Form 20-1-4161 U.S. producers' questionnaire

OMB No. 3117-0016/USITC No. 20-1-4161; Expiration Date: : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
WOOD MOULDINGS AND MILLWORK PRODUCTS FROM BRAZIL AND CHINA
This questionnaire must be received by the Commission by January 22, 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 countervailing and antidumping duty investigations concerning wood mouldings and millwork
products and millwork products from Brazil and China (Inv. Nos. 701-TA-636 and 731-TA-1469-1470 (Preliminary)). 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 wood mouldings and millwork products (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: WOOD)
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 – Wood Mouldings and Millwork Products (Preliminary)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on January 8, 2020, by the
Coalition of American Millwork Producers. 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/701731/2020/wood_mouldings_and_millwork_products_brazil_a
nd/preliminary.htm.
Wood mouldings and millwork products covered by these investigations are made of wood (regardless
of wood species), laminated veneer lumber (LVL), or of wood and composite materials (where the
composite materials make up less than 50 percent of the total merchandise), and which are woodwork
or building materials that are produced in a mill or otherwise undergo remanufacturing.
The covered products include, but are not limited to, the following: interior and exterior door frames or
jambs (including split, flat, stop applied, single- or double-rabbeted), frame or jamb kits, packaged door
frame trim or casing sets, mullions, mull posts, mouldings (crowns, beds, coves, quarter rounds, half
rounds, base shoes, astragals, shelf edge/screen moulds, glass bead mouldings, base caps, brickmould,
panel mouldings, drip caps, comer guards, shingle/panel mouldings, battens, closet rod, hand rails,
rounds, squares, screen/"surfaced on 4 sides" (S4S) and/or "surface 1 side, 2 edges" (S1S2E) stock (also
called boards) that are finger jointed and/or coated with any surface coating (including primed), lattice,
dowels, picture moulding, wainscot/ply cap, back bands, chair rails, stops, sashes, base mouldings,
casing, trim, panel strips, shelf cleats, chamfer strips, inside comers, window stools (flat/rabbeted), sills,
door stiles, thresholds/saddles, decorative wood mouldings (embossed, dentil, carved rope moulding),
rosettes, plinth blocks, interior siding, including nickel gap or shiplap, that is LVL or finger jointed and/or
coated with any surface coating (including primed), and finger-jointed or edge-glued moulding or
millwork blanks (whether or not resawn).
The covered products may be solid wood, laminated, finger-jointed, edge-glued, or otherwise joined in
the production or remanufacturing process and are covered by the scope whether imported raw, coated
(e.g., gesso, polymer, or plastic), primed, painted, stained, wrapped (paper or vinyl overlay), any
combination of the aforementioned surface coatings, treated, or which incorporate rot-resistant
elements (whether wood or composite). The covered products are covered by the scope whether or not
any surface coating(s) or covers obscures the grain, textures, or markings of the wood, whether or not
they are ready for use or require final machining (e.g. endwork/dado, hinge/strike machining,
weatherstrip or application thereof, mitre) or packaging.
All wood mouldings and millwork products are included within the scope even if they are trimmed; cutto-size; notched; punched; drilled; or have undergone other forms of minor processing. Subject
merchandise also includes wood mouldings and millwork products that have been further processed in a
third country, including but not limited to trimming, cutting, notching, punching, drilling, coating, or any
other processing that would not otherwise remove the merchandise from the scope of the
investigations if performed in the country of manufacture of the in-scope product.
Excluded from the scope of these investigations are exterior fencing, exterior decking and exterior siding
products, finished and unfinished doors, flooring, and parts of stair steps.
Excluded from the scope of these investigations are all products covered by the scope of the
antidumping and countervailing duty orders on Hardwood Plywood from the People's Republic of China.

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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).
Excluded from the scope of these investigations are all products covered by the scope of the
antidumping and countervailing duty orders on Multilayered Wood Flooring from the People's Republic
of China. Multilayered Wood Flooring From the People's Republic of China: Amended Final Determination
of Sales at Less Than Fair Value and Antidumping Duty Order, 76 FR 76690 (December 8, 2011);
Multilayered Wood Flooring from the People's Republic of China: Countervailing Duty Order, 76 FR 76693
(December 8, 2011).
Wood mouldings and millwork products are currently imported under statistical reporting numbers
4409.10.4010, 4409.10.4090, 4409.10.4500, 4409.10.5000, 4409.22.4000, 4409.22.5000, 4409.29.4000,
4409.29.4100, 4409.29.5000, and 4409.29.5100 of the Harmonized Tariff Schedule of the United States
(HTSUS). They may also be imported under HTSUS statistical reporting numbers 4409.10.6000,
4409.10.6500, 4409.22.6000, 4409.22.6500, 4409.29.6100, 4409.29.6600, 4418.99.9095 and
4421.99.9780. The HTSUS provisions 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
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 wood mouldings and millwork products 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 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.

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

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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, contact person’s
title, 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 – Wood Mouldings and Millwork Products (Preliminary)
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 wood mouldings and
millwork products, 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
7
8
9
10
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

Yes

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
I-4.

Page 6

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

Support

Oppose

Take no position

Brazil AD
China AD
China CVD
I-5.

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

Firm name

I-6.

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

Country

Extent of
ownership
(percent)

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
I-7.

Page 7

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Charles Cummings (202-7081666, [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 wood mouldings and millwork products since January 1,
2016.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-3a.

Page 9

Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce wood mouldings and millwork
products, and the combined production capacity on this shared equipment, machinery, or
employees in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in board feet)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Overall production capacity

1

Production of:
Wood mouldings and millwork products2

0

0

0

0

0

0

0

0

0

0

Other products

3

Total production using same
machinery or workers

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of wood mouldings and millwork products will populate here once reported in
question II-7.
3
Please identify these products:
.
1
2

II-3b.

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

Weeks per year

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

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II-3c.

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

II-3d.

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

II-4.

Product shifting.—
(a)

Is your firm able to switch production (capacity) between wood mouldings and millwork
products and other products using the same equipment and/or labor?

No

(b)

II-5.

Yes

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

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

Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of wood mouldings and millwork products?
“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.

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-6.

Page 11

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce wood mouldings and millwork products
in and/or admit wood mouldings and millwork products 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 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).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import wood mouldings and millwork products into a foreign trade zone (FTZ) for use in
distribution of wood mouldings and millwork products and/or the production of
downstream articles?

(b)

No

Yes

If yes--Identify the firms and the FTZs.

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-7.

Page 12

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of wood mouldings and millwork products
in its U.S. establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-7.

Page 13

Production, shipment, and inventory data.--Continued
Quantity (in board feet) and value (in dollars)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Average production capacity (quantity) (A)
1

Beginning-of-period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including product
shipped to your firm's retail
establishments:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
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

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1

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:
.
1

0

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

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

II-8.

Quantity (in board feet)
Calendar years
Item

2016

January-September

2017

2018

2018

2019

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

2016

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

January-September

2017
0

2018
0

2018
0

2019
0

U.S. shipments by material.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of wood mouldings and
millwork products, by material.

II-9.

Quantity (in board feet), Value (dollars)
Calendar year
Item
U.S. shipments:
Softwood material1
Quantity (P)
Value (Q)
Hardwood material (temperate)2
Quantity (R)
Value (S)
Hardwood material (tropical)3
Quantity (T)
Value (U)
Laminated veneer lumber
Quantity (V)
Value (W)
Combination of wood/composite materials
Quantity (X)
Value (Y)
Please identify the wood species
Please identify the wood species
3.
Please identify the wood species
1.
2.

2018

0

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RECONCILIATION OF U.S. SHIPMENTS BY MATERIAL.--Please ensure that the quantities and values reported for U.S.
shipments by material (i.e., lines P through W) 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 year
Reconciliation

2018

Quantity: P + R + T + V + X – D - F- H = zero
("0"), if not revise.

0

Value: Q+ S + U + W +Y – E - G- I = zero ("0"), if
not revise.

0

II-10.

U.S. shipments by product.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of wood mouldings and
millwork products, by product.
Quantity (in board feet), Value (dollars)
Calendar year
Item

2018

U.S. shipments:
Crown/cove mouldings
Quantity (Z)
Value (AA)
Door frames or jambs/astragals
Quantity (AB)
Value (AC)
Base caps/corner guards
Quantity (AD)
Value (AE)
Other in-scope products1
Quantity (AF)
Value (AG)
1

Please identify these products:

.

RECONCILIATION OF U.S. SHIPMENTS BY PRODUCT.--Please ensure that the quantities and values reported for U.S.
shipments by material (i.e., lines X through AC) 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 year
Reconciliation

2018

Quantity: Z + AB + AD + AF - D - F- H = zero
("0"), if not revise.

0

Value: AA + AC + AE +AG - E - G- I = zero ("0"), if
not revise.

0

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-11.

Page 16

Employment data.--Report your firm’s employment-related data related to the production of
wood mouldings and millwork products 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.
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)

Explanation of trends:

II-12.

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.

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-13.

Page 17

Purchases.--Has your firm purchased wood mouldings and millwork products 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 board feet)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Purchases from U.S. importers of wood
mouldings and millwork products
from—
Brazil
1

China
All other sources
Purchases from domestic producers2
Purchases from other sources3
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 U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.
1

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
II-14

Page 18

Conversion into board feet.--Are the quantity data reported in part II properly reported in board
feet?
No.--Please revise your questionnaire to report your firm’s data in the requested measure
(board feet) prior to submission to the Commission.
Yes.--Please indicate how your firm came up with its quantity data in the requested measure
(board feet).
Method

Description of methodology

Firm’s records maintained in
board feet

Not applicable

Firm specific conversion
factor or estimates based on
specific products produced
Other
II-15.

Imports.--Since January 1, 2016, has your firm imported wood mouldings and millwork
products?
No

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

II-16.

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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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Emily Kim (202-205-1800, [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.—Please provide the following information on 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:
Note: Regardless of your firm’s fiscal year, please report financial data on a
calendar year basis.

B.1.

products:

2.
3.

4.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include wood mouldings and
millwork products:
Does your firm prepare profit/loss statements for wood mouldings and millwork
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 wood mouldings and
millwork products, as well as specific statements and worksheets) used to compile these data.

III-3.

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

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Page 20

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 wood mouldings and millwork products, and provide the share of net sales accounted
for by these products in your firm’s most recent calendar year.
Products

Share of sales

Wood mouldings and millwork products

%
%
%
%
%

III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of wood mouldings and millwork products 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

No—Skip to question III-9a.

III-7a. Inputs from related suppliers detailed.--Please identify the inputs used in the production of
wood mouldings and millwork products that your firm purchases from related suppliers and that
are reflected in question III-9a. For “Share of total COGS” please report this information by
relevant input on the basis of your most recently completed calendar year. For “Input
valuation” please describe the basis, as recorded in your company’s own accounting system, of
the purchase cost from the related supplier; e.g., the related supplier’s actual cost, cost plus,
negotiated transfer price to approximate fair market value.
Input

Related supplier

Input valuation as recorded in the firm’s accounting books and records

Share of total COGS

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III-7b. Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7a, are reported in III-9a (financial results on wood
mouldings and millwork products) in a manner consistent with your firm’s accounting books and
records.

Yes

III-8.

No

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

By-products.—State how your firm classifies revenues from the sales of residual wood chips,
barks, shavings, sawdust, and other products produced during the course of producing wood
mouldings and millwork products as:
Co-Product or
By-Product
If your answer is “By-Product”, report the revenues associated with the sale or transfer of such
by-products for your firm’s three most recently completed calendar years, and for the specified
interim periods. Note: the data provided below will appear in question III-9a as a reduction to
COGS
Value (in dollars)
Calendar years ended-Item
By-product sales revenue

2016

2017

January-September
2018

2018

2019

1

Please describe how your firm classifies these by-product revenues in the normal course of
business (e.g., included in net sales values, as a reduction to COGS, included in “all other income”).
1

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III-9a. Operations on wood mouldings and millwork products.--Report the revenue and related cost
information requested below on the wood mouldings and millwork products 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 calendar years, and for the
specified interim periods. If your firm was involved in tolling operations (either as the toller or as
the tollee), please contact Emily Kim at (202) 205-1800 before completing this section of the
questionnaire.
Quantity (in board feet) and value (in dollars)
Calendar years ended-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
Raw materials

(COGS):3

Direct labor
Other factory costs
Less: by-product revenue

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 in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

2

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

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

Yes

III-9c.

No

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

Raw materials.--Please report the share of total raw material costs in 2018 (reported in III-9a)
for the following raw material inputs:
Procurement method

Input

Share of total
raw material
costs (percent)

Primarily
produced by
your firm

Primarily
purchased by
your firm

Softwood
Hardwood
Wood inputs

Laminated veneer lumber
Wood composite materials and
other wood inputs

Adhesives
Primer/coating materials
Other material inputs1
Total (should sum to 100 percent)

0.0

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

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

Item

2016

2017

January-September

2018

2018

2019

Value (dollars)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Income statement classification of the nonrecurring item

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III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.

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

III-13.

Describe

2016

2017

2018

1

.

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for wood mouldings and millwork
products. Provide data for your firm’s three most recently completed calendar years, and for
the specified interim periods.
Value (in dollars)
Calendar years ended--

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

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

Your firm’s fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period. 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.
Calendar years ended-Reconciliation

2016

2017

January-September
2018

2018

2019

Quantity: Trade data from question II-7
(lines D, F, H, and J) less financial total
net sales quantity data from question III9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II-7
(lines E, G, I, and K) less financial total
net sales value data from question III-9a,
= zero ("0").

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-7?
Yes

No

If no, please explain.

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If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2016, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of wood mouldings and millwork products from Brazil and 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)

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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 wood mouldings and millwork products from
Brazil and 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)

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Page 29

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
wood mouldings and millwork products from Brazil and 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.

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

Contact information.--Please identify the 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.—Fingerjointed lineal trim, made of pine/ fir, with dimensions of 9/16” x 5-1/4”, WM618, primed or coated.
Product 2.-- Fingerjointed lineal trim, made of pine/ fir, 5/8” x 2-1/4”, LWM-366, primed or
coated.
Product 3.-- Fingerjointed lineal trim, made of pine/ fir, 11/16” x 11/16” x 16’ WM-106, primed
or coated.
Product 4.—Jamb: Exterior door frame nominally 1-1/4” thick with a nominal ½” rabbeted drop
for door stop x nominal 4-9/16” width x nominal 7’ long and machined with end
dadoes for threshold and head attachment, primed or coated.
Product 5.—Jamb: Exterior door frame nominally 1-1/4” thick with a nominal ½” rabbeted drop
for door stop x nominal 6-9/16” width x nominal 7’ long and machined with end
dadoes for threshold and head attachment, primed or coated.
Product 6.—Brick moulding: Casing that attaches to exterior edge of door frame nominally 11/4” thick x 2” wide and 7’ long with moulded profile on face, primed or coated.

Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV-2a. During January 2016-September 2019, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question IV-3.

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IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Please provide data for products 1-3 in LINEAL, not board, feet.
Report data in LINEAL feet and actual dollars (not 1,000s).
(Quantity in LINEAL feet, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, 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:

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IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm. Please provide data for products 4-6 in NUMBER OF UNITS, not board feet.
Report data in NUMBER OF UNITS and actual dollars (not 1,000s).
(Quantity in NUMBER OF UNITS, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, 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 4:
Product 5:
Product 6:

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U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)
IV-2c.

Page 33

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

√ if Yes

In actual dollars (not $1,000) and lineal feet (products 1-3) or units (products
4-6)?
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 question II-7 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 – Wood Mouldings and Millwork Products (Preliminary)
IV-3.

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

IV-4.

Contracts

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 wood mouldings and millwork
products usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 34

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 wood
mouldings and millwork products 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 – Wood Mouldings and Millwork Products (Preliminary)
IV-7.

Page 35

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced wood mouldings and millwork products (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 between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced wood mouldings and millwork products?
Source

Lead time (Average
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 – Wood Mouldings and Millwork Products (Preliminary)
IV-9.

Page 36

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced wood mouldings and
millwork products 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 wood mouldings and
millwork products 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 wood mouldings and millwork products 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 – Wood Mouldings and Millwork Products (Preliminary)

Page 37

IV-11. End uses.--List the end uses of the wood mouldings and millwork products that your firm
manufactures. For each end-use product, what percentage of the total cost is accounted for by
wood mouldings and millwork products and other inputs?
Share of total cost of end use product
accounted for by
Wood mouldings and
millwork products

End-use product

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Substitutes.--Can other products be substituted for wood mouldings and millwork products?
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 wood mouldings and
millwork products?
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 wood mouldings and millwork products has changed since January 1, 2016.
Explain any trends and describe the principal factors that have affected these changes in
demand.

Overall
increase

Market

Fluctuate
No
Overall
with no
change decrease clear trend

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 wood mouldings and millwork products since January 1, 2016?
No

Yes

If yes, please describe and quantify if possible.

Business Proprietary
U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

Page 38

IV-15. Conditions of competition.-(a) Is the wood mouldings and millwork products market subject to business cycles (other
than general economy-wide conditions) and/or other conditions of competition distinctive
to wood mouldings and millwork products? 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
wood mouldings and millwork products since January 1, 2016?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply wood mouldings
and millwork products 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 wood mouldings and millwork products 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 wood
mouldings and millwork products.

Business Proprietary
U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

Page 39

IV-18. Interchangeability.—Are wood mouldings and millwork products 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

Brazil

China

Other countries

United States
Brazil
China
For any country-pair producing wood mouldings and millwork products 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 – Wood Mouldings and Millwork Products (Preliminary)

Page 40

IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wood mouldings and
millwork products 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

Brazil

China

Other countries

United States
Brazil
China
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of wood mouldings and millwork products, identify the country-pair
and report the advantages or disadvantages imparted by such factors:

Business Proprietary
U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

Page 41

IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for wood mouldings and millwork products since January 1, 2016. Indicate the share
of the quantity of your firm’s total shipments of wood mouldings and millwork products that
each of these customers accounted for in 2018.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2018
sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

Page 42

IV-21. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products

under section 301 have an impact on the wood mouldings and millwork products
market in the United States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced wood
mouldings and
millwork products
Supply of wood
mouldings and
millwork products
imported from China
Supply of wood
mouldings and
millwork products
imported from other
countries
Prices for wood
mouldings and
millwork products
Overall U.S. demand
for wood mouldings
and millwork
products

No

Don’t know

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

Business Proprietary
U.S. Producers’ Questionnaire – Wood Mouldings and Millwork Products (Preliminary)

Page 43

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

Lost revenue.--Since January 1, 2016: To avoid losing sales to competitors selling wood
mouldings and millwork products from Brazil and 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 wood mouldings and
millwork products to imports of this product from Brazil and China?
No

(c)

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: WOOD)

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 – Wood Mouldings and Millwork Products (Preliminary)

Page 44

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/701731/2020/wood_mouldings_and_millwork_pr
oducts_brazil_and/preliminary.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: WOOD

• 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.