Report your firm’s employment-related data related to the production of
silicomanganese and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. 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
Employment data:
Average number of PRWs
(number) (O)
Hours worked by PRWs (1,000
hours) (P)
Wages paid to PRWs ($1,000)
(Q)
Explanation of trends:
2015
2016
January-June
2017
2017
2018
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II-8.
Transfers to related firms.--If your firm reported transfers to related firms in question II-4,
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-9.
Purchases.--Other than direct imports, has your firm otherwise purchased silicomanganese
since January 1, 2012?
No
Yes-- Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity and
value of such purchases below for the specified periods.
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
Reason for purchases:
Item
Purchases from U.S. importers
of silicomanganese from—
China
Ukraine
2015
Calendar year
2016
2017
January-June
2017
2018
1
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 - Silicomanganese
II-10.
Page 17
Toll production.--Since January 1, 2012, has your firm been involved in a toll agreement
regarding the production of silicomanganese?
“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
II-11.
Yes
If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce silicomanganese in and/or admit
silicomanganese into a foreign trade zone (FTZ)?
(a)
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import silicomanganese into a foreign trade zone (FTZ) for use in distribution of
silicomanganese and/or the production of downstream articles?
(b)
No
II-12.
Yes
Yes
If yes--Identify the firms and the FTZs.
Direct imports.--Since January 1, 2012, has your firm imported silicomanganese?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
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Page 18
For questions II-13 and II-14, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II-13.
Effect of orders.--Describe the significance of the existing antidumping duty orders covering
imports of silicomanganese from China and Ukraine in terms of their 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 orders.
II-14.
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
silicomanganese in the future if the antidumping duty orders on silicomanganese from China
and Ukraine were to be revoked?
No
II-15.
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 silicomanganese (in short tons) for 2018 and 2019.
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 - Silicomanganese
Page 19
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202-205-3432,
[email protected]).
III-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III-2.
Accounting system.--Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain below:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for which
financial statements are prepared that include silicomanganese:
2.
3.
4.
Does your firm prepare profit/loss statements for silicomanganese:
Yes
No
How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive basis of
accounting (specify)
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 silicomanganese, 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.).
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
Page 20
III-4.
Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III-5.
Product listing.--Please list the products your firm produces in the facilities in which it produces
silicomanganese, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
Share of sales
Silicomanganese
%
%
%
%
%
III-6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of silicomanganese from any related suppliers (e.g., inclusive of transactions
between related firms, divisions and/or other components within the same company)?
Yes--Continue to question III-7.
III-7.
No--Continue to question III-9a.
Inputs from related suppliers.--Please identify the inputs used in the production of
silicomanganese that your firm purchases from related suppliers and that are reflected in
question III-9a. For “Share of total COGS” please report this information by relevant input on
the basis of your most recently completed fiscal year. For “Input valuation” please describe the
basis, as recorded in 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.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
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U.S. Producers’ Questionnaire - Silicomanganese
III-8.
Page 21
Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in question III-9a (financial results on
silicomanganese) in a manner consistent with the firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in question III-9a.
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U.S. Producers’ Questionnaire - Silicomanganese
Page 22
III-9a. Operations on silicomanganese.--Report the revenue and related cost information requested
below on the silicomanganese operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact
Charles Yost at (202) 205-3432 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item
Net
2015
2016
January-June
2017
2017
2018
sales quantities:2
Commerci al s ales (“CS”)
Internal consumption (“IC”)
Tra ns fers to related firms (“Transfers”)
Tota l net sales quantities
0
0
0
0
0
0
0
0
0
0
Tota l COGS
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
Net
sales values:2
Commerci al s ales
Internal consumption
Tra ns fers to related firms
Tota l net sales va lues
Cost of goods sold
Ra w ma terials
(COGS):3
Di rect l abor
Other fa ctory costs
Selling, general, and administrative
(SG&A) expenses:
Sel ling expenses
General and administrative expenses
Tota l SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Al l other expense i tems
Al l other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1
2 Less discounts, returns, allowances, and
Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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Page 23
III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes
No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
III-10a. Raw material costs.--Report the related cost of raw materials reported in question III-9a on the
silicomanganese operations for the three fiscal years and specified interim periods.
Fiscal years ended-Item
2015
2016
January-June
2017
2017
2018
Value in $1,000
Si l icon
Ma nga nese
Other (fl ux, iron, etc.)
Tota l raw material costs
0
0
0
0
0
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Page 24
III-10b. By products.--Does your firm’s silicomanganese operations result in the production of by
products (e.g., slag)?
No
Yes
If yes, please describe the by product(s) produced.
Does your firm sell by products produced from the production of silicomanganese?
No
Yes
If yes, please specify the value for the three fiscal years and
specified interim periods and classification in your accounting
records and question III-9a.
Fiscal years ended-Item
2015
2016
January-June
2017
2017
2018
Value in $1,000
Byproducts
Cl a ssified in firm’s a ccounting records
a s sales revenue;
as other revenue;
a s deduction from costs;
Cl a ssified in question III-9a:
as sales revenue;
a s other revenue;
as deduction from costs.
III-10c. Energy costs. – Please identify the most important forms of energy consumed in your firm’s
production of silicomanganese
Fiscal years ended-Item
2015
2016
January-June
2017
2017
2018
Value in $1,000
El ectri city
Na tura l gas
Other
Tota l energy costs
0
0
0
0
Energy cost classification: In this table please indicate the specific line item(s) in table III-9a where the energy
costs are classified.
Income statement classification of the energy costs
El ectri city
Na tura l gas
Other
Please state how your firm controls energy costs, e.g., hedging, etc.
0
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Page 25
III-11. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to question
III-9a, only the allocated value amount included in question III-9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.
Fiscal years
2015
Item
2016
January-June
2017
2017
2018
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
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 where the nonrecurring item is classified.
Description of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Income statement classification of the nonrecurring item
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U.S. Producers’ Questionnaire - Silicomanganese
Page 26
III-12. 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-11 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-11 identify where these items
are reported in question III-9a.
III-13. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of silicomanganese. If your firm does not maintain some
or all of the specific asset information necessary to calculate total assets for silicomanganese in
the normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III-9a.
Provide data as of the end of your firm’s six most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net) 1
2015
2016
2017
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Page 27
III-14. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for silicomanganese. Provide data for
your firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Item
2015
Capital expenditures
Research and
development
expenses2
1 Please describe the
2 Please describe the
Fiscal years ended-2016
January-June
2017
2017
2018
1
nature, focus, and significance of your firm’s capital expenditures on the subject product.
nature, focus, and significance of your firm’s R&D expenses related to subject product.
III-15. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-6 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.-- Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Full year data
Reconciliation
Quantity: Trade data from question
II-4 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").
Value: Trade data from question II-4
(lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").
2015
2016
Partial year periods
2017
2017
2018
0
0
0
0
0
0
0
0
0
0
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Page 28
Do these data in question III-9a reconcile with data in question II-6?
Yes
No
If no, please explain.
III-16. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
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Page 29
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Emily Burke (202-205-3191,
[email protected]).
IV-1.
Contact information.--Please identify the 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.--ASTM grade B bulk silicomanganese sold to steel producers under contracts.
Product 2.--ASTM grade B bulk silicomanganese sold to distributors under contracts.
Product 3.--ASTM grade B bulk silicomanganese sold to steel producers as spot sales.
Product 4.--ASTM grade B bulk silicomanganese sold to distributors as spot sales.
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 2015-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 as appropriate.
No.--Skip to question IV-3.
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Page 30
IV-2(b). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value
Product 4
Period of shipment
Quantity
Value
2015:
Ja nuary-March
Apri l -June
Jul y-September
October-December
2016:
Ja nuary-March
Apri l -June
Jul y-September
October-December
2017:
Ja nuary-March
Apri l -June
Jul y-September
October-December
2018:
Ja nuary-March
Apri l -June
1 Net va l ues (i.e., gross sales va lues 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 Pri ci ng product definitions are provided on the first page of Pa rt IV.
Note.--If your fi rm’s product does not exactly meet the product s pecifications but is competitive with the s pecified product,
provi de a description of the product. Also, please explain a ny a nomalies i n your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
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Page 31
IV-2 (c). Price data checklist.--Please check that the pricing data in question IV-2(a) has been correctly
reported.
√ if Yes
Is the price data reported above:
In actual dollars (not $1,000) and in actual short tons (not 1,000 short tons)?
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-4 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 of
silicomanganese (check all that apply)? If your firm issues price lists, please submit sample
pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Set
price
lists
Other
If other, describe
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire - Silicomanganese
IV-5.
Pricing terms.-(a)
What are your firm’s typical sales terms for its U.S.-produced silicomanganese?
Net 30
days
(b)
Net 60
days
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic silicomanganese usually quoted (check
one)?
Delivered
IV-6.
Page 32
F.o.b.
If f.o.b., specify point
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
silicomanganese in 2017 was on a (1) long-term contract basis, (2) annual contract basis, (3)
short-term contract basis, and (4) spot sales basis?
Share of 2017
sales
Long-term
contracts
(multiple
deliveries for
more than 12
months)
%
Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
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U.S. Producers’ Questionnaire - Silicomanganese
IV-7.
Page 33
Contract provisions.—
(a) Please fill out the table regarding your firm’s typical sales contracts for U.S.-produced
silicomanganese (or check “not applicable” if your firm does not sell on a long-term, short-term
and/or annual contract basis).
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
Fixed quantity
and/or price
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long-term contracts
(multiple deliveries for
more than 12 months)
365
No
Quantity
Price
Both
Yes
Meet or release
provision
No
Not applicable
(b) Are contracts indexed to raw material costs?
No
IV-8.
Yes
If yes, describe.
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 silicomanganese?
Source
From inventory
Produced to order
Total (should sum to 100.0%)
Share of 2017 Lead time (Average
sales
number of days)
%
%
0.0 %
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U.S. Producers’ Questionnaire - Silicomanganese
IV-9.
Page 34
Shipping information.-(a)
What is the approximate percentage of the cost of U.S.-produced silicomanganese that
is accounted for by U.S. inland transportation costs?
%
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(c)
Indicate the approximate percentage of your firm’s sales of silicomanganese 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 silicomanganese since January 1, 2012 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
√ if applicable
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IV-11. End uses.-(a)
List the end uses of the silicomanganese that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by silicomanganese and
other inputs?
Share of total cost of end use product
accounted for by
End use product
(b)
No
(c)
Silicomanganese
Other inputs
Total
(should sum to
100.0% across)
%
%
%
%
0.0 %
0.0 %
%
%
0.0 %
Do ASTM A, ASTM B, ASTM C, and high-phosphorus silicomanganese have different end
uses?
Yes
If yes, please explain
Have there been any changes in the end uses of silicomanganese since January 1, 2012?
Do you anticipate any future changes?
Changes in end
uses
Changes since
January 1, 2012
Anticipated
changes
No
Yes
Explain
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Page 36
IV-12. Substitutes.-(a)
Can other products be substituted for silicomanganese?
No
Substitute
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for silicomanganese?
No Yes
Explanation
1.
2.
3.
(b)
Have there been any changes in the number or types of products that can be
substituted for silicomanganese since January 1, 2012? Do you anticipate any future
changes?
Changes in
substitutes
Changes since
January 1, 2012
Anticipated
changes
No Yes
Explain
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Page 37
IV-13. Availability of supply.--Has the availability of silicomanganese in the U.S. market changed since
January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
market
Please explain, noting the countries and reasons for the
No Yes changes.
Changes since January 1, 2012:
U.S.-produced product
Imports from China and
Ukraine
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from China and
Ukraine
Imports from all other
countries
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Page 38
IV-14. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for silicomanganese 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
Overall
increase
No
change
Fluctuate
Overall
with no
decrease clear trend
Explanation and factors
Demand since January 1, 2012
Within the United States
Outside the United States
Anticipated future demand
Within the United States
Outside the United States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of silicomanganese 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
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U.S. Producers’ Questionnaire - Silicomanganese
IV-16.
Page 39
Conditions of competition.-(a) Is the silicomanganese market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to silicomanganese?
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
silicomanganese since January 1, 2012?
No
Yes
If yes, describe.
IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply silicomanganese
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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Page 40
IV-18. Raw materials.-(a) Indicate how silicomanganese raw material prices have changed since January 1, 2012, and
how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no
Overall
No
Overall
clear
increase change decrease trend
Explain, noting how raw material
price changes have affected your
firm’s selling prices for
silicomanganese.
Changes since
January 1,
2012
Anticipated
changes
(b) Indicate how silicomanganese energy costs have changed since January 1, 2012, and how
you expect they will change in the future.
Fluctuate
with no
Overall
No
Overall
clear
Energy costs increase change decrease trend
Explain, noting how energy cost
changes have affected your firm’s
selling prices for silicomanganese.
Changes since
January 1,
2012
Anticipated
changes
IV-19. Price comparisons.--Please compare market prices of silicomanganese in U.S. and non-U.S.
markets, if known. Provide specific information as to time periods and regions for any price
comparisons.
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Page 41
IV-20. 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 silicomanganese 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 Ukraine, and (3)
the world as a whole. Of particular interest is such data from 2012 to the present and forecasts
for the future.
IV-21. Export constraints.--Describe how easily your firm can shift its sales of silicomanganese
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 silicomanganese between the U.S. and alternative country markets within a
12-month period.
IV-22. Barriers to trade.--Are your firm’s exports of silicomanganese subject to any tariff or non-tariff
barriers to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2012, or that are expected to occur in the future.
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IV-23. Interchangeability.--Is silicomanganese produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair
China
Ukraine
Other countries
United States
China
Ukraine
For any country-pair producing silicomanganese that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:
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IV-24. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between silicomanganese
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair
China
Ukraine
Other countries
United States
China
Ukraine
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of silicomanganese, identify the country-pair and report the
advantages or disadvantages imparted by such factors:
IV-25. Effect of 232 investigation of steel on conditions of competition.-(a) Are you familiar with the 232 investigation conducted by the United States under section 232
of the Trade Expansion Act of 1962 as amended (19 U.S.C. § 1862) on imports of certain steel
products and the related proclamations issued by the President or the subsequent imposition
of tariffs on imported steel products?
No (skip to IV-26)
Yes--Please fill out the table.
(b) Did the announcement of the section 232 investigation in April 2017 or the President’s
subsequent issuance of proclamations on certain imported steel products beginning in March
2018 impact the conditions of competition for silicomanganese used in the production of
steel?
No
Announcement of the section 232
investigation in April 2017
Issuance of proclamations on certain
imported steel products beginning in
March 2018
Yes If yes, describe.
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IV-26. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2017/silicomanganese_china_and_ukrain
e_fourth_review/full_review.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: SIMN
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | US Producer questionnaire - sunset |
| Author | Duffy, Julie |
| File Modified | 2018-06-13 |
| File Created | 2018-06-13 |