20-2-4166 U.S. importers' questionnaire

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

US importers--Engines (P)

Vertical shaft engines from China (Inv. nos. 701-TA-637 and 731-TA-1471) Prelim

OMB: 3117-0016

⚠️ Notice: This form may be outdated.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

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OMB No. 3117-0016/USITC No. 20-2-4166; Expiration Date : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
VERTICAL SHAFT ENGINES FROM CHINA
This questionnaire must be received by the Commission by January 29, 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 duty and antidumping duty investigations concerning vertical shaft engines from
China (Inv. Nos. 701-TA-637 and 731-TA-1471 (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 imported vertical shaft engines (as defined on next page) from any country at any time since
January 1, 2016?

(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: ENGCN)
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

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
This proceeding was instituted in response to a petition filed on January 15, 2020, by the Coalition of
American Vertical Engine Producers (Kohler Co., Kohler, Wisconsin, and Briggs & Stratton Corporation,
Wauwatosa, Wisconsin). Countervailing and/or antidumping duties may be assessed on the subject
imports as a result of these proceedings if the Commission makes affirmative determinations 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/vertical_shaft_engines_china/preliminary.htm.
Vertical shaft engines covered by these investigations are spark-ignited, non-road, vertical shaft
engines, whether finished or unfinished, whether assembled or unassembled, designed primarily for use
in riding lawn mowers and zero-turn radius lawn mowers. Engines meeting this physical description may
also be designed for use in other non-hand-held outdoor power equipment. The subject engines are
spark ignition, single or multiple cylinder, air cooled, internal combustion engines with vertical power
take off shafts with a minimum displacement of 225 cubic centimeters ("cc") and a maximum
displacement of 999cc. Typically, engines with displacements of this size generate gross power of
between 6. 7 kilowatts ("kw'') to 42 kw.
Engines covered by this scope normally must comply with and be certified under Environmental
Protection Agency (EPA) air pollution controls title 40, chapter I, subchapter U, part 1054 of the Code of
Federal Regulations standards for small non-road spark-ignition engines and equipment. Engines that
otherwise meet the physical description of the scope but are not certified under 40 CFR part 1054 and
are not certified under other parts of subchapter U of the EPA air pollution controls are not excluded
from the scope of this proceeding. Engines that may be certified under both 40 CFR part 1054 as well as
other parts of subchapter U remain subject to the scope of this proceeding.
For purposes of these investigations, an unfinished engine covers at a minimum a sub-assembly
comprised of, but not limited to, the following components: crankcase, crankshaft, camshaft, pistons(s),
connecting rod(s), and oil pan. Importation of these components together, whether assembled or
unassembled, and whether or not accompanied by additional components such as a manifold, cylinder
head(s), valve train, or valve cover(s), constitutes an unfinished engine for purposes of these
investigations. The inclusion of other products such as spark plugs fitted into the cylinder head or
electrical devices (e.g., ignition modules, ignition coils) for synchronizing with the motor to supply
tension current does not remove the product from the scope. The inclusion of any other components
not identified as comprising the unfinished engine subassembly in a third-country does not remove the
engine from the scope.
The engines subject to these investigations are typically classified in the Harmonized Tariff Schedule of
the United States (HTSUS) at statistical reporting numbers: 8407.90.1020, 8407.90.1060, and
8407.90.1080. Engines subject to these investigations may also enter under HTSUS 8407.90.9060 and
8407.90.9080. The engine subassemblies that are subject to these investigations enter under HTSUS
8409.91.5085, and 8409.91.9990. The HTSUS statistical reporting numbers are provided for convenience
and customs purposes only, and the written description of the merchandise under investigation is
dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing vertical shaft engines (as defined above) into the United States from a foreign manufacturer
or through its selling agent.

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 3

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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Abu B.
Kanu (202-205-2597, [email protected]).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
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
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2a.

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

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

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I-2b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-2c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):

I-3.

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

Firm name

I-4.

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 vertical shaft engines from China into the United States
or that are engaged in exporting vertical shaft engines from China to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of vertical shaft engines?
No

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on
vertical shaft engines. More than one answer may be applicable.
Importer of record

I-7.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported product(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of vertical shaft engines but is not the
consignee, please list the consignees below (firm name, address, telephone number, and
individual to contact).

Firm name

Address

Contact person
and phone
number

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
I-8.

Page 7

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

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond

I-9.

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

Yes

If yes, Yes–Please specify.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Abu B. Kanu (202-205-2597,
[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 importation of vertical shaft engines since January 1, 2016.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

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

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-3a.

Page 9

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

Yes
If yes, fill out the table below.

Period
Source

Oct-Dec 2019

Jan-Mar 2020

Apr-June 2020

Jul-Sept 2020

Quantity (in units)
China
All other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported vertical shaft
engines from any source between January 2019 and December 2019 (i.e., all of 2019)
No

Yes
If yes, report the quantity of such import below by source.

Quantity (in units)
Source

January 2019 through December 2019

China
All other sources
II-4.

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

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 10

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-5a.

Page 11

U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of vertical shaft engines imported from China by your firm during the specified periods.

China
Quantity (in units), value (in $1,000s)
Calendar years
Item

2016

2017

January-September
2018

2018

2019

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

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

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-5a.

Page 12

U.S. imports from China.–Continued

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

2016

2017

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

January-September
2018

2018
0

2019
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-5b.

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

China
Calendar years
Item

2016

2017

January-September
2018

2018

2019

Quantity (in units)
Channels of distribution:
U.S. shipments:
To distributors or dealers (M)
To OEMs (N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., 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 item
M + N – D – F – H = zero ("0"), if not
revise.

2016

2017
0

January-September
2018

2018
0

2019
0

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-5c.

Page 13

U.S. imports by level of processing: China.--Report your firm’s U.S. imports from China by level
of processing during the specified periods.

China
Quantity (in units) and value (in $1,000s)
Calendar years
Item

2016

January-September

2017

2018

2019

U.S. imports:
Unfinished: 1
Quantity (O)
Value (P)
Finished:
Quantity (Q)
Value (R)
No

Does your company finish the unfinished engines domestically in the United States?
describe the nature and extent of the finishing operations conducted by your firm.

Yes If yes, please

RECONCILATION OF IMPORTS BY LEVEL OF PROCESSING.--Please ensure that the quantities and values
reported for U.S. imports in this question (i.e., lines O through R) in each time period equal the quantity
and value reported for U.S. imports in previous question II-5a (i.e., lines B and C) 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.

Reconciliation
Quantity: O + Q – B = zero (“0”), if not
revise
Value: P + R – C = zero, (“0”), if not
revise.

Calendar years
2017

2016

January-September
2018
2019

2018

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-6a.

Page 14

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of vertical shaft engines imported from all other sources by your firm during the
specified periods.

All other sources
(list sources:

)
Quantity (in units), value (in $1,000s)
Calendar years

Item

2016

2017

January-September
2018

2018

2019

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-6a.

Page 15

Imports from all other sources.–Continued

2016

2017

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

January-September
2018

2018
0

2019
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-6b.

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

All other sources
Calendar years
Item

2016

2017

January-September
2018

2018

2019

2016

2017
0

January-September
2018

2018
0

2019
0

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
II-6c.

Page 16

U.S. Imports by level of processing: All other sources.--Report your firm’s U.S. imports from all
other sources by level of processing during the specified periods.

All other sources
Quantity (in units) and value (in $1,000)
Calendar years
Item

2016

January-September

2017

2018

2019

U.S. Imports:
Unfinished: 1
Quantity (O)
Value (P)
Finished:
Quantity (Q)
Value (R)
No

Does your company finish the unfinished engines domestically in the United States?
describe the nature and extent of the finishing operations conducted by your firm.

Yes If yes, please

Reconciliation
Quantity: O + Q – B = zero (“0”), if not
revise
Value: P + R – C = zero, (“0”), if not
revise.

Calendar years
2017

2016

January-September
2018
2019

2018

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 17

II-7.

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

II-8.

Other explanations.--If your firm would like to further explain a response to a question in Part II
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. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 18

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
III-1.

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products your firm imported
from China:
Product 1.-- Vertical Shaft Engine, Air-Cooled, Single Cylinder, Carbureted, 340-400cc
displacement
Product 2.-- Vertical Shaft Engine, Air-Cooled, Single Cylinder, Carbureted, 410-550cc
displacement
Product 3.-- Vertical Shaft Engine, Air-Cooled, Twin Cylinder, Carbureted, 650-700cc
displacement
Product 4.-- Vertical Shaft Engine, Air-Cooled, Twin Cylinder, Carbureted, 701-725cc
displacement

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).
During January 2016-September 2019, did your firm import from China and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question III-3.

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 19

III-2a. Price data.--Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.

China

Report data in units and actual dollars (not 1,000s).

Period of shipment
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

(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

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 III.

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

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of these data, as Commission staff may contact your firm regarding questions. 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. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
III-2b.

Page 20

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

√ if Yes

In actual dollars (not $1,000s)?
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 part II in each year?
III-2c.

Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

PURCHASE COST DATA
III-3.

This question requests quarterly quantity and landed-duty paid value data for your firm’s
imports of the products defined above (on the first page of part III) for internal consumption
from China since January 1, 2016. These are imports that your firm does not resell as vertical
shaft engines.
During January 2016-September 2019, did your firm import any of the products listed on the
first page of part III from China for internal consumption?
Yes.--Please complete the following table(s) as appropriate.
No.--Skip to question III-4.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 21

III-3a. Imports for internal use.—Report below the import data1 for pricing products2 imported from
China and used by your own firm. These are imports that your firm does not resell as vertical
shaft engines.
Please note that values should be landed, duty-paid (LDP) and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid by your firm (i.e., should be net
of all returns, discounts, allowances, and rebates).

China
Report data in units and actual dollars (not 1,000s).

Period of importation
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

(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity LDP Value Quantity LDP Value Quantity LDP Value

Product 4
Quantity LDP Value

LDP value (i.e., landed duty-paid values): Values reported should be landed, duty-paid values at the U.S. port of entry, including ocean
freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland freight in the United States). See “Import
values” definition in Part II (Trade and Related Information – Definitions).
2 Pricing product definitions are provided on the first page of Part III.
1

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U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

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The following questions ask about the costs/benefits (not included in the LDP values reported above)
that factor into your firm’s decision to import vertical shaft engines rather than purchase from a U.S.
producer or importer of vertical shaft engines.
III-3b. Additional costs for your firm’s imports of vertical shaft engines for your firm’s internal use.—
i.

Did your firm incur any additional costs by importing vertical shaft engines rather than
purchasing from a U.S. producer or importer (e.g., logistical or supply chain
management costs, warehousing/inventory carrying costs, insurance or other risk
management fees, demurrage fees, indirect and overseas costs)?
No

Yes—Please answer parts ii, iii, and iv.

ii.

Please provide an estimate of the total additional cost incurred (as a percentage
compared to LDP value) when importing vertical shaft engines rather than purchasing
from a U.S. producer or importer. (Report only the portion that is related to your firm’s
importing activities, either directly or indirectly, and not already included in the LDP
value. Do NOT include any costs that also would be incurred if your firm purchased the
product from a U.S. producer or importer.)
percent compared to LDP value.

iii.

Please identify and explain the specific additional costs incurred by your firm and
estimate each cost (in percent) compared to the cost of importing. (Only report costs
and the portion of each cost that was related to your firm’s importing activities for
vertical shaft engines, either directly or indirectly, and that are not already included in
the LDP value. Do NOT report costs that your firm would incur when purchasing vertical
shaft engines from a U.S. producer or importer.)

Costs

iv.

Estimated
percentage
compared to LDP
value (percent)
%
%
%
%

Explanation

Briefly describe how your firm’s additional costs (beyond the purchase price) by
importing vertical shaft engines directly compare with the additional costs your firm
incurs when purchasing from a U.S. producer or U.S. importer.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
III-3c.

Page 23

Decision basis.—To which source(s) does your firm compare costs in determining whether or
not to import vertical shaft engines? Check all that apply.
U.S. importers

U.S. producers

Neither U.S. importers nor U.S. producers

III-3d. Benefits of importing vertical shaft engines.
i.

Briefly identify the benefits of importing vertical shaft engines instead of purchasing
vertical shaft engines from a U.S. importer or from a U.S. producer.

ii.

Is it your firm’s experience that the vertical shaft engines your firm imported from China
are priced lower than they would be if your firm purchased from a U.S. importer or U.S.
producer?

Imports are priced lower when

Yes (If yes to either, please
answer parts iii and iv)

Not including the additional costs above
Including the additional costs above
iii.

Please estimate your firm’s savings by importing vertical shaft engines instead of
purchasing from a U.S. producer or U.S. importer since January 1, 2016 (as a percent of
the purchase price from the U.S. importer or U.S. producer). For your estimate,
compare the price of purchasing from a U.S. importer or U.S. producer to the cost of
direct imports (including the additional costs described above in III-3.b).

Factors

iv.

Estimated savings
(percent of purchase price from
U.S. importer/producer)

U.S. producer

U.S. importer

What methods or experience did you base the estimates in III-3d.iii (i.e. based on
previous transactions with U.S. producers and/or U.S. importers, market research, etc.)
Check all that apply.
Reported estimates in III-3d.iii based on
Previous company transactions
Market research
Other – Please explain

√ if Yes

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 24

If your firm imports vertical shaft engines for internal use only, please skip to question III-12.
III-4.

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

III-5.

Annual
total
volume
discounts

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported vertical shaft engines from
China usually quoted (check one)?
Delivered

III-7.

Other

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

Quantity
discounts

III-6.

Contracts

Set
price
lists

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of vertical shaft engines
imported from China in 2018 was on a (1) short-term contract basis, (2) annual contract basis,
(3) long-term contract basis, and (4) spot sales basis?

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. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
III-8.

Page 25

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
vertical shaft engines imported from China (or check “not applicable” if your firm does not sell
on a short-term, annual and/or long-term contract basis).
Short-term contracts
(multiple deliveries
for less than 12
months)

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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:

III-9.

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

Source

Lead time
(Average number
Share of 2018 sales
of days)

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 26

III-10. Shipping information.—
(a)

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

(b)

When your firm sells vertical shaft engines imported from China, from where is it
shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of vertical shaft engines
imported from China that are delivered the following distances from your firm’s U.S.
point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

III-11. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold vertical
shaft engines imported from China since January 1, 2016 (check all that apply)?
Geographic area

China

Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
III-12. Inland transportation costs.—What is the approximate percentage of the cost of vertical shaft
engines imported from vertical shaft engines that is accounted for by U.S. inland transportation
costs?
percent.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 27

III-13. End uses.--List the end uses of the vertical shaft engines that your firm imports. For each enduse product, what percentage of the total cost is accounted for by vertical shaft engines and
other inputs?
Share of total cost of end-use product
accounted for by
End-use product

Vertical shaft engines

Total
(should sum to
100.0% across)

Other inputs

0.0 %

III-14. Substitutes.--Can other products be substituted for vertical shaft engines?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for vertical shaft engines?
No Yes

Explanation

1.
2.
3.
III-15. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for vertical shaft engines has changed since January 1, 2016. Explain any trends
and describe the principal factors that have affected these changes in demand.

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 28

III-16. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of vertical shaft engines since January 1, 2016?
No

Yes

If yes, please describe.

III-17. Conditions of competition.—
(a) Is the vertical shaft engines market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to vertical shaft
engines?
Check all that apply.

Please describe.

Skip to question III-18.

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
vertical shaft engines since January 1, 2016?
No

Yes

If yes, describe.

III-18. Supply constraints.--Has your firm refused, declined, or been unable to supply vertical shaft
engines 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.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 29

III-19. Raw materials.—
(a) How have vertical shaft engines raw material prices changed since January 1, 2016?

Factor

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

Cost of raw materials
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for vertical shaft engines?

Factor

Overall increase

No change

Overall decrease

Fluctuate with
no clear trend

Cost of raw materials after
section 232 tariffs imposed
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for vertical shaft engines?

Factor
Prices for vertical shaft
engines

No change

Overall
Increase

Fluctuate
Overall
with no
Decrease clear trend

Explanation

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)
III-20.

Page 30

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

China

Other countries

United States
China
For any country-pair producing vertical shaft engines that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

III-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between vertical shaft engines
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

China

Other countries

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

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 31

III-22. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products under
section 301 have an impact on the vertical shaft engines market in the United States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced vertical
shaft engines
Supply of vertical shaft
engines imported
from China
Supply of vertical shaft
engines imported
from other countries
Prices for vertical shaft
engines
Overall U.S. demand
for vertical shaft
engines
Raw material costs for
vertical shaft engines

Overall
No
Overall
increase change decrease

Don’t know

Explain, noting how the imposition
Fluctuate of tariffs under section 301 affected
with no
each factor of the vertical shaft
clear
engines market in the United
trend
States.

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 32

III-23. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for vertical shaft engines since January 1, 2016. Indicate the share of the quantity of
your firm’s total shipments of vertical shaft engines that each of these customers accounted for
in 2018.

Customer’s name

Contact person

Telephone

City

State

Share
of
2018
sales
(%)

1
2
3
4
5
6
7
8
9
10

III-24. Other explanations.--If your firm would like to further explain a response to a question in Part III
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. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 33

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

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

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

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

Business Proprietary
U.S. Importers’ Questionnaire – Vertical Shaft Engines (Preliminary)

Page 34

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/vertical_shaft_engines_china/preli
minary.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: ENGCN

• 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 did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	Microsoft Word - US importers--Engines (P)
Author	abu.kanu
File Modified	2020-01-17
File Created	2020-01-17