18-2-3905 US importers' questionnaire

OMB No. 3117-0016/USITC No. 18-2-3905; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ 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 orders concerning silicomanganese from China and Ukrai ne (i nv.
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 imported silicomanganese (as defined on the next page) from any country at any time
since January 1, 2012?

NO

(Si gn the certification below a nd 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 investigations 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

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U.S. Importers’ 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, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
purchaser and/or foreign producer questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and

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U.S. Importers’ Questionnaire - Silicomanganese

Page 3

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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Julie
Duffy (202-708-2579, [email protected]).
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. Importers’ Questionnaire - Silicomanganese
I-1.

Page 4

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, me ani ngful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 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 name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of silicomanganese,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

I-3.

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

Firm name

Yes--List the following information.

Address

Extent of
ownership
(percent)

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
I-4.

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

Yes--List the following information.

Firm name

I-5.

Country

Affiliation

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-6.

Page 5

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on
silicomanganese. More than one answer may be applicable.
Importer of record

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
I-7.

Consignees.--If your firm is an importer of record of silicomanganese but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).
Firm name

I-8.

Page 6

Contact person and
phone number

Address

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters silicomanganese
into, or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also
indicate whether your firm imports silicomanganese under the TIB (temporary importation
under bond) program.
“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, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby, imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule (HTS).
Item
Foreign trade zones
Bonded warehouses
Temporary importation under bond

No

Yes

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
I-9.

Business plan.--In Parts II and III 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

I-10.

Page 7

Yes–Please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes–Please specify.

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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 importation of silicomanganese since January 1, 2012.
Check as many as appropriate.
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

If checked, please describe; leave blank if not applicable.

Business Proprietary
U.S. Importers’ 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 importation of silicomanganese in the future?

No

II-3.

Page 9

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.

Arranged imports.--Has your firm imported or arranged for the importation of silicomanganese
for delivery after June 30, 2018?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Period/Source

Yes–Fill out the table below.
Quantity (in short tons)
Jul-Sept 2018
Oct-Dec 2018
Jan-Mar 2019

Apr-Jun 2019

China
Ukraine
Other sources
II-4.

Reasons for importing if producer.--If your firm also produces silicomanganese in the United
States, please indicate the reasons for importing this product. If your firm’s reasons differ by
source, please elaborate.

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial 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.

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U.S. Importers’ Questionnaire - Silicomanganese
II-5a.

Page 11

Imports from China.--Report your firm’s imports and your firm’s shipments and inventories of
silicomanganese imported from China during the specified periods.

CHINA
Quantity (in short tons), value (in $1,000)
Calendar year
Item
Beginning-of-period
inventories (quantity) (A)

2015

2016

2017

January-June
2017

2018

Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (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 Please identify

the foreign producers, if known:
.
to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each period identified above:
.
3 Identify your firm’s principal export markets:
.
2 Sales

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U.S. Importers’ Questionnaire - Silicomanganese
II-5a.

Page 12

Imports from China.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 A),
plus imports (i.e., line B), 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 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.

Reconciliation

Calendar year
2016

2015

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

0

1 Explanation if the calculated fields

.

January-June
2017
2018

2017

0

0

0

0

above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) in each time period equal the quantity reported for commercial U.S. commercial
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.

Item
M + N + O - D = zero
("0"), if not revise.

Calendar year
2016

2015
0

0

January-June
2017
2018

2017
0

0

0

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II-5b. U.S. shipments by grade. – Report the quantity and value of your firm’s U.S. shipments by
grade during the three year period and specified interim periods.
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
Quantity: P + R + T + V
+ X - D - F - H = zero
("0"), if not revise.
Value: Q + S + U + W +
Y - E - G - I = zero ("0"),
if not revise.

Calendar year
2016

2015

January-June
2017
2018

2017

0

0

0

0

0

0

0

0

0

0

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U.S. Importers’ Questionnaire - Silicomanganese

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II-5c. Historical U.S. imports. --Report the quantity your firm’s U.S. imports of silicomanganese from
China during the specified periods.

Item
Silicomanganese
Quantity
Value

Quantity (in short tons)
2012

2013

2014

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U.S. Importers’ Questionnaire - Silicomanganese
II-6a.

Page 15

Imports from Ukraine.--Report your firm’s imports and your firm’s shipments and inventories of
silicomanganese imported from Ukraine during the specified periods.

UKRAINE
Quantity (in short tons), value (in $1,000)
Calendar year
Item
Beginning-of-period
inventories (quantity) (A)

2015

2016

2017

January-June
2017

2018

Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (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 Please identify

the foreign producers, if known:
.
to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each period identified above:
.
3 Identify your firm’s principal export markets:
.
2 Sales

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U.S. Importers’ Questionnaire - Silicomanganese
II-6b.

Page 16

Imports from Ukraine.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 A),
plus imports (i.e., line B), 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 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.

Reconciliation

Calendar year
2016

2015

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

0

1 Explanation if the calculated fields

.

January-June
2017
2018

2017

0

0

0

0

above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) in each time period equal the quantity reported for commercial U.S. commercial
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.

Item
M + N + O - D = zero
("0"), if not revise.

Calendar year
2016

2015
0

0

January-June
2017
2018

2017
0

0

0

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II-6c. U.S. shipments by grade. – Report the quantity and value of your firm’s U.S. shipments by grade
during the specified periods.
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
Quantity: P + R + T + V
+ X - D - F - H = zero
("0"), if not revise.
Value: Q + S + U + W +
Y - E - G - I = zero ("0"),
if not revise.

Calendar year
2016

2015

January-June
2017
2018

2017

0

0

0

0

0

0

0

0

0

0

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U.S. Importers’ Questionnaire - Silicomanganese

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II-6d. Historical U.S. imports. --Report the quantity your firm’s U.S. imports of silicomanganese from
Ukraine during the specified periods.

Item
Silicomanganese
Quantity
Value

Quantity (in short tons)
2012

2013

2014

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
II-7a.

Page 19

Imports from all other sources.-- Report your firm’s imports and your firm’s shipments and
inventories of silicomanganese imported from all other sources combined during the specified
periods.

(list sources:

ALL OTHER SOURCES COMBINED
)
Quantity (in short tons), value (in $1,000)
Calendar year

Item
Beginning-of-period
inventories (quantity) (A)

2015

2016

2017

January-June
2017

2018

Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (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 Please identify

the foreign producers, if known:
.
to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each period identified above:
.
3 Identify your firm’s principal export markets:
.
2 Sales

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
II-7b.

Page 20

Imports from all other sources.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 A),
plus imports (i.e., line B), 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 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.

Reconciliation

Calendar year
2016

2015

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

0

1 Explanation if the calculated fields

.

January-June
2017
2018

2017

0

0

0

0

above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines K and L) in each time period equal the quantity reported for commercial U.S. commercial
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.

Item
M + N + O– D = zero
("0"), if not revise.

Calendar year
2016

2015
0

0

January-June
2017
2018

2017
0

0

0

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
II-7c.

Page 21

U.S. Shipments by grade. – Report the quantity and value of your firm’s U.S. shipments by grade
during the three year period and specified interim periods.
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
Quantity: P + R + T + V
+ X - D - F - H = zero
("0"), if not revise.
Value: Q + S + U + W +
Y - E - G - I = zero ("0"),
if not revise.

Calendar year
2016

2015

January-June
2017
2018

2017

0

0

0

0

0

0

0

0

0

0

Business Proprietary
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Page 22

II-7d. Historical U.S. imports. --Report the quantity your firm’s imports of silicomanganese imported
from all other sources combined during the specified periods.

Item
Silicomanganese
Quantity
Value

Quantity (in short tons)
2012

2013

2014

Business Proprietary
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Page 23

For questions II-8 and II-9, if your firm’s response differs for particular orders, please indicate and
explain the particular effect of imposition and/or revocation of specific orders.
II-8.

Effect of order(s).--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
imports, U.S. shipments of imports, and inventories. You may wish to compare your firm’s
operations before and after the imposition of the order.

II-9.

Likely impact of revocation. --Would your firm anticipate any changes in in the character of its
operations or organization, including its imports, U.S. shipments of imports, or inventories of
silicomanganese in the future if the antidumping duty orders on silicomanganese from China
and Ukraine were to be revoked?

No

II-10.

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.

Other explanations.--If your firm would like to further explain a response to a question in Part II
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
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Page 24

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Emily Burke (202-205-3191,
[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

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products your firm imported from China and/or
Ukraine:
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 import from China and/or Ukraine and sell to
unrelated U.S. customers any of the above listed products (or any products that were
competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-3.

Business Proprietary
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Page 25

III-2(b). Price data (China).--Report below the quarterly price data1 for pricing products2 imported from
China and sold by your firm.

China

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 III.
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 any a nomalies i n your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
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Page 26

III-2(c). Price data (Ukraine).--Report below the quarterly price data1 for pricing products2 imported
from Ukraine and sold by your firm.

Ukraine

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 III.
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 any a nomalies i n your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
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Page 27

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

√ if Yes

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-5 in each year?
III-2(e). Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
III-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

III-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

III-5.

Page 28

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for silicomanganese imported from China
and/or Ukraine?
Net 30 Net 60 2/10 net
days
days
30 days
Other
Other (specify)

(b)

On what basis are your firm’s prices of imported silicomanganese from China and/or
Ukraine usually quoted? (check one)
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
III-6.

Contract versus spot.-- Approximately what share of your firm’s sales of silicomanganese
imported from China and/or Ukraine 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 your
2017 sales
III-7.

Page 29

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

Type of sale
Annual
contracts
(multiple
deliveries for 12
months)

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

%

%

%

Spot sales
(for a single
delivery)
%

Total
(should
sum to
100.0%)
0.0

%

Contract provisions.—

(a) Please fill out the table regarding your firm’s typical sales contracts for silicomanganese from
China and/or Ukraine (or check “not applicable” if your firm does not sell on a long-term, shortterm, and/or 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)

365

No
Quantity
Price
Both
Yes

Meet or release
provision

No

Not applicable
(b) Are contracts indexed to raw material costs?
No

Yes

Annual contracts
(multiple
deliveries for 12
months)

If yes, describe.

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

Business Proprietary
U.S. Importers’ Questionnaire - Silicomanganese
III-8.

Page 30

Lead times.--What is your firm’s share of sales of silicomanganese imported from China and/or
Ukraine from inventory and produced to order and what is the typical lead time between a
customer’s order and the date of delivery for your firm’s sales of silicomanganese?
Source
From inventory

Share of 2017
sales
%

From foreign manufacturers’ inventory
Produced to order
Total (should sum to 100.0%)
III-9.

Lead time (Average
number of days)

%
%
0.0

%

Shipping information.-(a)

What is the approximate percentage of the cost of silicomanganese imported from
China and/or Ukraine 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)

When your firm sells silicomanganese imported from China and/or Ukraine, from where
is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your sales of silicomanganese imported from
China and/or Ukraine that are delivered the following distances from your firm’s U.S.
point of shipment.
Distance from your firm’s U.S. point of shipment

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0 %

%

Business Proprietary
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Page 31

III-10. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold
silicomanganese imported from subject countries since January 1, 2012 (check all that apply)?
Geographic area

China

Ukraine

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.
III-11. End uses.-(a)

List the end uses of the silicomanganese that your firm imports. 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

Silicomanganese
%
%

Other inputs
%
%

%
(b)

No

(c)

%

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

Business Proprietary
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Page 32

III-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 33

III-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/or Ukraine
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from China
and/or Ukraine
Imports from all other
countries
III-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

Overall
decrease

Fluctuate
with no
clear trend

Demand since January 1, 2012
Within the United States
Outside the United States
Anticipated future demand
Within the United States
Outside the United States

Explanation and factors

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III-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

Explain

Changes since
January 1, 2012
Anticipated
changes
III-16. 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 III-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.

III-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 35

III-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
III-19. Price comparisons.--Please compare market prices of silicomanganese in U.S. and non-U.S.
markets if known. Provide information as to time periods and regions for any price comparisons.

III-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.

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III-21. 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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Page 37

III-22. 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:

III-23. 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 III-24)

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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Page 38

III-24. Other explanations.--If your firm would like to further explain a response to a question in Part III
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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Page 39

Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.

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Page 40

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 import 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.