Form 19-1-4129 U.S. producers' questionnaire

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

US Producers--Cabinets (Final)

Wooden cabinets and vanities from China (Inv. nos. 701-TA-620 and 731-TA-1445) Final

OMB: 3117-0016

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U.S. PRODUCERS’ QUESTIONNAIRE
WOODEN CABINETS AND VANITIES FROM CHINA
This questionnaire must be received by the Commission by December 2, 2019
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning wooden cabinets and vanities from
China (Inv. Nos. 701-TA-620 and 731-TA-1445 (Final)). The information requested in the questionnaire is requested
under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result
in a subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced wooden cabinets and vanities (as defined on next page) at any time since January 1,
2016?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: CABN)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements
Name of Authorized Official

Signature

Title of Authorized Official

Phone

Date

Email address

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U.S. Producers’ Questionnaire – Wooden Cabinet and Vanities (Final)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on March 6, 2019, by the
American Kitchen Cabinet Alliance. Countervailing and/or antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2019/wooden_cabinets_and_vanities_china/final.htm.
Wooden cabinets and vanities covered by these investigations are wooden cabinets and vanities that
are for permanent installation (including floor mounted, wall mounted, ceiling hung or by attachment of
plumbing), and wooden components thereof. Wooden cabinets and vanities and wooden components
are made substantially of wood products, including solid wood and engineered wood products
(including those made from wood particles, fibers, or other wooden materials such as plywood, strand
board, block board, particle board, or fiberboard), or bamboo. Wooden cabinets and vanities consist of a
cabinet box (which typically includes a top, bottom, sides, back, base blockers, ends/end panels,
stretcher rails, toe kicks, and/or shelves) and may or may not include a frame, door, drawers and/or
shelves. Subject merchandise includes wooden cabinets and vanities with or without wood veneers,
wood, paper or other overlays, or laminates, with or without non-wood components or trim such as
metal, marble, glass, plastic, or other resins, whether or not surface finished or unfinished, and whether
or not completed.
Wooden cabinets and vanities are covered by the investigation whether or not they are imported
attached to, or in conjunction with, faucets, metal plumbing, sinks and/or sink bowls, or countertops. If
wooden cabinets or vanities are imported attached to, or in conjunction with, such merchandise, only
the wooden cabinet or vanity is covered by the scope.
Subject merchandise includes the following wooden component parts of cabinets and vanities: (1)
wooden cabinet and vanity frames (2) wooden cabinet and vanity boxes (which typically include a top,
bottom, sides, back, base blockers, ends/end panels, stretcher rails, toe kicks, and/or shelves), (3)
wooden cabinet or vanity doors, (4) wooden cabinet or vanity drawers and drawer components (which
typically include sides, backs, bottoms, and faces), (5) back panels and end panels, (6) and desks,
shelves, and tables that are attached to or incorporated in the subject merchandise.
Subject merchandise includes all unassembled, assembled and/or “ready to assemble” (RTA) wooden
cabinets and vanities, also commonly known as “flat packs,” except to the extent such merchandise is
already covered by the scope of antidumping and countervailing duty orders on Hardwood Plywood
from the People's Republic of China. See Certain Hardwood Plywood Products from the People's Republic
of China: Amended Final Determination of Sales at Less Than Fair Value, and Antidumping Duty Order, 83
FR 504 (January 4, 2018); Certain Hardwood Plywood Products from the People's Republic of China:
Countervailing Duty Order, 83 FR 513 (January 4, 2018). RTA wooden cabinets and vanities are defined
as cabinets or vanities packaged so that at the time of importation they may include: (1) wooden
components required to assemble a cabinet or vanity (including drawer faces and doors); and (2) parts
(e.g., screws, washers, dowels, nails, handles, knobs, adhesive glues) required to assemble a cabinet or
vanity. RTAs may enter the United States in one or in multiple packages.
Subject merchandise also includes wooden cabinets and vanities and in-scope components that have
been further processed in a third country, including but not limited to one or more of the following:
trimming, cutting, notching, punching, drilling, painting, staining, finishing, assembly, or any other

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U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

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processing that would not otherwise remove the merchandise from the scope of the investigation if
performed in the country of manufacture of the in-scope product.
Excluded from the scope of this investigation, if entered separate from a wooden cabinet or vanity are:
(1) Aftermarket accessory items which may be added to or installed into an interior of a cabinet and
which are not considered a structural or core component of a wooden cabinet or vanity.
Aftermarket accessory items may be made of wood, metal, plastic, composite material, or a
combination thereof that can be inserted into a cabinet and which are utilized in the function of
organization/accessibility on the interior of a cabinet; and include:
•
•

Inserts or dividers which are placed into drawer boxes with the purpose of organizing or dividing
the internal portion of the drawer into multiple areas for the purpose of containing smaller
items such as cutlery, utensils, bathroom essentials, etc.
Round or oblong inserts that rotate internally in a cabinet for the purpose of accessibility to
foodstuffs, dishware, general supplies, etc.

(2) Solid wooden accessories including corbels and rosettes, which serve the primary purpose of
decoration and personalization.
(3) Non-wooden cabinet hardware components including metal hinges, brackets, catches, locks, drawer
slides, fasteners (nails, screws, tacks, staples), handles, and knobs.
(4) Medicine cabinets that meet all of the following five criteria are excluded from the scope: (1) wall
mounted; (2) assembled at the time of entry into the United States; (3) contain one or more mirrors; (4)
be packaged for retail sale at time of entry; and (5) have a maximum depth of seven inches.
Also excluded from the scope of this investigation are:
(1) All products covered by the scope of the antidumping duty order on Wooden Bedroom Furniture
from the People’s Republic of China. See Notice of Amended Final Determination of Sales at Less Than
Fair Value and Antidumping Duty Order: Wooden Bedroom Furniture from the People’s Republic of
China, 70 FR 329 (January 4, 2005).
(2) All products covered by the scope of the antidumping and countervailing duty orders on Hardwood
Plywood from the People's Republic of China. See Certain Hardwood Plywood Products from the People’s
Republic of China: Amended Final Determination of Sales at Less Than Fair Value, and Antidumping Duty
Order, 83 FR 504 (January 4, 2018); Certain Hardwood Plywood Products from the People’s Republic of
China: Countervailing Duty Order, 83 FR. 513 (January 4, 2018).
Imports of subject merchandise are classified under Harmonized Tariff Schedule of the United States
(HTSUS) statistical numbers 9403.40.9060 and 9403.60.8081. The subject component parts of wooden
cabinets and vanities may be entered into the United States under HTSUS statistical number
9403.90.7080. Although the HTSUS subheadings are provided for convenience and customs purposes,
the written description of the scope of this investigation is dispositive.
Full units are (1) fully assembled wooden cabinets and vanities and/or (2) RTA "flat packs" of wooden
cabinets and vanities containing all the necessary components for a fully assembled wooden cabinet or
vanity.

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Components are specifically the parts of cabinets and vanities such as: wooden cabinet and vanity
frames; the cabinet box; wooden cabinet or vanity doors; and wooden cabinet or vanity drawer and
drawer components. This does not include any accessories that are excluded from the scope of these
investigations (e.g., moldings and carven wooden accessories).
Cabinets consist of a cabinet box (which typically includes a top, bottom, sides, back, base blockers,
ends/end panels, stretcher rails, toe kicks, and/or shelves) and may or may not include a frame, door,
drawers and/or shelves that are usually found in the kitchen or non-bathroom settings.
Vanities consist of a cabinet box (which typically includes a top, bottom, sides, back, base blockers,
ends/end panels, stretcher rails, toe kicks, and/or shelves) and may or may not include a frame, door,
drawers and/or shelves that are usually found in the bathroom.
Furniture style are fully assembled, packaged for retail sale finished units that 1) include an integrated
countertop and sink, 2) include at least one of the following: doors, drawers or shelves 3) do not include
a toe kick and that are usually found in the bathroom. FSVs are sold as a final product and are not
customizable by the consumer. Reported data should exclude the value of the out-of-scope
merchandise included in the retail package (e.g. countertops and sinks).
Hospitality style consists of permanently affixed articles meeting the definitions of cabinets and vanities
above, but intended for installation and use in hotels.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of wooden cabinet and vanities and your responses to the
questions in Part I of the producer questionnaire will be provided to the U.S. Department of Commerce,
upon its request, for use in connection with (and only in connection with) its requirement pursuant to

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section 702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination
concerning the extent of industry support for the petition requesting this proceeding. Any information
provided to Commerce will be transmitted under the confidentiality and release guidelines set forth
above. Your response to these questions constitutes your consent that such information be provided to
Commerce under the conditions described above.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
I-1a.

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes

No

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U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
I-2a.

Page 6

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of wooden cabinets and
vanities, 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.

Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No

I-4.

Yes

Petition support.--Does your firm support or oppose the petition?
Country

China (AD)
China (CVD)

Support

Oppose

Take no position

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U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
I-5.

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

Firm name

I-6.

Page 7

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing wooden cabinets and vanities from China into the United
States or that are engaged in exporting wooden cabinets and vanities from China to the United
States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
I-7.

Page 8

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wooden cabinets and vanities?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Ahdia Bavari (202-205-3191,
[email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of wooden cabinets and vanities since January 1, 2016.
(check as many as appropriate)
Office/warehouse/showroom
openings
Office/warehouse/showroom
openings
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 – Wooden Cabinets and Vanities (Final)
II-3.

Page 10

Product shifting: To/from other products.-(a)

Is your firm able to switch production (capacity) between to/from other (out-of-scope)
products using the same equipment and/or labor as wooden cabinets and vanties?

No

(b)

Yes

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

Has your firm actually produced products other than wooden cabinets and vanities using the
same equipment and/or labor as wooden cabinets and vanities since January 1, 2016?
Yes--Please specify the total value of these products
produced in the specified periods.

No

Value (in $1,000)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Revenue related to other
products produced using same
equipment and/or labor as
wooden cabinets and vanities

II-4a.

Changing parameters.—Could you add more shifts or work longer hours on you present shifts?

No

II-4b.

Yes

If yes—please explain what allows for adding more shifts or hours. If no—
please explain what constrains your ability to do so.

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 – Wooden Cabinets and Vanities (Final)
II-4c.

Peak historical output.—Since January 1, 2016, did you actually operate at the level indicated by the
shifts you reported
No

II-5.

Page 11

Yes

If no—please explain why you did not utilize all the shifts as reported

Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of wooden cabinets and vanities?
“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-6.

Yes

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

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce wooden cabinets and vanities in and/or
admit wooden cabinets and vanities into a foreign trade zone (FTZ)?

(a)

“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 designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.

No

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 wooden cabinets and vanities into a foreign trade zone (FTZ) for use in
distribution of wooden cabinets and vanities and/or the production of downstream
articles?

(b)

No

Yes

If yes--Identify the firms and the FTZs.

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Select technical definitions
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments”--Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business, excluding retail sales. Report
net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the
value of returned goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption / including for own retail sales”--Product consumed internally by your
firm, which includes (a) using wooden cabinets or vanities in the production of a downstream
further process final product, (b) installing wooden cabinets or vanities in a building in
transactions in which your firm mixes the cost of wooden cabinets or vanities with services (i.e.,
installation, design work), and (c) merchandise that your firm transferred to your own firm's
retail locations. These transactions should be valued at fair market wholesale value of the
wooden cabinets or vanities used, i.e., not the total value of final downstream processed
merchandise (in the case of internal consumption), nor the total value of any installation/design
services (in case your firm provides installation or design services), nor the retail sale value (in
the case of your firm owning and operating its own retail locations).
“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 sole 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 – Wooden Cabinets and Vanities (Final)
II-7.

Page 13

Production, shipment, and inventory data: (full units).--Report your firm’s production capacity,
production, shipments, and inventories related to the production of full cabinet and vanity units
in its U.S. establishment(s) during the specified periods.

Full Units
Quantity (in number of units) and value (in $1,000)
Calendar years
Item
Average production capacity
(quantity) (A)

2016

2017

January-September
2018

2018

2019

1

Beginning-of-period inventories
Quantity (B)
Value (C)
Production (quantity) (D)
U.S. shipments:
Commercial shipments:
Quantity (E)
Value (F)
Internal consumption/
including for own retail
sales:2
Quantity (G)
Value2 (H)
Transfers to related firms:2
Quantity (I)
Value2 (J)
Export shipments:3
Quantity (K)
Value (L)
End-of-period inventories
Quantity (M)
Value (N)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1

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II-7.

Page 14

Production, shipment, and inventory data: (full units).--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.—Generally, the data reported for the
quantity of end-of-period inventories (i.e., line M) should be equal to the quantity of beginning-of-period
inventories (i.e., line B), plus production (i.e., line D), less the quantity of total shipments (i.e., lines E, G, I,
and K). Please ensure that any differences are not due to data entry errors in completing this form, but
rather reflect your firm’s actual records; and, also provide explanations for any differences (e.g., theft,
loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation

2016

2017

B + D – E – G – I – K – M = should
equal zero (“0”) or provide an
explanation.1
1

January-September
2018

0

0

2018

0

2019

0

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

II-8.

0
.

U.S. shipments by assembly.--Report your firm’s U.S. shipments of full units of cabinets and
vanities (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to
related firms) by assembly, (i.e., fully assembled vs ready-to-assemble (RTA) flat pack).

Full Units
Quantity (in number of units) and value (in $1,000)
Calendar years
U.S. shipments

2016

2017

January-September
2018

2018

2019

Fully assembled
Quantity (O)
Value (P)
RTA flat pack
Quantity (Q)
Value (R)
RECONCILIATION OF SHIPMENT BY ASSEMBLY.--Please ensure that the quantities and values reported for
U.S. shipments of assembled and non-assembled cabinets and vanities (i.e., lines O through R) in each
time period equal the quantities and values reported for U.S. shipments (i.e., lines E through J) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported
must be revised prior to submission to the Commission.
Calendar years
Reconciliation

2016

2017

January-September
2018

2018

2019

Quantity: O + Q – E – G – I =
zero ("0"), if not revise.

0

0

0

0

0

Value: P + R – F – H – J = zero
("0"), if not revise.

0

0

0

0

0

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U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-9.

Page 15

Open market production, shipment, and inventory data: (components).--Report your firm’s
open market production, shipments, and inventories related to the production of the
components of cabinets and vanities in its U.S. establishment(s) during the specified periods.
Open market production relates to the production, shipments, and inventories of components
not being used by your firm in the production of full units (i.e., excluding internally consumed
components whose final products, full cabinets and vanities, are reported in II-7). Inventory data
(lines S and AD) should only reflect inventories stored and maintained for open market sales.

Components
Value (in $1,000)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Beginning-of-period inventories (S)
Open market production:1
Component: Frames (T)
Component: Boxes (U)
Component: Doors (V)
Component: Drawers (W)
Component: Back and end panels (X)
Component: Other (Y)
Total open market production (Z)

0

0

0

0

0

U.S. shipments:
Commercial shipments (AA)
2

Transfers to related firms (AB)3
Export shipments Quantity (AC)4
End-of-period inventories (AD)
The production reported is based on operating
hours per week,
weeks per year.
Do not report internal consumption of components.
3
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.
4
Identify your firm’s principal export markets:
.
1
2

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-10.

Page 16

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

Full Units
Quantity (in number of units) and value (in $1,000)
Calendar years
Channels of distribution

2016

2017

January-September
2018

2018

2019

U.S. shipments: Full units
to Distributors:
Quantity (AE)
Value (AF)
to Designers/dealers:
Quantity (AG)
Value (AH)
to Retailers :
Quantity (AI)
Value (AJ)
to End users:
Quantity (AK)
Value (AL)

Components
Value (in $1,000)
Calendar years
Channels of distribution
U.S. shipments: Components
to Distributors (AM)
to Designers/dealers (AN)
to Retailers (AO)
to End users (AP)

2016

2017

January-September
2018

2018

2019

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-10.

Page 17

Channels of distribution.--Continued

RECONCILIATION OF CHANNELS.--Please ensure that the quantity and values of full cabinet units
reported for channels of distribution (i.e., lines AE through AL) in each time period equal the sum of the
quantity and values reported for U.S. shipments of full cabinet units (i.e., lines E through J). Furthermore,
please ensure that the value of components reported for channels of distribution (lines AM through AP)
in each time period equal the sum of the values reported for U.S. shipments of components (lines AA and
AB). If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation

2016

2017

January-September
2018

2018

2019

Reconciliation for full units: quantity
AE + AG + AI + AK – E – G – I = zero
("0"), if not revise.

0

0

0

0

0

Reconciliation for full units: value
AF + AH + AJ + AL – F – H – J = zero
("0"), if not revise.

0

0

0

0

0

Reconciliation for components:
value
AM + AN + AO + AP – AA – AB = zero
("0"), if not revise.

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-11.

Page 18

U.S. shipments by broad category: --Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by broad
category (i.e., vanities vs cabinets).

Full Units
Quantity (in number of units) and value (in $1,000)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

U.S. shipments.-Vanities
Quantity (AQ)
Value (AR)
Cabinets
Quantity (AS)
Value (AT)
RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities and values U.S. shipments by broad
category (i.e., lines AQ through AT) in each period in this question are equal to the quantities and values
reported for U.S. shipments (i.e., lines D though I) in each period from question II-7. If the calculated
fields below return values other than zero (i.e., “0”), the data reported must be revised prior to
submission to the Commission.
Calendar years
Reconciliation

2016

2016

January-September
2018

2018

2019

Quantity: AQ + AS – E –
G – I = zero ("0"). If not,
revise.

0

0

0

0

0

Value: AR + AT – F – H –
J = zero ("0"). If not,
revise.

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-12.

Page 19

U.S. shipments of furniture style vanities: --Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of furniture
style vanities.

Full Units

Quantity (in number of units) and value (in $1,000)
Calendar years
January-September
2016
2017
2018
2018
2019

Item
U.S. shipments.-Furniture style
vanities
Quantity (AU)
Value (AV)
All other products1
Quantity
0
0
0
0
0
Value
0
0
0
0
0
1
Please ensure that that quantities and values reported for lines AU and AV do not exceed quantities
and values U.S. shipments reported in lines E through J in question II-7. If the calculated fields for “all
other products” above are returning negative values, please revise your data prior to submission to the
Commission.
II-13.

U.S. shipments of hotel style vanities and cabinets: --Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
hotel style vanities and cabinets.

Full Units

Quantity (in number of units) and value (in $1,000)
Calendar years
January-September
2016
2017
2018
2018
2019

Item
U.S. shipments.-Hotel style vanities
and cabinets
Quantity (AW)
Value (AX)
All other products1
Quantity
0
0
0
0
0
Value
0
0
0
0
0
1
Please ensure that that quantities and values reported for lines AW and AX do not exceed quantities
and values U.S. shipments reported in lines E through J in question II-7. If the calculated fields for “all
other products” above are returning negative values, please revise your data prior to submission to the
Commission.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-14.

Page 20

Employment data.--Report your firm’s employment-related data related to the production of
cabinets and vanities (full units and components) 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. 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 June periods,
calculate similarly and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid”--Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.

Full Units and Components
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends. If applicable, please address any challenges you have had in attracting or
retailing production-related workers due to tightness or competitiveness in the labor market,
low employment, availability of skilled workers, or low population density. Please discuss any
efforts or strategies that you have implemented to mitigate these challenges, such as increased
wages, or benefits, and to what extent those strategies have been successful.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 21

II-15.

Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.

II-16.

Purchases.--Has your firm purchased cabinets and vanities produced in the United States or in
other countries since January 1, 2016? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire).

No

Yes

If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases.

Full Units and Components
Value (in $1,000)
Calendar years
Item
Purchases from U.S. importers
of cabinets from-China

2016

2017

January-September
2018

2018

2019

1

All other sources
Purchases from domestic
producers2
Purchases from other sources2
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:
.
1

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
II-17.

Page 22

Imports.--Since January 1, 2016, has your firm imported wooden cabinets and/or vanities?
No

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

II-18.

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

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 23

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[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 wooden cabinets and
vanities:

2.
3.

4.

Does your firm prepare profit/loss statements for wooden cabinets and vanities:
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,
10 Qs,
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 wooden cabinets and
vanities, as well as specific statements and worksheets) used to compile these data.

Please note that we are requesting financial data be reported on a CALENDAR YEAR basis.
If a question below does not specify a specific products (e.g., full cabinet units, cabinet
components, full vanity units, or vanity components), then it should be answered for all wooden
cabinets and vanities.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 24

III-3.

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

III-4.

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

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced wooden cabinets and vanities, and provide the share of net sales accounted for by
these products in 2018.
Products
Wooden cabinets and vanities

Share of sales
%
%
%
%
%

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of wooden cabinets and vanities 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.

Page 25

No--Continue to question III-9a.

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
wooden cabinets and vanities that your firm purchases from related suppliers and that are
reflected in questions III-9a and/or III-9b. If your firm reports data for both of these tables (i.e.,
full units and components), please specify the table number for which the input is used. For
“share of total COGS” please report this information by relevant input for 2018.

Describe input:

Related supplier:

Share of
total COGS
in 2018 (%)

Specify to which
table this input
relates: III-9a
and/or III-9b

Describe the basis, as recorded in your company’s own accounting system, of the purchase cost
from the related supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price
to approximate fair market value:
.
III-8.

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in questions III-9a-b (financial results on
wooden cabinets and vanities) in a manner consistent with your firm’s accounting books and
records.

Yes

No

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

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 26

III-9a. Operations on wooden cabinets and vanities.--Report the revenue and related cost information
requested below on the wooden cabinets and vanities operations of your firm’s U.S.
establishment(s).1 Note that internal consumption and transfers to related firms must be valued
at fair market value. If your firm was involved in tolling operations (either as the toller or as the
tollee), please contact Jennifer Brinckhaus at (202) 205-3188 before completing this section of
the questionnaire. Include only components or parts sold as a complete cabinet (whether
assembled or not). Any other finished components should be reported in question III-9b.

Full Units
Quantity (number of units) and value (in $1,000)
Calendar years
Item

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 quantities

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 (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 for full sets 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.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 27

III-9b. Operations on COMPONENTS of wooden cabinets and vanities not included at III-9a.--Report
the revenue and related cost information requested below on open market sales of
COMPONENTS of wooden cabinets and vanities from your firm’s U.S. establishment(s).1
Components that are excluded from the scope (e.g., moldings, carved wood accessories, etc.)
should not be reported. Do not report (i.e., double-count) any parts/components that were
reported in question III-9a (i.e., do NOT report “internal consumption” here for merchandise
reported in a more finalized form in question III-9a).

Components
Value (in $1,000)
Calendar years
Item
Net sales

2016

2017

January-September

2018

2018

2019

values:2

Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
III-9c.

Page 28

Financial data reconciliation.--The calculable line items from questions III-9a and III-9b (i.e.,
total net sales, 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 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.

III-9d. Raw materials.--Please report the share of total raw material costs in 2018 (reported in III-9a
and/or III-9b) for the following raw material inputs used in the production of wooden cabinets
and vanities:

Full Units and Components
Procurement method

Input

Share of total raw
material costs
(percent)

Primarily
produced by
your firm

Primarily
purchased by
your firm

Solid or natural wood
Engineered wood
Other material inputs1
Total (should sum to 100 percent)

0.0

Please indicate any notable "other material inputs” not expressly identified above and provide the
share of the total raw material costs that they account for:
.
1

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 29

III-10. Nonrecurring items (charges and gains) included in the cabinet and vanities financial results.-For each period for which financial results are reported in question III-9a (full units) and/or III-9b
(components), please specify all material (significant) nonrecurring items (charges and gains) in
the schedule below. The values (in $1,000) should reflect the amount included in question III-9a
and/or III-9b; 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 and/or III-9b.

Full Units and Components
Calendar years

2016

2017

Item

January-September

2018

2018

2019

Value (in $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,
indicate the specific line item in table III-9a or III-9b where the nonrecurring item is classified, and if the company
reported data for both III-9a (full units) and III-9b (components), indicate in which table the nonrecurring item
appears.

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

Nonrecurring item
appears in III-9a (full
cabinets) or III-9b
(cabinet components)

The line item in
which the
nonrecurring item
is included at III9a or III-9b

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 30

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 questions III-9a-b.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of wooden cabinets and vanities. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for
wooden cabinets 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 and/or III-9b.
Note: Total assets should reflect assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to wooden cabinets and vanities 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.

Full Units and Components
Value (in $1,000)
Calendar years
Item
Total assets (net)
1

Describe

2016
1

.

2017

2018

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 31

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for wooden cabinets and vanities.

Full Units and Components
Value (in $1,000)
Calendar years

Item
Capital expenditures

2016

2017

January-September

2018

2018

2019

1

Research and development
expenses2
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.
.
1

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
III-14.

Page 32

Data consistency and reconciliation.--Please confirm that your firm’s financial data for
questions III-9a and III-9b are based on a calendar year. If your firm has not reported the data
on a calendar year basis, please specify the fiscal year used:
Yes – Data is reported on a
calendar year basis

No – Data has been reported
on a fiscal year basis
Specify fiscal year

Full Units and Components
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments). Similarly, the value of net sales in III-9b
should reconcile with the total shipment values reported at II-9.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments at II-7 equal total net sales at III-9a and that the total shipment values from II-9 equal
the net sales values from III-9b in each time period. If the financial data from part III are reported on a
fiscal year basis, the partial year periods should still 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.
January-September

Calendar years
Reconciliation
FULL UNITS:
Quantity: Trade data from question II-7 (lines
E, G, I, and K) less financial total net sales
quantity data from question III-9a, = zero ("0").
Value: Trade data from question II-7 (lines F, H,
J, and L) less financial total net sales value data
from question III-9a, = zero ("0").
COMPONENTS:
Value: Total shipment value from question II-9
(lines AA, AB, and AC) less financial net sales
value data from question III-9b, = zero ("0").

2016

2017

2018

2018

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Do the data relating to full units (question III-9a) reconcile with data in question II-7?
Yes

No

If no, please explain.

Do the data relating to components (question III-9b) reconcile with data in question II-9?
Yes

No

If no, please explain.

2019

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 33

III-15. Effects of imports on investment.--Since January 1, 2016, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of wooden cabinets and vanities from China?
No

Yes

If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 34

III-16. Effects of imports on growth and development. --Since January 1, 2016, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of wooden cabinets and vanities from China?
No

Yes

If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 35

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
wooden cabinets and vanities from China?
No

Yes

If yes, my firm anticipates negative effects as follows.

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 36

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Craig Thomsen (202-2053226, [email protected]).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products produced by your
firm.
Product 1.-- Assembled 30" width x 24" depth x 34-35" height base cabinet with three or four
drawers, painted, plywood box construction, shaker style or flush face doors
Product 2.-- Assembled 30" width x 12" depth x 30" height wall cabinet with two doors, painted,
plywood box construction, shaker style or flush face doors
Product 3.-- Assembled 36" width x 24" depth x 34-35" height sink base with two doors and one
or two faux drawer faces, painted, plywood box construction, shaker style or flush
face doors
Product 4.-- Assembled 36" width x 36" depth x 34-35" height corner cabinet with Lazy Susan,
painted, plywood box construction, shaker style or flush face doors
Product 5a.-- Assembled 18" width x 24" depth x 34-35" height base cabinet with one door and
one drawer, painted, plywood box construction, shaker style or flush face doors
Product 5b.-- RTA 18" width x 24" depth x 34-35" height base cabinet with one door and one
drawer, painted, plywood box construction, shaker style or flush face doors
Product 6a.-- Assembled 24" width x 21" depth x 34-35" height vanity base with two doors and
faux drawer face, no attached countertop or sink, painted, plywood box
construction, shaker style or flush face doors
Product 6b.-- RTA 24" width x 21" depth x 34-35" height vanity base with two doors and faux
drawer face, no attached countertop or sink, painted, plywood box construction,
shaker style or flush face doors
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.
inland transportation costs. Values should reflect the final net amount paid to your firm (i.e.,
should be net of all deductions for discounts or rebates).

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IV-2a. 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 tables as appropriate.
No.--Skip to question IV-3.

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

Product 2
Quantity
(number of
Value
cabinets)
(dollars)

Product 3
Quantity
(number of
Value
cabinets)
(dollars)

Product 4
Quantity
(number of
Value
cabinets)
(dollars)

Period of
shipment
2016:
Jan-Mar
Apr-June
July-Sep
Oct-Dec
2017:
Jan-Mar
Apr-June
July-Sep
Oct-Dec
2018:
Jan-Mar
Apr-June
July-Sep
Oct-Dec
2019:
Jan-Mar
Apr-June
July-Sep
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 38

IV-2b. Price data.—Continued.
Report data in number of cabinets and actual dollars (not 1,000s).
Product 5a
Quantity
(number of
Value
cabinets)
(dollars)

Product 5b
Quantity
(number of
Value
cabinets)
(dollars)

Product 6a
Quantity
(number of
Value
cabinets)
(dollars)

Product 6b
Quantity
(number of
Value
cabinets)
(dollars)

Period of
shipment
2016:
Jan-Mar
Apr-June
July-Sep
Oct-Dec
2017:
Jan-Mar
Apr-June
July-Sep
Oct-Dec
2018:
Jan-Mar
Apr-June
July-Sep
Oct-Dec
2019:
Jan-Mar
Apr-June
July-Sep
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 5a:
Product 5b:
Product 6a:
Product 6b:

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
IV-2c.

Page 39

Price data checklist.--Please check that the pricing data in question IV-2b has been correctly
reported.
Is the price data reported above:

√ if Yes

In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in questions II-7 and II-12 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.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

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Please note that the remaining questions in Part IV of this questionnaire refer to all kitchen cabinets
and bathroom vanities. If the answers to the questions in this section differs by product type (as
defined on pages 3-4) then indicate the difference the most appropriate narrative field; if a question
does not contain an available narrative field for such an explanation, indicate the difference in the in
question IV-23.
IV-3.

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

IV-4.

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of domestic wooden cabinets and vanities
usually quoted (check one)?
Delivered

IV-6.

Contracts

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

Quantity
discounts

IV-5.

Set
price
lists

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
wooden cabinets and vanities in 2018 was on a (1) short-term contract basis, (2) annual contract
basis, (3) long-term contract basis, and (4) spot sales basis?

Item
Share of 2018
sales

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)
%

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
IV-7.

Page 41

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced wooden cabinets and vanities (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

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

IV-8.

.

Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time in business days between a customer’s order and the date of delivery for
your firm’s sales of its U.S.-produced wooden cabinets and vanities?
Source

Share of 2018 sales

From inventory
Fully assembled

%

RTA Flat pack

%

Components

%

Produced to order
Fully assembled

%

RTA flat pack

%

Components

%

Total (should sum to 100.0%)

0.0

%

Lead time
(range of days)

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
IV-9.

Page 42

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced wooden cabinets and
vanities that is accounted for by U.S. inland transportation costs?
percent

(b)

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

(c)

Indicate the approximate percentage of your firm’s sales of wooden cabinets and
vanities that are delivered the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced cabinets since January 1, 2016 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

√ if applicable

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 43

IV-11. Sales representative agreements.-(a) Did your firm have contracts with independent sales representatives since January 1, 2016?
No

Yes--Please answer part (b).

(b) Did these contracts allow representation of product lines from different suppliers (whether
domestic or imported)?

No

Yes

If no, please describe the restrictions placed on independent sales
representatives in these contracts.

IV-12. Substitutes.--Can other products be substituted for wooden cabinets and vanities?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for wooden cabinets and
vanities?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for wooden cabinets and vanities has changed since January 1, 2016. Explain
any trends and describe the principal factors that have affected these changes in demand.

Market
Within the United States
Outside the United States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Business Proprietary
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Page 44

IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of wooden cabinets and vanities since January 1, 2016?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a) Is the wooden cabinets and vanities market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to wooden
cabinets and vanities? If yes, describe.
Check all that apply.

Please describe.

No

Skip to question IV-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
wooden cabinets and vanities since January 1, 2016?
No

Yes

If yes, describe.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 45

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply wooden cabinets
and vanities since January 1, 2016 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, being unable to meet timely shipment commitments,
etc.)?
No

Yes

If yes, please describe.

IV-17. Raw materials.--How have wooden cabinets and vanities raw material prices changed since
January 1, 2016?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for
wooden cabinets and vanities.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 46

IV-18. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products

under to section 301 have an impact on the wooden cabinet and vanity market in the
United States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced wooden
cabinets and vanities
containers
Supply of wooden
cabinets and vanities
imported from China
Supply of wooden
cabinets and vanities
imported from other
countries
Prices for wooden
cabinets and vanities
Overall U.S. demand
for wooden cabinets
and vanities
Raw material costs
for wooden cabinets
and vanities

No

Don’t know

Explain, noting how the
Fluctuate imposition of tariffs under section
with no
301 affected each factor of the
clear
wooden cabinet and vanity
Overall
No
Overall
increase change decrease trend
market in the United States.

Business Proprietary
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Page 47

IV-19. Interchangeability.--Is wooden cabinets and vanities 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 wooden cabinets and vanities that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:
.
IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wooden cabinets and
vanities 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 sales of wooden cabinets and vanities, identify the country-pair and
report the advantages or disadvantages imparted by such factors:
.

Business Proprietary
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IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for wooden cabinets and vanities since January 1, 2016. Indicate the share of the
quantity of your firm’s total shipments of wooden cabinets and vanities that each of these
customers accounted for in 2018.
Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2018
sales (%)

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 49

IV-22. Competition from imports.-(a)

Lost revenue.--Since January 1, 2016: To avoid losing sales to competitors selling
wooden cabinets and vanities from China, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2016: Did your firm lose sales of wooden cabinets and
vanities to imports of this product from China?
No

Yes

IV-23. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 50

PART V.--ALTERNATIVE PRODUCT INFORMATION
Further information on this part of the questionnaire can be obtained from Ahdia Bavari (202-205-3191,
[email protected]).
V-1.

Comparability of various products.--For each of the following indicate whether cabinets and
vanities are: fully comparable or the same, i.e., have no differentiation between them; mostly
comparable or similar; somewhat comparable or similar; never or not-at-all comparable or
similar; or no familiarity with products.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and End Uses.--The differences and similarities in the physical
characteristics and end uses.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:

Cabinets vs vanities
Furniture style vanities vs all other
cabinets and vanities
Hotel style cabinets and vanities
vs all other cabinets and vanities
(b) Interchangeability.--The ability to substitute the products in the same application.

Product-pair
Cabinets vs vanities
Furniture style vanities vs all other
cabinets and vanities
Hotel style cabinets and vanities
vs all other cabinets and vanities

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
V-1.

Page 51

Comparability of various products.--Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(c) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:

Cabinets vs vanities
Furniture style vanities vs all other
cabinets and vanities
Hotel style cabinets and vanities
vs all other cabinets and vanities
(d) Manufacturing facilities, production processes, and production employees.--Whether
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.

Product-pair
Cabinets vs vanities
Furniture style vanities vs all other
cabinets and vanities
Hotel style cabinets and vanities
vs all other cabinets and vanities

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)
V-1.

Page 52

Comparability of various products.--Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(e) Customer and producer perceptions.--Perceptions as to the differences and/or
similarities in the market (e.g., sales/marketing practices).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:

Cabinets vs vanities
Furniture style vanities vs all other
cabinets and vanities
Hotel style cabinets and vanities
vs all other cabinets and vanities
(f) Price.--Whether prices are comparable or differ between the products.

Product-pair
Cabinets vs vanities
Furniture style vanities vs all other
cabinets and vanities
Hotel style cabinets and vanities
vs all other cabinets and vanities

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:

Business Proprietary
U.S. Producers’ Questionnaire – Wooden Cabinets and Vanities (Final)

Page 53

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/wooden_cabinets_and_vanities_chi
na/final.htm.
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: CABN

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


File Typeapplication/pdf
File TitleUS producer questionnaire
SubjectTitle 7 investigations
AuthorChang, Calvin
File Modified2019-10-17
File Created2019-10-17

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