Form 18-1-3992 US producers' questionnaire

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

US producer questionnaire--Glycine (F)

Glycine from China, India, Japan, and Thailand (Inv. nos. 701-TA-603-605 and 731-TA-1413-1415)

OMB: 3117-0016

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U.S. PRODUCERS’ QUESTIONNAIRE
GLYCINE FROM CHINA, INDIA, JAPAN, AND THAILAND
This questionnaire must be received by the Commission by January 7, 2019
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 countervailing duty investigations concerning glycine and certain precursor products from
China, India, and Thailand and in connection with antidumping investigations concerning glycine and certain
precursor products from India, Japan, and Thailand (Inv. Nos. 701-TA-603-605 and 731-TA-1413-1415 (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 produced or exported glycine and/or certain precursor products of glycine (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: GLYC)
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 - Glycine

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 28, 2018, by GEO
Specialty Chemical, Lafayette, Indiana and Chattem Chemicals, Inc., Chattanooga, Tennessee.
Countervailing and 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 dumping. Questionnaires and other information pertinent to this
proceeding are available
https://www.usitc.gov/investigations/701731/2018/glycine_china_india_japan_and_thailand/final.htm.
Glycine covered by these investigations is glycine at any purity level or grade. This includes glycine of all
purity levels, which covers all forms of crude or technical glycine including but not limited to sodium
glycinate, glycine slurry and any other forms of amino acetic acid or glycine. Subject merchandise also
includes glycine and precursors of dried crystalline glycine that are processed in a third country,
including, but not limited to, refining or any other processing that would not otherwise remove the
merchandise from the scope of the investigations if performed in the country of manufacture of the inscope glycine or precursors of dried crystalline glycine.
Glycine has the Chemical Abstracts Service (CAS) registry number of 56-40-6. Glycine and glycine slurry
are classified under Harmonized Tariff Schedule of the United States (HTSUS) subheading 2922.49.43.00.
Sodium glycinate is classified in the HTSUS under 2922.49.80.00. While the HTSUS subheadings and CAS
registry number are provided for convenience and customs purposes, the written description of the
scope of these investigations is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
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.

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)

Page 3

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.
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.
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 – Glycine (Final)
I-2.

Page 4

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 glycine, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

I-3.

Additional discussion on establishments consolidated in this questionnaire:

.

Petition support.--Does your firm support or oppose the petition?
Country

China CVD
India AD
India CVD
Japan AD
Thailand AD
Thailand CVD

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
I-4.

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

Firm name

I-5.

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 glycine from China, India, Japan and Thailand into the
United States or that are engaged in exporting glycine from China, India, Japan and Thailand to
the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
I-7.

Page 6

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

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, [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 glycine since January 1, 2015.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
II-3a.

Page 8

Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce glycine, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
"Nameplate capacity”– The maximum level of production that your establishment(s) could have
obtained during the specified periods assuming maximum operating parameters and conditions
(e.g., using equipment and machinery in place and ready to operate; twenty-four hours
operating levels (hours per week/weeks per year) and no time for downtime, no maintenance,
no repair, and no cleanup).
“Overall production 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 1,000 pounds)
Calendar years
Item

2015

2016

January –September
2017

2017

2018

Nameplate capacity
Overall production capacity
Production of:
Glycine1
Other products
Total
1
2

0

0

0

0

0

0

0

0

0

0

2

Data entered for production of glycine will populate here once reported in question II-7.
Please identify these products:
.

II-3b.

Operating parameters.--The overall production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week

Weeks per year

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)

Page 9

II-3c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.

II-3d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-3e.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between glycine and other products using
the same equipment and/or labor?

No

(ii)

II-4.

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:

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.

Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of glycine?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

Yes

If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
II-5.

Page 10

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce glycine in and/or admit glycine 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

(b)

If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import glycine into a foreign trade zone (FTZ) for use in distribution of glycine and/or
the production of downstream articles?
No

II-6.

Yes

Yes

If yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2015, has your firm imported glycine?
“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 – Glycine (Final)
II-7.

Page 11

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of glycine in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

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

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
II-7.

Page 12

Production, shipment, and inventory data.--Continued
Quantity (in 1,000 pounds) and value (in $1,000)

January –September

Calendar years
Item
Average production capacity
(quantity) (A)

2015

2016

2017

2017

2018

1

Beginning-of-period inventories
(quantity) (B)
Production (quantity).-Using HCN process (C)
Using MCA process (D)
Total production (E)

0

0

0

0

0

U.S. shipments:
Commercial shipments:
Quantity (F)
Value (G)
Internal consumption:2
Quantity (H)
Value2 (I)
Transfers to related firms:2
Quantity (J)
Value2 (K)
Export shipments:3
Quantity (L)
Value (M)
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
Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however,
provide the data above at fair market value).
3
Identify your firm’s principal export markets:
.

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U.S. Producers’ Questionnaire – Glycine (Final)

Page 13

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., lines C and D), less total shipments (i.e., lines 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.
January –September

Calendar years

Reconciliation

2015

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

2016

0

2017

2017

0

0

2018

0

0

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

II-8.

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 1,000 pounds)

January –September

Calendar years
Item

2015

2016

2017

2017

2018

Channels of distribution:
U.S. shipments:
To distributors (O)
To end users (P)

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines O and P) in each time period equal the quantity reported for U.S. shipments (i.e., lines 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.
January –September

Calendar years

Reconciliation
O + P – F –H – J = zero ("0"), if
not revise.

2015

2016

0

2017

2017

0

0

2018

0

0

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U.S. Producers’ Questionnaire – Glycine (Final)
II-9.

Page 14

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.
Quantity (in 1,000 pounds)

January –September

Calendar years
Item

2015

2016

2017

2017

2018

U.S. shipments:
Technical grade glycine:
Quantity (Q)
Value (R)
USP grade glycine:
Quantity (S)
Value (T)
Pharmaceutical grade glycine,
not injectable:
Quantity (U)
Value (V)
Pharmaceutical grade glycine,
injectable:
Quantity (W)
Value (X)
In-scope glycine precursor
products:
Quantity (Y)
Value (Z)

RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities and values reported for U.S.
shipments by product type (i.e., lines Q through Y) in each time period equal the quantities and values
reported for U.S. shipments (i.e., lines F through K) 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.
January –September

Calendar years

Reconciliation

2015

2016

2017

2017

2018

Quantity: Q + S + U + W + Y –
F – H – J = zero ("0"), if not
revise.

0

0

0

0

0

Value: R + T + V + X + Z– G – I – K
= zero ("0"), if not revise.

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
II-10.

Page 15

U.S. shipments by certification.--Report your firm’s U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) by certification in 2017.

U.S. shipments

Calendar year 2017
Quantity (1,000 pounds)

FDA certified, but not EDQM certified (AA)
EDQM certified, but not FDA certified (AB)
Both FDA and EDQM certified (AC)
Neither FDA nor EDQM certified (AD)
RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities reported for U.S. shipments
by certification (i.e., lines AA through AD) in each time period equal the quantities reported for
U.S. shipments in 2017 (i.e., lines D, F and H) reported 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.
Reconciliation
Quantity: AA + AB + AC + AD – D – F – H = zero
("0"), if not revise.

Calendar year 2017
0

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
II-11.

Page 16

Employment data.--Report your firm’s employment-related data related to the production of
glycine 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 September periods, calculate similarly and divide by 9.
“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 –September
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-11.

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 nonmarket 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 – Glycine (Final)
II-12.

Page 17

Purchases.--Other than imports, has your firm otherwise purchased glycine (domestic or
imported) any time since January 1, 2015?
“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

If yes-- Report such purchases below and explain the reasons for your
firms' purchases:

Yes

(Quantity in 1,000 pounds)
Calendar years
Item
Purchases from U.S. importers
of glycine from—
China

2015

2016

January –September
2017

2017

2018

1

India
Japan
Thailand
All other sources
Purchases from domestic
producers2
Purchases from other sources2
1

Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import suppliers
differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.

II-13.

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 – Glycine (Final)

Page 18

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[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 glycine:

2.

Does your firm prepare profit/loss statements for glycine:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

3.

4.

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 glycine, as well as
specific statements and worksheets) used to compile these data.

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Page 19

III-3.

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 glycine, and provide the share of net sales accounted for by these products in 2017.
Products
Glycine

Share of sales
%
%
%
%
%

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)

III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of glycine 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.

Page 20

No--Continue to question III-9a.

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
glycine 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 glycine) 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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III-9a. Operations on glycine.--Report the revenue and related cost information requested below on
the glycine operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that internal consumption and transfers to related firms must be valued at fair market
value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm on a
calendar year basis, and for the specified interim periods.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item

2015

2016

January-September

2017

2017

2018

quantities:2

Net sales
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

values:2

Net sales
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold
Raw materials

(COGS):3

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Legal expenses4
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
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.
4 Please indicate where these legal expenses appear in the company’s own books and records (e.g., within G&A, other expenses,
etc.):
1

2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

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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.

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
III-9c.

Page 23

Raw materials for producers using the Strecker amino acid synthesis (HCN) process.--If your
firm produces glycine using the Strecker amino acid synthesis process, please report the raw
material costs (reported in III-9a) for the following raw material inputs:
Value (in $1,000)
Calendar years

Input

2015

2016

January-September

2017

2017

2018

HCN process raw materials:
Formaldehyde
Hydrogen cyanide
Ammonia
Other material inputs1
1

Please indicate any other notable "other" raw materials not expressly identified above:

III-9d. Raw materials for producers using the monochloroacetic acid (MCAA) process.--If your firm
produces glycine using the monochloroacetic acid process, please report the raw material costs
(reported in III-9a) for the following raw material inputs:
Value (in $1,000)
Calendar years

Input

2015

2016

January-September

2017

2017

MCAA process raw materials:
Ammonia
Monochloroacetic acid
Hexamethylenetetramine or
other catalyst(s)
Other material inputs1
1

Please indicate any other notable "other" raw materials not expressly identified above:

2018

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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

2015
Item

2016

January-September

2017

2017

2018

Value ($1,000)

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item

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

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.

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III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of glycine. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for glycine 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 on a
calendar year basis.
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)
Calendar years
Item
Total assets (net)
1

III-13.

2015

2016

2017

1

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for glycine. Provide data for your firm
on a calendar year basis, and for the specified interim periods.
Value (in $1,000)
Calendar years

Item
Capital expenditures

2015

2016

January-September

2017

2017

2018

1

Research and development expenses2
1

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.

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U.S. Producers’ Questionnaire – Glycine (Final)

Page 26

III-14. Data consistency and reconciliation.--Please confirm that your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year basis. The quantities and values
reported in question III-9a should reconcile with the data reported in question II-7 (including
export shipments).
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Calendar years
Reconciliation

2015

2016

January-September
2017

2017

2018

Quantity: Trade data from question II-7
(lines F, H, J and L) less financial total net
sales quantity data from question III-9a,
= zero ("0").

0

0

0

0

0

Value: Trade data from question II-7
(lines 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.

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Page 27

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 glycine from China, India, Japan, or Thailand?
No

Yes
If yes, my firm has experienced actual negative effects as follows:

(check as many as appropriate)
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

(please describe)

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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 glycine from China, India, Japan, or Thailand?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the
issue of stocks or bonds
Ability to service debt

Other

(please describe)

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III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
glycine from China, India, Japan, or Thailand?
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.

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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Nabil Abbyad
([email protected], 202-708-1446).
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.--Pharmaceutical-grade glycine -- a white, odorless, crystalline powder with a sweet
taste, having an assay (glycine content) of 98.5 percent to 101.5 percent (dry basis),
and ≤ 7ppm chloride, ≤ 65 ppm sulfate, and ≤1 ppm heavy metals.
Product 2.--USP-grade glycine -- a white, odorless, crystalline powder with a sweet taste, having
an assay (glycine content) of 98.5 percent to 101.5 percent (dry basis) and ≤ 70 ppm
chloride, ≤ 65 ppm sulfate, ≤ 20 ppm heavy metals, and not otherwise qualifying as
pharmaceutical-grade glycine.
Product 3.--Technical-grade glycine -- a white, off-white, or slightly yellow crystalline powder,
having an assay (glycine content) of 98.5 percent to 101.5 percent (dry basis), with
maximum chlorides of 0.4 percent, and not otherwise qualifying as USP-grade
glycine.

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 in the quarter of the original sale).
IV-2 (a). During January 2015-September 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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IV-2(b). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds (not 1,000s) and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

Period of shipment
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 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:

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IV-2 (c). 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) and actual pounds (not 1,000 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-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. Producers’ Questionnaire – Glycine (Final)
IV-3.

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

IV-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 its U.S.-produced glycine?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic glycine usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 33

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
glycine 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

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

%

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
IV-7.

Page 34

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced glycine (or check “not applicable” if your firm does not sell on a long-term, shortterm and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Meet or release
provision

Price
Both
Yes
No

Not applicable
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 glycine?

Source

Share of 2017 sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

Lead time (Average
number of days)

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)
IV-9.

Page 35

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced glycine 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)

Indicate the approximate percentage of your firm’s sales of glycine 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 glycine 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.

√ if applicable

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IV-11. End uses.--List the end uses of the glycine that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by glycine and other inputs?
Share of total cost of end use product
accounted for by
End use product

Glycine

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Pharmaceutical-grade glycine.-(a) Did your firm produce pharmaceutical-grade glycine since 2015?
No

Yes--Please complete the table below.

(b) Please describe the packaging type(s) and estimate the percentage of the total cost is
accounted for by the packaging.

Packaging type

Packaging
(percent of total cost)
%
%
%

(c) Please describe the pharmaceutical end use(s) and estimate the average price premium of
these products when compared to USP-grade glycine prices.

Pharmaceutical end use

Price premium
compared to USP-grade
(percent)
%
%
%

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IV-13. Substitutes.--Can other products be substituted for glycine?
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 glycine?
No Yes

Explanation

1.
2.
3.
IV-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for glycine has changed since January 1, 2015. Explain any trends and describe
the principal factors that have affected these changes in demand.
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Market

Explanation and factors

Within the United States
Outside the United States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of glycine since January 1, 2015?
No

Yes

If yes, please describe and quantify if possible.

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IV-16. Conditions of competition.-(a) Is the glycine market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to glycine? If yes, describe.
Check all that apply.

Please describe.

No

Skip to question IV-17.

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

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply glycine 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-18. Raw materials.--How have glycine raw material prices changed since January 1, 2015?
Fluctuate
Overall
No
Overall
with no
Explain, noting how raw material price changes
increase change decrease clear trend have affected your firm’s selling prices for glycine.

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IV-19. Product quality issues.--Have any of your customers returned glycine or canceled orders due to
quality issues such as product impurities or caking issues, since January 1, 2015?
No

Yes

If yes, please describe.

IV-20. Interchangeability.--Is glycine 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

India

Japan

Thailand

Other
countries

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

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IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between glycine 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

India

Japan

Thailand

Other
countries

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

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IV-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for glycine since January 1, 2015. Indicate the share of the quantity of your firm’s
total shipments of glycine that each of these customers accounted for in 2017.
Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2017 sales (%)

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IV-23. Competition from imports
(a)

Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling
glycine from China, India, Japan, and/or Thailand, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2015: Did your firm lose sales of glycine to imports of this
product from China, India, Japan, and/or Thailand?
No

Yes

IV-24. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – Glycine (Final)

Page 43

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at: LINK
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: GLYC

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.


File Typeapplication/pdf
File TitleMicrosoft Word - US producer questionnaire--Glycine (F)
Authorcelia.feldpausch
File Modified2018-11-14
File Created2018-11-14

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