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pdfOMB No. 3117‐0016/USITC No. 19‐3‐4051; Expiration Date: 6/30/2020
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LOST SALES AND LOST REVENUE SURVEY
VERTICAL METAL FILE CABINETS FROM CHINA
This survey must be received by the Commission by May 14, 2019
See last page for filing instructions.
The information called for in this survey is for use by the United States International Trade Commission in connection
with its countervailing duty and antidumping duty investigations concerning vertical metal file cabinets from China (Inv.
Nos. 701‐TA‐623 and 731‐TA‐1449 (Preliminary)). The information requested in the survey 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 possession (19 U.S.C. § 1333(a)).
Further information on this survey can be obtained from Pamela Davis (202‐205‐2218, [email protected]).
Name of firm
Address
City
State
Zip Code
Website
Has your firm purchased or imported for own use or retail sale vertical metal file cabinets (as defined on next
page) at any time since January 1, 2016?
NO
(Sign the certification below and promptly return only this page of the survey to the Commission)
YES
(Complete all parts of the survey, and return the entire survey 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: FILE)
CERTIFICATION
I certify that the information herein supplied in this survey 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 submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
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
investigation or other proceeding 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
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 2
GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on April 30, 2019, by Hirsh
Industries LLC, Des Moines, Iowa. 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/or dumping. U.S. producers of freestanding vertical
metal file cabinets have provided the USITC with allegations about sales or revenue that they have lost
due to competition from imports of vertical metal file cabinets from China. One or more domestic
producer(s) have named your firm in such an allegation.
Vertical metal file cabinets “VMFCs” covered by these investigations are freestanding vertical metal file
cabinets containing extendable file storage elements, having a width of 25 inches or less1, and having a
height that is greater than its width ("vertical metal file cabinets").
The subject vertical metal file cabinets have bodies made of carbon and/or alloy steel and or other
metals, regardless of whether painted, powder coated, galvanized or otherwise coated for corrosion
protection or aesthetic appearance. The subject vertical metal file cabinets must have two to five
extendable elements for file storage (e.g., file drawers) of a height that permits hanging files of either
letter (8.5" x 11") or legal (8.5" x 14") sized documents.
An “extendable element” is defined as a movable load‐bearing storage component including, but not
limited to, drawers and filing frames. Extendable elements typically have suspension systems, consisting
of glide blocks or ball bearing glides, to facilitate opening and closing.
The subject vertical metal file cabinets typically come in models with two, three, four, or five file
drawers. The inclusion of an additional non‐file‐sized extendable storage element, not sized for storage
files (e.g., a box or pencil drawer), does not remove an otherwise in‐scope product from the scope. The
inclusion of an integrated storage area that is 6" or less in height that is not extendable, (i.e., a cubby),
also does not remove a subject vertical metal file cabinet from the scope. Accessories packaged with a
subject vertical file cabinet, such as separate printer stands or shelf kits that sit on top of the in‐scope
vertical file cabinet are not considered integrated storage.
“Freestanding” means the unit has a solid top rather than an open top and is not designed to be
attached to, be hung from or to support a desktop or other work surface. The ability to anchor a vertical
file cabinet to a wall for stability or to prevent it from tipping over does not exclude the unit from the
scope.
Subject vertical file cabinets may have different handle styles including plastic, metal, recessed or
otherwise integrated handles. The addition of mobility elements such as casters or wheels, a dolly or
other mobility elements does not remove the product from the scope. Packaging a subject vertical metal
file cabinet with other accessories, including, but not limited to, locks, leveling glides, caster kits, drawer
1
Vertical file cabinets are defined by the Business and Institutional Furniture Manufacturers Association (“BIFMA”)
X5.9 testing standard as having a depth greater than its width and all imported vertical metal filing cabinets
currently meet this standard. To prevent circumvention of the scope, petitioners have set a width limitation.
Because the narrowest lateral file sold in the market is over 29 inches wide, petitioners have set the maximum
width for an in‐scope vertical file at 25 inches.
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 3
accessories (e.g., including but not limited to follower wires, follower blocks, file compressors, hanger
rails, pencil trays, and hanging file folders), printer stand, shelf kit and magnetic hooks, also does not
remove the product from the scope.
Excluded from the scope are vertical file cabinets with bodies made of plastic, wood, or other non‐
metallic substances.
Also excluded from the scope are lateral file cabinets. Lateral file cabinets typically have a body that is
more than 25 inches wide and have a width that is greater than the body depth.
Also excluded from the scope are pedestal file cabinets. Pedestal file cabinets are metal file cabinets
with body depths that are greater than or equal to their width, are under 31” in height, and have the
following characteristics: (1) an open top or the means for the cabinet to be attached to or hung from a
desktop or other work surface (i.e., not freestanding); or (2) freestanding file cabinets that have: (a) at
least a 90 percent drawer extension for all extendable storage elements; (b) a central locking system; (c)
a minimum weight density of 9.5 lbs/cubic foot; and (d) casters or leveling glides. A “central locking
system” locks all drawers in a unit.
Also excluded from the scope are fire proof or fire resistant file cabinets that meet Underwriters
Laboratories (“UL”) fire protection standard 72, class 350, which covers the test procedures applicable
to fire‐resistant equipment intend to protect paper records.
The merchandise subject to the investigation is classified in the Harmonized Tariff Schedule of the
United States ("HTSUS") subheading 9403.10.00 (statistical reporting number 9403.10.0020). While
HTSUS subheadings are provided for convenience and Customs purposes, the written description of the
scope of the investigation is dispositive; decisions on classification are within the authority of Customs.
Reporting of information.‐‐ If information is not readily available from your records, provide carefully
prepared estimates.
Confidentiality.‐‐The data furnished in response to this survey 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.
Release of information.‐‐The information provided by your firm in response to this survey, 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. Please also retain a copy of the final document that you submit
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 4
Contact information.‐‐Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.
PURCHASE INFORMATION
1.
Purchases and imports.‐‐Report separately your firm’s domestic purchases and imports of
vertical metal file cabinets.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2016
2017
2018
Item
Purchases of VMFCs produced in—
United States
China
Quantity (in number of units)
1
Sources unknown
0
0
0
0
0
0
All other countries
2
Total purchases
Imports of VMFCs from—
China
1
All other countries
Total imports3
1
Please identify these countries:
Please indicate the firm(s) from which you purchased this merchandise:
3
If your firm imported vertical metal file cabinets at any time since January 1, 2016, please also
complete and return a U.S. importers' questionnaire in this proceeding. It can be downloaded at:
https://www.usitc.gov/sites/default/files/documents/us_importers_questionnaire‐original.pdf
2
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 5
2. Changes in purchasing patterns.‐‐Please indicate how the shares of your firm’s purchases of VMFCs
from different sources have changed since January 1, 2016.
Source of Did not
purchases purchase Decreased Increased Constant Fluctuated
Explanation for trend
United
States
China
All other
sources
Sources
unknown
3. Major purchasing factors.‐‐Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase VMFCs.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 6
4. Purchasing subject imports rather than domestic products.‐‐
(a)
Since January 2016, did your firm import and/or purchase imports of VMFCs from China
instead of purchasing U.S.‐produced VMFCs?
Yes
No
Source
(also respond to parts (b) and (c))
(If “No”, skip to next question)
China
(b)
If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source
Yes
No
China
(c)
If you responded “Yes” to part (a), was price a primary reason for importing and/or
purchasing imports from China rather than domestic product?
Source
Yes
If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2016
(in number of units)
China
No
If No, please indicate the
reason your firm imported
and/or purchased imports
instead of domestic product
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 7
5.
U.S. producers and import competition.—
(a)
Since January 1, 2016, in connection with a sale or offer to sell VMFCs to your firm, did
U.S. producers reduce their prices of domestically produced vertical metal file cabinets
in order to compete with lower‐priced imports of VMFCs from the subject countries?
Yes (also respond to
No (If “No”, skip to next
Source
question part (b))
question)
Don’t know
China
(b)
If your firm responded “yes”, please provide an estimate of the reduction in U.S.
producers’ prices, and any additional explanations, such as timing (e.g., months/years),
frequency of price reductions, or other market/competitive factors.
Source
China
Estimated reduction in U.S. prices
(percent)
%
Additional explanation, including
such information as timing (e.g.,
months/years), frequency of price
reductions, or other
market/competitive factors
6. Other explanations‐‐Please provide any additional comments in this box.
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Vertical metal file cabinets (Preliminary)
Page 8
OMB INFORMATION
7. OMB statistics.‐‐Please report the actual number of hours required and the cost to your firm of
completing this survey.
Hours
Dollars
The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.
HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey 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: FILE
• E‐mail.—E‐mail the MS Word survey 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 purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
File Type | application/pdf |
File Title | Microsoft Word - LSLR questionnaire |
Author | jessica.oliva |
File Modified | 2019-05-02 |
File Created | 2019-05-02 |