18-2-3909 US importers' questionnaire

OMB No. 3117-0016/USITC No. 18-2-3909; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
STEEL RACKS FROM CHINA
This questionnaire must be received by the Commission by July 5, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning steel racks from China (Inv. Nos. 701TA- 608 and 731-TA-1420 (Preliminary)). The information requested in the questionnaire is requested under the
authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a
subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm imported steel racks (as defined on next page) from any country at any time since January 1,
2015?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: SRACK)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Email address

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 20, 2018, by Bulldog
Rack Company, Weirton, West Virginia; Hannibal Industries, Inc., Los Angeles, California; Husky Rack and
Wire, Denver, North Carolina; Ridg-U-Rak, Inc., North East, Pennsylvania; SpaceRAK, A Division of
Heartland Steel Products, Inc., Marysville, Michigan; Speedrack Products Group, Ltd., Sparta, Michigan;
Steel King Industries, Inc., Stevens Point, Wisconsin; Tri-Boro Shelving & Partition Corp., Farmville,
Virginia; and UNARCO Material Handling, Inc., Springfield, Tennessee. Countervailing and/or
antidumping duties may be assessed on the subject imports as a result of these proceedings if the
Commission makes an affirmative determination of injury, threat, or material retardation, and if the U.S.
Department of Commerce (“Commerce”) makes an affirmative determination of subsidization and/or
dumping. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/steel_racks_china/preliminary.htm.
Steel racks covered by these investigations is steel racks and parts thereof, assembled or unassembled.
Steel racks are racks made of steel of dimensions and configurations that can be adjusted as required,
with or without locking tabs or slots, and with or without bolted, clamped, or welded connections,
including any of the following: uprights, posts, columns, braces, frames, beams, arms, locking devices,
and rails.
A steel rack is a structure typically made from cold-formed or hot-rolled steel structural members and
includes, but is not limited to, components such as plates, rods, angles, shapes, sections, tubes and the
like. Welding, bolting, and clipping are the typical methods of assembly. Connections may also be made
with locking devices such as clips, end plates, and beam connectors. Steel racks may be made to ANSI
MH16.1 or ANSI MH16.3. All steel racks and parts thereof meeting the physical description set out
herein are covered by the scope of this investigation, whether or not produced according to a particular
standard.
The vertical components of steel racks may be referred to as posts, columns, or uprights, and may be
connected with horizontal or diagonal braces to form upright frames. A typical storage configuration
comprises upright frames perpendicular to the aisles, independently adjustable, positive locking beams
parallel to the aisle and spanning between the upright frames, and braces designed to support unit loads
between the beams. A cantilever rack consists of uprights running parallel to the aisle and cantilever
beams or arms connected to the uprights and running perpendicular to the aisle rather than spanning
two upright frames.
The scope includes all steel racks and parts thereof meeting the description above, regardless of: (1)
dimensions, weight, strength, gauge, or load rating; (2) vertical upright or frame type (including
structural, roll-form, or other); (3) horizontal support or beam / brace type (including but not limited to
structural, roll-form, slotted, unslotted, Z-beam, C-beam, L-beam, step beam, cantilever beam, and
cargo rack); (4) number of supports; (5) number of levels; (6) surface coating, if any (including but not
limited to paint, epoxy, powder coating, zinc, and other metallic coating); (7) shape (including but not
limited to rectangular, square, corner, and cantilever); (8) the method by which the vertical and
horizontal supports connect (including but not limited to locking tabs or slots, bolting, clamping, and
welding); and (9) the inclusion or not of moving components (including but not limited to rails, wheels,
rollers, tracks, channels, carts, and conveyors).
Steel racks may be referred to as pallet racks, storage racks, stacker racks, retail racks, pick modules, or
cantilever racks. Steel racks that incorporate moving components may also be referred to as pallet flow
racks, carton flow racks, push back racks, movable shelf racks, drive-in racks, and drive-through racks.

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Subject merchandise includes material matching the above description that has been finished,
assembled, or packaged in a third country, including by coating, painting, assembling, attaching to, or
packaging with another product, or any other finishing, assembly, or packaging that would not
otherwise remove the merchandise from the scope of the investigation if performed in the country of
manufacture of the steel racks and parts thereof.
Steel racks and parts thereof are covered whether or not imported attached to, or in conjunction with,
other parts and accessories such as wire decking, nuts, and bolts. If steel racks and parts thereof are
imported attached to, or in conjunction with, such non-subject merchandise, only the steel racks and
parts thereof are covered by the scope.
Specifically excluded from the scope of this investigation are any products covered by the existing
antidumping and countervailing duty orders on boltless steel shelving units prepackaged for sale from
the People’s Republic of China. See Boltless Steel Shelving Units Prepackaged for Sale From the People’s
Republic of China: Antidumping Duty Order, 80 Fed. Reg. 63,741 (October 21, 2017); Boltless Steel
Shelving Units Prepackaged for Sale From the People’s Republic of China: Amended Final Affirmative
Countervailing Duty Determination and Countervailing Duty Order, 80 Fed. Reg. 63,745 (October 21,
2017).
Merchandise covered by this investigation is currently classified in the Harmonized Tariff Schedule of the
United States (HTSUS) under the following subheadings: 7326.90.86881 and 9403.20.0080.2 Subject
merchandise may also enter under subheadings 7308.90.3000, 7308.90.6000, 7308.90.9590, and
9403.20.0090. The HTSUS subheadings set forth above are provided for convenience and U.S. Customs
purposes only. The written description of the scope is dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing steel racks (as defined above) into the United States from a foreign manufacturer or through
its selling agent.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.-- The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting

Prior to January 1, 2017, such merchandise was classified under HTS statistical reporting number 7326.90.8588.
From July 1, 2015 through December 31, 2017, such merchandise was classified under HTS statistical reporting
number 9403.20.0080. Prior to July 1, 2015 such merchandise was classified under HTS statistical reporting
number 9403.20.0020.
1
2

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documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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 Amelia
Shister (202-205-2047, [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 - Steel racks (Preliminary)
I-1.

Page 5

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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 steel racks, 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 - Steel racks (Preliminary)
I-4.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing steel racks from China into the United States or that are
engaged in exporting steel racks from China 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 steel racks?
No

Yes--List the following information.

Firm name

I-6.

Page 6

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on steel
racks. 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 - Steel racks (Preliminary)
I-7.

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

Firm name

I-8.

Page 7

Contact person
and phone
number

Address

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters steel racks into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports steel racks 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 of the United States (HTS).
Item

No

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

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

If yes, 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 Amelia Shister (202-2052047, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the importation of steel racks since January 1, 2015.
(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)

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-3a.

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Arranged imports.--Has your firm imported or arranged for the importation of steel racks for
delivery after March 31, 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

Yes

If yes, fill out the table below.

Period
Source

Apr-Jun 2018

Jul-Sept 2018

Oct-Dec 2018

Jan-Mar 2019

Quantity (in pounds)
China
Other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported steel racks
from any source between June 1, 2017 and May 30, 2018? (i.e., the last seven months in 2017
and first five months in 2018 combined)
No

Yes

If yes, report the quantity of such import below by source.

Quantity (in pounds)
Source

June 2017 through May 2018

China
Other sources
II-4.

Reasons for importing if producer.--If your firm also produces steel racks 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 - Steel racks (Preliminary)
II-5a.

Page 11

U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of steel racks imported from China by your firm during the specified periods.

China
Quantity (in pounds), value (in dollars)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Beginning-of-period
inventories (quantity) (A)
Imports:1 2
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value2 (G)
Transfers to related
firms:3
Quantity (H)
Value2 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
Please identify the HTS statistical reporting numbers used for the imports of these products:
.
3
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different basis for
valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided
above in this table should be based on fair market value.
4
Identify your firm’s principal export markets:
.
1
2

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-5a.

Page 12

U.S. 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.
Calendar years
Reconciliation

2015

2016

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

0

January-March
2017

0

2017
0

2018
0

0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1

II-5b.

Channels of distribution: China.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related parties) of imports
from China by channel of distribution.

China

Calendar years
Item

2015

January-March

2016

2017

2017

2018

Quantity (in pounds)
Channels of distribution:
U.S. shipments:1
To distributors / for
re-sale (M)
To end users / for
installation (N)
1

Sales to retailers should be classified as “end users” to the degree the sales are not merchandise intended for resale.

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 U.S. shipments (i.e., lines D, F, and
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
M + N – D – F – H = zero ("0"), if not
revise.

2015

2016
0

January-March
2017

0

2017
0

2018
0

0

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-5c.

Page 13

Rack coatings: China.--Please indicate the share of quantity of your firm's U.S. shipment (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
imports from China in 2017 by coating type.

China

Coating
No coating
Paint
Epoxy coated
Zinc or other galvanized
Other1
Total (should sum to 100.0 percent)
1

Please identify:

.

Share of 2017 U.S. Shipments
(percent)

0.0

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-6a.

Page 14

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of steel racks imported from all other sources by your firm during the specified
periods.

All other sources

(list sources:

)
Quantity (in pounds), value (in dollars)
Calendar years

Item

2015

2016

January-March
2017

2017

2018

Beginning-of-period
inventories (quantity) (A)
Imports:1 2
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value2 (G)
Transfers to related
firms:3
Quantity (H)
Value2 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
Please identify the HTS statistical reporting numbers used for the imports of these products:
.
3
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different basis for
valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided
above in this table should be based on fair market value.
4
Identify your firm’s principal export markets:
.
1
2

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-6a.

Page 15

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.
Calendar years
Reconciliation

2015

2016

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

0

January-March
2017

0

2017
0

2018
0

0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1

II-6b.

Channels of distribution: All other sources.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related parties) of imports
from all other sources by channel of distribution.

All other sources
Calendar years

Item

2015

2016

January-March

2017

2017

2018

Quantity (in pounds)
Channels of distribution:
U.S. shipments:1
To distributors / for
re-sale (M)
To end users / for
installation (N)
1

Sales to retailers should be classified as “end users” to the degree the sales are not merchandise intended for resale.

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 U.S. shipments (i.e., lines D, F, and
H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
M + N – D – F – H = zero ("0"), if not
revise.

2015

2016
0

January-March
2017

0

2017
0

2018
0

0

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-6c.

Page 16

Rack coatings: All other sources.--Please indicate the share of quantity of your firm's U.S.
shipment (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to
related firms) of imports from all other sources in 2017 by coating type.

All Other Sources

Coating
No coating
Paint
Epoxy coated
Zinc or other galvanized
Other1
Total (should sum to 100.0 percent)
1

Please identify:

.

Share of 2017 U.S. Shipments
(percent)

0.0

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-7.

Page 17

Rack types.--Please indicate which of the following steel racks your firm imports and sells or
uses.

(check as many as appropriate)

Cantilever Rack.--A rack structure comprised primarily of vertical columns, extended bases, horizontal
arms projecting from the face of the columns, and down-aisle bracing between columns. There can be
shelf beams between arms depending on the product being stored. Cantilever columns may be freestanding or overhead tied.
Case-Flow Rack.--A specialized pallet rack structure in which either the horizontal shelf beams support
case-flow lanes or case-flow shelf assemblies are supported by the upright frames. The case-flow lanes or
shelves are installed at a slight pitch permitting multiple-depth case or box storage with loading from one
service aisle and unload or picking from another service aisle.

Drive-In Rack.--A rack structure comprised primarily of vertical upright frames, horizontal support arms,
and horizontal load rails typically used for one-wide by multiple-depth storage. This structure includes an
“anchor section” with horizontal beams supporting the load rails. Loading and unloading within a bay must
be done from the same aisle. A two-way drive-in rack is a special case where back-to-back rows of drive-in
racks are combined into a single entity with a common rear post.
Drive-Through Rack.--A rack structure comprised primarily of vertical upright frames, horizontal support
arms, and horizontal load rails typically used for one-wide by multiple-depth storage. This structure lacks
the ‘anchor section’ found in drive-in racks; therefore, loading and unloading can be accomplished from
both ends of a bay.
Movable-Shelf Rack.--A rack structure comprised primarily of vertical upright frames and horizontal shelf
beams and typically used for one-deep pallet or hand-stack storage. Typically, the locations of a couple of
shelf levels are "fixed" with the location of the in-fill shelves being flexible.
Pallet-Flow Rack.--A specialized pallet rack structure in which the horizontal shelf beams support palletflow lanes. The pallet-flow lanes are typically installed on a slight pitch permitting multiple-depth pallet
storage with loading from one service aisle and unloading from another service aisle.
Pallet Rack.--A rack structure comprised primarily of vertical upright frames and horizontal shelf beams
and typically used for one and two-deep pallet storage.
Pick Modules.--A rack structure comprised primarily of vertical frames and horizontal beams, typically
having one or more platform levels of selective, case-flow, or pallet-flow bays feeding into a central pick
aisle(s) {work platform(s)} supported by the rack structure.
Portable Rack (Stacking Frames).--An assembly, typically with four corner columns, that permits stacking
of one assembly on top of another without applying any additional load to the product being stored on
each assembly.
Push-Back Rack.--A specialized pallet rack structure in which the horizontal shelf beams support pushback lanes comprised of tracks and carts. The push-back lanes are installed on a slight pitch permitting
multiple-depth pallet storage. Loading and unloading are done from the same service aisle by pushing the
pallets back.
Stacker Rack.--A rack structure similar to one of the other rack structures that is serviced by an automated
storage and retrieval machine.
Other steel racks or parts thereof1

1

Please identify:

.

Business Proprietary
U.S. Importers’ Questionnaire - Steel racks (Preliminary)
II-8.

Page 18

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.

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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Jon Ruder (202-205-3435,
[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 since January 1, 2015 of the following products imported from
China:
Product 1.--Beam, non-galvanized, 96” length, 4” face, 3 pins connection, 1 5/8” step
Product 2.--Beam, non-galvanized, 120” length, 5” face, 4 pins connection, 1 5/8” step
Product 3.--Frame, non-galvanized, 14 gauge, 3” x 1 5/8” posts, 42” x 120”
Product 4.--Frame, non-galvanized, 14 gauge, 3” x 3” posts, 42” x 192”

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).
During January 2015-March 2018, did your firm import from China and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question III-3.

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

China

Report data in pounds and dollars
Product 1
Quantity
Value

(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

Product 4
Period of shipment
Quantity
Value
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

III-2(b). Price data checklist.--Please check that the pricing data in question III-2(a) has been correctly
reported.
Is the price data reported above:
Value data reported in dollars?
Quantity data reported in pounds?
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 part II in each year?

√ if Yes

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III-2(c). 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.
III-3.

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

III-4.

Contracts

Other

If other, describe

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

Quantity
discounts

III-5.

Set
price
lists

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for steel racks imported from China?
Net 30
days

(b)

Net 60
days

2/10 net 30
days

Other

Other (specify)

On what basis are your firm’s prices of imported steel racks from China usually quoted
(check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Importers’ Questionnaire - Steel racks (Preliminary)
III-6.

Contract versus spot.--Approximately what share of your firm’s sales of steel racks imported
from China in 2017 was on a (1) long-term contract basis, (2) annual contract basis, (3) shortterm contract basis, and (4) spot sales basis?

Item
Share of 2017
sales
III-7.

Page 22

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

%

Contract provisions.—Please fill out the table regarding your firm’s typical sales contracts for
steel racks from China (or check “not applicable” if your firm does not sell on a long-term, shortterm 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
Meet or release
provision
Not applicable

No
Quantity
Price
Both
Yes
No

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

Annual contracts
(multiple deliveries
for 12 months)
365

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

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)
III-8.

Page 23

Lead times.--What is your firm’s share of sales of steel racks imported from China 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 steel racks?

Source

Lead time
(Average number
Share of 2017 sales
of days)

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

Total (should sum to 100.0%)
III-9.

0.0 %

Shipping information.—
(a)

What is the approximate percentage of the cost of steel racks imported from China that
is accounted for by U.S. inland transportation costs?
percent.

(b)

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

(c)

When your firm sells steel racks imported from China, from where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of steel racks imported from
China 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

%

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)

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III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold steel racks
imported from subject countries since January 1, 2015 (check all that apply)?
Geographic area

China

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.--List the end uses of the steel racks that your firm imports. For each end-use product,
what percentage of the total cost is accounted for by steel racks and other inputs?
Share of total cost of end-use product
accounted for by
End use product

Steel racks

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

III-12. Substitutes.--Can other products be substituted for steel racks?
No

Substitute
1.
2.
3.

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 steel racks?
No Yes

Explanation

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)

Page 25

III-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for steel racks has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within the United States
Outside the United States
III-14. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of steel racks since January 1, 2015?
No

Yes

If yes, please describe.

III-15. Conditions of competition.—
(a) Is the steel racks market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to steel racks?
Check all that apply.

Please describe.

No

Skip to question III-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
steel racks since January 1, 2015?
No

Yes

If yes, describe.

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)

Page 26

III-16. Supply constraints.--Has your firm refused, declined, or been unable to supply steel racks since
January 1, 2015 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

III-17. Raw materials.--How have steel racks raw material prices changed since January 1, 2015?
Fluctuate
with no Explain, noting how raw material price changes
clear
have affected your firm’s selling prices for steel
Overall
No
Overall
increase change decrease trend
racks.

Item
Steel tubing or long
products
Other steel
components
Other materials

III-18. Interchangeability.--Is steel racks 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

Other countries

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

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III-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between steel racks 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 significant9
0 = no familiarity with products from a specified country-pair
Country-pair

China

Other countries

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

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U.S. Importers’ Questionnaire - Steel racks (Preliminary)

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III-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for steel racks since January 1, 2015. Indicate the share of the quantity of your firm’s
total shipments of steel racks that each of these customers accounted for in 2017.

Customer’s name

Contact person

Email

Telephone

City

State

Share
of
2017
sales
(%)

1
2
3
4
5
6
7
8
9
10

III-21. 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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U.S. Importers’ Questionnaire - Steel racks (Preliminary)

Page 29

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 30

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at: LINK
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: SRACK

• 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 did 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.