19-2-4058 US importers' questionnaire

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

US importer questionnaire (F) Kegs

Stainless steel kegs from China, Germany, and Mexico (Inv. nos. 701-TA-610 and 731-TA-1425-1427)

OMB: 3117-0016

⚠️ Notice: This form may be outdated.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

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OMB No. 3117-0016/USITC No. 19-2-4058; Expiration Date : 6/30/2020
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U.S. IMPORTERS’ 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 imported refillable stainless steel kegs (as defined on next page) from any country at any time
since January 1, 2016?

(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

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

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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 at

https://www.usitc.gov/investigations/701731/2019/refillable_stainless_steel_kegs_china_german
y_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.

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Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing refillable stainless steel kegs (as defined above) into the United States from a foreign
manufacturer or through its selling agent.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.-- The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Celia
Feldpausch (202-205-2387, [email protected]).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
I-1.

Page 4

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of refillable stainless steel
kegs, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities.

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
I-3.

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

Firm name

I-4.

Page 5

Yes--List the following information

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing 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

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
I-5.

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

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

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

I-7.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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

Firm name

Address

Contact person
and phone
number

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
I-8.

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FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters refillable stainless
steel kegs into, or withdraws such merchandise from, foreign trade zones or bonded
warehouses. Also indicate whether your firm imports refillable stainless steel kegs under the TIB
(temporary importation under bond) program.
“Foreign trade zone” is a designated location in the United States where firms utilize special
procedures that allow delayed or reduced customs duty payments on foreign merchandise, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designated as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes

If yes, Yes–Please specify.

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Nature of operations.--Please identify the nature of your firm’s operations.
Definition of Operations.--For the purposes of this questionnaire, the size of commercial
breweries is defined as:




Large Commercial Breweries (production above 6 million barrels).
Medium Size Commercial Breweries (production of 100,000 to 6 million barrels); and
Small Commercial Breweries (production below 100,000 barrels);

Large
commercial
brewery

Medium size
commercial
brewery

Small
commercial
brewery

Keg leasing
and rental
company

Distributor /
reseller

Other (specify)

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the importation of refillable stainless steel kegs since January 1, 2016.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

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

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-3.

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Arranged imports.--Has your firm imported or arranged for the importation of refillable
stainless steel kegs for delivery after March 31, 2019?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes
If yes, fill out the table below.

Period
Source

Apr-Jun 2019

Jul-Sep 2019

Oct-Dec 2019

Jan-Mar 2020

Quantity (in units)
China
Germany
Mexico
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces refillable stainless steel kegs in
the United States, please indicate the reasons for importing this product. If your firm’s reasons
differ by source, please elaborate.

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial shipments”— Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“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 domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“Export shipments”— Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress. 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.

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-5a.

Page 12

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

China
Quantity (in units), value (in dollars)
Calendar years
Item

2016

2017

January-March
2018

2018

2019

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (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

Please identify the foreign producers, if known:
.
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:
.
2

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Page 13

U.S. imports from China.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation
A + B – D – F – H – J -L = should equal
zero ("0") or provide an explanation.1
1

2016

2017
0

January-March
2018

2018
0

2019
0

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

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-5b.

Page 14

Monthly U.S. imports (China).–Report your firm’s monthly U.S. imports of refillable stainless
steel kegs from China during the specified periods.
Quantity (in units)
Monthly U.S. imports from China

Month

Ningbo
Master

Ningbo
Haishu

Guangzhou
Jingye

Guangzhou
Ulix

All other
firms

Total Imports

2017.-September

October

November

December

2018.-January

February

March

April

May

June

July

August

September

October

November

December

2019.-January

February

March

RECONCILIATION OF MONTHLY IMPORTS.-- Please ensure that the total imports reported for full year
2018, and for the partial periods (e.g., January to March 2018, and January to March 2019) reported in
question II-5a matches the monthly data reported here. If the calculated fields below return values other
than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Reconciliation for
U.S. imports from China (II5b), revise if not returning
zero ("0")

Full year 2018

Jan-Mar 2018

Jan-Mar 2019

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-5c.

Page 15

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

China

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., lines D, F,
and H) in each time period as reported in part "a" of this question. If the calculated fields below return
values other than zero (i.e., “0”), the data reported must be revised prior to submission to the
Commission.
Calendar years
Reconciliation
M+N+O+P+Q+R–D–F–H=
zero ("0"), if not revise.

2016

2017
0

January-March
2018

2018
0

2019
0

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-5d.

Page 16

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

China
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. shipments by product type: China.--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 as reported in
part “a” of this question. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation

2016

2017

January-March
2018

2018

2019

Quantity: S+ U + W + Y + AA + AC + AE + AG
– D – F – H= zero ("0"), if not revise

Value: : T +V + X + Z + AB + AD + AF + AH– E
– G – I= zero ("0"), if not revise

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-6a.

Page 18

U.S. imports from Germany.–Report your firm’s imports and your firm’s shipments and
inventories of refillable stainless steel kegs imported from Germany by your firm during the
specified periods.

Germany
Quantity (in units), value (in dollars)
Calendar years
Item

2016

2017

January-March
2018

2018

2019

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U.S. imports from Germany.–Continued

2016

2017
0

January-March
2018

2018
0

2019
0

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

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-6b.

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Monthly U.S. imports (Germany).–Report your firm’s monthly U.S. imports of refillable stainless
steel kegs from Germany during the specified periods.
Quantity (in units)
Monthly U.S. imports from Germany
Month

Blefa GmbH

All other firms

Total Imports

2017.-September

October

November

December

2018.-January

February

March

April

May

June

July

August

September

October

November

December

2019.-January

February

March

RECONCILIATION OF MONTHLY IMPORTS.-- Please ensure that the total imports reported for full year
2018, and for the partial periods (e.g., January to March 2018, and January to March 2019) reported in
question II-6a matches the monthly data reported here. If the calculated fields below return values other
than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Reconciliation for
U.S. imports from Germany (II6b), revise if not returning zero
("0")

Full year 2018

Jan-Mar 2018

Jan-Mar 2019

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-6c.

Page 21

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

Germany

Quantity (in units)
Calendar years
Item

2016

2017

January-March
2018

2018

2019

2016

2017
0

January-March
2018

2018
0

2019
0

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-6d.

Page 22

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

Germany
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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-6d.

Page 23

U.S. shipments by product type: Germany.--Continued

2016

2017

January-March
2018

2018

2019

Quantity: S+ U + W + Y + AA + AC + AE + AG
– D – F – H= zero ("0"), if not revise

Value: : T +V + X + Z + AB + AD + AF + AH– E
– G – I= zero ("0"), if not revise

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-7a.

Page 24

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

Mexico
Quantity (in units), value (in dollars)
Calendar years
Item

2016

2017

January-March
2018

2018

2019

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-7a.

Page 25

U.S. imports from Mexico.–Continued

2016

2017
0

January-March
2018

2018
0

2019
0

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

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-7b.

Page 26

Monthly U.S. imports (Mexico).–Report your firm’s monthly U.S. imports of refillable stainless
steel kegs from Mexico during the specified periods from the following entity in Mexico.
Quantity (in units)
Monthly U.S. imports from Mexico
Month

Thielmann

All other firms

Total Imports

2017.-September

October

November

December

2018.-January

February

March

April

May

June

July

August

September

October

November

December

2019.-January

February

March

RECONCILIATION OF MONTHLY IMPORTS.-- Please ensure that the total imports reported for full year
2018, and for the partial periods (e.g., January to March 2018, and January to March 2019) reported in
question II-7a matches the monthly data reported here. If the calculated fields below return values other
than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Reconciliation for
U.S. imports from Mexico (II-7b),
revise if not returning zero ("0")

Full year 2018

Jan-Mar 2018
0

Jan-Mar 2019
0

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-7c.

Page 27

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

Mexico

Quantity (in units)
Calendar years
Item

2016

2017

January-March
2018

2018

2019

2016

2017
0

January-March
2018

2018
0

2019
0

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-7d.

Page 28

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

Mexico
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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-7d.

Page 29

U.S. shipments by product type: Mexico.--Continued

2016

2017

January-March
2018

2018

2019

Quantity: S+ U + W + Y + AA + AC + AE + AG
– D – F – H= zero ("0"), if not revise

Value: : T +V + X + Z + AB + AD + AF + AH– E
– G – I= zero ("0"), if not revise

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8a.

Page 30

U.S. imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of refillable stainless steel kegs imported from all other sources by your firm during
the specified periods.

All other sources
(List sources:

)
Quantity (in units), value (in dollars)
Calendar years

Item

2016

2017

January-March
2018

2018

2019

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8a.

Page 31

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

2016

2017
0

January-March
2018

2018
0

2019
0

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

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8b.

Page 32

Monthly U.S. imports (All Other Sources).–Report your firm’s monthly U.S. imports of refillable
stainless steel kegs from all other sources during the specified periods.
Quantity (in units)
Monthly U.S. imports from all other sources
Month

All other sources

Total Imports

2017.-September

October

November

December

2018.-January

February

March

April

May

June

July

August

September

October

November

December

2019.-January

February

March

RECONCILIATION OF MONTHLY IMPORTS.-- Please ensure that the total imports reported for full year
2018, and for the partial periods (e.g., January to March 2018, and January to March 2019) reported in
question II-8a matches the monthly data reported here. If the calculated fields below return values other
than zero (i.e., “0”), the data reported must be revised prior to submission to the Commission.
Reconciliation for
U.S. imports from all other
sources (II-8b), revise if not
returning zero ("0")

Full year 2018

Jan-Mar 2018

Jan-Mar 2019

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8c.

Page 33

Channels of distribution: All other sources.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution.

All other sources
Quantity (in units)
Calendar years

Item

2016

2017

January-March
2018

2018

2019

2016

2017
0

January-March
2018

2018
0

2019
0

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8d.

Page 34

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

All other sources
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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
II-8d.

Page 35

U.S. shipments by product type: All other sources.--Continued

2016

2017

January-March
2018

2018

2019

Quantity: S+ U + W + Y + AA + AC + AE + AG
– D – F – H= zero ("0"), if not revise

Value: : T +V + X + Z + AB + AD + AF + AH– E
– G – I= zero ("0"), if not revise

II-9.

Domestic processing.--Does your firm perform any processing on stainless steel kegs that are
imported in an unassembled format, such as adding or welding together component pieces of
the unassembled kegs? If yes, please explain the nature and extent of processing below.
No

II-10.

Yes

If yes, please describe.

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

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

Page 36

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (202-205-2049,
[email protected]).
III-1.

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products your firm imported
from China, Germany, and Mexico:
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).
During January 2016-March 2019, did your firm import from China, Germany, and Mexico and
sell to unrelated U.S. customers any of the above listed products (or any products that were
competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-3.

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

Page 37

III-2a. Price data.--Report below the quarterly price data1 for pricing products2 imported from China,
and sold by your firm. Exclude sales of filled stainless steel kegs.

China
Report data in units and dollars.

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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

Page 38

III-2b. Price data.--Report below the quarterly price data1 for pricing products2 imported from
Germany, and sold by your firm. Exclude sales of filled stainless steel kegs.

Germany
Report data in units and dollars.

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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-2c.

Page 39

Price data.--Report below the quarterly price data1 for pricing products2 imported from Mexico,
and sold by your firm. Exclude sales of filled stainless steel kegs.

Mexico
Report data in units and dollars.
(Quantity in units, value in dollars)
Product 1
Quantity
Value

Product 2

Period of shipment
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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-2d.

Page 40

Price data checklist.--Please check that the pricing data in question III-2(a) 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 part II in each year?
III-2e. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

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

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-3.

Page 41

Imports for internal use.--Did your firm import refillable stainless steel kegs for internal
consumption, use in own firm’s keg leasing operations, or use for sales in your firm’s own or a
related firm's retail locations since January 1, 2016?
Yes.--Please complete the following table as appropriate.
No.--Skip to question III-4.

Report below the import data1 for pricing products2 imported from China, Germany, and/or Mexico and
used by your own firm. These are imports that your firm does not resell as refillable stainless steel kegs.
Please note that values should be landed, duty-paid and should not include U.S.-inland transportation
costs. Values should reflect the final net amount paid by your firm (i.e., should be net of all returns,
discounts, allowances, and rebates).

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

Page 42

III-3a. Purchase costs data: China.--Report below the quarterly purchase cost data1 for products2
imported from China and used by your own firm (i.e., internally consumed, which includes
stainless steel kegs (a) used in and incorporated into the manufacture of downstream products,
(b) added to your firm’s leasing and rental asset base, and (c) transferred to your firm’s or a
related firm’s retail establishments for eventual retail level sale). Include any refillable stainless
steel kegs imported unfilled and subsequently filled by your firm in the United States. Do not
include the purchase costs data for stainless steels kegs that your firm sold commercially (at a
non-retail level) which are reported in questions III-2b through III-2d.

China
Report data in units and dollars.

Product 12
Landed, duty-paid
(LDP)
value1 (dollars)

Product 22
Landed, duty-paid
Quantity
(LDP)
(units)
value1 (dollars)

Quantity
Period of importation
(units)
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 LDP value (i.e., landed duty-paid values): Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland freight in the
United States). See “Import values” definition in Part II (Trade and Related Information – Definitions).
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.

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

Page 43

III-3b. Purchase costs data: Germany.--Report below the quarterly purchase cost data1 for products2
imported from Germany and used by your own firm (i.e., internally consumed, which includes
stainless steel kegs (a) used in and incorporated into the manufacture of downstream products,
(b) added to your firm’s leasing and rental asset base, and (c) transferred to your firm’s or a
related firm’s retail establishments for eventual retail level sale). Include any refillable stainless
steel kegs imported unfilled and subsequently filled by your firm in the United States. Do not
include the purchase costs data for stainless steels kegs that your firm sold commercially (at a
non-retail level) which are reported in questions III-2b through III-2d.

Germany
Report data in units and dollars.

Product 12
Landed, duty-paid
(LDP)
value1 (dollars)

Product 22
Landed, duty-paid
Quantity
(LDP)
(units)
value1 (dollars)

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-3c.

Page 44

Purchase costs data: Mexico.--Report below the quarterly purchase cost data 1 for products2
imported from Mexico and used by your own firm (i.e., internally consumed, which includes
stainless steel kegs (a) used in and incorporated into the manufacture of downstream products,
(b) added to your firm’s leasing and rental asset base, and (c) transferred to your firm’s or a
related firm’s retail establishments for eventual retail level sale). Include any refillable stainless
steel kegs imported unfilled and subsequently filled by your firm in the United States. Do not
include the purchase costs data for stainless steels kegs that your firm sold commercially (at a
non-retail level) which are reported in questions III-2b through III-2d.

Mexico
Report data in units and dollars.

Product 12
Landed, duty-paid
(LDP)
value1 (dollars)

Product 22
Landed, duty-paid
Quantity
(LDP)
(units)
value1 (dollars)

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U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)

Page 45

III-3d. Inland transportation costs for your firm’s direct imports of refillable stainless steel kegs for
internal use.-If your firm reported import purchase costs above (questions III-3a through III-3c), what is the
approximate percentage of the total cost of refillable stainless steel kegs that you directly
imported from China, Germany, and Mexico that is accounted for by U.S. inland transportation
costs from the port of importation to your distribution network, retail store(s), or manufacturing
plant(s)?
Country

III-3e.

Percent

China

Germany

Mexico

Additional costs for your firm’s direct imports of refillable stainless steel kegs for your firm’s
internal use.
(i)

If your firm reported direct import purchase costs above (question III-3a), please identify
the factors (other than U.S. inland transportation costs or costs already included in
landed duty paid values) that add to your cost of importing directly since January 1,
2016. Estimate the approximate amount of additional costs not embodied in your firm’s
reported landed duty paid values of your firm’s decision to import refillable stainless
steel kegs instead of purchasing from an importer or domestic producer. Report the
additional costs as a ratio to your firm’s reported landed duty paid values by factor and
explain the specific costs associated with each category. Do not include U.S inland
transportation costs as a factor in this analysis.

Factors
Logistical or supply chain management
costs (not already included in LDP
value)
Warehousing/inventory carrying costs
(such as rent, unloading, and
palletizing; not already included in LDP
value)
Insurance costs (not already included in
LDP value)
Other , please identify (
)

Estimated share
of landed dutypaid value
(percent)

Explanation

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
(ii)

Page 46

To which source(s) does your firm compare costs in determining your additional
transaction costs to directly import?
U.S. importers

(iii)

U.S. producers

Both

Neither

(a) Briefly identify the benefits of directly importing refillable stainless steel kegs instead
of purchasing refillable stainless steel kegs from a U.S. importer or from a U.S. producer.

(b) Please provide the estimated margin saved by having directly imported refillable
stainless steel kegs instead of purchasing from a U.S. importer.
percent of landed
duty-paid value.
(c) Explain any variation in the margin saved since January 1, 2016.

III-3f.

Did your firm purchase refillable stainless steel kegs from a U.S. producer or importer?
No

Yes--Complete the U.S. purchaser questionnaire.

Business Proprietary
U.S. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-4.

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

III-5.

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 imported refillable stainless steel kegs
from China, Germany, and Mexico usually quoted (check one)?
Delivered

III-7.

Set
price
lists

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

Quantity
discounts

III-6.

Page 47

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of refillable stainless steel
kegs imported from China, Germany, and Mexico 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. Importers’ Questionnaire - Refillable Stainless Steel Kegs (Final)
III-8.

Page 48

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
refillable stainless steel kegs imported from China, Germany, and Mexico (or check “not
applicable” if your firm does not sell on a short-term, annual and/or long-term contract basis).
Short-term contracts
(multiple deliveries
for less than 12
months)

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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:

III-9.

Lead times.--What is your firm’s share of sales of refillable stainless steel kegs imported from
China, Germany, and Mexico 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 refillable
stainless steel kegs?

Source

Lead time
(Average number
Share of 2018 sales
of days)

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

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III-10. Shipping information.—
(a)

What is the approximate percentage of the cost of refillable stainless steel kegs
imported from China, Germany, and Mexico that is accounted for by U.S. inland
transportation costs?
percent.

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(c)

When your firm sells refillable stainless steel kegs imported from China, Germany, and
Mexico, from where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of refillable stainless steel kegs
imported from China, Germany, and Mexico that are delivered the following distances
from your firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

III-11. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold refillable
stainless steel kegs imported from subject countries 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.

China

Germany

Mexico

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III-12. 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.
(c) Substitute imports.--Has your firm ever imported substitutes for refillable stainless steel kegs?

Substitute product that was
imported by your firm
1.
2.
3.

Time frame for substitute
imports

Approximate percentage of
your firm’s demand for
refillable stainless steel kegs
that was filled by substitute
import products

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III-13. 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.

Overall
increase

Market

No
change

Overall
decrease

Fluctuate
with no clear Explanation and
trend
factors

Within the United States
Outside the United States
III-14. 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.

III-15. 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?
Check all that apply.

Please describe.

Skip to question III-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
refillable stainless steel kegs since January 1, 2016?
No

Yes

If yes, describe.

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III-16. 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.

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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IV-17. 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.

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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III-18. 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.

III-19. 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.

Yes

If yes, please explain why your firm did not become certified.

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III-20 (a). Raw materials.--How have refillable stainless steel keg 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

Fluctuate
with no
No
clear
Increase change Decrease
trend

Don’t know

Explanation and factors

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III-21. 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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III-22. 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:

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III-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

City

State

Share of
2018 sales
(%)

Average
shipment
quantity

1
2
3
4
5
6
7
8
9
10

III-24. Warranties.--Does your firm offer warranties for your products?

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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III-25. Services.--Does your firm offer any pre- and post-sales services relating to stainless steel kegs?

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

III-26. Branding.--Please describe the financial investment and other efforts your firm has made to
develop your brand in the U.S. market.

III-27. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The U.S. International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):






START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.

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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 did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	Microsoft Word - US importer questionnaire (F) Kegs
Author	celia.feldpausch
File Modified	2019-06-10
File Created	2019-06-10