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U.S. PRODUCERS’ QUESTIONNAIRE
Sodium Sulfate Anhydrous from Canada
This questionnaire must be received by the Commission by January 8, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping duty investigation concerning sodium sulfate anhydrous from Canada (Inv. No. 731‐TA‐
1446 (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 sodium sulfate anhydrous (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: SSAF)
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 Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on March 28, 2019, by
Cooper Natural Resources, Inc., Fort Worth, Texas; Elementis Global LLC, East Windsor, New Jersey; and
Searles Valley Minerals, Inc., Overland Park, Kansas. Antidumping duties may be assessed on the subject
imports as a result of these proceedings if the Commission makes an affirmative determination of injury,
threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes an
affirmative determination of dumping. Questionnaires and other information pertinent to this
proceeding are available at
https://www.usitc.gov/investigations/701731/2019/sodium_sulfate_anhydrous_canada/final.htm
Sodium sulfate anhydrous covered by this investigation includes sodium sulfate (Na2 SO4) (Chemical
Abstracts Service (CAS) Number 7757‐82‐6) that is anhydrous (i.e., containing no water), regardless of
purity, grade, color, production method, and form of packaging, in which the percentage of particles
between 20 mesh and 100 mesh, based on U.S. mesh series screens, ranges from 10‐95% and the
percentage of particles finer than 100 mesh, based on U.S. mesh series screens, ranges from 5‐90%.
Excluded from the scope of this investigation are specialty sodium sulfate anhydrous products, which
are products whose particle distributions fall outside the described ranges. Glauber's salt (Na2 SO4∙10H2
O), also known as sodium sulfate decahydrate, an intermediate product Start Printed Page 60377in the
production of sodium sulfate anhydrous that has no known commercial uses, is not included within the
scope of the investigation, although some end‐users may mistakenly refer to sodium sulfate anhydrous
as Glauber's salt. Other forms of sodium sulfate that are hydrous (i.e., containing water) are also
excluded from the scope of the investigation.
Sodium sulfate anhydrous is currently imported under statistical reporting number 2833.11.5010 of the
Harmonized Tariff Schedule of the United States (HTSUS). It may also be imported under HTSUS
statistical reporting numbers 2833.11.1000, 2833.11.5050, and 2833.19.0000. The HTSUS provisions and
CAS registry number are for convenience and customs purposes; the written description of the scope is
dispositive.
Reporting of information.‐‐ If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
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
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 3
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
I‐1a.
Page 4
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
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
I‐2a.
Page 5
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of sodium sulfate anhydrous,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
I‐2c.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
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): .
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
I‐3.
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Canada
I‐6.
Support
Oppose
Take no position
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing sodium sulfate anhydrous from Canada into the United
States or that are engaged in exporting sodium sulfate anhydrous from Canada to the United
States?
No
Yes‐‐List the following information.
Petition support.‐‐Does your firm support or oppose the petition?
Country
I‐5.
Page 6
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
I‐7.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of sodium sulfate anhydrous?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202‐205‐
2136, [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 sodium sulfate anhydrous since January 1, 2016.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 9
II‐3a. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐3b. Product shifting.—
(i)
Is your firm able to switch production (capacity) between sodium sulfate anhydrous and
other products using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐4.
Tolling.‐‐Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of sodium sulfate anhydrous?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐ Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
II‐5.
Page 10
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce sodium sulfate anhydrous in and/or
admit sodium sulfate anhydrous into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐ Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import sodium sulfate anhydrous into a foreign trade zone (FTZ) for use in distribution
of sodium sulfate anhydrous and/or the production of downstream articles?
II‐6.
No
Yes
If yes‐‐Identify the firms and the FTZs.
Importer.‐‐Since January 1, 2016, has your firm imported sodium sulfate anhydrous?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes‐‐ COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
II‐7 & II‐8.
Page 11
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of sodium sulfate anhydrous in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 12
II‐7a. Production, shipment, and inventory data.—Continued
Naturally-produced sodium sulfate anhydrous
(i.e., sodium sulfate anhydrous that is produced from lake brine)
Quantity (in short tons) and value (in dollars)
Calendar years
Item
2016
1
2017
January‐September
2018
2018
2019
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
2
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐period
inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus production (i.e., line C), less
total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data entry errors in completing
this form, but rather reflect your firm’s actual records; and, also provide explanations for any differences (e.g., theft, loss,
damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
2016
2017
0
January‐September
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
0
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 13
II‐7b. Channels of distribution (NATURALLY‐PRODUCED).‐‐Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) by
channel of distribution.
Naturally-produced sodium sulfate anhydrous
Quantity (in short tons); Value (in dollars)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To distributors
Quantity (M)
2016
2017
January‐September
2018
2018
2019
Value (N)
To end users
Quantity (O)
Value (P)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through P) in each time period equal the quantity and value reported for U.S.
shipments (i.e., lines D through I) in each time period. 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: M + O – D – F – H = zero
("0"), if not revise.
0
0
0
0
0
Value: N + P – E – G – I = zero ("0"), if
not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
II‐7c.
Page 14
Employment data.‐‐Report your firm’s employment‐related data related to the production of
naturally‐produced sodium sulfate anhydrous and provide an explanation for any trends in these
data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to September periods, calculate similarly and divide by 9.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).”
“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.
Naturally‐produced sodium sulfate anhydrous
Calendar years
Item
2016
2017
January‐September
2018
2018
2019
Average number of PRWs (number)
Hours worked by PRWs (actual hours)
Wages paid to PRWs (dollars)
Explanation of trends:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 15
II‐8a. Production, shipment, and inventory data.—Continued
Synthetically-produced sodium sulfate anhydrous
(i.e., sodium sulfate anhydrous that is a by‐product of other chemical and manufacturing processes)
Quantity (in short tons) and value (in dollars)
Calendar years
Item
2016
1
2017
January‐September
2018
2018
2019
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
2
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐period
inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus production (i.e., line C), less
total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data entry errors in completing
this form, but rather reflect your firm’s actual records; and, also provide explanations for any differences (e.g., theft, loss,
damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
2016
2017
0
January‐September
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
0
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 16
II‐8b. Channels of distribution (SYNTHETICALLY‐PRODUCED).‐‐Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) by
channel of distribution.
Synthetically-produced sodium sulfate anhydrous
Quantity (in short tons); Value (in dollars)
Calendar years
Item
Channels of distribution:
U.S. shipments:
To distributors
Quantity (M)
2016
2017
January‐September
2018
2018
2019
Value (N)
To end users
Quantity (O)
Value (P)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities and values reported for channels of
distribution (i.e., lines M through P) in each time period equal the quantity and value reported for U.S.
shipments (i.e., lines D through I) in each time period. 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: M + O – D – F – H = zero
("0"), if not revise.
0
0
0
0
0
Value: N + P – E – G – I = zero ("0"), if
not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
II‐8c.
Page 17
Employment data.‐‐Report your firm’s employment‐related data related to the production of
synthetically‐produced sodium sulfate anhydrous and provide an explanation for any trends in
these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to September periods, calculate similarly and divide by 9.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).”
“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.
Synthetically‐produced sodium sulfate anhydrous
Calendar years
Item
2016
2017
January‐September
2018
2018
2019
Average number of PRWs (number)
Hours worked by PRWs (actual hours)
Wages paid to PRWs (dollars)
Explanation of trends:
II‐10. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non‐market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 18
II‐11. Purchases.‐‐ Has your firm purchased sodium sulfate anhydrous produced in the United States
or in other countries since January 1, 2016? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐ Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in short tons)
Calendar years
Item
2016
2017
January‐September
2018
2018
2019
1
Purchases from U.S. importers
of sodium sulfate anhydrous
from—
Canada
All other sources
Purchases from domestic
producers2
2
Purchases from other sources
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s
import suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this
product: .
II‐12. 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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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 19
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[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 sodium sulfate anhydrous:
2. Does your firm prepare profit/loss statements for sodium sulfate anhydrous:
Yes
No
3. 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
4. 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 sodium sulfate
anhydrous, as well as specific statements and worksheets) used to compile these data.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 20
III‐3.
Please indicate below how your company accounts for sodium sulfate anhydrous in its financial
records:
Product/co‐product (Naturally‐produced sodium sulfate anhydrous)
If your company accounts for sodium sulfate anhydrous as a product/co‐
product, please complete, as applicable, questions III‐4 through III‐10, III‐12, III‐
13 and III‐15 through III‐22.
Product/co‐product (Synthetically‐produced sodium sulfate anhydrous)
If your company accounts for sodium sulfate anhydrous as a product/co‐
product, please complete, as applicable, questions III‐4 through III‐9, III‐11
through III‐13, and III‐15 through III‐22.
Byproduct (Synthetically‐produced sodium sulfate anhydrous)
If your company accounts for sodium sulfate anhydrous as a byproduct, please
complete, as applicable, questions III‐4 through III‐9, and III‐14 through III‐22.
III‐4. A.
Cost accounting system.‐‐For product/co‐product producers and byproduct producers,
please briefly describe your firm’s cost accounting system (e.g., standard cost, job order
cost, etc.).
B.
For co‐product producers only, please generally describe the joint and separable costs
and their assignment to sodium sulfate anhydrous (as reported in question III‐10 or III‐
11, as applicable).
Please identify relevant co‐products.
C.
For byproduct producers only, please describe the general terms of sale associated with
sodium sulfate anhydrous. In your description, please also describe the extent to which
amounts paid by the purchaser of sodium sulfate anhydrous are fixed for a specific
period and/or also incorporate a variable component; e.g., which adjusts the amount
received for the ultimate sales price paid by the end user/final customer.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
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Please describe any relevant revenue adjustments or “true‐ups” associated with
byproduct sales activity and confirm, as appropriate, that all relevant adjustments are
included in the total byproduct sales revenue reported in table III‐14.
Please describe how byproduct sodium sulfate anhydrous is normally accounted for in
the company’s financial results (e.g., deduction to primary product costs or as part of
“other income”).
Please generally describe the separable byproduct‐related manufacturing/processing
costs/expenses and/or SG&A expenses incurred (as reported in question III‐14).
Please also identify the relevant primary product or products that yield byproduct
sodium sulfate anhydrous.
III‐5a. Allocation basis.‐‐For product/co‐product producers, please briefly describe your firm’s
allocation basis, if any, for COGS, SG&A, and interest expense and other income and expenses
(as reported in question III‐10 or question III‐11, as applicable).
For byproduct producers, please describe your firm’s allocation basis, if any, for separable
byproduct‐related manufacturing/processing costs/expenses and/or SG&A expenses (as
reported in question III‐14).
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 22
III‐5b. Production decisions.‐‐If your firm is a co‐product or byproduct producer, please indicate
which product primarily drives your firm’s production decisions for sodium sulfate
anhydrous (check only one option) and describe the primary factors involved in the
production decision(s).
Solely sodium
sulfate anhydrous
Primarily sodium
sulfate
anhydrous
Equally sodium
sulfate
anhydrous and
relevant co‐/
primary
product(s)
Primarily
relevant co‐/
primary
product(s)
Solely relevant co‐/
primary product(s)
Please describe the factors driving the production decision(s).
III‐6.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced sodium sulfate anhydrous, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products
Share of sales
Sodium sulfate anhydrous
%
%
%
%
%
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
III‐7.
Page 23
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of sodium sulfate anhydrous from any related suppliers
(e.g., inclusive of transactions between related firms, divisions and/or other components within
the same company)? Note: For byproduct producers, relevant inputs in the context of this
question relate to the further manufacturing/processing and sale of byproduct sodium sulfate
anhydrous, not the primary product.
Yes‐‐Continue to question III‐8
III‐8.
No‐‐Product/co‐product producers (Naturally‐
produced SSA) continue to question III‐10.
No‐‐Product/co‐product producers (Synthetically‐
produced SSA) continue to question III‐11.
No‐‐Byproduct producers continue to question III‐14.
Inputs from related suppliers detailed.‐‐For product/co‐product producers, please identify the
inputs used in the production of sodium sulfate anhydrous that your firm purchases from
related suppliers and that are reflected, as applicable, in question III‐10 or III‐11. For byproduct
producers, please identify the inputs used in the further manufacturing/processing and sale of
byproduct sodium sulfate anhydrous that your firm purchases from related suppliers and that
are reflected in question III‐14. For “Share of total COGS” and “Share of total separable
byproduct costs/expenses,” as applicable depending on production method, please report this
information by relevant input on the basis of your most recently completed fiscal year. For
“Input valuation” please describe the basis, as recorded in your company’s own accounting
system, of the purchase cost from the related supplier; e.g., the related supplier’s actual cost,
cost plus, negotiated transfer price to approximate fair market value.
Share of total product/co‐
product COGS or Share of
total separable byproduct
Input
Related supplier
costs/expenses
Input valuation as recorded in the firm’s accounting books and records
III‐9.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐8, were reported, as applicable, in questions III‐10, III‐11, or
III‐14 in a manner consistent with your firm’s accounting books and records.
Yes
No
If no‐‐In the space below and as applicable, please report the valuation
basis of inputs purchased from related suppliers as reported in questions
III‐10, III‐11, or III‐14.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 24
III‐10. Product/co‐product operations on naturally‐produced sodium sulfate anhydrous.‐‐Report the
revenue and related cost information requested below on the primary/co‐product operations of
your firm’s U.S. establishment(s).1 Do not report resales of products. Note that internal
consumption and transfers to related firms must be valued at fair market value. Input purchases
from related suppliers should be consistent with and based on information in the firm’s
accounting books and records. Provide data for your firm’s three most recently completed fiscal
years, and for the specified interim periods.
Quantity (in short tons) and value (in dollars)
Fiscal years ended‐‐
Item
2016
2017
January‐September
2018
2018
2019
Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
Raw materials
Direct labor
Other factory costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total net sales quantities
Net sales values:2
Total net sales values
Cost of goods sold (COGS):3
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included
above4
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment
quantities and values reported in Part II (naturally‐produced sodium sulfate anhydrous) of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 To the extent the company incurred depreciation/amortization, which is included in reported COGS, SG&A expenses, and/or all other
expenses, please separately report these amounts for each year in this line item.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 25
III‐11. Product/co‐product operations on synthetically‐produced sodium sulfate anhydrous.‐‐Report
the revenue and related cost information requested below on the primary/co‐product
operations of your firm’s U.S. establishment(s).1 Do not report resales of products. Note that
internal consumption and transfers to related firms must be valued at fair market value. Input
purchases from related suppliers should be consistent with and based on information in the
firm’s accounting books and records. Provide data for your firm’s three most recently completed
fiscal years, and for the specified interim periods.
Quantity (in short tons) and value (in dollars)
Fiscal years ended‐‐
Item
2016
2017
January‐September
2018
2018
2019
Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
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
All other expense items
All other income items
0
0
0
0
0
Total net sales quantities
Net sales values:2
Total net sales values
Cost of goods sold (COGS):3
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
Net income or (loss) before income taxes
Depreciation/amortization included
above4
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment
quantities and values reported in Part II (synthetically‐produced sodium sulfate anhydrous) of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 To the extent the company incurred depreciation/amortization, which is included in reported COGS, SG&A expenses, and/or all
other expenses, please separately report these amounts for each year in this line item.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 26
III‐12. Nonrecurring items (charges and gains) included in product/co‐product sodium sulfate
anhydrous financial results (natural and synthetic production).‐‐For each annual period for
which financial results are reported in question III‐10 or III‐11, please specify all material
(significant) nonrecurring items (charges and gains) in the schedule below, the specific question
III‐10 or III‐11 line item where the nonrecurring items are included, a brief description of the
relevant nonrecurring items, and the associated values (in dollars), as reflected in question III‐10
or III‐11; i.e., if an aggregate nonrecurring item has been allocated to question III‐10 or III‐11,
only the allocated value amount included in question III‐10 or III‐11 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 financial results reported in
question III‐10 or III‐11.
Fiscal years ended‐‐
2016
January‐September
2017
2018
2018
2019
Value (in dollars)
Item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III‐10 or III‐11, as applicable, where the nonrecurring item is classified.
Item
Description of the nonrecurring item
Income statement classification 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
III‐13. 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‐12 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‐12 identify where these items
are reported, as applicable, in question III‐10 or III‐11.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 27
III‐14. Byproduct operations on sodium sulfate anhydrous.‐‐Report the revenue and incremental
cost/expense information requested below on the byproduct sodium sulfate anhydrous
operations of your firm’s U.S. establishment(s).1 Total byproduct revenue should, as applicable,
include all relevant true‐ups and/or adjustments associated with variable components of
revenue (see question III‐4.C. above). Do not report resales of products. Note that internal
consumption and transfers to related firms must be valued at fair market value. Input purchases
from related suppliers should be consistent with and based on information in the firm’s
accounting books and records. Provide data for your firm’s three most recently completed fiscal
years, and for the specified interim periods.
Quantity (in short tons) and value (in dollars)
Fiscal years ended‐‐
Item
2016
2017
January‐September
2018
2018
2019
Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Commercial sales
Internal consumption
Transfers to related firms
0
0
0
0
0
0
0
0
0
0
Total net sales quantities
Net sales values:2
Total net sales values
Separable byproduct costs/expenses
Manufacturing/processing costs:3
Selling, general, and administrative
(SG&A) expenses4
Net byproduct revenue
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Total byproduct revenue should, as applicable, include all relevant true‐ups and/or adjustments associated with variable components
of revenue (see question III‐4.C.) or equivalent. Less discounts, returns, allowances, and prepaid freight. The quantities and values should
approximate the corresponding shipment quantities and values reported in Part II (synthetically‐produced sodium sulfate anhydrous) of
this questionnaire.
3 Manufacturing/processing costs specific to or assignable to byproduct sodium sulfate anhydrous.
4 SG&A expenses specific to or assignable to byproduct sodium sulfate anhydrous, incurred to sell byproduct. As applicable,
commissions paid to sales agent should be reported as a component of separable SG&A expense, as opposed to a deduction to revenue.
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Page 28
Note: The remaining questions in this part of the U.S. producer questionnaire (Part III) should be
completed, as applicable, by both product/co‐product producers and byproduct producers.
III‐15. Financial data reconciliation.‐‐As applicable, the calculable line items from questions III‐10, III‐
11, and III‐14 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.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 29
III‐16. Asset values.—In the line item specific to the sodium sulfate anhydrous activity specific to your
firm’s operations, report the total assets (i.e., both current and long‐term assets) associated
with the production, warehousing, and sale of sodium sulfate anhydrous. (Note: Byproduct
producers should report total net assets that are specific or assignable to byproduct activity
only; i.e., please do not include assets that are specific or assignable to primary operations.) If
your firm does not maintain some or all of the specific asset information necessary to calculate
total assets for sodium sulfate anhydrous 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 questions III‐10, III‐11, and III‐14, as applicable. Provide data as of the
end of your firm’s three most recently completed fiscal years, and for the specified interim
periods.
(Note: Total assets should reflect net assets after any accumulated depreciation and
allowances deducted. Total assets should be allocated to sodium sulfate anhydrous if these
assets are also related to other products.)
Value (in dollars)
Fiscal years ended‐‐
Item
2016
Total assets (net).‐‐
Product/coproduct
producers (naturally‐
produced SSA) 1
Product/coproduct
producers (synthetically‐
produced SSA)1
2
Byproduct producers
1
2017
January‐September
2018
2018
2019
Product/co‐product producers (natural and synthetic), please describe any substantial changes in total asset value
during the period; e.g., due to asset write‐offs, revaluation, and major purchases: .
2
Byproduct producers, please describe any substantial changes in total asset value during the period; e.g., due to asset
write‐offs, revaluation, and major purchases: .
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Page 30
III‐17. Capital expenditures and research and development (R&D) expenses.‐‐In the line item specific
to the sodium sulfate anhydrous activity specific to your firm’s operations, report your firm’s
capital expenditures and R&D expenses related to sodium sulfate anhydrous. (Note: Byproduct
producers should report capital expenditures and R&D expenses that are specific or assignable
to byproduct activity only; i.e., please do not include capital expenditures and R&D expenses
that are specific or assignable to primary operations.) Provide data for your firm’s three most
recently completed fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years ended‐‐
Item
2016
Capital expenditures.‐‐
Product/coproduct
producers (naturally‐
produced SSA) 1
Product/coproduct
producers (synthetically‐
produced SSA)1
2
Byproduct producers
R&D expenses.‐‐
Product/coproduct
producers (naturally‐
produced SSA) 3
Product/coproduct
producers (synthetically‐
produced SSA)3
4
Byproduct producers
1
2017
January‐September
2018
2018
2019
Product/coproduct producers (natural and synthetic), please describe the nature, focus, and significance of
your firm’s capital expenditures related to sodium sulfate anhydrous. .
2
Byproduct producers, please describe the nature, focus, and significance of your firm’s capital expenditures
related to sodium sulfate anhydrous. .
3
Product/coproduct producers (natural and synthetic), please describe the nature, focus, and significance of
your firm’s R&D expenses related to sodium sulfate anhydrous. .
4
Byproduct producers, please describe the nature, focus, and significance of your firm’s R&D expenses related to
sodium sulfate anhydrous. .
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III‐18. Data consistency and reconciliation.‐‐As applicable, please indicate whether your firm’s
financial data for questions are based on a calendar year or on your firm’s fiscal year:
Data Grids
Calendar year
Fiscal year
Specify fiscal year
For product/coproduct producers (naturally‐produced
SSA): III‐10, III‐16, and III‐17
For product/coproduct producers (synthetically ‐
produced SSA): III‐11, III‐16, and III‐17
Byproduct producers: III‐14, III‐16, and III‐17
Please note that, depending on the type of production engaged in, the quantities and values
reported in question III‐10 (product/co‐product producers (naturally‐produced sodium sulfate
anhydrous)), question III‐11 (product/co‐product producers (synthetically‐produced sodium
sulfate anhydrous)), or question III‐14 (byproduct producers) should reconcile with the data
reported in question II‐7a (naturally‐produced sodium sulfate anhydrous) (including export
shipments) or question II‐8a (synthetically‐produced sodium sulfate anhydrous) (including
export shipments), respectively, as long as they are reported on the same calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the relevant quantities and values
reported for total shipments in part II equal the quantities and values reported for total net sales in part
III of this questionnaire in each time period unless the financial data from part III are reported on a fiscal
year basis, in which case only the interim periods must reconcile. If the calculated fields below return
values other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the
discrepancy below.
Reconciliation specific to sodium sulfate anhydrous product/co‐product operations (natural production):
January‐September
Fiscal years ended‐‐
Reconciliation
2016
2017
2018
2018
2019
Quantity: Trade data
from question II‐7a (lines
D, F, H, and J) less
financial total net sales
quantity data from
question III‐10, = zero
("0").
0
0
0
0
0
Value: Trade data from
question II‐7a (lines E, G,
I, and K) less financial
total net sales value data
from question III‐10, =
zero ("0").
0
0
0
0
0
If applicable, do these data in question III‐10 reconcile with data in question II‐7a?
Yes
No
If no, please explain.
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Reconciliation specific to sodium sulfate anhydrous product/co‐product operations (synthetic
production):
January‐September
Fiscal years ended‐‐
Reconciliation
2016
2017
2018
2018
2019
Quantity: Trade data
from question II‐8a (lines
D, F, H, and J) less
financial total net sales
quantity data from
question III‐11, = zero
("0").
0
0
0
0
0
Value: Trade data from
question II‐8a (lines E, G,
I, and K) less financial
total net sales value data
from question III‐11, =
zero ("0").
0
0
0
0
0
If applicable, do these data in question III‐11 reconcile with data in question II‐8a?
Yes
No
If no, please explain.
Reconciliation specific to sodium sulfate anhydrous byproduct operations (synthetic production):
January‐
September
Fiscal years ended‐‐
Reconciliation
2016
2017
2018
2018
2019
Quantity: Trade data from question II‐8a (lines D, F, H, and J)
less financial total net sales quantity data from question III‐
14, = zero ("0").
0
0
0
0
0
Value: Trade data from question II‐8a (lines E, G, I, and K)
less financial total net sales value data from question III‐14, =
zero ("0").
0
0
0
0
0
Do these data in question III‐14 reconcile with data in question II‐8a?
Yes
No
If no, please explain.
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
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III‐19. 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 sodium sulfate anhydrous from Canada?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
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
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U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 34
III‐20. 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 sodium sulfate anhydrous from Canada?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
III‐21. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
sodium sulfate anhydrous from Canada?
No
Yes
If yes, my firm anticipates negative effects as follows.
III‐22. 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 – Sodium Sulfate Anhydrous (Final)
Page 35
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202‐205‐
3250, [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.—Sodium sulfate anhydrous in bulk, hopper cars (approximately 100 short tons)
Product 2.—Sodium sulfate anhydrous in bulk, trucks (approximately 25 short tons)
Product 3.—Sodium sulfate anhydrous in 2,000 pound supersacs
Product 4.—Sodium sulfate anhydrous in 50 pound bags
Please report the values as f.o.b., U.S. factory/warehouse (the price net of any logistical and
transportation costs), and delivered price (which includes all logistical and transportation costs) in the
appropriate columns. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV‐2a. During January 2016‐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.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 36
IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to distributors.
Sales to Distributors
Report data in short tons and dollars.
(Quantity in short tons, value in dollars)
Product 1
Value –
Value –
f.o.b.3
delivered4
Quantity
Product 2
Value –
Period of shipment
Quantity
Value – f.o.b.3
delivered4
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, prepaid freight, and the value of returned
goods).
2 Pricing product definitions are provided on the first page of Part IV.
3 F.o.b., U.S. factory/warehouse price, i.e. the price at the door of the production facility.
4 Delivered price, inclusive of all transportation and logistical costs.
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:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 37
IV‐2b. Price data ‐ Continued.‐‐Report below the quarterly price data1 for pricing products2 produced
and sold by your firm to distributors.
Sales to Distributors
Report data in short tons and dollars.
(Quantity in short tons, value in dollars)
Product 3
Value –
Value –
f.o.b.3
delivered4
Quantity
Product 4
Value –
Period of shipment
Quantity
Value – f.o.b.3
delivered4
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, prepaid freight, and the value of returned
goods).
2 Pricing product definitions are provided on the first page of Part IV.
3 F.o.b., U.S. factory/warehouse price, i.e. the price at the door of the production facility.
4 Delivered price, inclusive of all transportation and logistical costs.
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 3:
Product 4:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 38
IV‐2c. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to end users.
Sales to End Users
Report data in short tons and dollars.
(Quantity in short tons, value in dollars)
Product 1
Value –
Value –
f.o.b.3
delivered4
Quantity
Product 2
Value –
Period of shipment
Quantity
Value – f.o.b.3
delivered4
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, prepaid freight, and the value of returned
goods).
2 Pricing product definitions are provided on the first page of Part IV.
3 F.o.b., U.S. factory/warehouse price, i.e. the price at the door of the production facility.
4 Delivered price, inclusive of all transportation and logistical costs.
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:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 39
IV‐2c. Price data ‐ Continued.‐‐Report below the quarterly price data1 for pricing products2 produced
and sold by your firm to end users.
Sales to End Users
Report data in short tons and dollars.
(Quantity in short tons, value in dollars)
Product 3
Value –
Value –
f.o.b.3
delivered4
Quantity
Product 4
Value –
Period of shipment
Quantity
Value – f.o.b.3
delivered4
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, prepaid freight, and the value of returned
goods).
2 Pricing product definitions are provided on the first page of Part IV.
3 F.o.b., U.S. factory/warehouse price, i.e. the price at the door of the production facility.
4 Delivered price, inclusive of all transportation and logistical costs.
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 3:
Product 4:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 40
IV‐2d. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
In dollars (not $1,000)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II‐7 in each year?
IV‐2d. Pricing data preparation.‐‐Please indicate how your firm quotes prices and how your firm
prepared the price data in questions IV‐2(a) to IV‐2(c).
Quote f.o.b factory/warehouse price.‐‐My firm quotes on an f.o.b. price, net of any
transportation and logistical costs. My firm reported the actual f.o.b. price and
reported a constructed delivered price.
Quote delivered.‐‐My firm quotes on a delivered price, including any transportation
and logistical costs. My firm reported the actual delivered price and reported a
constructed f.o.b. price.
IV‐2e. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data. In particular, please describe in detail the method
that was used to convert an actual price to a constructed price, depending on your firm’s answer
to Question IV‐2d above.
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 – Sodium Sulfate Anhydrous (Final)
IV‐3.
Page 41
Price setting.‐‐How does your firm determine the prices that it charges for sales of sodium
sulfate anhydrous (check all that apply)? If your firm issues price lists, please submit sample
pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐ On what basis are your firm’s prices of domestic sodium sulfate anhydrous
usually quoted (check one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced
sodium sulfate anhydrous 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
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
IV‐7.
Page 42
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced sodium sulfate anhydrous (or check “not applicable” if your firm does not sell on
a short‐term, annual and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
IV‐8.
Lead times.‐‐What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.‐produced sodium sulfate anhydrous?
Lead time (Average
Source
Share of 2018 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
IV‐9.
Page 43
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced sodium sulfate
anhydrous that is accounted for by U.S. inland transportation and logistical costs?
percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of sodium sulfate anhydrous
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 sodium sulfate anhydrous since January 1, 2016 (check all that apply)?
Geographic area
Share of volume
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.
%
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 44
IV‐11. End uses.‐‐List the end uses of the sodium sulfate anhydrous that your firm manufactures. For
each end‐use product, what percentage of the total cost is accounted for by sodium sulfate
anhydrous and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
Sodium sulfate
100.0% across)
End‐use product
anhydrous
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐12. Substitutes.‐‐ Can other products be substituted for sodium sulfate anhydrous?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for sodium sulfate
anhydrous?
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 sodium sulfate anhydrous has changed since January 1, 2016. Explain any
trends and describe the principal factors that have affected these changes in demand.
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Market
Explanation and factors
Within the United States
Outside the United States
IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of sodium sulfate anhydrous since January 1, 2016?
No
Yes
If yes, please describe and quantify if possible.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 45
IV‐15. Conditions of competition.‐‐
(a) Is the sodium sulfate anhydrous market subject to business cycles (other than general
economy‐wide conditions) and/or other conditions of competition distinctive to sodium
sulfate anhydrous? 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
sodium sulfate anhydrous since January 1, 2016?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply sodium sulfate
anhydrous 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 sodium sulfate anhydrous raw material prices changed since January
1, 2016?
Fluctuate
Explain, noting how raw material price changes
Overall
No
Overall
with no have affected your firm’s selling prices for sodium
increase change decrease clear trend
sulfate anhydrous.
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 46
IV‐18. Role of Giles and Saltex in prices.—Explain how Giles and Saltex affect the price of sodium
sulfate anhydrous?
IV‐19. Natural vs synthetic interchangeability.‐‐How frequently are natural SSA interchangeable with
synthetic SSA (i.e., can they physically be used in the same applications)?
Always
Usually
Sometimes
Rarely or never
Please explain:
IV‐20. Interchangeability.‐‐Is sodium sulfate anhydrous 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
Canada
Other countries
United States
Canada
For any country‐pair producing sodium sulfate anhydrous that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that limit or preclude
interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 47
IV‐21. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between sodium sulfate
anhydrous 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
United States
Canada
Canada
Other countries
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of sodium sulfate anhydrous, identify the country‐pair and report
the advantages or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 48
IV‐22. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for sodium sulfate anhydrous since January 1, 2016. Indicate the share of the
quantity of your firm’s total shipments of sodium sulfate anhydrous that each of these
customers accounted for in 2018.
Customer’s name
State
Share of 2018 sales (%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire – Sodium Sulfate Anhydrous (Final)
Page 49
IV‐23. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2016: To avoid losing sales to competitors selling
sodium sulfate anhydrous from Canada, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2016: Did your firm lose sales of sodium sulfate anhydrous
to imports of this product from Canada?
No
Yes
IV‐24. 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 – Sodium Sulfate Anhydrous (Final)
Page 50
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/sodium_sulfate_anhydrous_canada
/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: SSAF
• 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 (202‐
205‐1803). 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 producers--SSA(F) |
| Author | keysha.martinez |
| File Modified | 2019-11-19 |
| File Created | 2019-11-19 |