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pdfOMB No. 3117‐0016/USITC No. 18‐1‐3932; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
STEEL TRAILER WHEELS FROM CHINA
This questionnaire must be received by the Commission by August 22, 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 trailer wheels (“trailer wheels”)
from China (Inv. Nos. 701‐TA‐609 and 731‐TA‐1421 (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 produced trailer wheels (as defined on next page) at any time since January 1, 2015?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: TRAIL)
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
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on August 8, 2018, by
Dexstar Wheel, Elkhart, Indiana. 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_trailer_wheels_china/preliminary.htm.
Trailer wheels covered by these investigations are certain on‐the‐road steel wheels, and components
thereof, for tubeless tires with a nominal wheel diameter of 12 inches to 16.5 inches, regardless of
width. Certain on‐the‐road steel wheels with a wheel diameter of 12 inches to 16.5 inches within the
scope are generally for road and highway trailers and other towable equipment, including, inter alia,
utility trailers, cargo trailers, horse trailers, boat trailers and recreational trailers. Rims may be entered
separately and sold to towable mobile home customers where the rim will be mounted to the wheel
hub without a disc. The standard widths of certain on‐the‐road steel wheels are 4 inches, 4.5 inches, 5
inches, 5.5 inches, 6 inches, and 6.5 inches, but all certain on‐the‐road steel wheels, regardless of width,
are covered by the scope.
The scope includes rims and discs for certain on‐the‐road steel wheels, whether imported as an
assembly, unassembled, or separately. The scope includes certain on‐the‐road steel wheels regardless of
steel composition, whether cladded or not cladded, whether finished or not finished, and whether
coated or uncoated. The scope also includes certain on‐the‐road steel wheels with discs in either a “hub‐
piloted” or “stud‐piloted” mounting configuration, though the stud‐piloted configuration is most
common in the size range covered.
All on‐the‐road wheels sold in the United States must meet Standard 110 or 120 of the National
Highway Traffic Safety Administration’s (NHTSA) Federal Motor Vehicle Safety Standards, which requires
a rim marking, such as the “DOT” symbol, indicating compliance with applicable motor vehicle
standards. See 49 C.F.R. § 571.110 and § 571.120. The scope includes certain on‐the‐road steel wheels
imported with or without NHTSA’s required markings.
Certain on‐the‐road steel wheels imported as an assembly with a tire mounted on the wheel and/or
with a valve stem or rims imported as an assembly with a tire mounted on the rim and/or with a valve
stem are included in the scope of this investigation. However, if the steel wheels or rims are imported as
an assembly with a tire mounted on the wheel or rim and/or with a valve stem attached, the tire and/or
valve stem is not covered by the scope.
Excluded from this scope are the following: steel wheels for tube‐type tires; such tires use multi‐piece
rims, which are two‐piece and three‐piece assemblies and require the use of an inner tube. Also
excluded from this scope are aluminum wheels and certain on‐the‐road steel wheels that are coated
with chrome. Steel wheels that do not meet Standard 110 or 120 of the NHTSA’s requirements are
excluded from the scope.
Certain on‐the‐road steel wheels subject to this investigation are properly classifiable under the
following category of the Harmonized Tariff Schedule of the United States (“HTSUS”): 8716.90.5035
which covers the exact product covered by the scope whether entered as an assembled wheel or in
components. Wheels entered with a tire mounted on them are believed entered under HTS
8716.90.5059 (Trailers and semi‐trailers; other vehicles, not mechanically propelled, parts, wheels,
other, wheels with other tires) (a category that will be broader than what is covered by the scope).
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 3
While the HTSUS subheading is provided for convenience and customs purposes, the written description
of the subject merchandise is dispositive.
Chrome‐coated steel trailer wheels.‐‐Steel trailer wheels which have been coated in chrome but
otherwise meet the dimensions of in‐scope trailer wheels (see above scope definition).
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 lost sales/lost revenue survey), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of trailer wheels and your responses to the questions in Part I
of the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request,
for use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 4
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b. TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
I‐2.
Page 5
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of trailer wheels, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐3.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Petitioner status.‐‐Is your firm the petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Petition support.‐‐Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
China ‐ AD
China ‐ CVD
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
I‐5.
I‐6.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing trailer wheels from China into the United States or that
are engaged in exporting trailer wheels from China to the United States?
No
Yes‐‐List the following information.
Page 6
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
I‐7.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of trailer wheels?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [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 production of trailer wheels since January 1, 2015.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
Relocations
Expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 9
II‐3a. Production using same machinery.‐‐Please report your firm’s production of goods using the
same equipment, machinery, or employees as used to produce trailer wheels, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.‐‐If your firm does not produce any out‐of‐scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II‐7. If, however, your firm does produce out‐of‐scope merchandise using the same
machinery and equipment as scope mercandhise, then the "average production capacity"
reported in question II‐7 should exclude the portion of "overall production capacity" that was
used to produce this out‐of‐scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in pounds)
Calendar years
Item
2015
1
Overall production capacity
2016
January‐June
2017
2017
2018
0
0
0
0
0
Other out‐of‐scope production
Total production using same
machinery or workers
0
0
0
0
0
Production of:
Trailer wheels2
3
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of trailer wheels will populate here once reported in question II‐7.
3
Please identify these products: .
2
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 10
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on the following
operating paramaters:
Hours per week
II‐3c.
Weeks per year
Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between trailer wheels and other products
using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
II‐4.
Page 11
Tolling.‐‐Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of trailer wheels?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
II‐5.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce trailer wheels in and/or admit trailer
wheels into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import trailer wheels into a foreign trade zone (FTZ) for use in distribution of trailer
wheels and/or the production of downstream articles?
II‐6.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2015, has your firm imported trailer wheels?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes‐‐ COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 12
Definitions
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
“Original Equipment Manufacturer (OEM)” – Manufacturers of trailers or mobile homes.
“Assembler” –Firms which further modify trailer wheels (e.g. by attaching a tire) for sale to
OEMs.
“Aftermarket” ‐‐Aftermarket distributors, retailers, and/or online sellers.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
II‐7.
Page 13
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of trailer wheels in its U.S.
establishment(s) during the specified periods.
Quantity (in pounds) and value (in $1,000)
Calendar years
Item
2015
2016
January‐June
2017
2017
2018
Average production capacity1 (quantity) (A)
Beginning‐of‐period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments sold without
attached tires/valve stems:
Quantity (D)
Export shipments:
Quantity (L)
Value (M)
Value (E)
Commercial shipments sold with attached
tires/valve stems:2
Quantity (F)
Value (G)
3
Internal consumption:
Quantity (H)
2
Value (I)
Transfers to related firms:3
Quantity (J)
2
Value (K)
4
End‐of‐period inventories (quantity) (N)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Report only the quantity and value of the wheel itself and exclude the portion of the weight and value of the
attached tire and/or valve stem.
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: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 14
II‐7. Production, shipment, and inventory data.—Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line N) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, J, and L). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar years
Reconciliation
2015
B + C – D – F – H – J – L – N = should
equal zero ("0") or provide an
explanation.1
2016
0
January‐June
2017
0
2017
0
2018
0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
II‐8.
0
.
Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in pounds)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To OEMs (O)
2015
2016
January‐June
2017
2017
2018
To assemblers (P)
To the aftermarket (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution (i.e.,
lines O through Q) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, H, and J) 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
O + P + Q ‐ D ‐ F – H – J = zero ("0"), if
not revise.
2015
2016
0
January‐June
2017
0
2017
0
0
2018
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
II‐9.
Page 15
U.S. shipments by product type.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by product
type during the specified periods.
Calendar years
Item
2015
U.S. shipments.—
Rims:
Quantity (R) in units
2016
January‐June
2017
2017
2018
Weight (S) in pounds
Value (T) in $1,000
Weight (V) in pounds
Value (W) in $1,000
Weight (AB) in pounds
Value (AC) in $1,000
Weight (AE) in pounds
Value (AF) in $1,000
Center discs:
Quantity (U) in units
Whole trailer wheels without tires/valve stems:
Quantity (X) in units
Weight (Y) in pounds
Value (Z) in $1,000
1
Whole trailer wheels with tires/valve stems:
Quantity (AA) in units
2
Other in‐scope products:
Quantity (AD) in units
1
Report only the quantity and value of the wheel itself and exclude the portion of the weight and value of the
attached tire and/or valve stem.
2
Please describe these other in‐scope products: .
RECONCILIATION OF SHIPMENTS BY PRODUCT TYPE.‐‐Please ensure that the quantity in weight and values reported
for product type shipments in this question equal the quantity and value reported for U.S. shipments (i.e., lines D
through K) in each time period in question II‐7. 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
Quantity: S + V + Y + AB + AE ‐ D ‐ F ‐ H ‐ J =
zero ("0"), if not revise.
Value: T + W + Z + AC + AF ‐ E ‐ G ‐ I ‐ K =
zero ("0"), if not revise.
2015
2016
January‐June
2017
2017
2018
0
0
0
0
0
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 16
II‐10. Production by additional attributes.‐‐Please check all that apply to any portion of trailer wheels
produced by your firm in 2017.
Wheel widths
Wheel dimensions
4 inches 4.5 inches 5 inches 5.5 inches 6 inches 6.5 inches
Wheel diameter sizes.‐‐
12 inches
13 inches
14 inches
15 inches
16 inches
16.5 inches
Other2
1
2
Describe these non‐standard wheel widths: .
Describe these non‐standard wheel diameter sizes: .
Steel used in production:
Carbon hot‐rolled steel
High strength low alloy (“HSLA”) hot‐rolled steel
Other steels (describe: )
Piloting:
Stud‐piloted
Hub‐piloted
Other (describe: )
Coating:
Cationic electro‐deposited grey primer base paint coat (“e‐coat”)
Polyester powder paint
Galvanized
Other coatings (describe: )
No coating
Cladding:
Cladded
Not cladded
Other (describe: )
Other1
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 17
II‐11. Employment data.‐‐Report your firm’s employment‐related data related to the production of
trailer wheels and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2015
2016
January‐June
2017
2017
2018
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐12. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a non‐
market formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 18
II‐13. Alternative production: chrome‐coated steel wheels.‐‐Did your firm produce chrome‐coated
steel trailer wheels (as defined on page 3) at any U.S. facility (i.e. not limited to facilities that
produce in‐scope trailer wheels) any time since January 1, 2015?
No
Yes
If yes‐‐ Complete the table below. (U.S. shipments are inclusive of
commercial U.S. shipments, internal consumption, and transfers to related
firms.)
Quantity (in pounds) and value (in $1,000)
Calendar year
Item
2015
2016
January‐June
2017
2017
2018
Production (quantity)
U.S. shipments:
Quantity
Value
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 19
II‐14. Purchases.‐‐Has your firm purchased trailer wheels produced in the United States or in other
countries since January 1, 2015? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐ Report such purchases in the table below and explain the reasons
for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in pounds)
Calendar years
Item
2015
2016
January‐June
2017
2017
2018
1
Purchases from U.S. importers of
trailer wheels from—
China
All other sources
Purchases from domestic producers2
2
Purchases from other sources
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 20
II‐15. Comparability of in‐scope whole trailer wheels and in‐scope parts.‐‐Please answer the
following questions regarding the differences and similarities between in‐scope whole trailer
wheels and in‐scope wheel parts (e.g. rims, center discs, or other parts as identified in the
definition of trailer wheels on page 2).
(a)
Uses.—
(i)
Is the upstream article (in‐scope wheel parts) dedicated to the production of the
downstream article (in‐scope whole trailer wheels)?
No
Yes
If yes‐skip to part (b)
What percentage of in‐scope wheel parts did your firm use in the production of
in‐scope whole trailer wheels subject to these investigations?
percent.
Please describe the uses for your firm’s in‐scope parts that you do not further
assemble into in‐scope whole trailer wheels subject to these investigations.
(ii)
(iii)
(b)
Markets.—
(i)
Do you perceive the in‐scope wheel parts market to be a separate market than
from the market for in‐scope whole trailer wheels?
Yes, in‐scope wheel parts and in‐scope whole trailer wheels are perceived as
distinct markets.
No, in‐scope wheel parts and in‐scope whole trailer wheels are perceived as
market.
(ii)
Please describe the market (e.g. who are the customers; what are the demand
drivers; how does it differ from whole trailer wheels, etc.) for your firm’s in‐
scope wheel parts that you do not first assemble into in‐scope whole trailer
wheels.
(iii)
Please describe the market for your firm’s in‐scope whole trailer wheels.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 21
II‐15. Comparability of in‐scope whole trailer wheels and in‐scope parts.‐‐Continued.
(c)
Characteristics and functions.‐‐Are there differences in the physical characteristics and
functions of the upstream (in‐scope wheel parts) and the downstream (in‐scope whole
trailer wheels) articles?
(d)
No
Yes
If yes‐‐Please describe the differences.
Price.‐‐Is there a significant difference in the cost or value between in‐scope wheel parts
and in‐scope whole trailer wheels when measured on a per pound basis?
No
Yes
If yes‐‐Please describe the differences.
(e)
Transformation process.‐‐Would you describe the process used to transform the
upstream in‐scope wheel parts into the in‐scope whole trailer wheels as significant and
particularly labor‐ or capital‐intensive?
No
Yes
If yes‐‐Please describe this process.
II‐16. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 22
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202‐205‐3432,
[email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain
below:
Note.‐‐Please note that we are requesting that firms report their financial data
on a calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include trailer wheels:
2. Does your firm prepare profit/loss statements for trailer wheels:
Yes
No
3. How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10 Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: GAAP, cash, tax, or other comprehensive
basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes trailer wheels, as well as
specific statements and worksheets) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
II‐3.
Page 23
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
III‐4.
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced trailer wheels, and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Share of sales
Steel trailer wheels
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
III‐6.
Page 24
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of trailer wheels from any related suppliers (e.g., inclusive
of transactions between related firms, divisions and/or other components within the same
company)?
Yes‐‐Continue to question III‐7
III‐7.
No‐‐Skip to question III‐9a.
Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of
trailer wheels that your firm purchases from related suppliers and that are reflected in question
III‐9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
III‐8.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, were reported in III‐9a (financial results on trailer wheels)
in a manner consistent with your firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a.:
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 25
III‐9a. Operations on fully assembled trailer wheels and trailer wheel parts.‐‐Report the revenue and
related cost information requested below on the fully assembled trailer wheels, rims, and center
disc operations of your firm’s U.S. establishment(s).1 Do not report resales of products. Note
that internal consumption and transfers to related firms must be valued at fair market value
(see definitions in part II). Input purchases from related suppliers should be consistent with and
based on information in the firm’s accounting books and records. Provide data for your firm’s
three most recently completed fiscal years, and for the specified interim periods. If your firm
was involved in tolling operations (either as the toller or as the tollee), please contact Charles
Yost at (202) 205‐3432 before completing this section of the questionnaire.
Quantity (in pounds) and value (in $1,000)
Fiscal years ended‐‐
Item
2015
2016
January‐June
2017
2017
2018
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
Total net sales values
0
0
0
0
0
Direct labor
Other factory costs
0
0
0
0
0
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
3
Cost of goods sold (COGS):
Raw materials
Total COGS
Gross profit or (loss)
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 26
III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes
No
If no‐‐ If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative‐‐instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
III‐9c. Raw materials.‐‐Please report the share of total raw material costs in 2017 and Jan.‐June 2018
(reported in III‐9a) for the following raw material inputs:
Procurement method
Share of total Share of total raw
material costs
Primarily
raw material
Primarily
(percent) in
costs (percent)
produced by purchased
January‐June 2018 your firm by your firm
in 2017
Input
Steel costs
Zinc coating costs
0.0
0.0
Paint/other coating costs
1
Other material inputs
Total (should sum to 100
percent)
1
Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that they account for:
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 27
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III‐9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III‐9a; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9a, only the allocated value amount included in question III‐9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III‐9a.
Calendar years
Item
2015
January‐June
2016
2017
2017
2018
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III‐9a where the nonrecurring item is classified.
Item
Description of the
nonrecurring item
Income statement classification of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 28
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of trailer wheels. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for trailer wheels in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III‐9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Total assets (net)
1
III‐13.
2016
2017
Describe
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for trailer wheels. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended‐‐
Item
2015
1
Capital expenditures
2
Research and development expenses
1
2016
January‐June
2017
2017
2018
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 29
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments) as long as they are reported on the same
calendar year basis. The data in questions III‐9b and III‐9c might not reconcile with the data
reported in question II‐9 to the extent that sales data in III‐9b and III‐9c include exports.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for shipments in part II equal the quantities and values reported for net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended‐‐
Reconciliation
2015
2016
January‐June
2017
2017
2018
Fully assembled wheels and parts:
Quantity: Trade data from question II‐7
(lines D, F, H, J, and L) less financial total
net sales quantity data from question III‐
9a, = zero ("0").
0
0
0
0
0
Fully assembled wheels and parts:
Value: Trade data from question II‐7
(lines E, G, I, K, and M) less financial total
net sales value data from question III‐9a,
= zero ("0").
0
0
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 30
If your responses to any of the items in questions III‐15, III‐16, and III‐17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III‐15. Effects of imports on investment.‐‐Since January 1, 2015, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of trailer wheels from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 31
III‐16. Effects of imports on growth and development.‐‐Since January 1, 2015, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of trailer wheels from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 32
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
trailer wheels from China?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 33
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Aimee Larsen (202‐205‐
3179, [email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2015 of the following products produced by your
firm.
Product 1.‐‐ 12 inches by 4 inches steel wheels, regardless of coating, sold to assemblers or
directly to OEMs.
Product 2.‐‐ 14 inches by 5.5 inches steel wheels, regardless of coating, sold to assemblers or
directly to OEMs.
Product 3.‐‐ 15 inches by 5 inches steel wheels, regardless of coating, sold to assemblers or
directly to OEMs.
Product 4.‐‐ 16 inches by 6 inches steel wheels, regardless of coating, sold to assemblers or
directly to OEMs.
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). Please report sales of trailers wheels that are unmounted
only. Trailer wheels that are assembled with a tire mounted should not be included.
IV‐2a. During January 2015‐June 2018, did your firm produce and sell to unrelated U.S. customers any of
the above listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data table as appropriate.
No.‐‐Skip to question IV‐3.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 34
IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Please report sales of trailers wheels that are unmounted only. Trailer wheels that are
assembled with a tire mounted should not be included.
Report data in actual number of wheels and actual dollars (not 1,000s).
(Quantity in actual number of wheels, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
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
April‐June
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 IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
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U.S. Producers’ Questionnaire ‐ Trailer wheels
Page 35
IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
In units (not 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 question II‐7 in each year?
IV‐2d. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
IV‐3.
Page 36
Price setting.‐‐How does your firm determine the prices that it charges for sales of trailer wheels
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Annual
total
volume
discounts
If other, describe
No
discount
policy
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced trailer wheels?
Net 30
days
Other
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV‐5.
Set
price
lists
(b)
Net 60
days
2/10 net
30 days
Other
On what basis are your firm’s prices of domestic trailer wheels usually quoted (check
one)?
Delivered
Other (specify)
F.o.b.
If f.o.b., specify point
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U.S. Producers’ Questionnaire ‐ Trailer wheels
IV‐6.
Page 37
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced trailer
wheels in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Item
Share of 2017
sales
IV‐7.
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
U.S.‐produced trailer wheels (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Long‐term contracts
(multiple deliveries for
more than 12 months)
365
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
1
Please identify the indexes used:
Annual contracts
(multiple
deliveries for 12
months)
Short‐term contracts
(multiple deliveries
for less than 12
months)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Trailer wheels
IV‐8.
Lead times.‐‐What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.‐produced trailer wheels?
Lead time (Average
Source
Share of 2017 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV‐9.
Page 38
0.0 %
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced trailer wheels that is
accounted for by U.S. inland transportation costs? percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of trailer wheels that are
delivered the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced trailer wheels since January 1, 2015 (check all that apply)?
Geographic area
√ if applicable
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
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IV‐11. End uses.‐‐List the end uses of the trailer wheels that your firm manufactures. For each end‐use
product, what percentage of the total cost is accounted for by trailer wheels and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
Trailer wheels
Other inputs
End use product
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐12. Substitutes.‐‐Can other products be substituted for trailer wheels?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for trailer wheels?
No Yes
Explanation
1.
2.
3.
IV‐13. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for trailer wheels has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explanation and factors
Within the United States
Outside the United States
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IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of trailer wheels since January 1, 2015?
No
Yes
If yes, please describe and quantify if possible.
IV‐15. Conditions of competition.‐‐
(a) Is the trailer wheels market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to trailer wheels? If yes,
describe.
Check all that apply.
Please describe.
No
Skip to question IV‐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
trailer wheels since January 1, 2015?
No
Yes
If yes, describe.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
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IV‐16. Effect of 232 investigation of steel on conditions of competition.‐‐
(a) Are you familiar with the 232 investigation or the subsequent imposition of tariffs on
imported steel products?
No (skip to IV‐17)
Yes (complete part b)
(b) Did the announcement of the 232 investigation in April 2017 or the subsequent imposition of
tariffs on imported steel products in March 2018 impact the conditions of competition for
trailer wheels?
No
Yes If yes, describe.
Announcement of the 232 investigation in
April 2017
Imposition of tariffs on imported steel
products in March 2018
IV‐17. AD/CVD orders on raw materials.‐‐Have antidumping duty and countervailing duty orders on
hot‐rolled steel and/or cut‐to‐length plate impacted the availability of trailer wheels?
No
Yes
If yes, please describe.
IV‐18. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply trailer wheels
since January 1, 2015 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐19. Raw materials.‐‐How have trailer wheels’ raw material prices changed since January 1, 2015?
Fluctuate
Explain, noting how raw material price changes
Overall
No
Overall
with no
have affected your firm’s selling prices for trailer
increase change decrease clear trend
wheels.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
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IV‐20. Interchangeability.‐‐Are trailer wheels produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing trailer wheels that is sometimes or never interchangeable, identify
the country‐pair and explain the factors that limit or preclude interchangeable use:
IV‐21. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between trailer wheels
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant factor
in your firm’s sales of trailer wheels, identify the country‐pair and report the advantages or
disadvantages imparted by such factors:
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U.S. Producers’ Questionnaire ‐ Trailer wheels
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IV‐22a. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for trailer wheels since January 1, 2015. Indicate the share of the quantity of your
firm’s total shipments of trailer wheels 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
IV‐22b. Customers who assemble in‐scope wheel parts into whole trailer wheels.—Of your firm’s 10
largest U.S. customers for trailer wheels, please identify any firms whom you believe to
assemble in‐scope wheel parts into in‐scope whole trailer wheels. (Do not include firms which
attach out‐of‐scope parts, e.g. tires and/or valve stems, to in‐scope whole trailer wheels.)
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U.S. Producers’ Questionnaire ‐ Trailer wheels
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IV‐23. Competition from imports
(a)
Lost revenue.‐‐Since January 1, 2015: To avoid losing sales to competitors selling trailer
wheels from China, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2015: Did your firm lose sales of trailer wheels to imports
of this product from China?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: TRAIL)
IV‐24. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV in which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
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U.S. Producers’ Questionnaire ‐ Trailer wheels
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2018/steel_trailer_wheels_china/prelimi
nary.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:
o
o
o
Web address: https://dropbox.usitc.gov/oinv/
Enter Investigation: Select “Steel Trailer Wheels from China” in the drop down menu
Pin: TRAIL
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US producers--Trailer Wheels (P) |
| Author | jordan.harriman |
| File Modified | 2018-08-10 |
| File Created | 2018-08-10 |