Form 18-2-3833 US importers' questionnaire

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

US importer--Rubber bands (P)

Rubber bands from China, Sri Lanka, and Thailand (701-TA-598-600 and 731-TA-1408-1410)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 18-2-3833; Expiration Date: 6/30/2020
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U.S. IMPORTERS’ QUESTIONNAIRE
RUBBER BANDS FROM CHINA, SRI LANKA, AND THAILAND
This questionnaire must be received by the Commission by February 13, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping and countervailing duty investigations concerning rubber bands from China, Sri Lanka,
and Thailand (Inv. Nos. 701-TA-598-600 and 731-TA-1408-1410 (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 rubber bands (as defined on next page) and/or select excluded rubber band products (as
defined on next page) from any country at any time since January 1, 2015?

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

Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Email address

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on January 30, 2018 by
Alliance Rubber Co., Hot Springs, Arkansas. Antidumping and countervailing duties may be assessed on
the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce
(“Commerce”) makes an affirmative determination of dumping and subsidization. Questionnaires and
other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/rubber_bands_china_sri_lanka_and_thailand/preli
minary.htm.
Rubber bands covered by the scope of these investigations are defined as bands made of vulcanized
rubber, with a flat length, as measured end-to-end by the band lying flat, no less than 1/2 inch and no
greater than 10 inches; with a width, which measures the dimension perpendicular to the length, of at
least 3/64 inch and no greater than 2 inches; and a wall thickness from 0.020 inch to 0.125 inch.
Vulcanized rubber has been chemically processed into a more durable material by the addition of sulfur
or other equivalent curatives or accelerators. Subject products are included regardless of color or
inclusion of printed material. The scope includes vulcanized rubber bands which are contained or
otherwise exist in various fowls and packages, such as, without limitation, vulcanized rubber bands
included within a desk accessory set or other type of set or package, and vulcanized rubber band balls,
but excludes Bedford Elastitags®, and bands that are being used at the time of import to fasten an
imported product.
Rubber bands are currently imported under statistical reporting number 4016.99.3510 of the
Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS provisions are for convenience and
customs purposes; the written description of the scope is dispositive.
Select excluded (or out-of-scope) rubber band products are as follows: (1) Vulcanized rubber bands with
a flat length less than 1/2 inches or greater than 10 inches, a width less than 3/64 inches or greater than
2 inches, or a wall thickness less than 0.020 inches or greater than 0.125 inches (“Excluded vulcanized
rubber bands”); (2) Bedford Elastitags®; and (3) Non-latex rubber bands.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing rubber bands (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
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.

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U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 3

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
Amanda Lawrence (202-205-3185, [email protected]).

I-1.

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

Dollars

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

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
I-2.

Page 4

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of rubber bands, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

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

Address

Extent of
ownership
(percent)

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

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of rubber bands?
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 rubber
bands. More than one answer may be applicable.

Importer of record

I-7.

Page 5

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of rubber bands 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 – Rubber Bands (Preliminary)
I-8.

Page 6

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters rubber bands into,
or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports rubber bands 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 designed 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

No

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–Please specify.

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amanda Lawrence (202-2053185, [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
Fax

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the importation of rubber bands since January 1, 2015.
(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 – Rubber Bands (Preliminary)
II-3.

Page 8

Arranged imports.--Has your firm imported or arranged for the importation of in-scope rubber
bands for delivery after December 31, 2017?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

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

Period/Source

Jan-Mar 2018

Apr-June 2018

July-Sept 2018

Oct-Dec 2018

China
Sri Lanka
Thailand
All other sources1
1

List other country sources:

II-4.

.

Reasons for importing if producer.--If your firm also produces rubber bands 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 – Rubber Bands (Preliminary)

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“Bulk 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. For the purposes of this
questionnaire, bulk commercial U.S. shipments should include sales to distributors, to end users,
and to retail establishments, whether or not already packaged for retail sale, but should not
include sales made at the retail level of trade to individual customers (including to other
businesses).
“Internal consumption / including for retail sale” --Product consumed internally by your firm
and product that is destined for sale by your firm at a retail level to individual consumers. Such
transactions should be valued at fair market value of the bulk rubber bands (i.e., not the retail
price).
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
“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 – Rubber Bands (Preliminary)
II-5a.

Page 10

U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of in-scope rubber bands imported from China by your firm during the specified periods.

China
Quantity (in pounds), value (in dollars)
Calendar years
Item

2015

2016

2017

Beginning-of-period inventories (quantity) (A)
1

Imports:
Quantity (B)
Value (C)
U.S. shipments:
Bulk commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including for retail sale
2
by your firm:
Quantity (F)
2

Value (G)
Transfers to related firms:
Quantity (H)

2

2

Value (I)
Export shipments:
Quantity (J)

3

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

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 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
A + B – D – F – H – J - L = should equal
zero ("0") or provide an explanation.1
1

2015

2016
0

2017
0

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

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-5b.

Page 11

Channels of distribution: China.--Report your firm’s U.S. shipments (i.e., inclusive of bulk
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
in-scope rubber bands from China by channel of distribution. If your firm is a retailer and directly
imports in-scope rubber bands for use in your own or a related firm’s retail locations, please
report those as U.S. shipments “To retailers” here.

China
Quantity (in pounds)
Calendar years
Item

2015

2016

2017

Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers and office supply stores: branded1 (N)
To retailers and office supply stores: private label1 (O)
To end users: agricultural/floral/grocery (P)
To end users: industrial/hardware/construction (Q)
To end users: newspaper/packaging/stationery2 (R)
To end users: all other end users3 (S)
1

Include stationery stores, such as Staples, Office Depot, etc., in retail category.
Include end users, such as government or post offices, that purchase rubber bands for stationery use in end
users category.
3
Please specify the other types of end users:
.
2

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through S) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P + Q + R + S – D – F – H = zero ("0"), if not revise.

2015

2016
0

2017
0

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-5c.

Page 12

U.S. shipments by product size: 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 of
in-scope rubber bands from China by product size.

China
Quantity (in pounds)
Item

Calendar year
2017

U.S. shipments.-Rubber bands balls (T)
Other than rubber band balls:
Sizes 8 through 19 and 117-A1 (U)
Sizes 27 through 33 and 117-B2 (V)
All other sizes (W)3
1

Sizes 8 through 19 and 117-A, based on common industry standards, have a width of 1/16”. Lengths are
as follows: size 8—7/8”, size 10—1 ¼”, size 12—1 ¾”, size 14—2”, size 16—2 ½”, size 18—3”, size 19—3 ½”,
and size 117-A—7”.
2
Sizes 27 through 33 and 117-B, based on common industry standards, have a width of 1/8”. Lengths are
as follows: size 27—1 ¼”, size 30—2”, size 31—2 ½”, size 32—3”, size 33—3 ½”, and size 117-B—7”.
3
Please specify the other sizes:
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
US shipments by product type (i.e., lines T through W) in 2017 equal the quantity and value
reported for U.S. shipments (i.e., lines D through I) in 2017 in question II-7. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to
submission to the Commission.

Reconciliation
Quantity: T + U + V + W – D – F – H = zero ("0"), if not
revise.

Calendar year
2017
0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-6a.

Page 13

U.S. imports from Sri Lanka.–Report your firm’s imports and your firm’s shipments and
inventories of in-scope rubber bands imported from Sri Lanka by your firm during the specified
periods.

Sri Lanka
Quantity (in pounds), value (in dollars)
Calendar years
Item

2015

2016

2017

Beginning-of-period inventories (quantity) (A)
1

Imports:
Quantity (B)
Value (C)
U.S. shipments:
Bulk commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including for retail sale
2
by your firm:
Quantity (F)
2

Value (G)
Transfers to related firms:
Quantity (H)

2

2

Value (I)
Export shipments:
Quantity (J)

3

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

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 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
A + B – D – F – H – J - L = should equal
zero ("0") or provide an explanation.1
1

2015

2016
0

2017
0

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

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-6b.

Page 14

Channels of distribution: Sri Lanka.--Report your firm’s U.S. shipments (i.e., inclusive of bulk
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
in-scope rubber bands from Sri Lanka by channel of distribution. If your firm is a retailer and
directly imports rubber bands for use in your own or a related firm’s retail locations, please
report those as U.S. shipments “To retailers” here.

Sri Lanka
Quantity (in pounds)
Calendar years
Item

2015

2016

2017

Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers and office supply stores: branded1 (N)
To retailers and office supply stores: private label1 (O)
To end users: agricultural/floral/grocery (P)
To end users: industrial/hardware/construction (Q)
To end users: newspaper/packaging/stationery2 (R)
To end users: all other end users3 (S)
1

Include stationery stores, such as Staples, Office Depot, etc., in retail category.
Include end users, such as government or post offices, that purchase rubber bands for stationery use in end
users category.
3
Please specify the other types of end users:
.
2

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through S) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P + Q + R + S – D – F – H = zero ("0"), if not revise.

2015

2016
0

2017
0

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-6c.

Page 15

U.S. shipments by product size: Sri Lanka.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
in-scope rubber bands from Sri Lanka by product size.

Sri Lanka
Quantity (in pounds)
Item

Calendar year
2017

U.S. shipments.-Rubber bands balls (T)
Other than rubber band balls:
Sizes 8 through 19 and 117-A1 (U)
Sizes 27 through 33 and 117-B2 (V)
All other sizes (W)3
1

Sizes 8 through 19 and 117-A, based on common industry standards, have a width of 1/16”. Lengths are
as follows: size 8—7/8”, size 10—1 ¼”, size 12—1 ¾”, size 14—2”, size 16—2 ½”, size 18—3”, size 19—3 ½”,
and size 117-A—7”.
2
Sizes 27 through 33 and 117-B, based on common industry standards, have a width of 1/8”. Lengths are
as follows: size 27—1 ¼”, size 30—2”, size 31—2 ½”, size 32—3”, size 33—3 ½”, and size 117-B—7”.
3
Please specify the other sizes:
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
US shipments by product type (i.e., lines T through W) in 2017 equal the quantity and value
reported for U.S. shipments (i.e., lines D through I) in 2017 in question II-7. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to
submission to the Commission.

Reconciliation
Quantity: T + U + V + W – D – F – H = zero ("0"), if not
revise.

Calendar year
2017
0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-7a.

Page 16

U.S. imports from Thailand.–Report your firm’s imports and your firm’s shipments and
inventories of in-scope rubber bands imported from Thailand by your firm during the specified
periods.

Thailand
Quantity (in pounds), value (in dollars)
Calendar years
Item

2015

2016

2017

Beginning-of-period inventories (quantity) (A)
1

Imports:
Quantity (B)
Value (C)
U.S. shipments:
Bulk commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including for retail sale
2
by your firm:
Quantity (F)
2

Value (G)
Transfers to related firms:
Quantity (H)

2

2

Value (I)
Export shipments:
Quantity (J)

3

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

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 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
A + B – D – F – H – J - L = should equal
zero ("0") or provide an explanation.1
1

2015

2016
0

2017
0

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

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-7b.

Page 17

Channels of distribution: Thailand.--Report your firm’s U.S. shipments (i.e., inclusive of bulk
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
in-scope rubber bands from Thailand by channel of distribution. If your firm is a retailer and
directly imports in-scope rubber bands for use in your own or a related firm’s retail locations,
please report those as U.S. shipments “To retailers” here.

Thailand
Quantity (in pounds)
Calendar years
Item

2015

2016

2017

Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers and office supply stores: branded1 (N)
To retailers and office supply stores: private label1 (O)
To end users: agricultural/floral/grocery (P)
To end users: industrial/hardware/construction (Q)
To end users: newspaper/packaging/stationery2 (R)
To end users: all other end users3 (S)
1

Include stationery stores, such as Staples, Office Depot, etc., in retail category.
Include end users, such as government or post offices, that purchase rubber bands for stationery use in end
users category.
3
Please specify the other types of end users:
.
2

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through S) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P + Q + R + S – D – F – H = zero ("0"), if not revise.

2015

2016
0

2017
0

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-7c.

Page 18

U.S. shipments by product size: Thailand.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
in-scope rubber bands from Thailand by product size.

Thailand
Quantity (in pounds)
Item

Calendar year
2017

U.S. shipments.-Rubber bands balls (T)
Other than rubber band balls:
Sizes 8 through 19 and 117-A1 (U)
Sizes 27 through 33 and 117-B2 (V)
All other sizes (W)3
1

Sizes 8 through 19 and 117-A, based on common industry standards, have a width of 1/16”. Lengths are
as follows: size 8—7/8”, size 10—1 ¼”, size 12—1 ¾”, size 14—2”, size 16—2 ½”, size 18—3”, size 19—3 ½”,
and size 117-A—7”.
2
Sizes 27 through 33 and 117-B, based on common industry standards, have a width of 1/8”. Lengths are
as follows: size 27—1 ¼”, size 30—2”, size 31—2 ½”, size 32—3”, size 33—3 ½”, and size 117-B—7”.
3
Please specify the other sizes:
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
US shipments by product type (i.e., lines T through W) in 2017 equal the quantity and value
reported for U.S. shipments (i.e., lines D through I) in 2017 in question II-7. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to
submission to the Commission.

Reconciliation
Quantity: T + U + V + W – D – F – H = zero ("0"), if not
revise.

Calendar year
2017
0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-8a.

Page 19

U.S. imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of in-scope rubber bands imported from all other sources by your firm during the
specified periods.

All other sources
(list sources:

)
Quantity (in pounds), value (in dollars)
Calendar years
Item

2015

2016

2017

Beginning-of-period inventories (quantity) (A)
1

Imports:
Quantity (B)
Value (C)
U.S. shipments:
Bulk commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including for retail sale
2
by your firm:
Quantity (F)
2

Value (G)
Transfers to related firms:
Quantity (H)

2

2

Value (I)
Export shipments:
Quantity (J)

3

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

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 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
A + B – D – F – H – J - L = should equal
zero ("0") or provide an explanation.1
1

2015

2016
0

2017
0

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

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-8b.

Page 20

Channels of distribution: All other sources.--Report your firm’s U.S. shipments (i.e., inclusive of
bulk commercial U.S. shipments, internal consumption, and transfers to related firms) of
imports of in-scope rubber bands from all other sources by channel of distribution. If your firm is
a retailer and directly imports in-scope rubber bands for use in your own or a related firm’s
retail locations, please report those as U.S. shipments “To retailers” here.

All other sources
Quantity (in pounds)
Calendar years
Item

2015

2016

2017

Channels of distribution:
U.S. shipments:
To distributors (M)
To retailers and office supply stores: branded1 (N)
To retailers and office supply stores: private label1 (O)
To end users: agricultural/floral/grocery (P)
To end users: industrial/hardware/construction (Q)
To end users: newspaper/packaging/stationery2 (R)
To end users: all other end users3 (S)
1

Include stationery stores, such as Staples, Office Depot, etc., in retail category.
Include end users, such as government or post offices, that purchase rubber bands for stationery use in end
users category.
3
Please specify the other types of end users:
.
2

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through S) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P + Q + R + S – D – F – H = zero ("0"), if not revise.

2015

2016
0

2017
0

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
II-8c.

Page 21

U.S. shipments by product size: 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 of in-scope rubber bands from all other sources by product size.

All other sources
Quantity (in pounds)
Item

Calendar year
2017

U.S. shipments.-Rubber bands balls (T)
Other than rubber band balls:
Sizes 8 through 19 and 117-A1 (U)
Sizes 27 through 33 and 117-B2 (V)
All other sizes (W)3
1

Sizes 8 through 19 and 117-A, based on common industry standards, have a width of 1/16”. Lengths are
as follows: size 8—7/8”, size 10—1 ¼”, size 12—1 ¾”, size 14—2”, size 16—2 ½”, size 18—3”, size 19—3 ½”,
and size 117-A—7”.
2
Sizes 27 through 33 and 117-B, based on common industry standards, have a width of 1/8”. Lengths are
as follows: size 27—1 ¼”, size 30—2”, size 31—2 ½”, size 32—3”, size 33—3 ½”, and size 117-B—7”.
3
Please specify the other sizes:
.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantities and values reported for
US shipments by product type (i.e., lines T through W) in 2017 equal the quantity and value
reported for U.S. shipments (i.e., lines D through I) in 2017 in question II-7. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to
submission to the Commission.

Reconciliation

Calendar year
2017

Quantity: T + U + V + W – D – F – H = zero ("0"), if not
revise.

II-9.

Other explanations.--If your firm would like to further explain a response to a question in Part II
that did not provide a narrative response box, 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.

0

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 22

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202-2053489, [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
Fax

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, 2015 of the following products your firm imported
from China, Sri Lanka, and/or Thailand:
Product 1.-- Size #32 rubber bands (3” x 1/8”), natural/latex, sold in 1 lb. poly bags
Product 2.-- Size #33 rubber bands (3 1/2” x 1/8”), natural/latex, sold in 1 lb. poly bags
Product 3.-- Size #64 rubber bands (3 1/2” x 1/4”), natural/latex, sold in 1 lb. poly bags
Product 4.-- Size #18 rubber bands (3” x 1/16”), newspaper size, natural/latex, sold in 1 lb. poly
bags
Product 5.-- Size #14 rubber bands (2" x 1/16"), agricultural size, natural/latex, sold in 1 lb. poly
bags
Product 6.-- Size #16, rubber bands (2 1/2" x 1/16”), agricultural size, natural /latex, sold in 1 lb.
poly bags

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 2015-December 2017, did your firm import from China, Sri Lanka, and Thailand
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 III-3.

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 23

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

China
Report data in pounds and dollars.

Period of shipment

(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

(Quantity in pounds, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Quantity
Value

2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December

Period of shipment

2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
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 4:

Product 2:

Product 5:

Product 3:

Product 6:

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 24

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

Sri Lanka
Report data in pounds and dollars.

Period of shipment

(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

(Quantity in pounds, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Quantity
Value

2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December

Period of shipment

2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
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 4:

Product 2:

Product 5:

Product 3:

Product 6:

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 25

III-2(c). Price data.--Report below the quarterly price data1 for pricing products2 imported from Thailand
and sold by your firm.

Thailand
Report data in pounds and dollars.

Period of shipment

(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

(Quantity in pounds, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Quantity
Value

2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December

Period of shipment

2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
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 4:

Product 2:

Product 5:

Product 3:

Product 6:

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 26

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

√ if Yes

In actual dollars (not $1,000) and pounds?
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-2(e). 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.
III-3.

Imports for internal use or retail sale.--Did your firm import any of the pricing products
identified above (III-2) for internal consumption or use for sales in your firm’s retail locations
since January 1, 2015?
No

Yes--Please fill out the table.
Share of imports for internal consumption or retail sales in
2017
(percent)
China
Sri Lanka
Thailand
(share of internal
consumption reported in
II-5a)

Product 1
Product 2
Product 3
Product 4
Product 5
Product 6
All other products
Total
(should sum to 100
percent)

(share of internal
consumption reported in
II-6a)

(share of internal
consumption reported in
II-7a)

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
III-4.

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

III-5.

Contracts

Other

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for rubber bands imported from China, Sri
Lanka, and Thailand?
Net 30
days

(b)

Net 60
days

2/10 net 30
days

Other

Other (specify)

On what basis are your firm’s prices of imported rubber bands from China, Sri Lanka,
and Thailand usually quoted (check one)?
Delivered

III-7.

Set
price
lists

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

Quantity
discounts

III-6.

Page 27

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of rubber bands imported
from China, Sri Lanka, and Thailand in 2017 was on a (1) long-term contract basis, (2) annual
contract basis, (3) short-term contract basis, and (4) spot sales basis?
Long-term
contracts
(multiple
deliveries for
more than 12
months)

Share of 2017
sales

%

Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)

%

%

0.0

%

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
III-8.

Page 28

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
rubber bands from China, Sri Lanka, and/or Thailand (or check “not applicable” if your firm does
not sell on a long-term, short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

Fixed quantity
and/or price

Price
Both

Meet or release
provision

Yes
No

Not applicable
III-9.

Lead times.--What is your firm’s share of sales of rubber bands imported from China, Sri Lanka,
and/or Thailand 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 rubber bands?

Source

Share of 2017
sales

Lead time (Average
number 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 – Rubber Bands (Preliminary)

Page 29

III-10. Shipping information.—
(a)

What is the approximate percentage of the cost of rubber bands imported from China,
Sri Lanka, and/or Thailand 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)

When your firm sells rubber bands imported from China, Sri Lanka, and/or Thailand,
from where is it shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of rubber bands imported from
China, Sri Lanka, and/or Thailand 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

Share

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 rubber
bands imported from subject countries since January 1, 2014 (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.

China

Sri Lanka

Thailand

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 30

III-12. End uses.--List the end uses of the rubber bands that your firm imports. For each end-use
product, what percentage of the total cost is accounted for by rubber bands and other inputs?
Share of total cost of end-use product
accounted for by
End use product

Rubber bands

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

III-13. Substitutes.--Can other products be substituted for rubber bands?
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 rubber bands?
No Yes

Explanation

1.
2.
3.
III-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for rubber bands has changed since January 1, 2015. Explain any trends and
describe the principal factors that have affected these changes in demand.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within the United States
Outside the United States

III-15. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of rubber bands since January 1, 2015?
No

Yes

If yes, please describe.

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 31

III-16. Conditions of competition.—
(a) Is the rubber bands market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to rubber bands?
Check all that apply.

Please describe.

No

Skip to question III-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
rubber bands since January 1, 2015?
No

Yes

If yes, describe.

III-17. Supply constraints.--Has your firm refused, declined, or been unable to supply rubber bands
since January 1, 2015 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

III-18. Raw materials.--How have rubber bands raw material prices changed since January 1, 2015?
Fluctuate
Explain, noting how raw material price changes
Overall
No
Overall
with no
have affected your firm’s selling prices for rubber
increase change decrease clear trend
bands.

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 32

III-19. Bundling sales.--Does your firm bundle sales of rubber bands with other products?

No

Yes

Estimate share
of your rubber
band sales
that were sold
in a bundle in
2017

Describe other product(s) that are typically in bundled
sales

III-20. Interchangeability.—Are rubber bands 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

Sri Lanka

Thailand

Other countries

United States
China
Sri Lanka
Thailand
For any country-pair producing rubber bands that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 33

III-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between rubber bands 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

Sri Lanka

Thailand

Other countries

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

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)

Page 34

III-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for rubber bands since January 1, 2015. Indicate the share of the quantity of your
firm’s total shipments of rubber bands that each of these customers accounted for in 2017.

Customer’s name

Contact person

Email

Telephone

City

State

Share
of 2017
sales
(%)

1
2
3
4
5
6
7
8
9
10
III-23. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative response box, 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 – Rubber Bands (Preliminary)

Page 35

PART IV.-- ALTERNATIVE PRODUCTS
Further information on this part of the questionnaire can be obtained from Amanda Lawrence (202-2053185, [email protected]).
IV-1.

Comparability of rubber band products.--For each of the following product pairs indicate
whether in-scope rubber bands produced in the United States are:
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.

Note.--Excluded vulcanized rubber bands, as defined on page 2, include bands made of vulcanized
rubber with a flat length less than 1/2" or greater than 10”, a width less than 3/64” or greater than 2”,
and a wall thickness less than 0.020” or greater than 0.125”.
(a) Physical Characteristics and Uses.--The differences and similarities in the physical
characteristics and uses.

Product-pair

Excluded vulcanized
rubber bands

Bedford Elastitags®

Non-latex rubber bands

In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their physical characteristics and uses:

(b) Interchangeability.--The ability to substitute the products in the same application.

Product-pair

Excluded vulcanized
rubber bands

Bedford Elastitags®

Non-latex rubber bands

In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their interchangeability:

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
IV-1.

Page 36

Comparability of rubber band products.--Continued
(c) Common manufacturing facilities, production processes, and production
employees.--Whether manufactured in the same facilities, from the same inputs, on
the same machinery and equipment, and using the same employees.

Product-pair

Excluded vulcanized
rubber bands

Bedford Elastitags®

Non-latex rubber bands

In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their common manufacturing facilities, production
processes, and production employees:

(d) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesalers/distributors, etc.).

Product-pair

Excluded vulcanized
rubber bands

Bedford Elastitags®

Non-latex rubber bands

In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their channels of distribution:

(e) Consumer and producer perceptions.--Perceptions as to the differences and/or
similarities.

Product-pair

Excluded vulcanized
rubber bands

Bedford Elastitags®

Non-latex rubber bands

In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their consumer and producer perceptions:

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
IV-1.

Page 37

Comparability of rubber band products.--Continued

(f) Price.--Whether prices are comparable or differ between products.

Product-pair

Excluded vulcanized
rubber bands

Bedford Elastitags®

Non-latex rubber bands

In-scope rubber bands
For any product-pair for which you indicated "S" or "N", please provide a narrative discussion for the
comparability ratings you provided in terms of their price:

IV-2.

Out-of-scope rubber band imports.--Report your firm’s imports of out-of-scope rubber band
products (i.e. excluded vulcanized rubber bands, as defined on page 2, Bedford Elastitags®, and
non-latex rubber bands) from China, Sri Lanka, Thailand, and all other sources. Data reported
below should not be included in data reported in part II.
(a) Imports from China

China
Quantity (in pounds)
Calendar years
Item
Imports from China:
Excluded vulcanized rubber bands:
Quantity
Value
Bedford Elastitags®:
Quantity
Value
Non-latex rubber bands:
Quantity
Value

2015

2016

2017

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
IV-2.

Page 38

Out-of-scope rubber band imports.--Continued
(b) Imports from Sri Lanka

Sri Lanka
Quantity (in pounds)
Calendar years
Item

2015

2016

2017

Imports from Sri Lanka:
Excluded vulcanized rubber bands:
Quantity
Value
Bedford Elastitags®:
Quantity
Value
Non-latex rubber bands:
Quantity
Value
(c) Imports from Thailand

Thailand
Quantity (in pounds)
Calendar years
Item
Imports from Thailand:
Excluded vulcanized rubber bands:
Quantity
Value
Bedford Elastitags®:
Quantity
Value
Non-latex rubber bands:
Quantity
Value

2015

2016

2017

Business Proprietary
U.S. Importers’ Questionnaire – Rubber Bands (Preliminary)
IV-2.

Page 39

Out-of-scope rubber band imports.--Continued
(d) Imports from all other sources

All other sources
(list sources:

)
Quantity (in pounds)
Calendar years

Item

2015

2016

2017

Imports from all other sources:
Excluded vulcanized rubber bands:
Quantity
Value
Bedford Elastitags®:
Quantity
Value
Non-latex rubber bands:
Quantity
Value

IV-3.

Other explanations.--If your firm would like to further explain a response to a question in Part V
that did not provide a narrative response box, 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 – Rubber Bands (Preliminary)

Page 40

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 US 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 – Rubber Bands (Preliminary)

Page 41

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/701731/2018/rubber_bands_china_sri_lanka_and
_thailand/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: BAND

• 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 Typeapplication/pdf
File TitleUS importer questionnaire
SubjectTitle 7 investigations
AuthorLawrence, Amanda
File Modified2018-01-31
File Created2018-01-31

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