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pdfOMB No. 3117‐0016/USITC No. 18‐4‐3931; Expiration Date: 6/30/2020
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FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
CRYSTALLINE SILICON PHOTOVOLTAIC CELLS AND MODULES FROM CHINA
This questionnaire must be received by the Commission by September 19, 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 review of the antidumping and countervailing duty orders concerning Crystalline Silicon Photovoltaic
(“CSPV”) Cells and Modules from China (Inv. Nos. 701‐TA‐481 and 731‐TA‐1190 (Review)). The information requested in
the questionnaire is requested under the authority of the Tariff Act of 1930, title VII.
Name of firm
Address
Website
Has your firm produced or exported CSPV cells (as defined on pages 2‐3) from China OR produced or exported
CSPV modules (from anywhere in the world) that contain Chinese‐origin CSPV cells (as defined on pages 2‐3) at
any time since January 1, 2012?
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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: CSPV1)
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 or reviews
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 proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone:
Fax:
Email address
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 2
PART I.‐‐GENERAL INFORMATION
Background.‐‐ On December 7, 2012, the Department of Commerce (“Commerce”) issued antidumping
and countervailing duty orders on imports of crystalline silicon photovoltaic (“CSPV”) cells and modules
from China (77 FR 73017–73021). On November 1, 2017, the Commission instituted reviews pursuant to
section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine whether revocation
of the orders would be likely to lead to continuation or recurrence of material injury to the domestic
industry within a reasonably foreseeable time. If both the Commission and Commerce make affirmative
determinations, the orders will remain in place. If either the Commission or Commerce makes negative
determinations, Commerce will revoke the orders. Questionnaires and other information pertinent to
this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/crystalline_silicon_photovoltaic_cells_and_modules
/first_review_full.htm
CSPV Cells and Modules covered by these reviews are defined by Commerce as follows:
The merchandise covered by the order are crystalline silicon photovoltaic cells, and modules,
laminates, and panels, consisting of crystalline silicon photovoltaic cells, whether or not partially
or fully assembled into other products, including, but not limited to, modules, laminates, panels
and building integrated materials.
The order covers crystalline silicon photovoltaic cells of thickness equal to or greater than 20
micrometers, having a p/n junction formed by any means, whether or not the cell has undergone
other processing, including, but not limited to, cleaning, etching, coating, and/or addition of
materials (including, but not limited to, metallization and conductor patterns) to collect and
forward the electricity that is generated by the cell.
Merchandise under consideration may be described at the time of importation as parts for final
finished products that are assembled after importation, including, but not limited to, modules,
laminates, panels, building‐integrated modules, building‐integrated panels, or other finished
goods kits. Such parts that otherwise meet the definition of merchandise under consideration are
included in the scope of the orders.
Excluded from the scope of the order are thin film photovoltaic products produced from
amorphous silicon (a‐Si), cadmium telluride (CdTe), or copper indium gallium selenide (CIGS).
Also excluded from the scope of the order are crystalline silicon photovoltaic cells, not exceeding
10,000 mm2 in surface area, that are permanently integrated into a consumer good whose
function is other than power generation and that consumes the electricity generated by the
integrated crystalline silicon photovoltaic cell. Where more than one cell is permanently
integrated into a consumer good, the surface area for purposes of this exclusion shall be the
total combined surface area of all cells that are integrated into the consumer good.
Additionally, excluded from the scope of this order are panels with surface area from 3,450 mm2
to 33,782 mm2 with one black wire and one red wire (each of type 22 AWG or 24 AWG not more
than 206 mm in length when measured from panel extrusion), and not exceeding 2.9 volts, 1.1
amps, and 3.19 watts. For the purposes of this exclusion, no panel shall contain an internal
battery or external computer peripheral ports.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 3
Modules, laminates, and panels produced in a third‐country from cells produced in China are
covered by the orders; however, modules, laminates, and panels produced in China from cells
produced in a third‐country are not covered by the order.
Merchandise covered by this order is currently classified in the Harmonized Tariff System of the
United States (HTSUS) under subheadings 8501.61.0000, 8507.20.80, 8541.40.6020,
8541.40.6030, and 8501.31.8000. These HTSUS subheadings are provided for convenience and
customs purposes; the written description of the scope of the order is dispositive.
Module.‐‐A joined group of CSPV cells, regardless of the number of cells or the shape of the joined
group, that are capable of generating electricity. The term “module” is frequently used interchangeably
with the term “panel.” A “laminate” is a module that does not have a frame.
Building Integrated Materials.‐‐Materials integrated into the building envelope, such as the façade or
roof, containing CSPV cells. These building integrated materials replace conventional construction
materials, such as glass or roof shingles, taking over the function that conventional materials would
otherwise perform while also producing electricity.
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,
purchaser and/or foreign producer 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.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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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 Mary
Messer (202‐205‐3193, [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
30 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‐2.
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 in China involved in the production or export of CSPV
cells and modules, including auxiliary facilities operated in conjunction with (whether or not
physically separate from) such facilities. Firms operating more than one establishment in China
should combine the data for all establishments into a single report. Also included are firms that
assemble modules, laminates, and panels in a third‐country from cells that were produced in
China. These firms that assemble modules in third‐countries from Chinese‐origin cells should
submit separate questionnaire responses for each country in which such module assembly
occurs.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐3.
Page 5
U.S. importers.‐‐Please provide the names, contacts, email addresses, and telephone numbers
of the FIVE largest U.S. importers of your firm’s CSPV cells and modules in 2017.
No. Importer’s name
I‐4.
Email address
1
2
3
4
5
U.S. or other country production.‐‐Does your firm or any related firm produce, have the
capability to produce, or have any plans to produce CSPV cells and modules in the United States
or other countries?
No
Yes‐‐Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire.
Contact person
Share of
Area code
your firm’s
and
2017 U.S.
telephone
exports
number
(%)
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐5.
Page 6
U.S. importation.‐‐Does your firm or any related firm import or have any plans to import CSPV
cells and modules into the United States?
No
Yes‐‐Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.
I‐6.
Business plan.‐‐In Parts II and III of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected future market conditions for CSPV cells
and modules?
No
Yes‐‐Please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Mary Messer (202‐205‐3193,
[email protected]). Supply all data requested on a calendar‐year basis.
Note.‐‐The data reported in this questionnaire should relate to CSPV cells and modules made from Chinese‐origin
cells regardless of the country of module assembly. These data should exclude modules assembled with non
Chinese‐origin cells, including those assembled in China.
II‐1.
II‐2.
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
Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of CSPV cells and modules since January 1, 2012.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Bankruptcy
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II ‐2b. Anticipated changes in operations.‐‐Does your firm anticipate any changes in in the character of
its operations or organization relating to the production of CSPV cells or the assembly (full or
partial) of CSPV cells into other products in the future?
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue. Include in your
response a specific projection of your firm’s capacity to
produce CSPV cells and modules (in kilowatts) for 2018 and
2019.
II‐3a. Product shifting (CSPV cells).
(i).
Is your firm able to switch production (capacity) between CSPV cells and other products
using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products.
(ii).
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐3b. Product shifting (CSPV modules).
(i).
Is your firm able to switch production (capacity) between CSPV modules and other products
using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products.
(ii).
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐4.
Share of sales.‐‐What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of CSPV cells and modules? percent.
II‐5.
Firm's estimated share of production in country.—
Please estimate the percentage of total production of CSPV cells in China accounted for by your
firm’s production in 2017. percent.
Please estimate the percentage of total production of CSPV modules that contain Chinese‐origin
cells accounted for by your firm’s production in the country in which your module assembly
establishment is located in 2017. percent.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐6.
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Firm's estimated share of country's exports.—
Please estimate the percentage of total exports to the United States of CSPV cells from China
accounted for by your firm’s exports in 2017. percent.
II‐7.
Please estimate the percentage of total exports to the United States of CSPV modules that
contain Chinese‐origin cells accounted for by your firm’s exports of such modules in 2017.
percent.
Third country trade actions.‐‐Are the CSPV cells and modules (as defined on pages 2‐3 to
include Chinese‐origin cells, as well as modules containing Chinese‐origin cells) produced or
exported by your firm subject to antidumping/countervailing duty/safeguard findings, remedies,
or proceedings?
No
Yes‐‐List the products(s), countries affected, and the date of such
findings/remedies/proceedings.
II‐8.
Other export markets.‐‐Identify export markets (other than the United States) that your firm
has developed or where it has increased its sales of CSPV cells and modules since 2012. Please
identify and discuss below.
II‐9.
Significance of antidumping and countervailing duty orders.‐‐Describe the significance of the
existing antidumping and countervailing duty orders covering imports of CSPV cells and modules
from China in terms of its effect on your firm’s production capacity, production, home market
shipments, exports to the United States and other markets, and inventories. You may wish to
compare your firm’s operations before and after the imposition of the order.
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐10. Likely impact of revocation.‐‐Would your firm anticipate any changes in in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of CSPV cells
and modules in the future if the antidumping and countervailing duty orders on CSPV cells and
modules from China were to be revoked?
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue. Include in your
response a specific projection of your firm’s capacity to
produce CSPV cells and modules (in kilowatts) for 2018 and
2019.
II‐11. CSPV Cells.‐‐Since January 1, 2012, has your firm produced CSPV cells?
No—Skip to question II‐13.
Yes—Please complete question II‐12 (CSPV cells in kilowatts).
Business Proprietary
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” ‐‐All production in your establishment(s) in China, including production consumed
internally within your firm.
“Shipments”‐‐Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns. 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 in China.
“Home market commercial shipments”‐‐Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”‐‐Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”‐‐Shipments to destinations outside China, including shipments
to related firms.
“Inventories”‐‐Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐12. Trade data‐‐CSPV Cells.‐‐Report your firm’s production capacity, production, shipments, and
inventories related to the production of CSPV cells in your establishment(s) in China during the
specified periods. Do not include resales of CSPV cells that your firm did not produce in this
question; those data to the degree they are exported to the United States should only be
reported in question II‐13.
CELLS
Quantity (in kilowatts) and Value (in 1,000 dollars)
Calendar year
Item
2012
1
2013
2014
2015
January‐June
2016
2017
2017
2018
Average production capacity (A)
Beginning‐of‐period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
quantity (D)
value (E)
Commercial shipments
quantity (F)
value (G)
Export shipments:
to the United States:
quantity (H)
value (I)
Total exports (quantity) (R)
0
0
0
0
0
0
0
0
Total shipments (quantity) (S)
0
0
0
0
0
0
0
0
End‐of‐period inventories (T)
to other NAFTA countries:2
quantity (J)
value (K)
3
to the European Union:
quantity (L)
value (M)
4
to Asia:
quantity (N)
value (O)
5
to all other markets:
quantity (P)
value (Q)
1
The production capacity reported is based on operating hours per week, weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity: .
2
Please report the calendar‐year 2017 share of the quantity of these exports that were made to Canada (
percent) and the share of the quantity of these exports that were made to Mexico ( percent).
3
Identify your firm’s principal European Union export markets: .
4
Identify your firm’s principal Asian export markets: .
5
Identify your firm’s principal Other export markets: .
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐12. Trade data‐‐CSPV Cells.—Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported
for the end‐of‐period inventories (i.e., line T) should be equal to the beginning‐of‐period
inventories (i.e., line B), plus production (i.e., line C), less total shipments (i.e., lines D, F, H, J, L, N,
and P). 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 year
Item
2012
B + C – D – F – H –J – L – N –
P – T = should equal zero
("0") or provide an
explanation.1
2013
0
2014
0
January‐June
2015
0
0
2016
0
2017
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐13. Exports to the United States not produced by your firm.‐‐Report your firm’s exports to the
United States of CSPV cells that were produced in China but not by your firm during the
specified periods (i.e., you firm is just the exporter, not the producer). Note these data should
not be included in question II‐12.
CELLS
Quantity (in kilowatts) and Value (in 1,000 dollars)
Calendar year
Item
Exports of CSPV cells to the United
States not produced by your
firm1.—
Quantity 1
Value
1
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
List the producer(s).
II‐14. CSPV Modules.‐‐Since January 1, 2012, has your firm produced CSPV modules (anywhere in the
world) using Chinese‐origin CSPV cells?
No—Skip to question II‐16.
Yes—Please complete question II‐15 (CSPV modules in kilowatts).
.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐15. Trade data‐‐CSPV Modules.‐‐Report your firm’s production capacity, production, shipments,
and inventories related to the production of CSPV modules in your establishment(s). Do not
include resales of CSPV modules that your firm did not produce; those data to the degree they
are exported to the United States should only be reported in question II‐16.
Note.‐‐These data should relate to modules made from Chinese‐origin cells regardless of the country of module
assembly or country of exportation. These data should exclude modules assembled with non Chinese‐origin
cells, including those assembled in China. Firms that assemble modules in third‐countries from Chinese‐origin
cells should submit separate questionnaire responses for each country in which such module assembly occurs.
MODULES
(list country of assembly:
)
Quantity (in kilowatts) and Value (in 1,000 dollars)
Calendar year
Item
2012
1
2013
2014
2015
January‐June
2016
2017
2017
2018
Average production capacity (A)
Beginning‐of‐period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
quantity (D)
value (G)
Export shipments:
to the United States:
quantity (H)
value (I)
Total exports (quantity) (R)
0
0
0
0
0
0
0
0
Total shipments (quantity) (S)
0
0
0
0
0
0
0
0
End‐of‐period inventories (T)
value (E)
Commercial shipments
quantity (F)
to other NAFTA countries:2
quantity (J)
value (K)
3
to the European Union:
quantity (L)
value (M)
4
to Asia:
quantity (N)
value (O)
5
to all other markets:
quantity (P)
value (Q)
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐15. Trade data‐‐CSPV Modules.—Continued.
1
The production capacity reported is based on operating hours per week, weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity: .
The capacity data reported in the table above for each time period requested must be for only the module assembly
capacity allocated for subject CSPV modules that contain Chinese‐origin cells. Please also report in the following blank
your firm’s total overall plant capacity in 2017 to assemble modules in this country regardless of whether they are from
Chinese‐origin cells. kilowatts
2
Please report the calendar‐year 2017 share of the quantity of these exports that were made to Canada (
percent) and the share of the quantity of these exports that were made to Mexico ( percent).
3
Identify your firm’s principal European Union export markets: .
4
Identify your firm’s principal Asian export markets: .
5
Identify your firm’s principal Other export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported
for the end‐of‐period inventories (i.e., line T) should be equal to the beginning‐of‐period
inventories (i.e., line B), plus production (i.e., line C), less total shipments (i.e., lines D, F, H, J, L, N,
P). 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 year
Item
2012
B + C – D – F – H –J – L – N –
P – T = should equal zero
("0") or provide an
explanation.1
2013
0
2014
0
2015
0
0
January‐June
2016
0
2017
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐16. Exports to the United States not produced by your firm.‐‐Report your firm’s exports to the
United States of CSPV modules that were assembled using Chinese‐origin CSPV cells but not by
your firm (i.e., your firm is just the exporter not the producer/assembler) during the specified
periods. Note these data should not be included in question II‐15.
Quantity (in kilowatts) and Value (in 1,000 dollars)
Calendar year
Item
Exports of CSPV modules to the
U.S. not produced by your firm1.—
Quantity 1
Value
1
List the producer(s).
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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II‐17. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not have a narrative 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.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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PART III.‐‐MARKET FACTORS
Further information on this part of the questionnaire can be obtained from James Horne (202‐205‐2722,
[email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and how Commission staff may
contact the individual regarding the confidential information submitted in part III.
Name
Title
Email
Telephone
Fax
III‐2. Contract versus spot.‐‐Approximately what share of your firm’s sales of CSPV cells and modules
to U.S. customers in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3)
short‐term contract basis, and (4) spot sales basis?
Type of sale
Short‐term
Long‐term
Annual
Total
contracts
contracts
Spot sales
contracts
(should
(multiple
(multiple
(for a single
(multiple
sum to
deliveries for
deliveries for
delivery)
deliveries for 12
100.0%)
less than 12
more than 12
months)
months)
months)
Share of your
2017 sales
%
%
%
% 0.0 %
(CSPV cells)
Share of your
2017 sales
%
%
%
% 0.0 %
(CSPV
modules)
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III‐3. Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts with
U.S. customers for CSPV cells and modules (or check “not applicable” if your firm does not sell on a long‐
term, short‐term and/or annual contract basis).
Short‐term contracts Annual contracts
Long‐term contracts
(multiple
(multiple deliveries
Typical sales
(multiple deliveries for
Item
deliveries for 12
for less than 12
contract provisions
more than 12 months)
months)
months)
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
III‐4.
365
Lead times.‐‐What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of CSPV cells and modules?
Source
Share of 2017 sales
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
III‐5.
Lead time (Average
number of days)
0.0 %
Raw materials.‐‐Indicate how CSPV cells and modules raw materials prices have changed since
January 1, 2012, and how you expect they will change in the future.
Raw
materials
prices
Fluctuate Explain, noting how raw material
price changes have affected your
with no
clear firm’s selling prices for CSPV cells and
Overall
No
Overall
modules.
increase change decrease trend
Changes since
January 1,
2012
Anticipated
changes
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
III‐6.
III‐7.
Page 20
Changes in factors affecting supply.‐‐Have any changes occurred in any other factors affecting
supply (e.g., changes in availability or prices of energy or labor; transportation conditions;
production capacity and/or methods of production; technology; export markets; or alternative
production opportunities) that affected the availability of China‐produced CSPV cells and
modules in the U.S. market since January 1, 2012?
No
Yes
If yes, please describe.
Availability of SUBJECT import supply.‐‐Do you anticipate any changes in terms of the
availability of China‐produced CSPV cells and modules in the U.S. market in the future?
If you anticipate changes in supply, please identify the changes,
including the time period and the impact of such changes on
No
Increase change Decrease shipment volumes and prices.
III‐8.
Product shifting.‐‐Describe how easily your firm can shift its sales of CSPV cells and modules
between the U.S. market and alternative country markets. In your discussion, please describe
any contracts, other sales arrangements, or other constraints (including any third‐country trade
barriers such as tariffs, quotas, or other non‐tariff barriers) that would prevent or retard your
firm from shifting CSPV cells and modules between the U.S. and alternative country markets
within a 12‐month period.
III‐9.
Product range.‐‐Is the product range, product mix, or marketing of CSPV cells and modules in
your firm’s home market different from that of CSPV cells and modules for export to the United
States or to third‐country markets?
No
Yes
If yes, please explain.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 21
III‐10. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of CSPV cells and modules in your firm’s home market, for export to the United
States, or for export to third‐country markets since January 1, 2012? Do you anticipate any
future changes?
Changes in
product range,
product mix, or
Explain (including in which market the change occurred and during
marketing
No Yes
what time period.)
Changes since
January 1, 2012
Anticipated
changes
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 22
III‐11. Substitutes. ‐‐
(a) Are thin film solar products considered substitutes for CSPV cells and modules in the
same end use(s)?
Are these
considered
substitutes in the
End use(s) in which
market?
this substitute is
No
Yes
used
Substitutes
Thin film solar
products
Have changes in the price of this
substitute affected the price for CSPV
cells and modules?
No
Yes
Explanation
(b) Can other products not already listed in part "a" of this question be substituted for CSPV
cells and modules?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Other substitutes
Have changes in the price of this substitute
affected the price for CSPV cells and modules?
No Yes
Explanation
1.
2.
3.
(c) Have there been any changes in the number or types of products that can be substituted for
CSPV cells and modules since January 1, 2012? Do you anticipate any future changes?
Changes in substitutes No Yes
Changes since
January 1, 2012
Anticipated changes
Explain
III‐12. Interchangeability.—Are the CSPV cells and modules produced by your firm and sold in its home
market interchangeable (i.e., can be used in the same applications) with your firm’s CSPV cells
and modules sold to the United States and/or to third‐country markets?
Yes
No
If no, identify the market(s) and any differences in the products.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐13. End uses.—
(a) Estimate the percent of your total production cost that is accounted for by CSPV cells and by
other inputs (such as labor, energy, and other raw materials) in modules.
Share of total cost in each of the product(s) your
Total
firm produces accounted for by
(should
sum to
100.0%
Product(s) your firm
across)
produces
CSPV cells
Other inputs
Module
% +
% =
0.0 %
(b) For products you make using CSPV modules, please estimate the percent of your total
production cost that is accounted for by CSPV modules and by other inputs (such as
labor, energy, and other raw materials).
Share of total cost in each of the product(s) your
firm produces accounted for by
Product(s) your firm
produces
CSPV modules
Other inputs
Residential system
% +
% =
0.0 %
Commercial system
% +
% =
0.0 %
Utility system
% +
% =
0.0 %
Off grid portable consumer
goods
% +
% =
0.0 %
Other:
% +
% =
0.0 %
(c)
Have there been any changes in the end uses of CSPV cells and modules since January 1,
2012? Do you anticipate any future changes?
Changes in end
uses
Total
(should
sum to
100.0%
across)
No
Yes
Explain
Changes since
January 1, 2012
Anticipated
changes
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐14. Demand trends.‐‐Indicate how demand in the following markets for CSPV cells and modules has
changed since January 1, 2012, and how you anticipate demand will change in the future.
Explain any trends and describe the principal factors that have affected, and that you anticipate
will affect, these changes in demand.
Fluctuate
with no
Your firm’s Overall
No
Overall
market
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2012
Home
market
United
States
(Residential)
United
States
(Utility)
Other
markets
Anticipated future demand
Home
market
United
States
(Residential)
United
States
(Utility)
Other
markets
III‐15. Price differences.‐‐Please compare market prices of CSPV cells and modules in your firm’s home
market, the United States, and third‐country markets.
III‐16. Description of home market.‐‐Describe briefly your firm’s home market for CSPV cells and
modules, including the number of, and competition between, producers.
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐17. Import competition.‐‐Does your firm face competition from imports of CSPV cells and modules
in your firm’s home market?
No
Yes
If yes, please identify the country sources of these imports.
III‐18. Impact of the section 201 safeguard on firm and market—
(a) Did the announcement on January 22, 2018 and subsequent implementation of remedies in
the section 201 safeguard proceeding have any discernible impact on your firm's CSPV cell
and module operations and/or the market as a whole? Include in this discussion the impact
of the 2.5 GW exemption and tariff‐rate quotas for CSPV cells if applicable.
No
Yes‐‐Please specify.
Item
Response
Impact on firm1
Impact on overall market2
1
Please identify the magnitude and timing of any effects, and compare your firm's operations before and
after the announcement of the safeguard measures on January 22, 2018.
2
Please identify the magnitude and timing of any effects, and compare the overall market before and after
the announcement of the safeguard measures on January 22, 2018.
(b) Please indicate the impact that your firm has observed with regards to the announcement
on January 22, 2018 and subsequent implementation of remedies in the section 201
safeguard proceeding.
Item
Fluctuate
with no
Overall
No
Overall
improve change worsen clear trend
Explanation and factors
Overall demand
for CSPV cells
and modules in
the U.S. market
Prices for CSPV
cells and
modules in the
U.S. market
Impacted your
own firm's CSPV
cell and module
operations in
the United
States
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Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 26
(c) What impact did the announcement on January 22, 2018 and subsequent implementation
of remedies in the section 201 safeguard proceeding have on your firm's forward‐looking
outlook?
Item
Firm's forward looking
outlook
Strongly
worsened
Somewhat
worsened No change
Somewhat
improved
Strongly
improved
Narrative explanation:
III‐19. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss CSPV cells and modules supply
(including production capacity and capacity utilization) and demand in (1) the United States, (2)
each of the other major producing/consuming countries, including China, and (3) the world as a
whole. Of particular interest is such data from 2012 to the present and forecasts for the future.
III‐20. 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
Foreign Producers’/Exporters’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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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 USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.
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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://usitc.gov/investigations/701731/2017/crystalline_silicon_photovoltaic_cells_an
d_modules/first_review_full.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: CSPV1
• 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 produce or export this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - Foreign producers--CSPV cells and modules (R1) |
| Author | mary.messer |
| File Modified | 2018-08-06 |
| File Created | 2018-08-06 |