Form 19-1-4125 U.S. producers' questionnaire

OMB No. 3117-0016/USITC No. 19-1-4125; Expiration Date : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
Small Diameter Graphite Electrodes from China
This questionnaire must be received by the Commission by November 8, 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 review of the antidumping duty order concerning small diameter graphite electrodes from China
(Inv. No. 731-TA-1143 (Second Review)). 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 small diameter graphite electrodes (as defined on the next page) at any time since
January 1, 2014?

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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: ELECT)
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 or reviews
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

Title of Authorized Official

Date

Signature

Phone

Email address

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

Page 2

PART I.—GENERAL INFORMATION
Background.--On February 26, 2009, the Department of Commerce (“Commerce”) issued an
antidumping duty order on imports of small diameter graphite electrodes from China. On May 1, 2019,
the Commission instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. §
1675(c)) (the Act) to determine whether revocation of the order would be likely to lead to continuation
or recurrence of material injury to the domestic industry within a reasonably foreseeable time. If both
the Commission and Commerce make an affirmative determination, the order will remain in place. If
either the Commission or Commerce makes a negative determination, Commerce will revoke the order.
Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2019/small_diameter_graphite_electrodes_china/second
_review_full.htm.
Small diameter graphite electrodes covered by this review are: (A)II small diameter graphite electrodes
of any length, whether or not finished, of a kind used in furnaces, with a nominal or actual diameter of
400 millimeters (16 inches) or less, and whether or not attached to a graphite pin joining system or any
other type of joining system or hardware. The merchandise covered by the order also includes graphite
pin joining systems for small diameter graphite electrodes, of any length, whether or not finished, of a
kind used in furnaces, and whether or not the graphite pin joining system is attached to, sold with, or
sold separately from, the small diameter graphite electrodes. Small diameter graphite electrodes and
graphite pin joining systems for small diameter graphite electrodes are most commonly used in primary
melting, ladle metallurgy, and specialty furnace applications in industries including foundries, smelters,
and steel refining operations. Small diameter graphite electrodes and graphite pin joining systems for
small diameter graphite electrodes that are subject to the order are currently classified under the
Harmonized Tariff Schedule of the United States (HTSUS) 8545.11.0010, 3801.10, and 8545.11.0020. The
HTS statistical reporting numbers are provided for convenience and customs purposes, but written
description of the scope is dispositive.
Reporting of information.--If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your files, worksheets, and
supporting documents used in the preparation of the questionnaire response. Please also retain a copy
of the final document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the

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Page 3

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-1.

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.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
I-2a.

Page 4

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. 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 small diameter graphite
electrodes, 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:

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.

.

Position regarding continuation of order.--Does your firm support or oppose continuation of
the following antidumping duty order currently in place for small diameter graphite electrodes?
Country
China

Support

Oppose

Take no position

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
I-4.

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

Firm name

I-5.

Page 5

Yes--List the following information, relating to the ultimate parent/owner.

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing small diameter graphite electrodes into the United States
or that are engaged in exporting small diameter graphite electrodes to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
I-6.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of small diameter graphite electrodes?
No

Yes--List the following information.

Firm name

I-7.

Page 6

Country

Affiliation

Business plan.--In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for small diameter
graphite electrodes?

No

Yes

If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Nitin Joshi (202-708-1669,
[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-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of small diameter graphite electrode since January 1,
2014.

Check as many as appropriate.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)

If checked, please describe; leave blank if not
applicable.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
II -2b

Anticipated changes in operations.—Does your firm anticipate any changes in in the character
of its operations or organization relating to the production of small diameter graphite electrodes
in the future?

No

II-3a.

Page 8

Yes

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 documentations that
address this issue.

Production using same machinery.-- Please report your firm’s production of products made
using the same equipment, machinery, or employees as used to produce small diameter
graphite electrodes, 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-7. 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-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
II-3a.

Page 9

Production using same machinery.—Continued
Quantity (in metric tons)
Calendar years
Item

Overall production capacity

2016

2017

January-September
2018

2018

2019

1

Production of:
Small diameter graphite
electrodes.—
Less than 14 inches in diameter
14 – 16 inches in diameter
All in-scope small diameter
graphite electrodes

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Out-of-scope production.-Large diameter graphite
electrodes less than 20 inches in
diameter
Large diameter graphite
electrodes greater than or equal
to 20 inches in diameter
Other products2
Subtotal, out-of-scope
production
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).
2
Please identify these products:
.

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week

Weeks per year

II-3c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.

II-3d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

II-3e.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between small diameter graphite
electrodes and other products using the same equipment and/or labor?

No

(ii)

II-3f.

Page 10

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

Does your firm convert unfinished.— Small diameter graphite electrodes (purchased or
imported by your firm) into further finished small diameter graphite electrodes?
No

Yes

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

II-3g.

Page 11

Finishing only operations.--Since January 1, 2014, has your firm purchased or imported small
diameter graphite electrodes covered by the investigations (either domestic or imported) and
conducted further finishing only operations on those purchases, resulting in a product that still
matches the definition of small diameter graphite electrodes?

No

Yes

If yes—Please describe the nature and extent of the following items in
relation to your firm's finishing only operations in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Any other costs and
activities

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
II-3h.

Page 12

Finishing only operations' complexity and importance.--On a scale of 1 to 5, please provide
your firm's subjective opinion as to the complexity, intensity, and importance of finishing only
operations. 1 being minimally complex, intense or important; 5 being extremely complex,
intense, and important.

1:
Minimally
complex, intense,
and important

2

Please describe the reason for your rating:

3

.

4

5:
Extremely
complex, intense,
and important

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II-4a.

Page 13

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of small diameter graphite electrodes in its
U.S. establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – 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.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
II-4a.

Page 14

Production, shipment, and inventory data. --Continued
Quantity (in metric tons) and value (in $1,000)
Calendar year
Item

Average production capacity
(quantity) (A)

2016

2017

January-September
2018

2018

2019

1

Beginning-of-period
inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:2
quantity (F)
value (G)
Transfers to related firms:2
quantity (H)
value (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 (use
additional pages as necessary).
.
2
Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however,
provide the data above at fair market value).
3
Identify your firm’s principal export markets:
.

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II-4a.

Page 15

Production, shipment, and inventory data.--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line 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 year
Item
B+C–D–F–H–J–L=
should equal zero ("0") or
provide an explanation.1

2016

2017

0

January-September
2018

0

2018

0

2019

0

1

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

II-4b.

Historical U.S. shipment data. --Report the quantity and value of your firm’s U.S. shipments
(including commercial U.S. shipments, internal consumption, and transfers, but not including
exports) of small diameter graphite electrodes produced in your U.S. establishment(s) during
the specified periods.
Quantity (metric tons) and value ($1,000)
Item

Small diameter graphite
electrodes
Quantity
Value

2014

2015

0

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
II-5.

Page 16

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 metric tons)
Calendar year
Item

2016

2017

January-September
2018

2018

2019

Channels of distribution:
U.S. shipments—
to distributors (M)
to end users (N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation item

2016

M + N – D – F –H = zero ("0"), if
not revise.
II-6.

2017
0

January-September
2018

0

2018
0

2019
0

0

U.S. shipments by type and size.--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 type and size.
Quantity (in metric tons)
Item

Ultra High
Power

High Power

Regular Power

Other

U.S. shipments in 2018.—
Less than 14 inches in diameter (O)
14 – 16 inches in diameter (P)
RECONCILIATION OF SHIPMENTS BY TYPE AND SIZE.--Please ensure that the quantities reported for
shipments by type and size (i.e., lines O, and P across all columns) equal the quantities reported for U.S.
shipments (i.e., lines D, F, and H) in 2018. 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 item
O + P – D – F – H = zero ("0"), if not revise.

2018
0

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II-7.

Page 17

U.S. shipments by application and size.--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
application and size.
Quantity (in metric tons)
Item

DC electric
arc furnace

AC electric
arc furnace

Submerged
arc furnace

Ladle
furnace

Other

U.S. shipments in 2018.—
Less than 14 inches in
diameter (Q)
14 – 16 inches in diameter (R)
RECONCILIATION OF SHIPMENTS BY APPLICATION AND SIZE.--Please ensure that the quantities reported
for shipments by application and size (i.e., lines Q, and R across all columns) equal the quantities
reported for U.S. shipments (i.e., lines D, F, and H) in 2018. 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 item
Q + R – D – F – H = zero ("0"), if not revise.

2018
0

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

II-8.

Page 18

Employment data.--Report your firm’s employment-related data related to the production of
small diameter graphite electrodes and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations. Average number employed may be computed by adding the
number of employees, both full time and part time, for the 12 pay periods ending closest to the
15th of the month and divide that total by 12. For the January to September periods, calculate
similarly and divide by 9.
“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 year
Item

Employment data:
Average number of PRWs
(number) (O)
Hours worked by PRWs (1,000
hours) (P)
Wages paid to PRWs ($1,000)
(Q)
Explanation of trends:

2016

2017

January-September
2018

2018

2019

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Page 19

II-9.

Transfers to related firms.--If your firm reported transfers to related firms in question II-4,
please identify the firm(s) and indicate the nature of the relationship between your firm and the
related firms (e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at
market value or by a non-market formula, whether your firm retained marketing rights to all
transfers, and whether the related firms also processed inputs from sources other than your
firm.

II-10.

Purchases.--Has your firm purchased small diameter graphite electrodes produced in the United
States or in other countries since January 1, 2014? (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 metric tons)
Calendar years
Item

2015

2016

January-September
2017

2018

2019

Purchases from U.S. importers1
of small diameter graphite
electrodes from—
China
All other sources
Purchases from domestic
producers2
Purchases from other sources2
1

Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
II-11.

Page 20

Imports.--Since January 1, 2014, has your firm imported small diameter graphite electrodes?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No

Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

II-12.

Toll production.--Since January 1, 2014, has your firm been involved in a toll agreement
regarding the production of small diameter graphite electrodes?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

II-13.

Yes

If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce small diameter graphite electrodes in
and/or admit small diameter graphite electrodes 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)

Yes

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 small diameter graphite electrodes into a foreign trade zone (FTZ) for use in
distribution of small diameter graphite electrodes and/or the production of downstream
articles?
No

Yes

If yes--Identify the firms and the FTZs.

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II-14.

Effect of order.--Describe the significance of the existing antidumping duty order covering
imports of small diameter graphite electrodes from China in terms of its effect on your firm’s
production capacity, production, U.S. shipments, inventories, purchases, employment,
revenues, costs, profits, cash flow, capital expenditures, research and development
expenditures, and asset values. You may wish to compare your firm’s operations before and
after the imposition of the order.

II-15.

Likely impact of revocation.--Would your firm anticipate any changes in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of small
diameter graphite electrodes in the future if the antidumping duty order on small diameter
graphite electrodes from China were to be revoked?

No

II-16.

Yes

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
documentations that address this issue.

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

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir at ((202) 205-3247,
[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 small diameter graphite electrodes:

2.
3.

4.

Does your firm prepare profit/loss statements for small diameter graphite electrodes:
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)
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 small diameter graphite
electrodes, as well as specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

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III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-5.

Product listing.--Please list the products your firm produces in the facilities in which it produces
small diameter graphite electrodes, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products

Share of sales

Small diameter graphite electrodes

%

Large diameter graphite electrodes

%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of small diameter graphite electrodes 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.--Please identify the inputs used in the production of small
diameter graphite electrodes that your firm purchases from related suppliers and that are
reflected in question III-9a. For “Share of total COGS” please report this information by relevant
input on the basis of your most recently completed fiscal year. For “Input valuation” please
describe the basis, as recorded in the 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

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III-8.

Page 24

Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in III-9a (financial results on small diameter
graphite electrodes) in a manner consistent with the firm’s accounting books and records.

Yes

No

If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:

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III-9a. Operations on small diameter graphite electrodes.--Report the revenue and related cost
information requested below on the small diameter graphite electrodes 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 metric tons) and value (in $1,000)
Fiscal years ended-2016

2017

January-September
2018

2018

2019

quantities:2

Net sales
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales values

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

values:2

Net sales
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income or (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

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III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

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III-10. Nonrecurring items (charges and gains) included in the small diameter graphite electrodes
financial results.--For each annual and interim period for which financial results are reported in
question III-9a, please specify all material (significant) nonrecurring items (charges and gains) in
the schedule below, the specific question III-9a line item where the nonrecurring items are
included, a brief description of the relevant nonrecurring items, and the associated values (in
$1,000), as reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated
to question III-9a, only the allocated value amount included in question III-9a should be reported
in the schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.

Fiscal years ended--

2016

2017

January-September

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-9a where the nonrecurring item is classified.
Description of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Income statement classification of the nonrecurring item

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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-9a.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of small diameter graphite electrodes. If your firm does
not maintain some or all of the specific asset information necessary to calculate total assets for
small diameter graphite electrodes in the normal course of business, please estimate this
information based upon a method (such as production, sales, or costs) that is consistent with
relevant cost allocations in question III-9a. Provide data as of the end of your firm’s three most
recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to operations on small diameter graphite electrodes if these
assets are also related to other products. Please provide a brief explanation if there are any
substantial changes in total asset value during the period; e.g., due to asset write-offs,
revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item

2016

2017

2018

Total assets (net)1
1

Describe

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for small diameter graphite electrodes.
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-September
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.

2

Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.

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III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-4a (including export shipments) as long as they are both reported on a
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.
Full year data
Reconciliation

2016

2017

Partial year periods
2018

2018

2019

Quantity: Trade data from question
II-4a (lines D, F, H, and J) less
financial total net sales quantity data
from question III-9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II4a (lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-4a?
Yes

No

If no, please explain.

III-15. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Benedetto (202-2053270, [email protected]).
IV-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 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. end user customers of the following products produced by your firm. (Please
do not report data for shipments to distributors.)
Product 1.—RP graphite electrodes, 350 mm. (14 inches) nominal diameter x 1,800 mm. (72
inches) nominal length, 3 TPI taper connecting pin.
Product 2.-- UHP graphite electrodes, 350 mm. (14 inches) nominal diameter x 1,800 mm. (72
inches) nominal length, 3 TPI taper connecting pin.
Product 3.— UHP graphite electrodes, 400 mm. (16 inches) nominal diameter x 1,800 mm. (72
inches) nominal length, 3 TPI taper connecting pin.

Please note that values should be on a delivered basis and should 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).
(a) During January 2016 -September 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.

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IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to end users.
Report data in pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
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
July-September
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, and the value of returned goods), delivered.
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
IV-2c.

Page 32

Price data checklist.--Please check that the pricing data in question IV-2(a) has been correctly
reported.
Are the price data reported above:

√ if Yes

In actual dollars (not $1,000) and pounds
On a delivered basis (i.e., does include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than or equal to reported commercial shipments in question II-4 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.--How does your firm determine the prices that it charges for sales of small
diameter graphic electrodes (check all that apply)? If your firm issues price lists, please submit
sample pages of a recent list.
Transaction
by
transaction

IV-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

Annual
total
volume
discounts

No
discount
policy

Other

Describe

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)
IV-5.

Pricing terms.--On what basis are your firm’s prices of domestic small diameter graphic
electrodes usually quoted (check one)?
Delivered

IV-6.

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 small
diameter graphic electrodes in 2018 was on a (1) short-term contract basis, (2) annual contract
basis, (3) long-term contract basis, and (4) spot sales basis?
Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

Short-term
contracts
(multiple
deliveries for
less than 12
months)
Share of 2018
sales
IV-7.

%

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced small diameter graphic electrodes (or check “not applicable” if your firm does not
sell on a short-term, annual and/or long-term contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Page 33

Please identify the indexes used:

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

Annual contracts
(multiple
deliveries for 12
months)
365

Long-term contracts
(multiple deliveries
for more than 12
months)

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IV-8.

Lead times.--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 small diameter graphic electrodes?
Share of 2018 Lead time (average
sales
number of days)

Source
From inventory

%

Produced to order

%

Total (should sum to 100.0%)
IV-9.

Page 34

0.0 %

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced small diameter
graphic electrodes that is accounted for by U.S. inland transportation costs?
%

(b)

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

(c)

Indicate the approximate percentage of your firm’s sales of small diameter graphic
electrodes that are delivered the following distances from your firm’s 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 small diameter graphic electrodes since January 1, 2014 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

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IV-11. End uses.--Have there been any changes in the end uses of small diameter graphic electrodes
since January 1, 2014? Do you anticipate any future changes?
Changes in end
uses

No

Yes

Explain

Changes since
January 1, 2014
Anticipated
changes
IV-12. Substitutes.--Have there been any changes in the number or types of products that can be
substituted for small diameter graphic electrodes since January 1, 2014? Do you anticipate any
future changes?
Changes in
substitutes

No Yes

Explain

Changes since
January 1, 2014
Anticipated
changes
IV-13. Availability of supply.--Has the availability of small diameter graphic electrodes in the U.S.
market changed since January 1, 2014? Do you anticipate any future changes?
Availability in the U.S.
market

Please explain, noting the countries and reasons for the
No Yes changes.

Changes since January 1, 2014:
U.S.-produced product
Imports from China
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from China
Imports from all other
countries

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IV-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for small diameter graphic electrodes has changed since January 1, 2014, and
how you anticipate demand will change in the future. Explain any trends and describe the
principal factors that have affected, and that you anticipate will affect, these changes in
demand.

Market

Overall
increase

Fluctuate
Overall
with no
decrease clear trend

No
change

Explanation and factors

Demand since January 1, 2014
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of small diameter graphic electrodes since January 1, 2014? Do you anticipate any
future changes?
Changes in product
range, product mix,
or marketing
Changes in customer
preference for HP,
UHP, and/or RHP
small diameter
graphic electrodes
Other changes since
January 1, 2014
Anticipated changes

No

Yes

Explain

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IV-16.

Page 37

Conditions of competition.-(a) Is the small diameter graphic electrodes market subject to business cycles (other than
general economy-wide conditions) and/or other conditions of competition distinctive to
small diameter graphic electrodes?
Check all that apply.

Please describe.

No

Skip to question IV-17.

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
small diameter graphic electrodes since January 1, 2014?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply small diameter
graphic electrodes since January 1, 2014 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, being unable to meet timely shipment commitments,
etc.)?
No

Yes

If yes, please describe.

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IV-18. Raw materials.-- Indicate how small diameter graphic electrodes raw material prices have
changed since January 1, 2014, and how you expect they will change in the future.

Raw
materials
prices

Fluctuate
Explain, noting how raw material
with no
price changes have affected your
Overall
No
Overall
clear
firm’s selling prices for small diameter
increase change decrease trend
graphic electrodes.

Changes since
January 1,
2014
Anticipated
changes
IV-19. Price comparisons.--Please compare market prices of small diameter graphic electrodes in U.S.
and non-U.S. markets, if known. Provide specific information as to time periods and regions for
any price comparisons.

IV-20. Market studies.--Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss small diameter graphic
electrodes supply (including production capacity and capacity utilization) and demand in (1) the
United States, (2) each of the other major producing/consuming countries, including China, and
(3) the world as a whole. Of particular interest is such data from 2014 to the present and
forecasts for the future.
IV-21. Export constraints.--Describe how easily your firm can shift its sales of small diameter graphic
electrodes between the U.S. market and alternative country markets. In your discussion, please
describe any contracts, other sales arrangements, or other constraints that would prevent or
retard your firm from shifting small diameter graphic electrodes between the U.S. and
alternative country markets within a 12-month period.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

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IV-22. Barriers to trade.--Are your firm’s exports of small diameter graphic electrodes subject to any
tariff or non-tariff barriers to trade in other countries?

No

Yes

If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2014, or that are expected to occur in the future.

IV-23. Interchangeability.--Is small diameter graphic electrodes produced in the United States and in
other countries interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

China

Other countries

United States
China
For any country-pair producing small diameter graphic electrodes which is sometimes or
never interchangeable, please identify the country-pair and explain the factors that limit or
preclude interchangeable use:

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

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IV-24. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between small diameter graphic
electrodes produced in the United States and in other countries a significant factor in your firm’s
sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

China

Other countries

United States
China
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of small diameter graphic electrodes, identify the country-pair
and report the advantages or disadvantages imparted by such factors:

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

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IV-25. Impact of the section 232 investigation.-- Did the imposition of tariffs on imported steel products
under section 232 have an impact on the small diameter graphic electrodes market in the
United States?
Yes— Please indicate the impact in the
table below.

Item
Overall demand for
small diameter graphic
electrodes in the U.S.
market
Prices for small
diameter graphic
electrodes in the U.S.
market

No

Don’t know

Explain, noting how the imposition
Fluctuate of tariffs under section 232 affected
with no
each factor of the small diameter
No
clear
graphic electrodes market in the
Increase change Decrease
trend
United States.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

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IV-26. Impact of section 301 tariffs.--Did the imposition of tariffs on Chinese-origin products under to
section 301 have an impact on the small diameter graphic electrodes market in the United
States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced small
diameter graphic
electrodes
Supply of small
diameter graphic
electrodes imported
from China
Supply of small
diameter graphic
electrodes imported
from other countries
Prices for small
diameter graphic
electrodes
Overall U.S. demand
for small diameter
graphic electrodes
Raw material costs for
small diameter graphic
electrodes

No

Overall
No
Overall
increase change decrease

Don’t know

Explain, noting how the imposition
of tariffs under section 301 affected
Fluctuate each factor of the small diameter
with no
graphic electrodes market in the
clear
United States.
trend

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

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IV-27. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response 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.

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U.S. Producers’ Questionnaire – Small Diameter Graphite Electrodes (Review 2)

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2019/small_diameter_graphite_electrod
es_china/second_review_full.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: ELECT

• 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.