19-2-4126 U.S. importers' questionnaire

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

US importers--Graphite Electrodes (R2)

Small diameter graphite electrodes from China (Inv. no. 731-TA-1143)

OMB: 3117-0016

⚠️ Notice: This form may be outdated.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

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OMB No. 3117-0016/USITC No. 19-2-4126; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ 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 imported small diameter graphite electrodes (as defined on the next page) from any
country at any time since January 1, 2014?

(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 investigations 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. Importers’ 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 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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Nitin
Joshi (202-708-1669, [email protected]).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
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
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

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

Page 4

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm involved in the importation of small diameter graphite
electrodes, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities.

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.

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

Firm name

Yes--List the following information.

Address

Extent of
ownership
(percent)

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I-4.

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

Yes--List the following information.

Firm name

I-5.

Country

Affiliation

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-6.

Page 5

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on small
diameter graphite electrodes. More than one answer may be applicable.
Importer of record

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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I-7.

Consignees.--If your firm is an importer of record of small diameter graphite electrodes but is
not the consignee, please list the consignees below (firm name, address, telephone number, and
individual to contact).
Firm name

I-8.

Page 6

Contact person and
phone number

Address

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

Yes

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I-9.

Business plan.--In Parts II and III 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?

I-10.

Page 7

Yes

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

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

Yes

If yes, please specify.

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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 importation of small diameter graphite electrodes since January 1,
2014.
Check as many as appropriate.
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

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

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II -2b

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

II-3.

Page 9

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.

Arranged imports.--Has your firm imported or arranged for the importation of small diameter
graphite electrodes for delivery after September 30, 2019?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes–Fill out the table below.
Quantity (in metric tons)

Period/Source

Oct-Dec 2019

Jan-Mar 2020

Apr-Jun 2020

Jul-Sept 2020

China
All other sources
II-4.

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

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial shipments”— Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” –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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II-5a.

Page 11

Imports: China.--Report your firm’s imports and your firm’s shipments and inventories of small
diameter graphite electrodes imported from China during the specified periods.

CHINA

Quantity (metric tons), value (in $1,000)
Calendar year
Item

2016

2017

January-September
2018

2018

2019

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity)
(L)
1

Please identify the foreign producers, if known:
.
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
2

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II-5a.

Page 12

Imports: China.–Continued

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

2016

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

2017

January-September
2018

2018

2019

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

II-5b.

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

CHINA

Quantity (in metric tons)
Calendar year
Item

2016

January-September

2017

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 K and L) in each time period equal the quantity reported for U.S. commercial shipments (i.e.,
line 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
M + N – D -F - H= zero ("0"), if not
revise.

2016

2017
0

January-September
2018

2018
0

2019
0

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II-5c.

Page 13

U.S. shipments by type and size: China.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) in 2018 of
imports from China by type and size.

CHINA

Quantity (in metric tons)
Ultra High
Power

Item

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.--Please ensure that the quantities reported for shipments by
type (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

2018

O + P – D – F – H = zero ("0"), if not revise.
II-5d.

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.
2018

Reconciliation item
Q + R – D – F – H = zero ("0"), if not revise.

II-5e.

Historical U.S. imports: China. --Report the quantity and value your firm’s imports of small
diameter graphite electrodes imported from small diameter graphite electrodes during the
specified periods.

CHINA

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Quantity (in metric tons)
Item
U.S. imports:
Quantity
Value

2014

2015

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II-6a.

Page 15

Imports: All other sources.--Report your firm’s imports and your firm’s shipments and
inventories of small diameter graphite electrodes imported from all other sources during the
specified periods.

ALL OTHER SOURCES
(list sources:

)
Quantity (in metric tons), value (in $1,000)
Calendar year

Item

2016

2017

January-September
2018

2018

2019

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II-6a.

Page 16

Imports: All other sources.–Continued

2016

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

2017

January-September
2018

2018

2019

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

II-6b.

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

2016

2017

January-September
2018

2018

2019

Quantity (in metric tons)
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 K and L) in each time period equal the quantity reported for U.S. commercial shipments (i.e.,
line 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
M + N – D -F - H= zero ("0"), if not
revise.

2016

2017
0

January-September
2018

2018
0

2019
0

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II-6c.

Page 17

U.S. shipments by type: All other sources.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) in 2018 of
imports from all other sources by type.

ALL OTHER SOURCES
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-6d.

Page 18

Item

AC electric
arc furnace

Submerged
arc furnace

Ladle
furnace

Other

2018

Q + R – D – F – H = zero ("0"), if not revise.

II-6e.

Historical U.S. imports: All other sources. --Report the quantity and value your firm’s imports of
small diameter graphite electrodes imported from small diameter graphite electrodes during
the specified periods.
Quantity (in metric tons)
Item

U.S. imports:
Quantity
Value

2014

2015

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II-7.

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
imports, U.S. shipments of imports, and inventories. You may wish to compare your firm’s
operations before and after the imposition of the order.

II-8.

Likely impact of revocation. --Would your firm anticipate any changes in the character of its
operations or organization, including its imports, U.S. shipments of imports, or inventories of
small diameter graphite electrodes in the future if the antidumping duty order on small
diameter graphite electrodes from China were to be revoked?

Yes

II-9.

Transfers to related firms.--If your firm reported transfers to related firms in any of the data
tables in part II, please identify the firm(s) and indicate the nature of the relationship between
your firm and the related firms (e.g., joint venture, wholly owned subsidiary) and whether the
transfers were priced at market value or by a non-market formula.

II-10.

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.

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Page 20

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Benedetto (202-2053270, [email protected]).
III-1.

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. end user customers of the following products your firm imported from China:
(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 import from China 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 III-3.

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III-2b. Price data (China).--Report below the quarterly price data1 for pricing products2 imported from
China and sold by your firm to end users.

China

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 III.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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III-2c.

Page 22

Price data checklist.--Please check that the pricing data in question III-2(b) 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 Part II in each year?

III-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.

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III-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

III-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

III-5.

Page 23

Annual
total
volume
discounts

No
discount
policy

Other

Describe

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

F.o.b.

If f.o.b., specify point

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III-6.

Contract versus spot.--Approximately what share of your firm’s sales of small diameter graphic
electrodes imported from China 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 your
2018 sales
III-7.

Spot sales
(for a single
delivery)
%

Total
(should
sum to
100.0%)
0.0

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
small diameter graphic electrodes imported from China (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 24

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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III-8.

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

Source

Share of 2018
sales

From inventory

From foreign manufacturers’ inventory

Produced to order

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

Page 25

0.0

Lead time (average
number of days)

Shipping information.-(a)

What is the approximate percentage of the cost of small diameter graphic electrodes
imported from China 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)

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

(d)

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

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

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III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold small
diameter graphic electrodes imported from China since January 1, 2014 (check all that apply)?
Geographic area

China

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.
III-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

Yes

Explain

Changes since
January 1, 2014
Anticipated changes
III-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
Changes since
January 1, 2014
Anticipated changes

Yes

Explain

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III-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
III-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

No
change

Overall
decrease

Fluctuate
with no
clear trend

Demand since January 1, 2014
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States

Explanation and factors

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III-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

Yes

Explain

Changes in customer
preference for HP,
UHP, and/or RHP
small diameter
graphic electrodes
Other changes since
January 1, 2014
Anticipated changes
III-16. 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.

Skip to question III-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.

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III-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.

III-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
III-19. Price comparisons.--Please compare market prices of small diameter graphic electrodes in U.S.
and non-U.S. markets if known. Provide information as to time periods and regions for any price
comparisons.

III-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.

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Page 30

III-21. 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:

III-22. 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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Page 31

III-23. 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

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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Page 32

III-24. 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

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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Page 33

III-25. 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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Page 34

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

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

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

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

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Page 35

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 import this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	Microsoft Word - US importers--Graphite Electrodes (R2)
Author	nitin.joshi
File Modified	2019-09-26
File Created	2019-09-26