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pdfOMB No. 3117‐0016/USITC No. 19‐4‐4112; Expiration Date: 6/30/2020
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FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
CRYSTALLINE SILICON PHOTOVOLTAIC CELLS
(WHETHER OR NOT PARTIALLY OR FULLY ASSEMBLED INTO OTHER PRODUCTS)
This questionnaire must be received by the Commission by October 4, 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 investigation No. TA‐201‐75 (Monitoring), Crystalline Silicon Photovoltaic (“CSPV”) Cells (Whether or
Not Partially or Fully Assembled Into Other Products)(“CSPV Products”): Monitoring Developments in the Domestic
Industry, under section 204 of the Trade Act of 1974 (19 U.S.C. § 2254). The information requested in the questionnaire
is needed to supplement data available to the Commission from other sources and is requested under the authority of
section 204 of the Tariff Act of 1974.
Name of firm
Address
Website
Has your firm produced or exported CSPV products as defined on the next five pages in or from any country at any time since
January 1, 2016?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Data reported in this questionnaire relate to a firm located in (Check only one country):
Canada
China
Germany
India
Indonesia
Japan
Korea
Malaysia
Mexico
Philippines
Singapore
Taiwan
Thailand
Turkey
Vietnam
Other: ________(please list country)
Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: CSPV)
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 investigations, reviews, or
general fact finding investigations conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone:
Email address
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 2
PART I.‐‐GENERAL INFORMATION
Background. On January 23, 2018, the President, pursuant to section 203 of the Trade Act of 1974,
issued Proclamation 9693, imposing a safeguard measure on imports of CSPV products, in the form of
(a) a tariff‐rate quota on imports of CSPV (or “solar”) cells not partially or fully assembled into other
products and (b) an increase in duties on imports of CSPV modules. The proclamation was published in
the Federal Register on January 25, 2018 (83 Fed. Reg. 3541). The measure took effect on February 7,
2018, for a period of four years, or through February 7, 2022. Section 204(a) of the Act requires the
Commission to submit a report to the President and Congress on its monitoring of industry
developments at the midpoint of the initial period of relief, including the progress and specific efforts
made by workers and firms in the domestic industry to make a positive adjustment to import
competition. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/title_7/2019/crystalline_silicon_photovoltaic_cells_whether_or/s
afeguard.htm
Crystalline Silicon Photovoltaic (“CSPV”) Cells (Whether or Not Partially or Fully Assembled Into Other
Products) (“CSPV products”).‐‐The articles covered by the investigation are crystalline silicon
photovoltaic cells, whether or not partially or fully assembled into other products, including, but not
limited to, modules, laminates, panels and building‐integrated materials.
The investigation covers crystalline silicon photovoltaic cells of a thickness equal to or greater than 20
micrometers, having a p/n junction (or variant thereof) formed by any means, whether or not the cell
has undergone other processing, including, but not limited to, cleaning, etching, coating, and/or
addition of materials (including, but not limited to, metallization and conductor patterns) to collect and
forward the electricity that is generated by the cell.
Included in the scope of the investigation are photovoltaic cells that contain crystalline silicon in addition
to other photovoltaic materials. This includes, but is not limited to, passivated emitter rear contact
(“PERC”) cells, heterojunction with intrinsic thin‐layer (“HIT”) cells, and other so‐called “hybrid” cells.
Articles under consideration may be described at the time of importation as components for final
finished products that are assembled after importation, including, but not limited to, modules,
laminates, panels, and building‐integrated materials.
Excluded from the investigation are CSPV cells, whether or not partially or fully assembled into other
products, if the CSPV cells were manufactured in the United States.
Also excluded from the investigation are thin film photovoltaic products produced from amorphous
silicon (“a‐Si”), cadmium telluride (“CdTe”), or copper indium gallium selenide (“CIGS”).
Also excluded from the scope of the investigation are CSPV cells, not exceeding 10,000mm2 in surface
area, that are permanently integrated into a consumer good whose function is other than power
generation and that consumes the electricity generated by the integrated CSPV cell. Where more than
one CSPV cell is permanently integrated into a consumer good, the surface area for purposes of this
exclusion shall be the total combined surface area of all CSPV cells that are integrated into the consumer
good.
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Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
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For Customs purposes, the CSPV cells covered by the investigation are provided for under Harmonized
Tariff Schedule of the United States (“HTSUS”) subheading 8541.40.60. Inverters or batteries with CSPV
cells attached can be imported under HTSUS subheadings 8501.61.00 and 8507.20.80, respectively. In
addition, CSPV cells covered by the investigation may also be classifiable as DC generators of
subheadings 8501.31.80 and 8501.32.60, when such generators are imported with CSPV cells attached.
While HTSUS provisions are provided for convenience, the written description of the scope is
dispositive.1
Included in the overall data collection in this questionnaire are certain excluded items (i.e., “low
wattage” modules) listed in the Presidential Proclamation (83 Fed. Reg. 3541, January 25, 2018)
and other excluded items listed in the September 19, 2018 and June 13, 2019 Federal Register
notices (83 Fed. Reg. 47393 and 84 Fed. Reg. 27684), although certain data concerning these items
are requested separately (see listings and definitions below for “bifacial,” “flexible fiberglass,”
“light directing film,” “Modules incorporating rear contact cells with tin‐coated solid copper
fingers,” “Rear contact cells with tin‐coated solid copper fingers,” and “low wattage”).
Presidential Proclamation 9693 excluded the following “low wattage” products from application of the
safeguard measure, which took effect on February 7, 2018 (83 Fed. Reg. 3541, January 25, 2018):
• 10 to 60 watt, inclusive, rectangular solar panels, where the panels have the following
characteristics: (A) Length of 250 mm or more but not over 482 mm or width of 400 mm or
more but not over 635 mm, and (B) surface area of 1000 cm2 or more but not over 3,061 cm2,
provided that no such panel with those characteristics shall contain an internal battery or
external computer peripheral ports at the time of entry.
• 1 watt solar panels incorporated into nightlights that use rechargeable batteries and have the
following dimensions: 58 mm or more but not over 64 mm by 126 mm or more but not over 140
mm.
• 2 watt solar panels incorporated into daylight dimmers that may use rechargeable batteries,
such panels with the following dimensions: 75 mm or more but not over 82 mm by 139 mm or
more but not over 143 mm.
• Off‐grid and portable CSPV panels, whether in a foldable case or in rigid form containing a
glass cover, where the panels have the following characteristics: (a) A total power output of 100
watts or less per panel; (b) a maximum surface area of 8,000 cm2 per panel; (c) does not include
a built‐in inverter; and where the panels have glass covers, such panels must be in individual
retail packaging (in this context, retail packaging typically includes graphics, the product name,
its description and/or features, and foam for transport).
• 3.19 watt or less solar panels, each with length of 75 mm or more but not over 266 mm and
width of 46 mm or more but not over 127 mm, with surface area of 338 cm2 or less, with one
black wire and one red wire (each of type 22 AWG or 24 AWG) not more than 206 mm in length
when measured from panel edge, provided that no such panel shall contain an internal battery
or external computer peripheral ports.
• 27.1 watt or less solar panels, each with surface area less than 3,000 cm2 and coated across
the entire surface with a polyurethane doming resin, the foregoing joined to a battery charging
and maintaining unit, such unit which is an acrylonitrile butadiene styrene (ABS) box that
incorporates a light emitting diode (LED) by coated wires that include a connector to permit the
incorporation of an extension cable.
1
CSPV products covered by the scope are currently subject to tariff‐rate quotas under a safeguard measure
imposed effective February 7, 2018, under subheadings 9903.45.21 and 9903.45.22 (CSPV cells) and 9903.45.25
(CSPV modules) and related legal notes.
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CSPV Products (Monitoring)
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The following additional CSPV products entered, or withdrawn from a warehouse for consumption, on
or after 12:01 a.m., EST, on September 19, 2018 are also excluded from the safeguard measure (83 Fed.
Reg. 47393, September 19, 2018):
• off‐grid, 45 watt or less solar panels, each with length not exceeding 950 mm and width of
100 mm or more but not over 255 mm, with a surface area of 2,500 cm2 or less, with a pressure‐
laminated tempered glass cover at the time of entry but not a frame, electrical cables or
connectors, or an internal battery.
• 4 watt or less solar panels, each with a length or diameter of 70 mm or more but not over 235
mm, with a surface area not exceeding 539 cm2, and not exceeding 16 volts, provided that no
such panel with these characteristics shall contain an internal battery or external computer
peripheral ports at the time of entry.
• solar panels with a maximum rated power of equal to or less than 60 watts, having the
following characteristics, provided that no such panel with those characteristics shall contain an
internal battery or external computer peripheral ports at the time of entry: (A) Length of not
more than 482 mm and width of not more than 635 mm or (B) a total surface area not
exceeding 3,061 cm2.
• flexible and semi‐flexible off‐grid solar panels designed for use with motor vehicles and boats,
where the panels range in rated wattage from 10 to 120 watts, inclusive.
• frameless solar panels in a color other than black or blue with a total power output of 90 watts
or less where the panels have a uniform surface without visible solar cells or busbars.
• solar cells with a maximum rated power between 3.4 and 6.7 watts, inclusive, having the
following characteristics: (A) A cell surface area between 154 cm2 and 260 cm2, inclusive, (B) no
visible busbars or gridlines on the front of the cell, and (C) more than 100 interdigitated fingers
of tin‐coated solid copper adhered to the back of the cell, with the copper portion of the metal
fingers having a thickness of greater than 0.01 mm.
• solar panels with a maximum rated power between 320 and 500 watts, inclusive, having the
following characteristics: (A) Length between 1,556 mm and 2,070 mm inclusive, and width
between 1,014 mm and 1,075 mm, inclusive, (B) where the solar cells comprising the panel have
no visible busbars or gridlines on the front of the cells, and (C) the solar cells comprising the
panel have more than 100 interdigitated fingers of tin‐coated solid copper adhered to the back
of the cells, with the copper portion of the metal fingers having thickness greater than 0.01 mm.
• modules incorporating only CSPV cells that are products of the United States and not
incorporating any CSPV cells that are the product of any other country.
The following additional CSPV products entered, or withdrawn from a warehouse for consumption, on
or after 12:01 a.m., EST, on June 13, 2019 are also excluded from the safeguard measure (84 Fed. Reg.
27684, June 13 19, 2019):
• bifacial solar panels that absorb light and generate electricity on each side of the panel and
that consist of only bifacial solar cells that absorb light and generate electricity on each side of
the cells.
• flexible fiberglass solar panels without glass components other than fiberglass, such panels
having power outputs ranging from 250 to 900 watts.
• solar panels consisting of solar cells arranged in rows that are laminated in the panel and that
are separated by more than 10 mm, with an optical film spanning the gaps between
all rows that is designed to direct sunlight onto the solar cells, and not including panels that lack
said optical film or only have a white or other backing layer that absorbs or scatters sunlight.
CSPV cell.‐‐A crystalline silicon photovoltaic (“CSPV”) cell converts sunlight to electricity and is the basic
element of a module. The investigation covers CSPV cells of a thickness equal to or greater than 20
micrometers, having a p/n junction (or variant thereof) formed by any means, whether or not the cell
has undergone other processing, including, but not limited to, cleaning, etching, coating, and/or
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 5
addition of materials (including, but not limited to, metallization and conductor patterns) to collect and
forward the electricity that is generated by the cell. Included are photovoltaic cells that contain
crystalline silicon in addition to other photovoltaic materials. This includes, but is not limited to,
passivated emitter rear contact (“PERC”) cells, heterojunction with intrinsic thin‐layer (“HIT”) cells, and
other so‐called “hybrid” cells.
CSPV module.‐‐A joined group of CSPV cells, regardless of the number of cells or the shape of the joined
group, that are capable of generating electricity. The term “module” is frequently used interchangeably
with the term “panel.” A “laminate” is a module that does not have a frame.
CSPV products = CSPV cells + CSPV modules
Building Integrated Materials.‐‐Materials integrated into the building envelope, such as the façade or
roof, containing CSPV cells. These building integrated materials replace conventional construction
materials, such as glass or roof shingles, taking over the function that conventional materials would
otherwise perform while also producing electricity.
Bifacial.‐‐Bifacial modules that absorb light and generate electricity on each side of the module and that
consist of only bifacial cells that absorb light and generate electricity on each side of the cells.
Flexible fiberglass.‐‐Flexible fiberglass modules without glass components other than fiberglass, such
modules having power outputs ranging from 250 to 900 watts.
Light directing film.‐‐Modules consisting of cells arranged in rows that are laminated in the module and
that are separated by more than 10 mm, with an optical film spanning the gaps between all rows that is
designed to direct sunlight onto the cells, and not including modules that lack said optical film or only
have a white or other backing layer that absorbs or scatters sunlight.
Rear contact cells with tin‐coated solid copper fingers.‐‐Cells with a maximum rated power between 3.4
and 6.7 watts, inclusive, having the following characteristics: (A) A cell surface area between 154 cm2
and 260 cm2, inclusive, (B) no visible busbars or gridlines on the front of the cell, and (C) more than 100
interdigitated fingers of tin‐coated solid copper adhered to the back of the cell, with the copper portion
of the metal fingers having a thickness of greater than 0.01 mm.
Modules incorporating rear contact cells with tin‐coated solid copper fingers.‐‐Modules with a
maximum rated power between 320 and 500 watts, inclusive, having the following characteristics: (A)
Length between 1,556 mm and 2,070 mm inclusive, and width between 1,014 mm and 1,075 mm,
inclusive, (B) where the cells comprising the module have no visible busbars or gridlines on the front of
the cells, and (C) the cells comprising the module have more than 100 interdigitated fingers of tin‐
coated solid copper adhered to the back of the cells, with the copper portion of the metal fingers having
thickness greater than 0.01 mm.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
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Low wattage.—Modules meeting one of the following eleven definitions:
(1) 10 to 60 watt, inclusive, rectangular modules, where the modules have the following characteristics:
(A) length of 250 mm or more but not over 482 mm or width of 400 mm or more but not over 635
mm, and (B) surface area of 1000 cm2 or more but not over 3,061 cm2), provided that no such
module with those characteristics shall contain an internal battery or external computer peripheral
ports at the time of entry; or
(2) 1 watt modules incorporated into nightlights that use rechargeable batteries and have the following
dimensions: 58 mm or more but not over 64 mm by 126 mm or more but not over 140 mm;
(3) 2 watt modules incorporated into daylight dimmers, that may use rechargeable batteries, such
modules with the following dimensions: 75 mm or more but not over 82 mm by 139 mm or more
but not over 143 mm;
(4) Off‐grid and portable CSPV modules, whether in a foldable case or in rigid form containing a glass
cover, where the modules have the following characteristics: (A) a total power output of 100 watts
or less per module; (B) a maximum surface area of 8,000 cm2 per module; (C) do not include a built‐
in inverter; (D) where the modules have glass covers, such modules must be in individual retail
packaging (for purposes of this provision, retail packaging typically includes graphics, the product
name, its description and/or features, and foam for transport);
(5) 3.19 watt or less modules, each with length of 75 mm or more but not over 266 mm and width of 46
mm or more but not over 127 mm, with surface area of 338 cm2 or less, with one black wire and
one red wire (each of type 22 AWG or 24 AWG) not more than 206 mm in length when measured
from module edge, provided that no such module shall contain an internal battery or external
computer peripheral ports;
(6) 27.1 watt or less modules, each with surface area less than 3,000 cm2 and coated across the entire
surface with a polyurethane doming resin, the foregoing joined to a battery charging and
maintaining unit, such unit which is an acrylonitrile butadiene styrene (“ABS”) box that incorporates
a light emitting diode (“LED”) by coated wires that include a connector to permit the incorporation
of an extension cable.
(7) Off‐grid, 45 watt or less modules, each with length not exceeding 950 mm and width of 100 mm or
more but not over 255 mm, with a surface area of 2,500 cm2 or less, with a pressure‐laminated
tempered glass cover at the time of entry but not a frame, electrical cables or connectors, or an
internal battery; or
(8) 4 watt or less modules, each with a length or diameter of 70 mm or more but not over 235 mm, with
a surface area not exceeding 539 cm2, and not exceeding 16 volts, provided that no such module
with these characteristics shall contain an internal battery or external computer peripheral ports at
the time of entry; or
(9) Modules with a maximum rated power of equal to or less than 60 watts, having the following
characteristics, provided that no such module with those characteristics shall contain an internal
battery or external computer peripheral ports at the time of entry: (A) Length of not more than 482
mm and width of not more than 635 mm or (B) a total surface area not exceeding 3,061 cm2;
(10)Flexible and semi‐flexible off‐grid modules designed for use with motor vehicles and boats, where
the modules range in rated wattage from 10 to 120 watts, inclusive; or
(11)Frameless modules in a color other than black or blue with a total power output of 90 watts or less
where the modules have a uniform surface without visible cells or busbars.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
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All Other Developing Countries.‐‐For the purposes of this questionnaire, the following countries are
considered “All Other Developing Countries” for which data are not otherwise collected separately
herein: Afghanistan, Albania, Algeria, Angola, Armenia, Azerbaijan, Belize, Benin, Bhutan, Bolivia, Bosnia
and Herzegovina, Botswana, Brazil, Burkina Faso, Burma, Burundi, Cambodia, Cameroon, Cape Verde,
Central African Republic, Chad, Comoros, Congo (Brazzaville), Congo (Kinshasa), Côte d’Ivoire, Djibouti,
Dominica, Ecuador, Egypt, Eritrea, Ethiopia, Fiji, Gabon, The Gambia, Georgia, Ghana, Grenada, Guinea,
Guinea‐Bissau, Guyana, Haiti, Iraq, Jamaica, Jordan, Kazakhstan, Kenya, Kiribati, Kosovo, Kyrgyzstan,
Lebanon, Lesotho, Liberia, Macedonia, Madagascar, Malawi, Maldives, Mali, Mauritania, Mauritius,
Moldova, Mongolia, Montenegro, Mozambique, Namibia, Nepal, Niger, Nigeria, Pakistan, Papua New
Guinea, Paraguay, Rwanda, Saint Lucia, Saint Vincent and the Grenadines, Samoa, Sao Tomé and
Principe, Senegal, Serbia, Sierra Leone, Solomon Island, Somalia, South Africa, South Sudan, Sri Lanka,
Suriname, Swaziland [Eswatini], Tanzania, Timor‐Leste, Togo, Tonga, Tunisia, Tuvalu, Uganda, Ukraine,
Uzbekistan, Vanuatu, Yemen (Republic of), Zambia and Zimbabwe.
All Other Developed Countries.—For purposes of this questionnaire, the following countries are
considered “All Other Developed Countries” for which data are not otherwise collected separately
herein: Australia, Austria, Bahamas, Bahrain, Bangladesh, Belarus, Belgium, Brunei, Chile, Croatia, Czech
Republic, Cyprus, Denmark, Estonia, Finland, France, Greece, Hong Kong, Hungary, Iceland, Iran, Ireland,
Israel, Italy, Kuwait, Latvia, Lithuania, Luxembourg, Macau, Malta, Netherlands, New Zealand, Norway,
Oman, Poland, Portugal, Qatar, San Marino, Saudi Arabia, Slovak Republic, Slovenia, Spain, Sweden,
Switzerland, United Arab Emirates, United Kingdom, and Uruguay.
All Other Countries.—For purposes of this questionnaire, “All Other Countries” are countries that are
not separately listed herein for data collection and are not included in the listing of “All Other
Developing Countries” and “All Other Develped Countries” defined above.
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,
purchaser and/or foreign producer questionnaire), you need to respond only once 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 CFR §§ 206.17(a)(1) and 206.52(c)). 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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Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
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Release of information.‐‐ The information provided by your firm in response to this questionnaire, as
well as any other confidential business 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 Trade Act of 1974 (19 U.S.C. § 2252(i)) and sections 206.17 and 206.52
of the Commission’s Rules of Practice and Procedure (19 CFR §§ 206.17(a)(1) and 206.52(c)). This means
that certain lawyers and other authorized individuals may temporarily be given access to the
information for use in connection with this proceeding or other import‐injury proceedings conducted by
the Commission on the same or similar merchandise; those individuals would be subject to severe
penalties if the information were divulged to unauthorized individuals.
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled 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.
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 are provided at the end of this questionnaire and are available upon request from
Mary Messer (202‐205‐3193, [email protected]).
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
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I‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
Public reporting burden for this questionnaire is estimated to average 20 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 them 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.
“Establishment” – Each facility of a firm in a country involved in the production or export of
CSPV cells (whether or not partially or fully assembled into other products), including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Firms operating more than one establishment in a country should combine the data for all
establishments into a single report. Multinational firms with establishments in more than one
country should submit a separate questionnaire response for each country.
I‐3.
I‐4.
Stock symbol information.‐‐ If your firm or any of the entities reported in question I‐2 are
publicly traded in the United States, please specify the stock exchange and trading symbol
(including American Depository Receipts, if applicable): .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm: .
Lead attorney(s): .
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CSPV Products (Monitoring)
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“Related firm” – A firm that your firm solely or jointly owns, manages, or otherwise controls, including
for example, parent companies, subsidiaries owned by the same parent company, and other affiliates.
I‐5.
I‐6.
I‐7.
Related producers.‐‐Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce CSPV cells or to assemble (partially or fully) CSPV cells into other
products in the United States or other countries?
No
Yes
If yes, name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire
Related U.S. importers.‐‐Does your firm or any related firm import or have any plans to import
CSPV cells (whether or not partially or fully assembled into other products) into the United
States?
No
Yes
If yes, name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.
U.S. importers.‐‐Please provide the names, contacts, email addresses, telephone numbers, and
street addresses (not P.O. boxes) of the FIVE largest U.S. importers of your firm’s CSPV cells
(whether or not partially or fully assembled into other products) in 2016.
No.
Importer’s
name
Contact
person
Email
address
Street
Area code address Share of your
(not P.O. firm’s 2016
and
telephone box), city, U.S. exports
(%)
number state, and
zip code
1
2
3
4
5
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Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
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PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Mary Messer (202‐205‐
3193, [email protected]). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of CSPV cells or the assembly (full or partial) of CSPV cells
into other products since January 1, 2012.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions/mergers/buyouts
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Technology
Other
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 12
II‐3. Anticipated changes in operations.‐‐Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of CSPV cells or the
assembly (full or partial) of CSPV cells into other products in the future?
No
II‐4.
Significance of safeguard measure.‐‐Describe the significance of the safeguard measure
imposed by the President effective on February 7, 2018, in terms of its effect on your firm’s
production, production capacity, home market shipments, exports to the United States and
other markets, and inventories. You may wish to compare your firm’s operations before and
after the imposition of the relief.
If yes, supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of business
plans or other supporting documentation that address this issue. Include in
the response a specific projection of your firm’s capacity to produce CSPV
cells and/or to assemble (fully or partially) CSPV cells into other products (in
Yes kilowatts) for 2017 and 2018.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 13
II‐5. Product shifting.
(i).
Is your firm able to switch production (capacity) between the production of CSPV cells
(including the assembly of CSPV cells into other products) and other products using the
same equipment and/or labor?
No
Yes
If yes,(i.e., your firm has produced other products or is able to produce
other products) please identify other actual or potential products
(ii).
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
(iii).
Please report any changes in the mix of your production that have ocurred since January 1,
2016 in facilities that produce CSPV cells (whether or not partially or fully assembled into
other products) and non‐scope products. In responding to this question, report: 1) the
date(s) such changes occurred; 2) the time involved to make the change; 3) the reason(s) for
the change.
II‐6.
II‐7.
Share of sales.‐‐What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of CSPV products? percent.
Estimated total production in the country identified by your firm on page 1.‐‐Please estimate the
total production of CSPV cells (in terms of quantity in kilowatts) and assembly of CSPV cells into
other products (e.g., laminates, panels, modules) (in terms of quantity in kilowatts) in the country
specified on page 1.
Estimated total production of CSPV cells in country identified on page 1 in 2018: kilowatts
Estimated total production of other products (e.g., laminates, panels, modules) partially or fully
assembled from CSPV cells in the country identified on page 1 in 2018: kilowatts
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 14
II‐8. Estimated total exports to the United States.‐‐Please estimate (in terms of kilowatts) the total
exports to the United States from all firms in the country specified on page 1.
Estimated total exports of CSPV cells to the United States in 2018 from all firms in the country
identified on page 1: kilowatts
Estimated total exports of other products (e.g., laminates, panels, modules) partially or fully
assembled from CSPV cells in 2018 from all firms in the country identified on page 1:
kilowatts
II‐9. Third country trade actions.‐‐Are the CSPV products exported by your firm subject to
antidumping duty/countervailing duty/safeguard findings, remedies, or proceedings?
No
Yes
If yes, list the products(s), countries affected, and the date of such
findings/remedies/proceedings.
II‐10. Effect of U.S. orders. Describe the significance, if any, of the existing U.S. antidumping and
countervailing duty orders on CSPV products from China and Taiwan on your firm’s production,
capacity, U.S. exports, inventories, purchases, or other indicators. You may wish to compare
your firm’s operations before or after imposition of the orders. If your response differs for
particular orders, please indicate and explain the particular effect of imposition of specific
orders.
II‐11. Other export markets.‐‐Identify export markets (other than the United States) that your firm
has developed or where it has increased its sales of CSPV products since January 1, 2016. Please
identify and discuss below.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 15
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your establishment(s), including production consumed
internally within your firm.
“Shipments” – Shipments of products produced in your establishment(s). Quantities
reported should be net of returns.
“Home market commercial shipments” – Shipments, other than internal consumption and
transfers to related firms in the market in which your establishments are located.
“Home market internal consumption/transfers to related firms” – Shipments made to
related firms in the market in which your establishments are located, including product
consumed internally by your firm, including CSPV cells used to assemble other CSPV products,
such as modules, panels, and laminates.
“Export shipments” – Shipments to destinations outside the country indicated on page 1,
including shipments to related firms.
“Inventories” – Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 16
II‐12. CSPV Cells.‐‐Since January 1, 2016, has your firm produced CSPV cells?
No
Yes‐‐Please complete questions II‐13 (CSPV cells in kilowatts). Also, indicate
below the type of cell for which data are being reported in this questionnaire
and provide an explanation concerning any product mix changes that have
occurred since January 1, 2016.
Check type of cell for which data are reported in this questionnaire. Check all that apply.
Mono cells
Multi cells
PERC cells
HIT cells
Bifacial cells
Other hybrid cells (please describe cell)
If checked, please provide explanation of any product mix changes since January 1, 2012.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 17
II‐13. Trade data.‐‐Report your firm’s production capacity, production, shipments, and inventories
related to the production of CSPV cells in your establishment(s) during the specified periods. In
this question, do not include resales of CSPV cells that your firm did not produce; data on such
resales of CSPV cells that your firm did not produce, to the degree they are exported to the United
States, should only be reported in question II‐15. Do not submit data by manufacturing facility if
the manufacturing facilities are in the same country. If your firm has multiple manufacturing
establishments within one country, you are required to combine data for those establishments
within one foreign producer questionnaire response. Do not submit data on multiple countries
combined. The establishments reported here should all be located in the country of the firm’s
address reported on page 1. Multinational companies with production in multiple countries
should submit separate foreign producer questionnaire responses for each country.
CELLS
Quantity (in kilowatts)
Projections1
Actual Experience
Calendar year
Item
2016
2
2017
January‐June
2018
2018
Calendar year
2019
2019
2020
Average production capacity (A)
Beginning‐of‐period inventories (B)
Production:
Bifacial (quantity) (C)3
Rear contact cells with tin‐
coated solid copper fingers
(quantity) (D)2
All other cells (quantity) (E)
0
0
0
0
0
0
0
Total cell production
Home market shipments:
Internal consumption/ transfers
to related firms (F)
Commercial home market
shipments (G)
Export shipments:
to the United States (H)
to Canada (I)
to Mexico (J)
4
to EU markets (K)
to all other markets5 (L)
Total exports
0
0
0
0
0
0
0
Total shipments
0
0
0
0
0
0
0
End‐of‐period inventories (M)
1
Please explain the basis for your firm’s projections. .
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity and explain any changes in reported capacity: .
3
See definitions on pages 5‐7.
4
Identify your firm’s principal EU export markets: .
5
Identify your firm’s principal other export markets: .
2
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
II‐13. Trade data.—Continued.
Page 18
CELLS
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported
for the end‐of‐period inventories (i.e., line M) should be equal to the beginning‐of‐period
inventories (i.e., line B), plus production (i.e., lines C, D, and E), less total shipments (i.e., lines F,
G, H, I, J, K, and L). 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.
Actual experience
Calendar year
Item
B + C + D + E – F – G –
H – I – J – K – L – M =
should equal zero
("0") or provide an
explanation.1
1
2016
2017
0
January‐June
2018
0
Projections
2018
0
Calendar year
2019
0
2019
0
2020
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 19
II‐14. Trade data.‐‐Report your firm’s production capacity, production, shipments, and inventories related to
the production of CSPV modules in your establishment(s) during the specified periods. Do not include
resales of CSPV modules that your firm did not produce; those data to the degree they are exported to
the United States should only be reported in question II‐15. Do not submit data by manufacturing
facility if the manufacturing facilities are in the same country. If your firm has multiple manufacturing
establishments within one country, you are required to combine data for those establishments within
one foreign producer questionnaire response. Do not submit data on multiple countries combined. The
establishments reported here should all be located in the country of the firm’s address reported on the
certification page. Multinational companies with production in multiple countries should submit
separate foreign producer questionnaire responses for each country. For purposes of II‐14, report data
for your firm’s operations related to the assembly of modules, regardless of the source of the cell.
MODULES
Quantity (in kilowatts)
Projections1
Actual Experience
Calendar year
Item
2016
2
2017
January‐June
2018
2018
Calendar year
2019
2019
2020
Average production capacity (N)
Beginning‐of‐period inventories (O)
Production of modules
incorporating:
Bifacial (quantity) (P)3
Light‐directing film (quantity)
(R)3
Rear contact cells with tin‐
coated solid copper fingers
(quantity) (S)3
0
0
0
0
0
0
0
to Canada (Y)
to Mexico (Z)
to EU markets (AA)
5
Total exports (quantity)
0
0
0
0
0
0
0
Total shipments (quantity)
0
0
0
0
0
0
0
Flexible fiberglass (quantity) (Q)
Low wattage (quantity) (T)
3
All other (quantity) (U)
Total, production
Home market shipments:
Internal consumption/transfers
to related firms (V)
Commercial home market
shipments (W)
Export shipments:
to the United States (X)
4
to all other markets (AB)
End‐of‐period inventories (AC)
3
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
II‐14. Trade data.—Continued.
Page 20
MODULES
Footnotes continued.
1
Please explain the basis for your firm’s projections. .
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity and explain any changes in reported capacity: .
3
See definitions on pages 5‐7.
4
Identify your firm’s principal EU export markets: .
5
Identify your firm’s principal other export markets: .
2
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line AC) should be equal to the beginning‐of‐period inventories (i.e., line
O), plus production (i.e., lines P through U), less total shipments (i.e., lines V through AB). 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.
Actual experience
Calendar year
Item
O + P + Q + R + S + T +
U – V – W – X – Y – Z –
AA – AB – AC = should
equal zero ("0") or
provide an
explanation.1
1
2016
2017
0
January‐June
2018
0
Projections
2018
0
Calendar year
2019
0
2019
0
2020
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 21
II‐15. Exports to the United States not produced by your firm.‐‐Report your firm’s exports to the
United States of CSPV cells and CSPV modules that were produced in the country identified on
page one of this response but not by your firm during the specified periods. Note these data
should not be included in questions II‐13 and II‐14.
Quantity (in kilowatts)
Actual experience
Projections
Calendar year
Item
Exports to the United
States not produced by
your firm:
Cells1
2018
2018
2019
2019
2020
Modules
List the producer(s) of the cells.
2
List the producer(s) of the modules.
1
2017
Calendar year
2
2016
January‐June
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 22
II‐16. Source of cells used in modules exported to the United States.‐‐If your firm reported exports of
modules to the United States in line (U) in question II‐14, please indicate below the four largest
country sources of CSPV cells for those modules and the quantity (in kilowatts) of cells from
that country source in the indicated period. If the country source of your CSPV cells changed
from one period to the next, please explain.
Calendar year
January‐June
Source of CSPV Cells
2016
2017
2018
2018
2019
Quantity (in kilowatts)
Exports of modules using CSPV
cells made in.‐‐1
Canada (AD)
China (AE)
Germany (AF)
India (AG)
Indonesia (AH)
Japan (AI)
Korea (AJ)
Malaysia (AK)
Mexico (AL)
Philippines (AM)
Singapore (AN)
Taiwan (AO)
Thailand (AP)
Turkey (AQ)
Vietnam (AR)
All other developing
countries2 (AS)
All other developed
countries3 (AT)
All other countries4 (AU)
0
0
0
0
0
Total
1
Explanation for any change in the country source of CSPV cells from one period to the next:
See definition on page 7. Please list other developing countries for which data were reported:
3
See definition on page 7. Please list other developed countries for which data were reported:
4
See definition on page 7. Please list the other countries for which data were reported:
2
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 23
II‐16. Source of cells used in modules exported to the United States.‐‐Continued.
RECONCILIATION OF EXPORTS TO THE UNITED STATES.‐‐The data reported in item II‐15 (lines AD
through AU) should be equal to the quantity of exports to the United States (line X).
Actual experience
Calendar year
Item
2016
2017
January‐June
2018
2018
2019
AD + AE + AF + AG + AH + AI +
AJ + AK + AL + AM + AN + AO
+ AP + AQ + AR + AS + AT +
AU ‐ X = should equal zero
("0"), if not, revise
0
0
0
0
0
II‐17. Home market competition.‐‐Does your firm compete with imports of CSPV cells (whether or not
partially or fully assembled into other products) in your home market?
No
Yes‐‐Indicate and explain below the trend in your firm’s home market
competition with imports since January 1, 2016.
Decreased Increased Constant Fluctuated
Explanation for trend
II‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 24
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 USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire –
CSPV Products (Monitoring)
Page 25
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/title_7/2019/crystalline_silicon_photovoltaic_cell
s_whether_or/safeguard.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: CSPV
• E‐mail.‐‐E‐mail the MS Word questionnaire to Mary Messer ([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 their 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 produce or export CSPV cells (whether or not partially or fully assembled into
other products), 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 C.F.R. § 206.17). A list of such parties may be obtained from the Commission’s Secretary
(202‐205‐1803). A certificate of service must accompany the completed questionnaire you submit (see
19 C.F.R. § 206.17). Service of the questionnaire must be made in paper form.
File Type | application/pdf |
File Title | Microsoft Word - Foreign producers--Solar panels (201)(Monitoring) |
Author | mary.messer |
File Modified | 2019-08-20 |
File Created | 2019-08-20 |