19-2-4094 US importers' questionnaire

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

US importers--VMFCs (F)

Vertical Metal File Cabinets From China (Inv. nos. 701-TA-623 and 731-TA-1449)

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⚠️ Notice: This form may be outdated.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. 19-2-4094; Expiration Date : 6/30/2020
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U.S. IMPORTERS’ QUESTIONNAIRE
VERTICAL METAL FILE CABINETS FROM CHINA
This questionnaire must be received by the Commission by August 28, 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 duty and antidumping duty investigations concerning vertical metal file cabinets
“VMFCs” from China (Inv. No. 701-TA-623 and 731-TA-1449 (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 vertical metal file cabinets (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: FILE)
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. Importers’ Questionnaire – Vertical metal file cabinets (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on April 30, 2019, by Hirsh
Industries LLC, West Des Moines, Iowa. Countervailing and antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2019/vertical_metal_file_cabinets_china/preliminary.htm
Vertical metal file cabinets “VMFCs” covered by these investigations are freestanding vertical metal file
cabinets containing two or more extendable file storage elements and having an actual width of 25
inches or less.
The subject vertical metal file cabinets have bodies made of carbon and/or alloy steel and or other
metals, regardless of whether painted, powder coated, or galvanized or otherwise coated for corrosion
protection or aesthetic appearance. The subject vertical metal file cabinets must have two or more
extendable elements for file storage (e.g., file drawers) of a height that permits hanging files of either
letter (8.5” x 11”) or legal (8.5” x 14”) sized documents.
An “extendable element” is defined as a movable load-bearing storage component including, but not
limited to, drawers and filing frames. Extendable elements typically have suspension systems, consisting
of glide blocks or ball bearing glides, to facilitate opening and closing.
The subject vertical metal file cabinets typically come in models with two, three, four, or five-file
drawers. The inclusion of one or more additional non-file-sized extendable storage elements, not sized
for storage files (e.g., box or pencil drawers), does not remove an otherwise in-scope product from the
scope as long as the combined height of the non-file-sized extendable storage elements does not exceed
six inches. The inclusion of an integrated storage area that is not extendable (e.g., a cubby) and has an
actual height of six inches or less, also does not remove a subject vertical metal file cabinet from the
scope. Accessories packaged with a subject vertical file cabinet, such as separate printer stands or shelf
kits that sit on top of the in-scope vertical file cabinet are not considered integrated storage.
“Freestanding” means the unit has a solid top and does not have an open top or a top with holes
punched in it that would permit the unit to be attached to, hung from, or otherwise used to support a
desktop or other work surface. The ability to anchor a vertical file cabinet to a wall for stability or to
prevent it from tipping over does not exclude the unit from the scope.
The addition of mobility elements such as casters, wheels, or a dolly does not remove the product from
the scope. Packaging a subject vertical metal file cabinet with other accessories, including, but not
limited to, locks, leveling glides, caster kits, drawer accessories (e.g., including but not limited to
follower wires, follower blocks, file compressors, hanger rails, pencil trays, and hanging file folders),
printer stand, shelf kit and magnetic hooks, also does not remove the product from the scope. Vertical
metal file cabinets are also in scope whether they are imported assembled or unassembled with all
essential parts and components included.
Excluded from the scope are lateral metal file cabinets. Lateral metal file cabinets have a width that is
greater than the body depth, and have a body with an actual width that is more than 25 inches wide.

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)

Page 3

Also excluded from the scope are pedestal file cabinets. Pedestal file cabinets are metal file cabinets
with body depths that are greater than or equal to their width, are under 31 inches in actual height, and
have the following characteristics: (1) an open top or other the means for the cabinet to be attached to
or hung from a desktop or other work surface such as holes punched in the top (i.e., not freestanding);
or (2) freestanding file cabinets that have all of the following: (a) at least a 90 percent drawer extension
for all extendable file storage elements; (b) a central locking system; (c) a minimum weight density of 9.5
lbs./cubic foot; and (d) casters or leveling glides.
“Percentage drawer extension” is defined as the drawer travel distance divided by the inside depth
dimension of the drawer. Inside depth of drawer is measured from the inside of the drawer face to the
inside face of the drawer back. Drawer extension is the distance the drawer travels from the closed
position to the maximum travel position which is limited by the out stops. In situations where drawers
do not include an outstop, the drawer is extended until the drawer back is 3-l/2 inches from the closed
position of inside face of the drawer front. The “weight density” is calculated by dividing the cabinet’s
actual weight by its volume in cubic feet (the multiple of the product’s actual width, depth, and height).
A “central locking system” locks all drawers in a unit.
Also excluded from the scope are fire proof or fire-resistant file cabinets that meet Underwriters
Laboratories (UL) fire protection standard 72, class 350, which covers the test procedures applicable to
fire-resistant equipment intended to protect paper records.
The merchandise subject to the investigation is classified under Harmonized Tariff Schedule of the
United States (HTSUS) subheading 9403.10.0020. The subject merchandise may also enter under HTSUS
subheadings 9403.10.0040, 9403.20.0080, and 9403.20.0090. While HTSUS subheadings are provided
for convenience and customs purposes, the written description of the scope of the investigation is
dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing VMFCs (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.

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)

Page 4

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
Lawrence Jones (202-205-3358, [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 – Vertical metal file cabinets (Final)
I-1.

Page 5

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

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
I-3.

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

Firm name

I-4.

Page 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 VMFCs from China into the United States or that are
engaged in exporting VMFCs from China to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of VMFCs?
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
VMFCs. More than one answer may be applicable.
Importer of record

I-7.

Page 7

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 VMFCs 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 – Vertical metal file cabinets (Final)
I-8.

Page 8

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters VMFCs into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports VMFCs 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 designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

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

Yes

If yes, Yes–Please specify.

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)

Page 9

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [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 VMFCs 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 – Vertical metal file cabinets (Final)
II-3a.

Page 10

Arranged imports.--Has your firm imported or arranged for the importation of VMFCs for
delivery after June 30, 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

Jul-Sep 2019

Oct-Dec 2019

Jan-Mar 2020

Apr-Jun 2020

Quantity (in units)
China
Mexico
All Other Sources
II-3b.

Imports in the 12-month period preceding the petition.--Has your firm imported VMFCs from
China or other sources between April 1, 2018 and March 31, 2019? (i.e., the last nine months in
2018 and first three months in 2019 combined)
No

Yes
If yes, report the quantity of such import below by source.

Quantity (in units)
Source

April 2018 through March 2019

China
Mexico
All other sources
II-4.

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

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)

Page 11

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).
“Commercial U.S. shipments”— Commercial shipments made within the United States as a
result of an arm’s length 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 own firm’s retail sales” – Product consumed internally by your
firm, which includes merchandise that your firm transferred to your own firm's retail locations.
Such transactions are valued at fair market value (i.e., not the total value of final downstream
processed merchandise (in the case of internal consumption), nor the retail sale value (in the
case of your firm owning and operating its own retail locations); rather, these transactions
should be recorded at the fair market wholesale value of the merchandise used for further
processing or for retail level sale). Do not include inter-store shipments. Internal consumption
for use in your firm's retail locations should represent the initial post-importation, wholesale
level shipment to the first retail location.
“Transfers to related firms” –Shipments made to related firms in the United States. Such
transactions are valued at fair market value. Do not include inter-store shipments/transfers.
Transfers reported should represent post-importation, wholesale-to-wholesale transfers to
related firms.
“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.
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 – Vertical metal file cabinets (Final)
II-5a.

Page 12

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

China
Quantity (in units) and value (in 1,000s of dollars)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Beginning-of-period inventories (quantity) (A)
Imports1 2
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/including for own
firm’s retail sales3 :
Quantity (F)
Value (G)
Transfers to related firms:
Quantity (H)
Value

(I)

Export shipments5:
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1

Please report imports based on country-of-origin of primary manufacturing location, regardless of final processing or
shipment location (if different). Please identify the foreign producers, if known:
.
2
Data on U.S. imports will populate into this table once reported in question II-7.
3
Include merchandise that your firm transferred to your own firm's retail locations.
4
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.
5
Identify your firm’s principal export markets:
.

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
II-5a.

Page 13

U.S. imports from China.--Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORY.--Generally, the data reported for the endof-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 reflect your firm’s actual records; and,
also provide explanations for any differences (e.g., theft, loss, damage, record issues, etc.) if they exist.
Calendar years
Reconciliation

2016

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

2017
0

January-June
2018

2018
0

2019
0

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

II-5b.

Channels of distribution: China.-- Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption including for own firm’s retail sales, and
transfers to related firms) of imports from China by channel of distribution. If you import and
sell the imported VMFCs in your own firm's retail locations, report those shipments as "to
retailers" consistent with the wholesale level of trade reported in part "a" of this question.

China
Quantity (in units)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers (N)
To end users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., lines 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 – D – F – H = zero ("0"),
if not revise.

2016

2017
0

January-June
2018

2018
0

2019
0

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
II-6a.

Page 14

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

Mexico
Quantity (in units) and value (in 1,000s of dollars)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

(I)

Export shipments5:
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1

Please report imports based on country-of-origin of primary manufacturing location, regardless of final processing
or shipment location (if different). Please identify the foreign producers, if known:
.
2
Data on U.S. imports will populate into this table once reported in question II-7.
3
Include merchandise that your firm transferred to your own firm's retail locations.
4
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.
5
Identify your firm’s principal export markets:
.

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
II-6a.

Page 15

U.S. imports from Mexico.--Continued

2016

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

2017
0

January-June
2018

2018
0

2019
0

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

II-6b.

Channels of distribution: Mexico.-- Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption including for own firm’s retail sales, and
transfers to related firms) of imports from Mexico by channel of distribution. If you import and
sell the imported VMFCs in your own firm's retail locations, report those shipments as "to
retailers" consistent with the wholesale level of trade reported in part "a" of this question.

Mexico
Quantity (in units)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

2016

2017
0

January-June
2018

2018
0

2019
0

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
II-7a.

Page 16

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of VMFCs imported from all other sources by your firm during the specified periods.

All other sources
(list sources:

)
Quantity (in units) and value (in 1,000s of dollars)
Calendar years

Item

2016

2017

January-June
2018

2018

2019

Please report imports based on country-of-origin of primary manufacturing location, regardless of final processing
or shipment location (if different). Please identify the foreign producers, if known:
.
2
Data on U.S. imports will populate into this table once reported in question II-7.
3
Include merchandise that your firm transferred to your own firm's retail locations.
4
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.
5
Identify your firm’s principal export markets:
.

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U.S. Importers’ Questionnaire – Vertical metal file cabinets (Final)
II-7a.

Page 17

Imports from All Other Sources.–Continued

2016

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

January-June

2017
0

2018
0

2019
0

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

II-7b.

Channels of distribution: All other sources.-- Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption including for own firm’s retail sales, and
transfers to related firms) of imports from all other sources by channel of distribution. If you
import and sell the imported VMFCs in your own firm's retail locations, report those shipments
as "to retailers" consistent with the wholesale level of trade reported in part "a" of this
question.

All other sources
Quantity (in units)
Calendar years
Item

2016

2017

January-June
2018

2018

2019

2016

2017
0

January-June
2018

2018
0

2019
0

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II-8.

Transfers to related firms.-- If your firm reported transfers to related firms in any of the data
tables in part II, 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) and whether the
transfers were priced at market value or by a non-market formula.

II-9.

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.

II-10.

Instructions.—Please check that the data in part II have been correctly reported.
Is the data reported in those questions:
In $1,000 dollars (not actual dollars)? (i.e., reporting 15 would represent
fifteen thousand dollars)
Inclusive of data limited to only in-scope VMFCs as defined on pages 2-3?
Net of all discounts, rebates, returns, etc.?
Properly accounted for based on the definitions on page 11?
Reconciled in the reconciliation tables above?

√ if Yes

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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Pamela Davis (202-2052218, [email protected]).
III-1.

PRICE DATA / PURCHASE COST DATA
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:
Product 1.-- Vertical metal file cabinet, 17.75” — 20.25” deep, two file drawers, letter size (14.0”
— 16.25” wide), containing a lock, not containing casters
Product 2.-- Vertical metal file cabinet, 20.75” — 24.25” deep, two file drawers, letter size (14.0”
— 16.25” wide), containing a lock, not containing casters
Product 3.-- Vertical metal file cabinet, 27.75” — 29.25” deep, two file drawers, letter size (14.0”
— 16.25” wide), containing a lock, not containing casters
Product 4.-- Vertical metal file cabinet, 17.75” — 20.25” deep, two file drawers and one pencil
drawer, letter size (14.00” — 16.25” wide), containing a lock, not containing casters
Product 5.-- Vertical metal file cabinet, 17.75” — 20.25” deep, three file drawers, letter size
(14.00” — 16.25” wide), containing a lock, not containing casters
Product 6.-- Vertical metal file cabinet, 25.75” — 27.25” deep, four file drawers, letter size (14.00”
— 16.25” wide), containing a lock, not containing casters
III-2.

Price data.--During January 2016-June 2019, did your firm import from China and commercially
sell to unrelated U.S. customers any of the above listed products (or any products that were
competitive with these products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question III-3.

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III-2a. Price data: China.--Report below the quarterly price data1 for pricing products2 imported from
China and sold by your firm. Do not include retail sales.

China
Report data in units and actual dollars (not 1,000s).
Product 1

(Quantity in units, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Period of shipment
Quantity
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
April-June
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 Product definitions are provided on the first page of Part III.
Note.-- 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). If your firm’s product does not exactly
meet the product specifications but is competitive with the specified product, provide a description of your firm’s product. Also, please explain
any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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III-2a. Price data: China.-- Continued Report below the quarterly price data1 for pricing products2
imported from China and sold by your firm. Do not include retail sales.

China
Report data in units and actual dollars (not 1,000s).
Product 4

(Quantity in units, value in dollars)
Product 5
Value
Quantity
Value

Product 6
Period of shipment
Quantity
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
April-June
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 Product definitions are provided on the first page of Part III.
Note.-- 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). 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 4:
Product 5:
Product 6:

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III-2b. Price data: Mexico.--Report below the quarterly price data1 for pricing products2 imported from
Mexico and sold by your firm. Do not include retail sales.

Mexico
Report data in units and actual dollars (not 1,000s).
Product 1

(Quantity in units, value in dollars)
Product 2
Value
Quantity
Value

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III-2a. Price data: Mexico.-- Continued Report below the quarterly price data1 for pricing products2
imported from Mexico and sold by your firm. Do not include retail sales.

Mexico
Report data in units and actual dollars (not 1,000s).
Product 4

(Quantity in units, value in dollars)
Product 5
Value
Quantity
Value

III-2c.

Price data checklist.--Please check that the pricing data in questions III-2a and III-2b has been
correctly reported.
Is the price data reported above:
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the original sale occurred?
Less than reported commercial shipments in part II in each year?

√ if Yes

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III-2d. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

III-3.

Imports for repackaging or retail sale.--Did your firm import VMFCs for repackaging or for sales
in your firm’s retail locations since January 1, 2016?
Yes.--Please complete the following table as appropriate.
No.--Skip to question III-5.

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III-3a. Purchase cost data: China.--Report below your firm's purchase cost data on imports 1 by
product2 used for your firm's or a related firm's retail level sales.
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).

China

Report data in units and actual dollars (not 1,000s).
Product 1
LDP
value1 (dollars)

Product 2

Product 3

LDP
value1 (dollars)

LDP
Period of importation
Quantity
Quantity
Quantity
value1 (dollars)
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
April-June
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 Product definitions are provided on the first page of Part III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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III-3a. Purchase cost data: China.--Continued Report below your firm's purchases cost data on
imports1 by product2 used for your firm's or a related firm's retail level sales.
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).

China

Report data in units and actual dollars (not 1,000s).

Product 4
LDP
value1 (dollars)

Product 5

Product 6

LDP
value1 (dollars)

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III-4a. Inland transportation costs for your firm’s purchases of VMFCs for retail sale.-If your firm reported import purchases costs above (questions III-3a), what is the approximate
percentage of the total cost VMFCs that you directly imported from China 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

Percent

China

III-4a. Additional costs for your firm’s purchases of VMFCs for retail sale.
(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 “LDP” values) that have added to your cost of importing directly since
January 1, 2016. Estimate the ratio to the cost of the landed duty-paid value, and
explain the specific costs associated with each category.

Factor
Logistical or supply chain management
costs (not already included in LDP value)
Warehousing/inventory carrying costs
(not already included in LDP value)
Insurance costs (not already included in
LDP value)
Other, please identify (
)

Estimated ratio
to LDP value
(percent)

Explanation

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III-4b. Additional costs for your firm’s purchases of VMFCs for retail sale.—Continued.
(ii)

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 VMFCs instead of purchasing VMFCs
from a U.S. importer or from a U.S. producer.

(b) Please provide the estimated margin saved by having directly imported VMFCs
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.

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.

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III-5.

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

III-6.

Contracts

Annual
total
volume
discounts

Online
price
lists

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported VMFCs usually quoted (check
one)?
Delivered

III-8.

Set
price
lists

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

Quantity
discounts

III-7.

Page 29

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of imported VMFCs 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

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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III-9.

Page 30

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
imported VMFCs (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/adjusted to
raw material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes/adjustments used:

III-10. Lead times.--What is your firm’s share of sales of VMFCs imported from China from inventory
and produced to order and what is the typical lead time between a customer’s order and the
date of delivery for your firm’s sales of VMFCs?

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-11. Shipping information. -(a)

What is the approximate percentage of the cost of VMFCs imported from China that is
accounted for by U.S. inland transportation costs?
percent.

(b)

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

(c)

When your firm sells VMFCs imported from China, from where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of VMFCs imported from China
that are delivered the following distances from your firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

III-12. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold VMFCs
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

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III-13. Substitutes.—
(a)

Specific substitutes.--Are these specific products considered as substitutes for VMFCs in
the same end use(s)?

Specific substitutes

Are these
considered
substitutes in the
Have changes in the price of this
End use(s) in which
market?
substitute affected the price of VMFCs?
this substitute is
No
Yes
used
No
Yes
Explanation

Lateral metal file
cabinets
Pedestal metal file
cabinets
Filing cabinets not
made of metal
Desks or other office
furniture with storage
capacity
Electronic document
storage
(b)

Other substitutes.--Can other products not already listed in part “a” of this question be
substituted for VMFCs?
No

Other substitutes
1.
2.
3.
4.

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 VMFCs?
No Yes

Explanation

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III-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for VMFCs has changed since January 1, 2016. Explain any trends and describe
the principal factors that have affected these changes in demand for your firm and the overall
VMFCs market (e.g., general economic growth, office vacancy rates, etc.).

Market

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within the United
States
Outside the United
States
III-15. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of VMFCs since January 1, 2016?
No

Yes

If yes, please describe.

III-16. Product characteristics. –
(a) Please list product characteristics or features (e.g., steel gauge or type of steel, color, finish,
design, safety, etc.) that would cause your firm to sell two products with similar dimensions
at different prices.

(b) Please list firm-specific product characteristics or features (e.g., steel gauge or type of steel,
color, finish, design, safety, etc.) of the VMFCs that would cause two products with similar
dimensions to be sold at different prices.

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III-17. Conditions of competition. -(a) Is the VMFCs market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to VMFCs?
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
VMFCs since January 1, 2016?
No

Yes

If yes, describe.

III-18. Supply constraints.--Has your firm refused, declined, or been unable to supply VMFCs 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.

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III-19. Raw materials.—

(a) How have VFMC raw material prices changed since January 1, 2016?

Overall
No
Overall
increase change decrease

Item

Fluctuate
with no
clear trend

Explain, noting how raw
material price changes
have affected your firm’s
selling prices for VMFCs.

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
VMFCs?
Yes—Please indicate the impact
in the table below.

Fluctuate
with no
No
clear
Increase change Decrease trend

Item

Don’t know

Explanation and factors

Raw material costs
for VMFCs in the
U.S. market
Prices for VFMCs in
the U.S. market
III-20. Impact of the section 301 investigation.-- This question concerns the section 301

investigation and subsequent announcement of additional tariffs that include VMFCs
proposed and implemented by the United States in response to Chinese trade practices.
(a) Has the implementation of tariff remedies in the section 301 investigation impact, or do you
anticipate that it will impact, your firm's VMFCs business and/or the U.S. VMFCs market as a
whole?
Yes—Please answer b and c.

Don’t know

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(b) Please indicate the impact of implementation of remedies in the section 301 investigation
and tariff actions regarding VMFCs on each of the following factors.

Impact on

Overall
Increase

No change

Overall
Decrease

Fluctuate with
no clear trend

Demand for VMFCs in the U.S.
market
Supply of imports from China of
VMFCs in the U.S. market
Supply of imports from other
sources of VMFCs in the U.S. market
Prices for VMFCs in the U.S. market
Raw materials costs for VMFCs in
the U.S. market
(b) Describe the impact of the 301 tariffs on your firm and the overall market for VMFCs. Please
identify the magnitude and timing of the reported effects, and compare your firm’s
operations/overall market before and after the implementation of tariffs.

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III-21. Interchangeability.--Are VMFCs produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

China

Mexico

Other countries

United States
China
Mexico
For any country-pair producing VMFCs 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 VMFCs produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

China

Mexico

Other countries

United States
China
Mexico
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of VMFCs, 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 VMFCs since January 1, 2016. Indicate the share of the quantity of your firm’s
total shipments of VMFCs that each of these customers accounted for in 2018.
Customer’s name

City

State

Share of 2018
sales (%)

1
2
3
4
5
6
7
8
9
10

III-24. 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 US International Trade
Commission’s questionnaires are set-up in the United States with the U.S. number formatting. When
this formatting interacts with a computer set to EU number formatting, we believe this may cause this
issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):






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

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

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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/vertical_metal_file_cabinets_china/
preliminary.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: FILE

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

File Type	application/pdf
File Title	Microsoft Word - US importers--VMFCs (F)
Author	lawrence.jones
File Modified	2019-07-26
File Created	2019-07-26