18-2-3989 US importers' questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

US importers--Steel wheels (F)

Steel wheels from China (Inv. nos. 701-TA-602 and 731-TA-1412)

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

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OMB No. 3117-0016/USITC No. 18-2-3989; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
STEEL WHEELS FROM CHINA
This questionnaire must be received by the Commission by November 26, 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 duty investigations concerning steel wheels from China (Inv. Nos. 701-TA-602 and 731-TA-1412
(Final)). 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 wheels (as defined on next page) from any country at any time since January 1,
2015?

(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: WHEEL)
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

Signature

Phone

Email address

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 27, 2018, by
Accuride Corporation, Evansville, Indiana, and Maxion Wheels Akron LLC, Akron, Ohio. 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_wheels_china/final.htm.
Steel wheels covered by these investigations are certain on-the-road steel wheels, discs, and rims for
tubeless tires, with a nominal rim diameter of 22.5 inches and 24.5 inches, regardless of width. Certain
on-the-road steel wheels with a nominal wheel diameter of 22.5 inches and 24.5 inches are generally for
Class 6, 7, and 8 commercial vehicles (as classified by the Federal Highway Administration Gross Vehicle
Weight Rating system), including tractors, semi-trailers, dump trucks, garbage trucks, concrete mixers,
and buses, and are the current standard wheel diameters for such applications. The standard widths of
certain on-the-road steel wheels are 7.5 inches, 8.25 inches, and 9.0 inches, but all certain on-the-road
steel wheels, regardless of width, are covered by the scope. While 22.5 inches and 24.5 inches are
standard wheel sizes used by Class 6, 7, and 8 commercial vehicles, the scope covers sizes that may be
adopted in the future for Class 6, 7, and 8 commercial vehicles.
The scope includes certain on-the-road steel wheels with either a “hub-piloted” or “stud-piloted”
mounting configuration, and includes rims and discs for such wheels, whether imported as an assembly
or separately. The scope includes certain on-the-road steel wheels, discs, and rims, of carbon and/or
alloy steel composition, whether cladded or not cladded, whether finished or not finished, and whether
coated or uncoated. All on-the-road wheels sold in the United States are subject to the requirements of
the National Highway Traffic Safety Administration and bear markings, such as the “DOT” symbol,
indicating compliance with applicable motor vehicle standards. See 49 CFR 571.120. The scope includes
certain on- the-road steel wheels imported with or without the 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
attached are included. However, if the certain on-the-road steel wheel is imported as an assembly with
a tire mounted on the wheel and/or with a valve stem attached, the certain on- the-road steel wheel is
covered by the scope, but the tire and/or valve stem is not covered by the scope.
Excluded from the scope are:
(1) steel wheels for tube-type tires that require a removable side ring;
(2) aluminum wheels;
(3) wheels where steel represents less than fifty percent of the product by weight; and
(4) steel wheels that do not meet National Highway Traffic Safety Administration requirements, other
than the rim marking requirements found in 49 CFR 571.120S5.2.
Imports of the subject merchandise are currently classified under the following Harmonized Tariff
Schedule of the United States (HTSUS) subheadings: 8708.70.4530, 8708.70.4560, 8708.70.6030,
8708.70.6060, 8716.90.5045, and 8716.90.5059. Merchandise meeting the scope description may also
enter under the following HTSUS subheadings: 4011.20.1015, 4011.20.5020, and 8708.99.4850. While
HTSUS subheadings are provided for convenience and customs purposes, the written description of the
subject merchandise is dispositive.

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U.S. Importers’ Questionnaire - Steel wheels

Page 3

Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing steel wheels (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
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 are provided at the end of this questionnaire and are available upon request from
Jordan Harriman (202-205-2610, [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 wheels
I-1.

Page 4

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, 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 wheels, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
I-3.

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

Firm name

I-4.

Page 5

Yes--List the following information

Address

Extent of
ownership
(percent)

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

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of steel wheels?
No

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

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

I-7.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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

Firm name

Address

Contact person
and phone
number

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
I-8.

Page 7

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters steel wheels into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports steel wheels 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

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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U.S. Importers’ Questionnaire - Steel wheels

Page 8

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202-2052610, [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 wheels 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)

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-3.

Page 9

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

Yes
If yes, fill out the table below.

Period
Source

Oct-Dec 2018

Jan-Mar 2019

Apr-Jun 2019

Jul-Sept 2019

Quantity (in actual number of wheels)
China
Mexico
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces steel wheels 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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U.S. Importers’ Questionnaire - Steel wheels

Page 10

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.
If your firm sells steel wheels (as described on page 2) with a tire already mounted on the
wheel and/or with a valve stem attached, the value and weight of such sales reported in
questions II-5, II-6, and II-7 should exclude the portion of the value and weight accounted for
by the attached tire and/or valve stem.
“Internal consumption” –Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories” –Finished goods inventory, not raw materials or work in progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-5a.

Page 11

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

China

Quantity (in actual number of wheels), value (in $1,000)
Calendar years
Item

2015

2016

January-September
2017

2017

2018

Beginning-of-period
inventories (quantity) (A)
Imports:1
Quantity (B)
Value2 (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value3 (G)
Transfers to related firms:3
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
1

Please identify the foreign producers, if known:
.
If your firm imports steel wheels (as described on page 2) with a tire already mounted on the wheel and/or with a valve
stem attached, information on those imports should be included. However, for purposes of reporting the value of such imports,
you should exclude the portion of the value accounted for by the 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:
.
2

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U.S. Importers’ Questionnaire - Steel wheels
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
A + B – D – F – H – J -L = should equal
zero ("0") or provide an explanation.1
1

2015

2016
0

January-September
2017

2017
0

2018
0

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

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-5b.

Page 13

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 firms) of imports from China by
channel of distribution during the specific periods.

China
Quantity (in actual number of wheels); Value (in $1,000)
Calendar years
Item

2015

2016

January-September
2017

2017

2018

U.S. shipments:
To truck OEMs
Quantity (M)
Value (N)
To trailer OEMs
Quantity (O)
Value (P)
To bus OEMs
Quantity (Q)
Value (R)
To other OEMs1
Quantity (S)
Value (T)
To aftermarket2
Quantity (U)
Value (V)
1

Please identify the nature of these ‘other’ OEMS (e.g., military, emergency vehicle, etc.):
.
This category includes aftermarket or replacement distributors, original equipment service (“OES”) providers (both product
distribution centers and dealer direct shipments), and other aftermarket firms.
2

RECONCILIATION OF CHANNELS.--Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through U) in each time period equal the quantity and value reported for U.S.
shipments (i.e., line D through I) in each time period in part “a” of this question. 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

2015

2016

January-September
2017

2017

2018

Quantity: M + O + Q + S
+ U – D – F – H = zero
("0"), if not revise.

Value: N + P + R + T + V
– E – G – I = zero ("0"), if
not revise.

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U.S. Importers’ Questionnaire - Steel wheels
II-5c.

Page 14

US shipments by product type: China.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from China by type of product during the specific periods.

China
Calendar years
Item

2015

2016

January-September
2017

2017

2018

U.S. shipments:
Carbon steel: 22.5 diameter
Quantity (W) in units
Weight (X) in pounds
Value (Y) in $1,000
Carbon steel: 24.5 diameter
Quantity (Z) in units
Weight (AA) in pounds
Value (AB) in $1,000
Alloy steel: 22.5 diameter
Quantity (AC) in units
Weight (AD) in pounds
Value (AE) in $1,000
Alloy steel: 24.5 diameter
Quantity (AF) in units
Weight (AG) in pounds
Value (AH) in $1,000
RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for U.S.
shipments by product type (i.e., lines W through AH) in each time period equal the quantity and value
reported for U.S. shipments (i.e., line D through I) in each time period in part “a” of this question. 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

2015

2016

January-September
2017

2017

2018

Quantity: W + Z + AC + AF – D –
F – H = zero ("0"), if not revise.

Value: Y + AB + AE + AH – E – G
– I = zero ("0"), if not revise.

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-5d.

Page 15

Monthly U.S. imports.—Report your firm’s monthly U.S. imports of steel wheels from China
during the specified periods:

China

Item
Quantity
(in actual number of wheels)

Month
2017.-January (AI)
February (AJ)
March (AK)
April (AL)
May (AM)
June (AN)
July (AO)
August (AP)
September (AQ)
October (AR)
November (AS)
December (AT)
2018.-January (AU)
February (AV)
March (AW)
April (AX)
May (AY)
June (AZ)
July (BA)
August (BB)
September (BC)

Month
Aggregation of monthly imports

Calendar year 2017
0

Jan-Sept 2017

Jan-Sept 2018
0

RECONCILIATION OF IMPORTS.--Please ensure that the total imports reported for full year 2017, and for
the two partial periods (e.g., January to September 2017 and 2018) reported in question II-5a matches
the monthly data reported here. 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.
Reconciliation for
Aggregated monthly data minus
U.S. imports from China (II-5a),
revise if not returning zero (“0”)

Calendar year 2017

Jan-Sept 2017

Jan-Sept 2018

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-6a.

Page 16

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

Mexico
Quantity (in actual number of wheels), value (in $1,000)
Calendar years
Item

2015

2016

January-September
2017

2017

2018

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U.S. Importers’ Questionnaire - Steel wheels
II-6a.

Page 17

U.S. imports from Mexico.–Continued

2015

2016
0

January-September
2017

2017
0

2018
0

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

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-6b.

Page 18

Channels of distribution: Mexico.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Mexico by channel of distribution during the specific periods.

Mexico
Quantity (in actual number of wheels); Value (in $1,000)
Calendar years
Item

2015

2016

January-September
2017

2017

2018

Please identify the nature of these ‘other’ OEMS (e.g. military, emergency vehicle, etc.):
.
This category includes aftermarket or replacement distributors, original equipment service (“OES”) providers (both product
distribution centers and dealer direct shipments), and other aftermarket firms.
2

2015

2016

January-September
2017

2017

2018

Quantity: M + O + Q + S
+ U – D – F – H = zero
("0"), if not revise.

Value: N + P + R + T + V
– E – G – I = zero ("0"), if
not revise.

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
II-6c.

Page 19

US shipments by product type: Mexico.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Mexico by type of product during the specific periods.

Mexico
Calendar years
Item

2015

2016

January-September
2017

2017

2018

2015

2016

January-September
2017

2017

2018

Quantity: W + Z + AC + AF – D –
F – H = zero ("0"), if not revise.

Value: Y + AB + AE + AH – E – G
– I = zero ("0"), if not revise.

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U.S. Importers’ Questionnaire - Steel wheels
II-6d.

Page 20

Monthly U.S. imports.—Report your firm’s monthly U.S. imports of steel wheels from Mexico
during the specified periods:

Mexico

Item
Quantity
(in actual number of wheels)

Month
Aggregation of monthly imports

Calendar year 2017
0

Jan-Sept 2017

Jan-Sept 2018
0

RECONCILIATION OF IMPORTS.--Please ensure that the total imports reported for full year 2017, and for
the two partial periods (e.g., January to September 2017 and 2018) reported in question II-5a matches
the monthly data reported here. 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.
Reconciliation for
Aggregated monthly data minus
U.S. imports from Mexico (II5a), revise if not returning zero
(“0”)

Calendar year 2017

Jan-Sept 2017

Jan-Sept 2018

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U.S. Importers’ Questionnaire - Steel wheels
II-7a.

Page 21

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of steel wheels imported from all other sources (i.e. all sources except China or
Mexico) by your firm during the specified periods. (Responses to question II-7a-7d should
include imports from Canada.)

All other sources
(list sources:

)
Quantity (in actual number of wheels), value (in $1,000)
Calendar years

Item

2015

2016

January-September
2017

2017

2018

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II-7a.

Page 22

U.S. imports from all other sources.–Continued

2015

2016
0

January-September
2017

2017
0

2018
0

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

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U.S. Importers’ Questionnaire - Steel wheels
II-7b.

Page 23

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 firms) of imports
from all other sources by channel of distribution during the specific periods.

All other sources
Quantity (in actual number of wheels); Value (in $1,000)
Calendar years
Item

2015

2016

January-September
2017

2017

2018

2015

2016

January-September
2017

2017

2018

Quantity: M + O + Q + S
+ U – D – F – H = zero
("0"), if not revise.

Value: N + P + R + T + V
– E – G – I = zero ("0"), if
not revise.

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II-7c.

Page 24

US shipments by product type: all other sources.--Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
imports from all other sources by type of product during the specific periods.

All other sources
Calendar years
Item

2015

2016

January-September
2017

2017

2018

2015

2016

January-September
2017

2017

2018

Quantity: W + Z + AC + AF – D –
F – H = zero ("0"), if not revise.

Value: Y + AB + AE + AH – E – G
– I = zero ("0"), if not revise.

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II-7d.

Page 25

Monthly U.S. imports.—Report your firm’s monthly U.S. imports of steel wheels from all other
sources during the specified periods:

All other sources

Item
Quantity
(in actual number of wheels)

Month
Aggregation of monthly imports

Calendar year 2017
0

Jan-Sept 2017

Jan-Sept 2018
0

RECONCILIATION OF IMPORTS.--Please ensure that the total imports reported for full year 2017, and for
the two partial periods (e.g., January to September 2017 and 2018) reported in question II-5a matches
the monthly data reported here. 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.
Reconciliation for
Aggregated monthly data minus
U.S. imports from all other
sources (II-5a), revise if not
returning zero (“0”)

Calendar year 2017

Jan-Sept 2017

Jan-Sept 2018

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II-9.

Page 26

Other explanations.--If your firm would like to further explain a response to a question in Part II
for 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. Importers’ Questionnaire - Steel wheels

Page 27

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Emily Burke (202-205-3191,
[email protected]).
III-1.

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 your firm imported
from China, Canada, or Mexico:
Product 1.--22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing 60 to 75 lbs.,
inclusive, sold to OEMs.
Product 2.--22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing 60 to 75 lbs.,
inclusive, sold to the aftermarket.
Product 3.--22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing more than
75 lbs., sold to OEMs.
Product 4.--22.5 inches by 8.25 inches steel wheels, regardless of coating, weighing more than
75 lbs., sold to the aftermarket.
Note: Aftermarket includes aftermarket or replacement distributors, original equipment service
(“OES”) providers (both product distribution centers and dealer direct shipments), and other
aftermarket firms.

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-September 2018, did your firm import from China or Mexico 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 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. Do not include sales of wheels with tires and/or valve stems already
attached.

China

Report data in number of wheels and actual dollars (not 1,000s).
(Quantity in 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
July-September
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:

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Page 29

III-2(b). Price data.--Report below the quarterly price data1 for pricing products2 imported from Mexico
and sold by your firm. Do not include sales of wheels with tires and/or valve stems already
attached.

Mexico

Report data in number of wheels and actual dollars (not 1,000s).
(Quantity in number of wheels, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

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

√ if Yes

In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in part II in each year?
III-2(d). Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
III-3.

Price setting.--How does your firm determine the prices that it charges for sales of steel wheels
(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

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for steel wheels 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 wheels from China usually quoted
(check one)?
Delivered

III-6.

Set
price
lists

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

Quantity
discounts

III-5.

Page 31

F.o.b.

If f.o.b., specify point

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

Item
Share of 2017
sales

Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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U.S. Importers’ Questionnaire - Steel wheels
III-7.

Page 32

Contract provisions.—Please fill out the table regarding your firm’s typical sales contracts for
steel wheels from China (or check “not applicable” if your firm does not sell on a short-term,
long-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity
Price
Both

Meet or release
provision

Yes

Raw material price
adjustments1

Yes

No
No

Not applicable
1

Please explain.--

III-8.

Lead times.--What is your firm’s share of sales of steel wheels 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 wheels?

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%)

0.0 %

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels
III-9.

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Shipping information.—
(a)

What is the approximate percentage of the cost of steel wheels 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 wheels 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 wheels 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

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold steel
wheels imported from China since January 1, 2015 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

China

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Page 34

III-11. Aluminum wheels.—
(a) Can aluminum wheels be substituted for steel wheels?
No

Yes

Explain

(b) Since January 1, 2015, have changes in the price of aluminum wheels affected the price for
steel wheels?
No

Yes

Explain

(c) Since January 1, 2015, have changes in demand for aluminum wheels impacted demand for
steel wheels in the U.S. market?
No

Yes

Explain

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U.S. Importers’ Questionnaire - Steel wheels

Page 35

III-12. Demand trends.—
(a) Indicate how overall demand within the United States and outside of the United States (if
known) for steel wheels 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
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Within the United States
Outside the United States
(b) Indicate how demand within the United States for steel wheels has changed since January 1,
2015 for the uses specified below.

U.S. demand for steel
wheels for:

Overall
increase

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Truck OEM
Trailer OEM
Bus OEM
Service/repair

III-13. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of steel wheels since January 1, 2015?
No

Yes

If yes, please describe.

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U.S. Importers’ Questionnaire - Steel wheels

Page 36

III-14. Conditions of competition.—
(a) Is the market for steel wheels subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to steel wheels?
Check all that apply.

Please describe.

Skip to question III-15.

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 wheels since January 1, 2015?
No

Yes

If yes, describe.

III-15. Supply constraints.--Has your firm refused, declined, or been unable to supply steel 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.

III-16. Raw materials.--How have steel wheels’ raw material prices changed since January 1, 2015?

Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes,
including the section 232 steel tariffs imposed in
March 2018, have affected your firm’s selling
prices for steel wheels.

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U.S. Importers’ Questionnaire - Steel wheels

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III-17. Impact of the section 301 investigation.--This question concerns the section 301 investigation
and subsequent announcement on additional tariffs that include steel wheels proposed and
implemented by the United States in response to Chinese trade practices. On September 17,
2018, the White House announced the placement of an additional 10 percent tariff on steel
wheels imported from China under HTS subheadings 4011.20.10, 4011.20.50, 8708.70.45,
8708.70.60, 8708.99.48, and 8716.90.50, which took effect on September 24, 2018. Effective
January 1, 2019, these tariffs will rise to 25 percent. (See
https://www.gpo.gov/fdsys/granule/FR-2018-07-17/2018-15090 and
https://www.whitehouse.gov/briefings-statements/statement-from-the-president-4/)
(a)

Did the imposition of the additional 10 percent tariffs and/or announcement of the
future increase in these tariffs impact, or do you anticipate that they will impact, your
firm's steel wheels business and/or the U.S. steel wheels market as a whole?
Yes

(b)

Don’t know

If yes, please explain.

Assessment of specific impacts of the section 301 investigation.--Please indicate the
impact of the announcements and subsequent implementation of remedies in the
section 301 investigation and tariff actions regarding steel wheels.

Item
Overall
demand/anticipated
demand for steel
wheels in the U.S.
market
Prices/anticipated
prices for steel wheels
in the U.S. market

Fluctuate
with no
No
clear
Increase change Decrease
trend

Explanation and factors

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U.S. Importers’ Questionnaire - Steel wheels

Page 38

III-18. Interchangeability.--Are the steel 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

China

Mexico

Other countries

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

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U.S. Importers’ Questionnaire - Steel wheels

Page 39

III-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between steel 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

China

Mexico

Other countries

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

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U.S. Importers’ Questionnaire - Steel wheels

Page 40

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

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
for 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.

Business Proprietary
U.S. Importers’ Questionnaire - Steel wheels

Page 41

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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U.S. Importers’ Questionnaire - Steel wheels

Page 42

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_wheels_china/final.htm.
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: WHEEL

• 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.

File Type	application/pdf
File Title	Microsoft Word - US importers--Steel wheels (F)
Author	jordan.harriman
File Modified	2018-10-25
File Created	2018-10-25