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pdfOMB No. 3117-0016/USITC No. 19-1-4097; Expiration Date: : 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
ACETONE FROM BELGIUM, KOREA, SINGAPORE, SOUTH AFRICA, AND SPAIN
This questionnaire must be received by the Commission by September 3, 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 antidumping investigations concerning acetone from Belgium, Korea, Singapore, South Africa, and
Spain Inv. No. 731-TA-1435-1436 and 1438-1440 (Final)). The information requested in the questionnaire is requested
under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result
in a subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).
Name of firm
Address
____________________________________
________________________________________________________
City
State
Zip Code
Website
Has your firm produced acetone (as defined on next page) at any time since January 1, 2016?
NO (Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES (Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: ACET)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my knowledge
and belief and understand that the information submitted is subject to audit and verification by the Commission. By means of this
certification I also grant consent for the Commission, and its employees and contract personnel, to use the information provided in
this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by the Commission on the
same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C. Appendix
3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all contract
personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official
Signature
Title of Authorized Official
Phone
Date
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Acetone (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on February 19, 2019, by
AdvanSix Inc., Parsippany, New Jersey, Altivia Petrochemicals, LLC, Haverhill, Ohio, and Olin Corporation,
Clayton, Missouri. 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 dumping. Questionnaires and other information pertinent to this proceeding are
available at:
https://www.usitc.gov/investigations/701731/2019/acetone_belgium_korea_saudi_arabia_singapore_s
outh/final.htm
Acetone covered by this investigations is acetone of all grades of liquid or aqueous acetone. Acetone is
also known under the International Union of Pure and Applied Chemistry (“IUPAC”) name propan-2-one.
In addition to the IUPAC name, acetone is also referred to as ß-ketopropane (or “beta-ketopropane”),
ketone propane, methyl ketone, dimethyl ketone, DMK, dimethyl carbonyl, propanone, 2-propanone,
dimethyl formaldehyde, pyroacetic acid, pyroacetic ether, and pyroactic spirit. Acetone is an isomer of
the chemical formula C3H6O, with a specific molecular formula of CH3COCH3 or (CH3)2CO.
The scope includes acetone that is combined or mixed with other products, including, but not limited to,
benzene, diethyl ether, methanol, chloroform, and ethanol. For such combined products, only the
acetone component is covered by the scope of these investigations. Acetone that has been combined
with other products is included within the scope, regardless of whether the combining occurs in third
countries.
Acetone that is otherwise subject to these investigations is not excluded when commingled with
acetone from sources not subject to these investigations. Only the subject merchandise component of
such commingled products is covered by the scope of these investigations. The Chemical Abstracts
Service (“CAS”) registry number for acetone is 67-64-1.
The merchandise covered by these investigations is currently classifiable under Harmonized Tariff
Schedule of the United States (“HTSUS”) subheadings 2914.11.1000 and 2914.11.5000. Although these
HTSUS subheadings and CAS registry number are provided for convenience and customs purposes, the
written description of the scope of these investigations is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
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.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 3
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
I-1a.
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful, and
as limited as possible. Public reporting burden for this questionnaire is estimated to average 50
hours per response, including the time for reviewing instructions, gathering data, and completing
and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this questionnaire. Please attach such comments
to your response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC
20436.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
I-1b.
TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
I-2a.
Page 4
No
Establishments’ covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of acetone, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 5
I-2b.
Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.
I-2c.
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):
I-3.
Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
.
Yes
Petition support.--Does your firm support or oppose the petition?
Country
Belgium
Korea
Singapore
South Africa
Spain
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
I-5.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-6.
Page 6
Yes--List the following information.
Country
Extent of
ownership
(percent)
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing acetone from Belgium, Korea, Singapore, South Africa
and/or Spain into the United States or that are engaged in exporting acetone from Belgium,
Korea, Singapore, South Africa and/or Spain to the United States?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
I-7.
Page 7
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of acetone?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 8
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Abu B. Kanu (202-205-2597,
[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 also indicate whether each identified change was a result of a
decision based on acetone market conditions or based on phenol market conditions.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
Weather related event(s) /
force majeure events(s)
other (e.g., technology)
(If checked, please describe; leave blank if not
applicable)
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-3a.
Page 9
Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce acetone, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-9. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-9 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in short tons)
Calendar years
Item
Overall production capacity
2016
2017
January-June
2018
2018
2019
1
Production of:
Acetone2
0
0
0
0
0
0
0
0
0
0
Co- or by-products of
acetone production (e.g.,
phenol)
Other, alternative
products3
Total production using
same machinery or
workers
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of acetone will populate here once reported in question II-9.
3
Please identify these products:
.
2
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week
Weeks per year
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 10
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity (including, if applicable, constraints relating to the storage of finished goods)..
II-3e.
Product shifting.—
(i)
Is your firm able to switch production (capacity) between acetone and other (i.e.,
alternative) products using the same equipment and/or labor?
No
(ii)
Yes
If yes—(i.e., have produced other than co-/by-products or are able to
produce other products) Please identify other actual or potential
products.
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-3f.
Production process.--Please indicate the production process your firm uses to produce acetone.
Process
Cumene process
IPA dehydration process
Fischer-Tropsch synthesis process
Other process1
1
II-3g.
Page 11
Check one
Describe the process your firm uses:
Acetone vs phenol ratio.--If your firm reported co-/by-product (phenol) production in II-3a,
what was the average ratio of acetone production to the co-/by-products (phenol) production
your firm achieved over the January 2016 through June 2019 period?
percent (acetone to
phenol).
Also was there variability in this ratio of primary product (acetone) to co-/by-product (phenol)
production over the period?
No
II-4.
Yes
If yes--Please describe the range in the ratio and how it changed over the
January 2016 through June 2019 period, and indicate to what degree this
variability was controlled by your firm.
Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of acetone?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-5.
Page 12
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce acetone in and/or admit acetone into a
foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.
No
(b)
If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import acetone into a foreign trade zone (FTZ) for use in distribution of acetone and/or
the production of downstream articles?
No
II-6a.
Yes
Yes
If yes--Identify the firms and the FTZs.
Production decisions.--If your firm is a by-/co-product producer, indicate which product
primarily drives your firm’s production decisions for acetone (check only one option)
and describe the primary factors involved in the production decision(s).
Solely
acetone
Primarily
acetone
Equally
acetone and
phenol
Primarily
phenol
Please describe the factors driving the production decision(s).
Solely
phenol
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-7.
Page 13
Storage capacity.--Report the total storage capacity (i.e., both owned and leased, including
barges) associated with your firm’s acetone and phenol operations at the end of the specified
period (i.e., December 31)?
Quantity (in short tons)
Calendar years ended (December 31)-Item
2016
2017
2018
Acetone Storage Capacity
Owned
Leased1
Total
0
0
Phenol Storage Capacity
0
2
Owned
Leased3
Total
Total Storage Capacity
0
0
0
0
0
0
1
Please report the name of the firm(s) from which you leased acetone storage capacity:
Can your firm's phenol storage capacity be switched to acetone storage capacity with minimal to
no capital investment or retooling?
Yes.
No. If no, please describe the amount of time,
money, and effort that would be required to convert your firm's phenol storage capacity to acetone
storage capacity:
.
3
Please report the name of the firm(s) from which you leased phenol storage capacity:
2
II-8a.
Storage expansion decisions.--Please report any periods during which your firm was required to
purchase or lease additional storage capacity for your acetone operations since January 1, 2016.
In your response, please identify the date the new capacity was required, the volume of that
new capacity, your reasons for adding capacity in that time period, and whether the decision to
add storage capacity was affected by (or affected) acetone prices.
Occurrence
Storage capacity
expansion (short
tons)
Date of
expansion
Description
First
Second
Third
All subsequent expansions
II-8b.
Discounted sales in lieu of storage expansions.--Please report instances when your firm decided
to sell acetone at a discount in order to free up storage capacity for additional acetone storage
since January 1, 2016. In your response, please identify the date of the discounted sales and the
amount of the discount provided.
Occurrence
First
Discounted
quantity sold
(short tons)
Date of
discounted
sale
Description
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 14
Second
Third
All subsequent expansions
II-8c.
Inventories exceeding 90 percent of storage capacity.--Report the share of the specified period
that your firm maintained inventory levels of acetone in excess of 90 percent of your firm's
acetone's storage capacity (i.e., a 75 percent would mean that your firm maintained inventories
at levels at or above 90 percent of your firm's acetone storage capacity in approximately 273 out
of 365 days in the period).
Calendar year
Item
2016
2017
Share of the period (percent)
>= 90 percent of capacity
2018
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 15
Select definitions
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-9.
Page 16
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of acetone in its U.S. establishment(s)
during the specified periods.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2016
2017
January-June
2018
2018
2019
1
Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different basis
for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data
provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus production
(i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data
entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide explanations for
any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
2016
2017
0
January-June
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
0
.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-10.
Page 17
Channels of distribution.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
U.S. shipments
2016
2017
January-June
2018
2018
2019
To distributors:
Quantity (M)
Value (N)
To end users:
Quantity (O)
Value (P)
RECONCILIATION OF CHANNELS.--Please ensure that the quantity and value reported for channels of
distribution (i.e., lines M through P) in each time period equal the quantity and value reported for U.S.
shipments (i.e., lines D through I) in each time period in question II-9. If the calculated fields below return
values other than zero (i.e., “0”), the data reported must be revised prior to submission to the
Commission.
Calendar years
Reconciliation
2016
2017
January-June
2018
2018
2019
Quantity: M + O - D - F - H= zero
("0"), if not revise.
0
0
0
0
0
Value: N + P - E - G - I= zero ("0"), if
not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-11.
Page 18
US shipments by type.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) in 2018 by product type.
Quantity (in short tons)
U.S. shipments
Calendar year 2018
Benzene free acetone.-Standard / technical grade (Q)
Specialty grades (e.g., low water, NF grade) (R)
Other acetone.-Standard / technical grade (S)
Specialty grades (e.g., low water, NF grade) (T)
RECONCILIATION OF SHIPMENTS BY TYPE.--Please ensure that the quantity reported for
shipments by type (i.e., lines Q through T) in this question equal the quantity reported
for U.S. shipments (i.e., lines D, F, and H) in 2018 in question II-10. If the calculated
fields below return values other than zero (i.e., “0”), the data reported must be revised
prior to submission to the Commission.
Reconciliation
Q + S - D - F - H= zero ("0"), if not revise.
Calendar year 2018
0
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-12.
Page 19
Employment data.--Report your firm’s employment-related data to the production of acetone
and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations. Average number employed may be computed by adding the
number of employees, both full time and part time, for the 12 pay periods ending closest to the
15th of the month and divide that total by 6. For the January to June periods, calculate similarly
and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2016
2017
January-June
2018
2018
2019
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II-13.
Joint PRWs.--Are any PRWs above also involved in the production of phenol? If yes, please
describe how has impacted the reported employment data relating to acetone above.
No
II-14.
Yes
If yes, please describe
Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-15.
Page 20
Purchases. -- Has your firm purchased acetone produced in the United States or in other
countries since January 1, 2016? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in short tons)
Calendar years
Item
2016
2017
January-June
2018
2018
2019
1
Purchases from U.S. importers of
acetone from—
Belgium
Korea
Singapore
South Africa
Spain
All other sources
Purchases from domestic producers2
Purchases from other sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
II-16.
Page 21
Imports.--Since January 1, 2016, has your firm imported acetone?
No
Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II-17.
Import inquiries.--Since January 1, 2016, has your firm made purchase inquires to foreign
acetone producers that did not result in a purchase?
No
II-18.
Yes
If yes--Report the timing of such inquiries and the reasons for your firm's
initial inquiries.
Other explanations.--If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 22
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Samuel Varela-Molina (202-205-3429,
[email protected]).
III-1.
Contact information.-- Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III-2.
Accounting system.--Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include acetone:
2.
Does your firm prepare profit/loss statements for acetone:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)
3.
4.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes acetone, as well as
specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 23
III-4.
Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III-5.
Product listing.--Please list the products your firm produced in the facilities in which your firm
produced acetone, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
Share of sales
Acetone
%
Phenol
%
%
%
%
%
III-6.
Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of acetone from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes--Continue to question III-7
III-7.
No--Continue to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
acetone that your firm purchases from related suppliers and that are reflected in question III-9d.
For “Share of total COGS” please report this information by relevant input on the basis of your
most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
III-8.
Page 24
Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9d (financial results on acetone) in a
manner consistent with your firm’s accounting books and records.
Yes
No
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.
III-9a. Co-products or by-products.--Does your firm's production process for acetone result in the
production of additional chemicals that are commercially sold?
No
Accounting
treatment of
non-acetone
products
Yes
If yes--Please identify the other (non-acetone) coproducts or by-products.
Co-products
By-products
III-9b. Co-product cost allocations.--If your firm reported co-product(s) in III-9a, please describe the
major shared costs between acetone and its co-products, and describe how those costs are
apportioned between acetone and the co-product(s).
III-9c.
(i) By-product revenue.-- If your firm reported yes to by-product accounting treatment in III-9a,
report your firm’s total by-product sales revenue, net of relevant processing costs, associated
with the acetone products operations of your U.S. establishment(s). Provide data for the three
most recently completed fiscal years, and for the specified interim periods. Note: the data
provided below will appear in question III-9d as a reduction to COGS.
Value (in $1,000)
Fiscal years ended-Item
By-product sales revenue
2016
2017
January-June
2018
2018
2019
1
1
Please describe how your firm classifies these by-product revenues in the normal course of business (e.g.,
included in net sales values, as a reduction to COGS, included in “all other income”).
.
III-9c.
(ii) Phenol revenue.-- Report your firm’s total phenol sales revenue of your U.S.
establishment(s). Provide data for the three most recently completed fiscal years, and for the
specified interim periods.
Value (in $1,000)
Fiscal years ended-Item
Phenol sales revenue
2016
2017
January-June
2018
2018
2019
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U.S. Producers’ Questionnaire - Acetone (Final)
Page 25
III-9d. Operations on acetone.--Report the revenue and related cost information requested below on
the acetone operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that internal consumption and transfers to related firms must be valued at fair market
value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three
most recently completed fiscal years, and for the specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item
2016
2017
January-June
2018
2018
2019
quantities:2
Net sales
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
values:2
Net sales
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
(COGS):3
Cost of goods sold
Raw materials (from III-9f)4
Direct labor
Other factory costs
Less: By-product revenue (from III-9b)
0
0
0
0
0
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 Data on raw material costs will populate here once reported in question III-9f.
2
Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire - Acetone (Final)
Page 26
III-9e. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes
III-9f.
No
If no-- If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative--instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
Raw materials.- Report the raw materials costs related to your firm's sales of acetone in the
specified periods by method of production and sourcing of material inputs.
Fiscal years ended-Item
2016
2017
January-June
2018
2018
2019
Production using Cumene process
Purchased/imported cumene
Internally produced cumene.—
Benzene
Propylene
Other inputs1
Other material inputs2
Production using IPA (or other) process
Isopropyl alcohol
Other material inputs3
Total raw materials
0
0
0
0
0
1
List other material inputs into your firm's internally produced cumene:
.
2
List other material inputs in addition to cumene used in your firm's acetone production:
.
3
List other material inputs in addition to isopropyl alcohol used in your firm's acetone production:
.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 27
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9d, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9d line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9d; i.e., if an aggregate nonrecurring item has been allocated to
question III-9d, only the allocated value amount included in question III-9d should be reported in
the schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9d.
Fiscal years ended-2016
Item
2017
January-June
2018
2018
2019
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9d where the nonrecurring item is classified.
Item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Description of the
nonrecurring item
Income statement classification of the nonrecurring
item
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 28
III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9d.
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of acetone. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for acetone in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9d. Provide data as
of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period (e.g., due to asset write-offs, revaluation, and major purchases) as well
as a brief explanation of any allocation methodologies used for assets used in co-production.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1
III-13.
2016
2017
2018
1
Describe
Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for acetone. Provide data for your firm’s
three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended--
Item
2016
2017
January-June
2018
2018
2019
Capital expenditures1
Research and development expenses2
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product,
as well as a brief explanation of any allocation methodologies used for capital expenditures covering both subject
product and any co-product(s).
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product, as
well as a brief explanation of any allocation methodologies used for research and development expenses
covering both subject product and any co-product(s).
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 29
III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9d, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III-9d should reconcile with the data
reported in question II-9 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended-Reconciliation
2016
2017
January-June
2018
2018
2019
Quantity: Trade data from question II-9
(lines D, F, H, and J) less financial total
net sales quantity data from question III9d, = zero ("0").
0
0
0
0
0
Value: Trade data from question II-9
(lines E, G, I, and K) less financial total
net sales value data from question III-9d,
= zero ("0").
0
0
0
0
0
Do these data in question III-9d reconcile with data in question II-9?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 30
If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2016, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of acetone from Belgium, Korea, Singapore, South Africa and/or Spain?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 31
III-16. Effects of imports on growth and development.--Since January 1, 2016, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of acetone from Belgium, Korea, Singapore, South
Africa and/or Spain?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
acetone from Belgium, Korea, Singapore, South Africa and/or Spain?
No
Yes
If yes, my firm anticipates negative effects as follows.
III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 32
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
IV-1.
Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
PRICE DATA
IV-2.
This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products produced by your
firm.
Product 1.--Standard grade acetone, sold in bulk to distributors, spot/short-term contract sales.
Product 2.--Standard grade acetone, sold in bulk to distributors, annual/long-term contract sales.
Product 3.--Standard grade acetone, sold in bulk to end users, spot/short-term contract sales.
Product 4.--Standard grade acetone, sold in bulk to end users, annual/long-term contract sales.
For purposes of these pricing products, “bulk” shipments are full-barge, railcar, or tanker truck
containers. “Short-term contracts” are less than 12 months in duration, and “annual/long-term”
contracts are for 12 months or longer.
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV-2a. During January 2016-June 2019, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question IV-3.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 33
IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in short tons and actual dollars (not 1,000s).
Product 1
Quantity
Value
(Quantity in short tons, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
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 Pricing product definitions are provided on the first page of Part IV.
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:
Product 4:
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U.S. Producers’ Questionnaire - Acetone (Final)
Page 34
IV-2c. Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
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 sale occurred?
Less than reported commercial shipments in part II in each year?
IV-2d.
Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
IV-3.
Price setting.
(a) How does your firm determine the prices that it charges for sales of acetone (check all that
apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
Set
price
lists
Published
benchmark/
price (e.g.
large buyer
price, RGP)
Other
If other, describe
(b) If your firm determines acetone prices by reference to the large buyer price or other
benchmark, or published RGP or other raw material price, please indicate how the discount
or multiplier is determined.
(c) Has the discount or multiplier from published prices for acetone changed since January 1,
2016?
No
Yes
If yes, please describe the changes.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
IV-4.
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV-5.
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Pricing terms.-- On what basis are your firm’s prices of domestic acetone usually quoted (check
one)?
Delivered
IV-6.
Page 35
F.o.b.
If f.o.b., specify point
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
acetone in each specified period was on a (1) short-term contract basis, (2) annual contract
basis, (3) long-term contract basis, and (4) spot sales?
Share of sales
in
Short-term
contracts
(multiple
deliveries for
less than 12
months)
Annual
contracts
(multiple
deliveries for 12
months)
Type of sale
Long-term
contracts
(multiple
deliveries for
more than 12
months)
Spot sales
(for a single
delivery)
Total (Each row
should sum to
100.0%)
2016
%
%
%
%
0.0
%
2017
%
%
%
%
0.0
%
2018
%
%
%
%
0.0
%
January-June
2019
%
%
%
%
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
IV-7.
Page 36
Contract provisions.
(a) Please fill out the table regarding your firm’s typical sales contracts for U.S.-produced acetone
(or check “not applicable” if your firm does not sell on a short-term, annual and/or long-term
contract basis).
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long-term contracts
(multiple deliveries
for more than 12
months)
365
No
Quantity
Fixed quantity
and/or price
Price
Both
Indexed to raw
material costs1
Yes
No
Not applicable
1
Please identify the indexes used:
IV-8.
Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced acetone?
Source
Share of 2018 sales
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0
%
Lead time (Average
number of days)
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U.S. Producers’ Questionnaire - Acetone (Final)
IV-9.
Page 37
Shipping information.-(a)
What is the approximate percentage of the cost of U.S.-produced acetone 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)
Does your firm generally recover transportation expenses through additives to the price
(e.g. “prepaid & add”)?
Yes
No (check one)
(d)
Indicate the approximate percentage of your firm’s sales of acetone that are delivered
the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0
%
IV-10. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced acetone since January 1, 2016 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
√ if applicable
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
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IV-11. End uses.--List the end uses of the acetone that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by acetone and other inputs?
Share of total cost of end use product
accounted for by
End-use product
Acetone
Other inputs
Total
(should sum to
100.0% across)
MMA
%
%
0.0 %
BPA
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-12. Substitutes.-- Can other products be substituted for acetone, either directly or in downstream
uses (e.g. production methods of MMA, BPA, or other downstream products, that do not use
acetone)?
No
Substitute
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 acetone?
No Yes
Explanation
1.
2.
3.
IV-13. Demand trends.-- Indicate how demand within the United States and outside of the United
States for acetone and phenol has changed since January 1, 2016. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Acetone demand within
the United States
Acetone demand outside
the United States
Phenol demand within
the United States
Phenol demand outside
the United States
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Don’t
know
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 39
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of acetone since January 1, 2016?
No
Yes
If yes, please describe and quantify if possible.
IV-15. Conditions of competition.-(a) Is the acetone market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to acetone? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV-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
acetone since January 1, 2016?
No
Yes
If yes, describe.
(c) Have business cycles or conditions of competition of phenol affected the business cycles
or conditions of competition for acetone since January 1, 2016?
No
Yes
If yes, describe.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 40
IV-16. Supply constraints.—
(a) Has your firm refused, declined, or been unable to supply acetone since January 1, 2016
(including an inability to supply the total volume requested formally or informally for the
following calendar year)? (Examples include placing customers on allocation or “controlled
order entry,” declining to accept new customers or renew existing customers, declining to
supply the quantity of acetone requested by new or existing customers seeking to commit
volume for annual requirements, delivering less than the quantity promised, being unable to
meet timely shipment commitments, force majeure, etc.)
No
Yes
If yes, please describe in detail, including the dates, customers, and
quantities of acetone involved.
(b) Since January 1, 2016, have weather-related events or plant closures (including the timing of
closure announcements versus actual closures) affected the overall supply of U.S.-produced
acetone in the U.S. market?
No
Yes
If yes, please describe, noting the specific events, and dates that the
market was affected.
IV-17. Raw materials.--How have acetone raw material prices changed since January 1, 2016?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for
acetone.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 41
IV-18. Interchangeability.--Is acetone 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
Belgium
Korea
Singapore
South Africa
Spain
Other countries
United States
Belgium
Korea
Singapore
South Africa
Spain
For any country-pair producing acetone that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 42
IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between acetone 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
Belgium
Korea
Singapore
South Africa
Spain
Other countries
United States
Belgium
Korea
Singapore
South Africa
Spain
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of acetone, identify the country-pair and report the advantages or
disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 43
IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for acetone since January 1, 2016. Indicate the share of the quantity of your firm’s
total shipments of acetone that each of these customers accounted for in 2018.
Customer’s name
1
2
3
4
5
6
7
8
9
10
City
State
Share of 2018 sales
(%)
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
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IV-21. Competition from imports.-(a)
Lost revenue.--Since January 1, 2016: To avoid losing sales to competitors selling
acetone from Belgium, Korea, Singapore, South Africa and/or Spain, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2016: Did your firm lose sales of acetone to imports of this
product from Belgium, Korea, Singapore, South Africa and/or Spain?
No
Yes
IV-22. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire - Acetone (Final)
Page 45
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/acetone_belgium_korea_saudi_arabia_singapore_s
outh/final.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: ACET
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Modified | 2019-08-01 |
| File Created | 2019-08-01 |