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pdfOMB No. 3117-0016/USITC No. 19-1-4057; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
REFILLABLE STAINLESS STEEL KEGS FROM CHINA, GERMANY, AND MEXICO
This questionnaire must be received by the Commission by July 5, 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 its countervailing and antidumping duty investigations concerning refillable stainless steel kegs from
China, Germany, and Mexico (Inv. Nos. 701-TA-610 and 731-TA-1425-1427 (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 refillable stainless steel kegs (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 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: KEGS)
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
Signature
Title of Authorized Official
Phone
Date
Email address
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on September 20, 2018, by
American Keg Company, LLC, Pottstown, Pennsylvania. 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/dumping.
Questionnaires and other information pertinent to this proceeding are available
athttps://www.usitc.gov/investigations/701731/2019/refillable_stainless_steel_kegs_china_germ
any_and/final.htm.
Refillable stainless steel kegs covered by these investigations are kegs, vessels, or containers with
bodies that are approximately cylindrical in shape, made from stainless steel (i.e., steel containing at
least 10.5 percent chromium by weight and less than 1.2 percent carbon by weight, with or without
other elements), and that are compatible with a “D Sankey” extractor (refillable stainless steel kegs)
with a nominal liquid volume capacity of 10 liters or more, regardless of the type of finish, gauge,
thickness, or grade of stainless steel, and whether or not covered by or encased in other materials.
Refillable stainless steel kegs may be imported assembled or unassembled, with or without all
components (including spears, couplers or taps, necks, collars, and valves), and be filled or unfilled.
“Unassembled” or “unfinished” refillable stainless steel kegs include drawn stainless steel cylinders that
have been welded to form the body of the keg and attached to an upper (top) chime and/or lower
(bottom) chime. Unassembled refillable stainless steel kegs may or may not be welded to a neck, may or
may not have a valve assembly attached, and may be otherwise complete except for testing,
certification, and/or marking.
Subject merchandise also includes refillable stainless steel kegs that have been further processed in a
third country, including but not limited to, attachment of necks, collars, spears or valves, heat
treatment, pickling, passivation, painting, testing, certification or any other processing that would not
otherwise remove the merchandise from the scope of the investigation if performed in the country of
manufacture of the in-scope refillable stainless steel keg.
Specifically excluded are the following:
(1) vessels or containers that are not approximately cylindrical in nature (e.g., box, ‘‘hopper’’ or
‘‘cone’’ shaped vessels);
(2) stainless steel kegs, vessels, or containers that have either a ‘‘ball lock’’ valve system or a
‘‘pin lock’’ valve system (commonly known as ‘‘Cornelius,’’ ‘‘corny’’ or ‘‘ball lock’’ kegs);
(3) necks, spears, couplers or taps, collars, and valves that are not imported with the subject
merchandise; and
(4) stainless steel kegs that are filled with beer, wine, or other liquid and that are designated by
the Commissioner of Customs as Instruments of International Traffic within the meaning of
section 332(a) of the Tariff Act of 1930, as amended.
Refillable stainless steel kegs are currently classified in the Harmonized Tariff Schedule of the United
States (HTSUS) under subheadings 7310.10.0010, 7310.10.0050, 7310.29.0025, and 7310.29.0050.
These HTSUS subheadings are provided for convenience and customs purposes; the written description
of the scope of this investigation 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.
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 3
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.
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
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 4
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
I-2.
No
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 refillable stainless steel
kegs, 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:
.
Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
I-4.
Page 5
Petition support.--Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
China CVD
China AD
Germany AD
Mexico AD
I-5.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-6.
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 refillable stainless steel kegs from China, Germany, and
Mexico into the United States or that are engaged in exporting refillable stainless steel kegs
from China, Germany, and Mexico to the United States?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (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 refillable stainless steel kegs?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 7
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 refillable stainless steel kegs since January 1, 2016.
(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 - Refillable Stainless Steel Kegs (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 refillable stainless steel kegs,
and the combined production capacity on this shared equipment, machinery, or employees in
the periods indicated.
"Theoretical 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” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope mercandhise, then the "average production capacity"
reported in question II-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in units)
Calendar years
Item
2016
2017
January-March
2018
2018
2019
Theoretical capacity
Overall production capacity1
Production of:
Refillable stainless steel kegs2
Other products
Total production using same
machinery or workers
1
0
0
0
0
0
0
0
0
0
0
3
Data reported for overall capacity should be greater than data reported for total production (last line).
Data entered for production of refillable stainless steel kegs will populate here once reported in question II-7.
3
Please identify these products:
.
2
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-3b.
Page 9
Operating parameters.--The production capacity reported in II-3a is based on the following
operating parameters:
Hours per week
Weeks per year
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.
Production capacity.--Do the figures in II-3a represent a consistent capacity over each annual
period, including times of peak seasonal demand?
No
II-3f.
Yes
Product shifting.—
(i)
Is your firm able to switch production (capacity) between refillable stainless steel kegs and
other products using the same equipment and/or labor?
No
(ii)
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.
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-4.
Page 10
Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of refillable stainless steel kegs?
“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
II-5.
Yes
If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce refillable stainless steel kegs in and/or
admit refillable stainless steel kegs 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 designated 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 refillable stainless steel kegs into a foreign trade zone (FTZ) for use in distribution
of refillable stainless steel kegs and/or the production of downstream articles?
No
II-6.
Yes
Yes
If yes--Identify the firms and the FTZs.
Importer.--Since January 1, 2016, has your firm imported refillable stainless steel kegs?
“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 - Refillable Stainless Steel Kegs (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 refillable stainless steel kegs 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 / including initial use in leasing operations”--Product consumed
internally by your firm. Such transactions should be valued at fair market value of the refillable
stainless steel kegs that were consumed/used (i.e., not the retail price, not the total value of the
downstream products). Internal consumption should include any refillable stainless steel kegs
initially added to the asset base relating to your firm's keg leasing operations if applicable. Once
reported as internal consumption at the time the kegs were transferred over to your firm’s
leasing operations, your firm should not continue to report that product as being in inventory.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” – A firm that your firm solely or jointly owned, managed, or otherwise
controlled; a firm that solely or jointly owned, managed, or otherwise controlled your firm;
and/or a firm that was solely or jointly owned, managed, or otherwise controlled by a firm that
also solely or jointly owned, managed, or otherwise controlled your firm.
“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. Also do not
include in reported inventories any stainless steel kegs currently being used as part of your
firm’s keg leasing operations if applicable.
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 - Refillable Stainless Steel Kegs (Final)
II-7.
Page 12
Production, shipment, and inventory data.--Continued
Quantity (in units) and value (in actual dollars )
Calendar years
Item
2016
2017
January-March
2018
2018
2019
1
Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/including initial use in
leasing operations:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity (e.g., how many shifts you operated during the year), and explain any
changes in reported capacity
.
2
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.
3
Identify your firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus production
(i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data
entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide explanations for
any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
2016
2017
0
January-March
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
0
.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8.
Page 13
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 units)
Calendar years
Item
2016
2017
January-March
2018
2018
2019
U.S. shipments:
To breweries or beer
manufacturers:
Large (M)1
Medium (N)2
Small (O)3
To keg leasing and rental
companies without beverage
manufacturing operations (P)
To distributors (Q)
To other firms (R)4
1
Large: Production of more than 6 million barrels per year.
Medium: Production of 100,000 to 6 million barrels per year.
3
Small: Production of fewer than 100,000 barrels per year.
4
Describe other firms:
2
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M through R) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, and H) in
each time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must
be revised prior to submission to the Commission.
Calendar years
Reconciliation
M+N+O+P+Q+R–D–F–H=
zero ("0"), if not revise.
2016
2017
0
January-March
2018
0
2018
0
2019
0
0
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (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) of refillable
stainless steel kegs by product type in the specified periods.
Quantity (in units) and value (in dollars)
Calendar years
Item
U.S. shipments.-10 liter.-Quantity (S)
Value (T)
1/8 Barrel (14.7 liters).-Quantity (U)
Value (V)
1/6 Barrel (19.5 liters).-Quantity (W)
Value (X)
1/4 Barrel (29.3 liters).-Quantity (Y)
Value (Z)
European 1/2 Barrel (25 liters).-Quantity (AA)
Value (AB)
1/2 Barrel (58.7 liters).-Quantity (AC)
Value (AD)
European Barrel (50 liters).-Quantity (AE)
Value (AF)
All other keg sizes.--1
Quantity (AG)
Value (AH)
1
Describe these sizes
2016
2017
January-March
2018
2018
2019
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-9.
Page 15
U.S. shipments by product type.--Continued
RECONCILIATION OF SHIPMENTS BY PRODUCT TYPE.--Please ensure that the quantities and values reported for U.S. shipments by
product type (i.e., lines S through AH) in each time period equal the quantity and value reported for U.S. shipments (i.e., lines D
through I) in each time period in question II-7. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
2016
2017
January-March
2018
2018
2019
Quantity: S+ U + W + Y + AA + AC + AE + AG
– D – F – H= zero ("0"), if not revise
0
0
0
0
0
Value: : T +V + X + Z + AB + AD + AF + AH– E
– G – I= zero ("0"), if not revise
0
0
0
0
0
II-10.
Employment data.--Report your firm’s employment-related data related to the production of
refillable stainless steel kegs 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 March periods, calculate
similarly and divide by 3.
“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
1
2016
2017
January-March
2018
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
1
Please refer to question II-3a and report shifts the company operated during each calendar year.
Explanation of trends:
2018
2019
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 16
II-11.
Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
II-12.
Purchases.--Has your firm purchased refillable stainless steel kegs produced in the United States
or in other countries since January 1, 2016? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in units)
Calendar years
Item
2016
2017
January-March
2018
2018
2019
1
Purchases from U.S. importers of
refillable stainless steel kegs from—
China
Germany
Mexico
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:
.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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II-13. Arranged sales.--Since January 1, 2016, has your firm brokered/facilitated any imports of
refillable stainless steel kegs for which your firm did not serve as importer or record or purchaser (as
defined in Questions II-12 and II-13)?
No
II-14.
Yes
If yes—explain and identify the producer, importer, and purchaser.
Other explanations.--If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-15.
Page 18
Trial production/production commencement.--Please report the following information.
(a) What date did you commence any trial production of refillable stainless steel kegs?
Date (month, day, year)
(b) What date did you commence commercial production of refillable stainless steel kegs?
Date (month, day, year)
(c) If your firm had either trial production or commercial production of refillable stainless steel
kegs prior to January 1, 2019, please provide the production volumes for each year.
Year
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
Trial production (units)
Commercial production
(units)
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-15
Page 19
Trial production/production commencement.--Continued
(d) After having commenced commercial production of refillable stainless steel kegs, did your
firm subsequently suspend or cease production at any time after January 1, 2016:
Yes
No
Date of non-production
(month, day, year)
Date of recommencement
(month, day, year)
(e) Did your firm produce other products at its facility prior to producing stainless steel kegs?
Yes
No
If so, please report the other products produced at the facility:
(f) Please provide copies of any feasibility and/or break even studies your firm prepared or
commissioned for your refillable stainless steel kegs operations. These include any analysis
that your firm prepared or commissioned regarding its goals, plans, assumptions, and/or
expectations when it decided to undertake, suspend, and/or resume refillable stainless steel
kegs operations.
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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202-708-4725,
[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:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include refillable stainless steel
kegs:
2.
Does your firm prepare profit/loss statements for refillable stainless steel kegs:
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 refillable stainless steel
kegs, as well as specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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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 refillable stainless steel kegs, and provide the share of net sales accounted for by
these products in your firm’s most recent fiscal year.
Products
Refillable stainless steel kegs
Share of sales
%
%
%
%
%
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-6.
Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of refillable stainless steel kegs 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 22
No--Continue to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
refillable stainless steel kegs 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 refillable
stainless steel kegs) in a manner consistent with your firm’s accounting books and records.
Yes
No
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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III-9a. Operations on refillable stainless steel kegs.--Report the revenue and related cost information
requested below on the refillable stainless steel kegs 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’s three most recently completed fiscal years, and for the
specified interim periods. If your firm was involved in tolling operations (either as the toller or as
the tollee), please contact David Boyland at (202) 708-4725 before completing this section of
the questionnaire.
Quantity (in units) and value (in actual dollars)
Fiscal years ended-Item
2016
2017
January-March
2018
2018
2019
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
Stainless steel
(COGS):3
Neck insert
Valve (D-Spear)
Direct labor
Other factory costs
Less: scrap sellback
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
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.
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.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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III-10a. Costs and expenses related to transition of operations from predecessor company (“Transition
costs and expenses”) included in financial results on stainless steel kegs.--For each annual and
interim period for which financial results are reported in question III-9a, please separately
identify transition costs and expenses, the specific question III-9a line item where the identified
transition costs and expenses are included, a brief description of the relevant transition costs
and expenses, and the associated values (in $1,000), as reflected in question III-9a; i.e., if an
aggregate transition cost or expense has been allocated to question III-9a, only the allocated
value amount included in question III-9a should be reported in the schedule below. As
appropriate, underlying transition costs and expenses can be grouped by relevant function; e.g.,
merchandising or manufacturing (cost of goods sold), selling, and administration.
Fiscal years
2016
2017
January-March
2018
2018
2019
Value (in actual dollars)
Transition cost/exp. 1
Transition cost/exp. 2
Transition cost/exp. 3
Transition cost/exp. 4
Transition cost/exp. 5
Transition cost/exp. 6
Transition cost/exp. 7
Transition costs and expenses: In the tables below please provide a detailed description of each transition
cost/expense reported above and indicate the specific line item in table III-9a where the item is classified.
Description of the transition cost or expense
Transition cost/exp. 1
Transition cost/exp. 2
Transition cost/exp. 3
Transition cost/exp. 4
Transition cost/exp. 5
Transition cost/exp. 6
Transition cost/exp. 7
Income statement classification of transition cost or expense
Transition cost/exp. 1
Transition cost/exp. 2
Transition cost/exp. 3
Transition cost/exp. 4
Transition cost/exp. 5
Transition cost/exp. 6
Transition cost/exp. 7
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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III-10b. Nonrecurring items (charges and gains) included in financial results on stainless steel kegs.-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), that were not
already reported in III-10a above, in the schedules 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.
Fiscal years
2016
2017
January-March
2018
2018
2019
Value (in actual dollars)
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
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Income statement classification of the nonrecurring item
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 27
III-11. Classification of identified transition costs/expenses or nonrecurring items (charges and gains)
in the accounting books and records of the company.--If transition costs/expenses or nonrecurring items were reported in questions III-10a or III-10b 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 questions III-10a or III-10b identify where these items are
reported in question III-9a.
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of refillable stainless steel kegs. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for
refillable stainless steel kegs in the normal course of business, please estimate this information
based upon a method (such as production, sales, or costs) that is consistent with relevant cost
allocations in question III-9a. Provide data as of the end of your firm’s three most recently
completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in actual dollars)
Fiscal years ended-Item
Total assets (net)
1
III-13.
2016
2017
2018
1
Describe
Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for refillable stainless steel kegs.
Provide data for your firm’s three most recently completed fiscal years, and for the specified
interim periods.
Value (in actual dollars)
Fiscal years ended--
Item
Capital expenditures
2016
2017
January-March
2018
2018
2019
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 - Refillable Stainless Steel Kegs (Final)
Page 28
III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
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.
Fiscal years ended-Reconciliation
2016
2017
January-March
2018
2018
2019
Quantity: Trade data from question II-7
(lines D, F, H, and J) less financial total
net sales quantity data from question III9a, = zero ("0").
0
0
0
0
0
Value: Trade data from question II-7
(lines E, G, I, and K) 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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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 29
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, 2016, 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 refillable stainless steel kegs from China, Germany, and Mexico?
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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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 30
III-16. Effects of imports on growth and development.--Since January 1, 2016, 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 refillable stainless steel kegs from China,
Germany, and Mexico?
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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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 31
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
refillable stainless steel kegs from China, Germany, and Mexico?
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
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
Page 32
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (202-205-2049,
[email protected]).
IV-1.
Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
PRICE DATA
IV-2.
This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products produced by your
firm.
Product 1.—1/2 barrel (also known as a keg); Assembled with no accessories; 300 series
stainless steel; volume of 15.5 gallons (58.7 liters); approximately 23.25 inches tall
(+/- 0.5 inches) with diameters ranging from 14.5 inches to 17.5 inches, thickness
ranging from 0.050 to 0.060 inches for the body and 0.070 to 0.090 inches for the
handles; rated to a maximum of 60 PSI of pressure; unfilled; finish may be dull,
polished, painted, or encapsulated in a rubber or plastic material.
Product 2.—1/6 barrel; Assembled with no accessories; 300 series stainless steel; volume of
5.16 gallons (19.5 liters); approximately 23.25 inches tall (+/- 0.5 inches) with
diameters ranging from 8.5 inches to 9.7 inches, thickness ranging from 0.045 to
0.055 inches for the body and 0.055 to 0.070 inches for the handles; rated to a
maximum of 60 PSI of pressure; unfilled; finish may be dull, polished, painted, or
encapsulated in a rubber or plastic material.
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).
IV-2a. During January 2016-March 2019, 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 tables as appropriate.
No.--Skip to question IV-3.
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IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in units and actual dollars (not 1,000s).
Period of shipment
(Quantity in units, value in dollars)
Product 1
Quantity
Value
Product 2
Quantity
Value
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
October-December
2019:
January-March
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
IV-2c.
Page 34
Price data checklist.--Please check that the pricing data in question IV-2(b) have been correctly
reported.
Are the price data reported above:
√ if Yes
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-2d.
Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of refillable
stainless steel kegs (check all that apply)? If your firm issues price lists, please submit sample
pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Annual
total
volume
discounts
Other
If other, describe
No
discount
policy
Other
Describe, including any volume or value
discount thresholds associated with
respective discount levels
Pricing terms.-- On what basis are your firm’s prices of domestic refillable stainless steel kegs
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 35
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
refillable stainless steel kegs in 2018 was on a (1) short-term contract basis, (2) annual contract
basis, (3) long-term contract basis, and (4) spot sales basis?
Item
Share of 2018
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. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
IV-7.
Page 36
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced refillable stainless steel kegs (or check “not applicable” if your firm does not sell
on a short-term, annual and/or long-term 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
Indexed to raw
material costs1
Price
Both
Yes
No
Not applicable
1
Please identify the indexes used:
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 refillable stainless steel kegs?
Source
Lead time (Average
Share of 2018 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0
%
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
IV-9.
Page 37
Shipping information.-(a)
What is the approximate percentage of the cost of U.S.-produced refillable stainless
steel kegs 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 refillable stainless steel kegs
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 refillable stainless steel kegs since January 1, 2016 (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. Substitutes.—
(a) Specific substitutes.--Are these specific products considered as substitutes for refillable stainless
steel kegs products in the same end use(s)?
Specific substitutes
Are these
considered
substitutes in the
End use(s) in which
market?
this substitute is
No
Yes
used
Have changes in the price of this
substitute affected the price for
refillable stainless steel kegs?
No
Yes
Explanation
Plastic kegs
Aluminum kegs
(b) Other substitutes.--Can other products not already listed in part "a" of this question be
substituted for refillable stainless steel kegs?
No
Other substitutes
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for refillable stainless steel
kegs?
No Yes
Explanation
1.
2.
3.
IV-12. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for refillable stainless steel kegs has changed since January 1, 2016. Explain any
trends and describe the principal factors that have affected these changes in demand.
Market
Within the United States
Outside the United States
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
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IV-13. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of refillable stainless steel kegs since January 1, 2016?
No
Yes
If yes, please describe and quantify if possible.
IV-14. Conditions of competition.-(a) Is the refillable stainless steel kegs market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to refillable
stainless steel kegs? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV-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
refillable stainless steel kegs since January 1, 2016?
No
Yes
If yes, describe.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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IV-15. Impact of 301 duties.--This question concerns the section 301 investigation and subsequent
announcement of additional tariffs that include refillable stainless steel kegs proposed and
implemented by the United States in response to Chinese trade practices.
(a) Did the announcement of the 301 investigation in June 2018 or the subsequent imposition
of tariffs on Chinese-origin products have an impact on the refillable stainless steel keg
market?
Yes—Please answer b and c.
No
Don’t know
(b) Please indicate the impact of the announcements and subsequent imposition of duties
under the section 301 investigation.
Item
Overall
increase
No
Overall
change decrease
Fluctuate with no
clear trend
Demand for U.S.-produced
refillable stainless steel kegs in
the U.S. market
Demand for imports from China
of refillable stainless steel kegs in
the U.S. market
Demand for imports from other
sources of refillable stainless
steel kegs in the U.S. market
Prices for refillable stainless steel
kegs in the U.S. market
(c) Describe the impact on your firm and the overall market for refillable stainless steel kegs.
Please identify the magnitude and timing of any effects, and compare your firm's
operations/overall market before and after the announcement.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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IV-16. Impact of duties on all goods from Mexico.--This question concerns the announcement of
tariffs on all goods from Mexico, beginning June 10, 2019 proposed by the United States
pursuant to the International Emergency Economic Powers Act.
(a) Did the announcement, and any subsequent imposition, of these tariffs have an impact on
the refillable stainless steel keg market?
Yes—Please answer b and c.
No
Don’t know
(b) Please indicate the impact of the announcements and subsequent imposition of duties.
Item
Overall
increase
No
change
Overall
decrease
Fluctuate with no
clear trend
Demand for U.S.-produced
refillable stainless steel kegs in
the U.S. market
Demand for imports from Mexico
of refillable stainless steel kegs in
the U.S. market
Demand for imports from other
sources of refillable stainless
steel kegs in the U.S. market
Prices for refillable stainless steel
kegs in the U.S. market
(c) Describe the impact on your firm and the overall market for refillable stainless steel kegs.
Please identify the magnitude and timing of any effects, and compare your firm's
operations/overall market before and after the announcement.
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply refillable
stainless steel kegs since January 1, 2016 (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. Certification.--
(a) Is your firm certified to sell to any brewers that produce 6 million or more barrels of beverage
per year, or to distributors/rental/lease firms that purchase 100,000 refillable stainless steel
keg units or more per year?
No Yes If yes, list which purchasers your firm is certified to supply.
(b) Is your firm certified to sell to any brewers that produce more than 100,000 but less than 6
million barrels of beverage per year, or to distributors/rental/lease firms that purchase more
than 50,000 but less than 100,000 refillable stainless steel keg units per year?
No
Yes
If yes, list which purchasers your firm is certified to supply.
(c) Has your firm ever failed a certification process with a purchaser or distributor/rental/lease
firm?
No
Yes
If yes, please explain why your firm did not become certified.
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IV-19. Raw materials.—
(a) How have refillable stainless steel kegs raw material prices changed since January 1, 2016?
Item
Overall
increase
No
change
Overall
decrease
Explain, noting how raw
material price changes have
Fluctuate
affected your firm’s selling
with no clear prices for refillable stainless
trend
steel kegs.
Cost of raw materials
(b) Effect of 232 duties on raw material prices.--Did the announcement of the 232 investigation in
April 2017 or the subsequent imposition of tariffs on imported steel products beginning in
March 2018 have an impact on the raw material prices for refillable stainless steel kegs?
Yes—Please indicate the impact in
the table below.
Item
Raw material costs for
refillable stainless
steel kegs in the U.S.
market
Prices for refillable
stainless steel kegs in
the U.S. market
No
Fluctuate
with no
No
clear
Increase change Decrease
trend
Don’t know
Explanation and factors
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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IV-20. Interchangeability.--Are refillable stainless steel kegs 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
Germany
Mexico
Other countries
United States
China
Germany
Mexico
For any country-pair producing refillable stainless steel kegs 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. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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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 refillable stainless steel
kegs 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
Germany
Mexico
Other countries
United States
China
Germany
Mexico
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of refillable stainless steel kegs, identify the country-pair and report
the advantages or disadvantages imparted by such factors:
IV-22. Competition from imports.-(a)
Lost revenue.--Since January 1, 2016: To avoid losing sales to competitors selling
refillable stainless steel kegs from China, Germany, and Mexico, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2016: Did your firm lose sales of refillable stainless steel
kegs to imports of this product from China, Germany, and Mexico?
No
Yes
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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IV-23. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for refillable stainless steel kegs since January 1, 2016. Indicate the share of the
quantity of your firm’s total shipments of refillable stainless steel kegs that each of these
customers accounted for in 2018 and your firm’s average annual shipment quantity of refillable
stainless steel kegs to each of these customers.
Customer’s name
Email
City
State
Share of
2018 sales
(%)
Average
shipment
quantity
1
2
3
4
5
6
7
8
9
10
IV-24. Warranties.--Does your firm offer warranties for your products?
No
Yes.--Please indicate the length(s) of warranty policies and the percentage of
sales such warranties represented of your total sales from 2018.
Average warranty
length
Percentage of 2018
sales sold under
warranty
Narrative
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U.S. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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IV-25. Services.--Does your firm offer any pre- and post-sales services relating to stainless steel kegs?
No
Yes.--Please describe these services and indicate whether these services are
included in the original purchase price of the stainless steel kegs or invoiced.
Service
Service included Service invoiced
in purchase price
separately
IV-26. Branding.--Please describe the financial investment and other efforts your firm has made to
develop your brand in the U.S. market.
IV-27. Other explanations.--If your firm would like to further explain a response to a question in Part
IV 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. Producers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2019/refillable_stainless_steel_kegs_chin
a_germany_and/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: KEGS
• 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 Type | application/pdf |
| File Title | Microsoft Word - US producer questionnaire (F) Kegs |
| Author | celia.feldpausch |
| File Modified | 2019-06-10 |
| File Created | 2019-06-10 |