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pdfOMB No. 3117-0016/USITC No. 19-1-4021; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
STEEL RACKS FROM CHINA
This questionnaire must be received by the Commission by May 1, 2019
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning steel racks from China (Inv. Nos. 701TA-608 and 731-TA-1420 (Final)). The information requested in the questionnaire is requested under the authority of the
Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other
order to compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced steel racks (as defined on next page) at any time since January 1, 2016?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: RACKS)
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. Producers’ Questionnaire - Steel racks (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 20, 2018, by Bulldog
Rack Company, Weirton, West Virginia; Hannibal Industries, Inc., Los Angeles, California; Husky Rack and
Wire, Denver, North Carolina; Ridg-U-Rak, Inc., North East, Pennsylvania; SpaceRAK, A Division of
Heartland Steel Products, Inc., Marysville, Michigan; Speedrack Products Group, Ltd., Sparta, Michigan;
Steel King Industries, Inc., Stevens Point, Wisconsin; Tri-Boro Shelving & Partition Corp., Farmville,
Virginia; and UNARCO Material Handling, Inc., Springfield, Tennessee. Countervailing and/or
antidumping duties may be assessed on the subject imports as a result of these proceedings if the
Commission makes an affirmative determination of injury, threat, or material retardation, and if the U.S.
Department of Commerce (“Commerce”) makes an affirmative determination of subsidization and/or
dumping. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/steel_racks_china/final.htm.
Steel racks covered by these investigations are steel racks and parts thereof, assembled, to any extent,
or unassembled, including but not limited to, vertical components (e.g., uprights, posts, or
columns), horizontal or diagonal components (e.g., arms or beams), braces, frames, locking devices (e.g.,
end plates and beam connectors), and accessories (including, but not limited to, rails, skid channels, skid
rails, drum/coil beds, fork clearance bars, pallet supports, row spacers, and wall ties).
Subject steel racks and parts thereof are made of steel, including, but not limited to, cold and/or
hot-formed steel, regardless of the type of steel used to produce the components and may, or may not,
include locking tabs, slots, or bolted, clamped, or welded connections. Subject steel racks have the
following physical characteristics:
(1) Each steel vertical and horizontal load bearing member (e.g., arms, beams, posts, and
columns) is composed of steel that is at least 0.044 inches thick;
(2) Each steel vertical and horizontal load bearing member (e.g., arms, beams, posts, and
columns) is composed of steel that has a yield strength equal to or greater than 36,000 pounds
per square inch;
(3) The width of each steel vertical load bearing member (e.g., posts and columns) exceeds two
inches; and
(4) The overall depth of each steel roll-formed horizontal load bearing member (e.g., beams)
exceeds two inches.
In the case of steel horizontal load bearing members other than roll-formed (e.g., structural beams, Zbeams, or cantilever arms), only the criteria in subparagraphs (1) and (2) apply to these horizontal load
bearing members. The depth limitation in subparagraph (4) does not apply to steel horizontal load
bearing members that are not roll-formed.
Steel rack components can be assembled into structures of various dimensions and configurations by
welding, bolting, clipping, or with the use of devices such as clips, end plates, and beam connectors,
including, but not limited to the following configurations: 1) racks with upright frames perpendicular to
the aisles that are independently adjustable, with positive-locking beams parallel to the aisle spanning
the upright frames with braces; and 2) cantilever racks with vertical components parallel to the aisle and
cantilever beams or arms connected to the vertical components perpendicular to the aisle. Steel racks
may be referred to as pallet racks, storage racks, stacker racks, retail racks, pick modules, selective racks,
or cantilever racks and may incorporate moving components and be referred to as pallet-flow racks,
carton-flow racks, push-back racks, movable-shelf racks, drive-in racks, and drive-through racks. While
steel racks may be made to ANSI MH16.l or ANSI MH16.3 standards, all steel racks and parts thereof
meeting the description set out herein are covered by the scope of these investigations, whether or not
produced according to a particular standard.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 3
The scope includes all steel racks and parts thereof meeting the description above, regardless of
(1) other dimensions, weight, or load rating;
(2) vertical components or frame type (including structural, roll-form, or other);
(3) horizontal support or beam/brace type (including but not limited to structural, roll-form, slotted,
unslotted, Z-beam, C-beam, L-beam, step beam, and cantilever beam);
(4) number of supports;
(5) number of levels;
(6) surface coating, if any (including but not limited to paint, epoxy, powder coating, zinc, or
other metallic coatings);
(7) rack shape (including but not limited to rectangular, square, corner, and cantilever);
(8) the method by which the vertical and horizontal supports connect (including but not limited
to locking tabs or slots, bolting, clamping, and welding); and
(9) whether or not the steel rack has moving components (including but not limited to rails, wheels,
rollers, tracks, channels, carts, and conveyors).
Subject merchandise includes merchandise matching the above description that has been finished or
packaged in a third country. Finishing includes, but is not limited to, coating, painting, or assembly,
including attaching the merchandise to another product, or any other finishing or assembly operation
that would not remove the merchandise from the scope of these investigations if performed in the
country of manufacture of the steel racks and parts thereof. Packaging includes packaging the
merchandise with or without another product or any other packaging operation that would not remove
the merchandise from the scope of these investigations if performed in the country of manufacture of
the steel racks and parts thereof.
Steel racks and parts thereof are included in the scope of these investigations whether or not imported
attached to, or included with, other parts or accessories such as wire decking, nuts, and bolts. If steel
racks and parts thereof are imported attached to, or included with, such non-subject merchandise, only
the steel racks and parts thereof are included in the scope.
The scope of these investigations does not cover: 1) decks, i.e., shelving that sits on or fits into the
horizontal supports to provide the horizontal storage surface of the steel racks; 2) wire shelving units,
i.e., units made from wire that incorporate both a wire deck and wire horizontal supports (taking the
place of the horizontal beams and braces) into a single piece with tubular collars that slide over the
posts and onto plastic sleeves snapped on the posts to create a finished unit; 3) pins, nuts, bolts,
washers, and clips used as connecting devices; and 4) non-steel components.
Specifically excluded from the scope of these investigations are any products covered by Commerce’s
existing antidumping and countervailing duty orders on boltless steel shelving units prepackaged for sale
from the People’s Republic of China. See Boltless Steel Shelving Units Prepackaged for Sale From the
People’s Republic of China: Antidumping Duty Order, 80 Fed. Reg. 63,741 (October 21, 2017); Boltless
Steel Shelving Units Prepackaged for Sale From the People’s Republic of China: Amended Final
Affirmative Countervailing Duty Determination and Countervailing Duty Order, 80 Fed. Reg. 63,745
(October 21, 2017).
Also excluded from the scope of these investigations are bulk-packed parts or components of boltless
steel shelving units that were specifically excluded from the scope of the Boltless Steel Shelving Orders
because such bulk-packed parts or components do not contain the steel vertical supports (i.e., uprights
and posts) and steel horizontal supports (i.e., beams, braces) packaged together for assembly into a
completed boltless steel shelving unit.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 4
Such excluded components of boltless steel shelving are defined as:
(1) boltless horizontal supports (beams, braces) that have each of the following characteristics: (a) a
length of 95 inches or less, (b) made from steel that has a thickness of 0.068 inches or less, and (c) a
weight capacity that does not exceed 2500 lbs per pair of beams for beams that are 78” or shorter, a
weight capacity that does not exceed 2200 lbs per pair of beams for beams that are over 78” long but
not longer than 90”, and/or a weight capacity that does not exceed 1800 lbs per pair of beams for
beams that are longer than 90”;
(2) shelf supports that mate with the aforementioned horizontal supports; and
(3) boltless vertical supports (upright welded frames and posts) that have each of the following
characteristics: (a) a length of 95 inches or less, (b) with no face that exceeds 2.90 inches wide, and (c)
made from steel that has a thickness of 0.065 inches or less.
Excluded from the scope of these investigations are: (1) wall-mounted shelving and racks, defined as
shelving and racks that suspend all of the load from the wall, and do not stand on, or transfer load to,
the floor; (2) ceiling-mounted shelving and racks, defined as shelving and racks that suspend all of the
load from the ceiling and do not stand on, or transfer load to, the floor; and (3) wall/ceiling mounted
shelving and racks, defined as shelving and racks that suspend the load from the ceiling and the wall and
do not stand on, or transfer load to, the floor. The addition of a wall or ceiling bracket or other device to
attach otherwise subject merchandise to a wall or ceiling does not meet the terms of this exclusion.
Also excluded from the scope of these investigations is scaffolding that complies with ANSI/ASSE
A10.8 - 2011 – Scaffolding Safety Requirements, CAN/CSA S269.2-M87 (Reaffirmed 2003) – Access
Scaffolding for Construction Purposes, and/or Occupational Safety and Health Administration
regulations at 29 C.F.R. Part 1926 subpart L – Scaffolds.
Also excluded from the scope of these investigations are tubular racks such as garment racks and drying
racks, i.e., racks in which the load bearing vertical and horizontal steel members consist solely of: (1)
round tubes that are no more than two inches in diameter; (2) round rods that are no more than two
inches in diameter; (3) other tubular shapes that have both an overall height of no more than two inches
and an overall width of no more than two inches; and/or (4) wire.
Also excluded from the scope of these investigations are portable tier racks. Portable tier racks must
meet each of the following criteria to qualify for this exclusion:
(1) They are freestanding, portable assemblies with a fully welded base and four freely inserted and
easily removable corner posts;
(2) They are assembled without the use of bolts, braces, anchors, brackets, clips, attachments, or
connectors;
(3) One assembly may be stacked on top of another without applying any additional load to the product
being stored on each assembly, but individual portable tier racks are not securely attached to one
another to provide interaction or interdependence; and
(4) The assemblies have no mechanism (e.g., a welded foot plate with bolt holes) for anchoring the
assembly to the ground.
Also excluded from the scope of these investigations are accessories that are independently bolted to
the floor and not attached to the rack system itself, i.e., column protectors, corner guards, bollards, and
end row and end of aisle protectors.
Merchandise covered by these investigations is currently classified in the Harmonized Tariff Schedule of
the United States (HTSUS) under the following subheadings: 7326.90.8688, 9403.20.0080, and
9403.90.8041. Subject merchandise may also enter under subheadings 7308.90.3000, 7308.90.6000,
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 5
7308.90.9590, and 9403.20.0090. The HTSUS subheadings are provided for convenience and U.S.
Customs purposes only. The written description of the scope is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of steel racks and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
I-1a.
Page 6
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.
TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes
I-2.
No
Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of steel racks, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
I-3.
Petitioner status.--Is your firm the petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
Page 7
Yes
Petition support.--Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
China AD
China CVD
I-5.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
Yes--List the following information.
Address
Extent of
ownership
(percent)
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
I-6.
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing steel racks from China into the United States or that are
engaged in exporting steel racks from China to the United States?
No
Firm name
I-7.
Page 8
Yes--List the following information.
Country
Affiliation
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of steel racks?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 9
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Stamen Borisson (202-2053125, [email protected]). Supply all data requested on a calendar-year basis.
II-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
II-2.
Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of steel racks since January 1, 2016.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
(If checked, please describe; leave blank if not applicable)
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
II-3a.
Page 10
Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce steel racks, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope mercandhise, then the "average production capacity"
reported in question II-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in pounds)
Calendar years
Item
2016
Overall production capacity
2017
January-March
2018
2018
2019
1
Production of:
Steel racks2
0
0
0
0
0
0
0
0
0
0
3
Out-of-scope production
Total production using
same machinery or
workers
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of steel racks will populate here once reported in question II-7.
3
Please identify these products:
.
2
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week
Weeks per year
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 11
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II-3e.
Product shifting.—
(i)
Is your firm able to switch production (capacity) between steel racks and other products
using the same equipment and/or labor?
No
(ii)
II-4.
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Tolling.--Since January 1, 2016, has your firm been involved in a toll agreement regarding the
production of steel racks?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
II-5.
Page 12
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce steel racks in and/or admit steel racks
into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
(b)
If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import steel racks into a foreign trade zone (FTZ) for use in distribution of steel racks
and/or the production of downstream articles?
No
II-6.
Yes
Yes
If yes--Identify the firms and the FTZs.
Importer.--Since January 1, 2016, has your firm imported steel racks?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
II-7.
Page 13
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of steel racks in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related 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. Producers’ Questionnaire - Steel racks (Final)
II-7.
Page 14
Production, shipment, and inventory data.—Continued
Quantity (in pounds) and value (in dollars)
Calendar years
Item
2016
2017
January-March
2018
2018
2019
1
Average production capacity (quantity) (A)
Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the
data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus production
(i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data
entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide explanations
for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
1
2016
2017
0
January-March
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
0
.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
II-8.
Page 15
Channels of distribution.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in pounds)
Calendar years
Item
2016
2017
January-March
2018
2018
2019
Channels of distribution:
U.S. shipments:1
To distributors / for re-sale (M)
To end users / for installation (N)
1 Sales
to retailers should be classified as “end users” to the degree the sales are not merchandise intended for resale.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e., lines
M and N) in each time period equal the quantity reported for U.S. shipments (i.e., 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 – D – F – H = zero ("0"), if not
revise.
2016
2017
0
January-March
2018
0
2018
0
2019
0
0
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U.S. Producers’ Questionnaire - Steel racks (Final)
II-9.
Page 16
Rack types.--Please indicate which of the following steel racks your firm produces and sells.
(check as many as appropriate)
Cantilever Rack - A rack structure comprised primarily of vertical columns, extended bases,
horizontal arms projecting from the face of the columns, and down-aisle bracing between
columns. There can be shelf beams between arms depending on the product being stored.
Cantilever columns may be free-standing or overhead tied.
Case-Flow Rack - A specialized pallet rack structure in which either the horizontal shelf beams
support case-flow lanes or case-flow shelf assemblies are supported by the upright frames. The
case-flow lanes or shelves are installed at a slight pitch permitting multiple-depth case or box
storage with loading from one service aisle and unload or picking from another service aisle.
Drive-In Rack - A rack structure comprised primarily of vertical upright frames, horizontal support
arms, and horizontal load rails typically used for one-wide by multiple-depth storage. This
structure includes an “anchor section” with horizontal beams supporting the load rails. Loading
and unloading within a bay must be done from the same aisle. A two-way drive-in rack is a special
case where back-to-back rows of drive-in racks are combined into a single entity with a common
rear post.
Drive-Through Rack - A rack structure comprised primarily of vertical upright frames, horizontal
support arms, and horizontal load rails typically used for one-wide by multiple-depth storage. This
structure lacks the ‘anchor section’ found in drive-in racks; therefore, loading and unloading can
be accomplished from both ends of a bay.
Movable-Shelf Rack - A rack structure comprised primarily of vertical upright frames and
horizontal shelf beams and typically used for one-deep pallet or hand-stack storage. Typically, the
locations of a couple of shelf levels are "fixed" with the location of the in-fill shelves being flexible.
Pallet-Flow Rack - A specialized pallet rack structure in which the horizontal shelf beams support
pallet-flow lanes. The pallet-flow lanes are typically installed on a slight pitch permitting multipledepth pallet storage with loading from one service aisle and unloading from another service aisle.
Pallet Rack - A rack structure comprised primarily of vertical upright frames and horizontal shelf
beams and typically used for one and two-deep pallet storage.
Pick Modules - A rack structure comprised primarily of vertical frames and horizontal beams,
typically having one or more platform levels of selective, case-flow, or pallet-flow bays feeding
into a central pick aisle(s) {work platform(s)} supported by the rack structure.
Portable Rack (Stacking Frames) - An assembly, typically with four corner columns, that permits
stacking of one assembly on top of another without applying any additional load to the product
being stored on each assembly.
Push-Back Rack - A specialized pallet rack structure in which the horizontal shelf beams support
push-back lanes comprised of tracks and carts. The push-back lanes are installed on a slight pitch
permitting multiple-depth pallet storage. Loading and unloading are done from the same service
aisle by pushing the pallets back.
Stacker Rack - A rack structure similar to one of the other rack structures that is serviced by an
automated storage and retrieval machine.
Other1
1
Please identify:
.
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U.S. Producers’ Questionnaire - Steel racks (Final)
II-10.
Page 17
U.S. shipments by coating type.--Please indicate the quantity and value of your firm's U.S.
shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to
related firms) in 2018 by coating type.
U.S. shipments by coating type
No coating
Quantity in pounds (O)
Value in dollars (P)
Painted (not galvanized)
Quantity in pounds (Q)
Value in dollars (R)
Epoxy coated
Quantity in pounds (S)
Value in dollars (T)
Calendar Year 2018
Zinc or other galvanized1
Quantity in pounds (U)
Value in dollars (V)
Other2
Quantity in pounds (W)
Value in dollars (X)
1
2
Whether or not painted.
Please identify:
.
RECONCILIATION OF COATINGS.--Please ensure that the quantities and values reported for rack
coatings (i.e., lines O through X) equal the quantity and values reported for U.S. shipments (i.e.,
lines D through I) in 2018. 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
2018
Quantity: O + Q + S + U + W – D – F – H =
zero ("0"), if not revise.
0
Value: P + R + T + V + X – E – G – I = zero
("0"), if not revise.
0
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U.S. Producers’ Questionnaire - Steel racks (Final)
II-11.
Page 18
U.S. shipments by rack sale type.--Please indicate the quantity and value of your firm's U.S.
shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to
related firms) in 2018 of racks as complete sets versus rack components not sold as a complete
set.
U.S. shipments by rack sale types
Complete rack set
Quantity in pounds (Y)
Value in dollars (Z)
Rack components not sold as a complete set
Quantity in pounds (AA)
Value in dollars (AB)
Calendar year 2018
RECONCILIATION OF COMPONENTS.--Please ensure that the quantities and value reported for
rack components (i.e., lines Y through AB) equal the quantity and values reported for U.S.
shipments (i.e., lines D through I) in 2018. 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
2018
Quantity: Y + AA – D – F – H = zero ("0"), if not
revise.
0
Value: Z + AB – E – G – I = zero ("0"), if not revise.
0
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U.S. Producers’ Questionnaire - Steel racks (Final)
II-12.
Page 19
U.S. shipments by load capacity.--Please indicate which of the following rack load capacities
your firm’s 2018 U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal
consumption, and transfers to related firms) of steel racks had (check all that apply):
U.S. shipments by load capacity
Calendar year 2018
Less than 2,500 pounds
2,500 pounds – 4,999 pounds
5,000 pounds and greater
II-13.
Employment data.--Report your firm’s employment-related data related to the production of
steel racks and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
Average number of PRWs (number)
Hours worked by PRWs (actual hours)
Wages paid to PRWs (actual dollars)
Explanation of trends:
2016
2017
January-March
2018
2018
2019
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U.S. Producers’ Questionnaire - Steel racks (Final)
II-14.
Page 20
Related firms.--If your firm reported transfers to related firms in question II-7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
II-15.
Page 21
Purchases.--Has your firm purchased steel racks produced in the United States or in other
countries since January 1, 2016? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in pounds)
Calendar years
Item
2016
2017
January-March
2018
2018
2019
1
Purchases from U.S. importers of
steel racks from—
China
All other sources
Purchases from domestic producers2
Purchases from other sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
II-16.
Other explanations.--If your firm would like to further explain a response to a question in Part II
that did not provide 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.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 22
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[email protected]).
III-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III-2.
Accounting system.--Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include steel racks:
2.
Does your firm prepare profit/loss statements for steel racks:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)
3.
4.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes steel racks, as well as
specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 23
III-4.
Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III-5.
Product listing.--Please list the products your firm produced in the facilities in which your firm
produced steel racks, and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
Steel racks
Share of sales
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
III-6.
Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of steel racks from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes--Continue to question III-7
III-7.
Page 24
No--Continue to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
steel racks that your firm purchases from related suppliers and that are reflected in question III9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation method, as recorded in the firm’s accounting books and records (e.g., related
supplier’s actual cost, cost plus, transfer price to approximate fair market value, etc.)
III-8.
Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on steel racks) in
a manner consistent with your firm’s accounting books and records.
Yes
No
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 25
III-9a. Operations on steel racks.--Report the revenue and related cost information requested below
on the steel racks operations of your firm’s U.S. establishment(s).1 Do not report resales of
products. Note that internal consumption and transfers to related firms must be valued at fair
market value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three most
recently completed fiscal years, and for the specified interim periods. If your firm was involved
in tolling operations (either as the toller or as the tollee), please contact Jennifer Brinckhaus at
(202) 205-3188 before completing this section of the questionnaire.
Quantity (in pounds) and value (in dollars)
Fiscal years ended-January-March
2016
Item
2017
2018
2018
2019
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials
3
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the
corresponding shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers. Any freight
expense that corresponds to prepaid freight removed from revenue, should also be removed from COGS.
2
Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 26
III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes
III-9c.
No
If no-- If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative--instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
Raw materials.--Please report the share of total raw material costs in 2018 (reported in III-9a)
for the major raw material inputs:
Input
Steel costs
Share of total raw
material costs (percent)
1
Other material inputs2
Total (should sum to 100 percent)
0.0
1
Does your firm purchase steel tubing as an input or make it internally?
Please indicate any other notable "other" raw materials not expressly identified
above and provide the share of the total raw material costs that they account for:
2
.
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 27
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in dollars), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to question
III-9a, only the allocated value amount included in question III-9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.
Fiscal years
2016
Item
2017
January-March
2018
2018
2019
Value (dollars)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Income statement classification of the nonrecurring item
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 28
III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.
III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of steel racks. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for steel racks in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9a. Provide data as
of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in dollars)
Fiscal years ended-Item
2016
Total assets (net)
1
III-13.
Describe
2017
2018
1
.
Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for steel racks. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years ended--
Item
Capital expenditures
2016
2017
January-March
2018
2018
2019
1
Research and development
expenses2
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject
product.
.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject
product.
.
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 29
III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended-Reconciliation
2016
2017
January-March
2018
2018
2019
Quantity: Trade data from question
II-7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").
0
0
0
0
0
Value: Trade data from question II7 (lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").
0
0
0
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 30
III-15. Effects of imports on investment.--Since January 1, 2016, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of steel racks from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 31
III-16. Effects of imports on growth and development.--Since January 1, 2016, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of steel racks from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows:
(check as many as appropriate)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
(please describe)
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 32
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
steel racks from China?
No
Yes
If yes, my firm anticipates negative effects as follows:
III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide 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.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 33
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
IV-1.
Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
PRICE DATA
IV-2.
This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products produced by your
firm.
Product 1.--Beam, non-galvanized, 16 gauge, 96” length, 4” face, 3 pins connection, 1 5/8” step,
RMI certified
Product 2.--Beam, non-galvanized, 16 gauge, 120” length, 5” face, 4 pins connection, 1 5/8”
step, RMI certified
Product 3.--Frame, non-galvanized, 15 gauge, 3” x 1 5/8” posts, 42” x 120,” RMI certified
Product 4.--Frame, non-galvanized, 14 gauge, 3” x 3” posts, 42” x 192,” RMI certified
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV-2 (a). During January 2016-March 2019, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question IV-3.
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 34
IV-2(b). Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds and dollars.
Product 1
Quantity
Value
(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
Period of shipment
Quantity
Value
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 35
IV-2 (c). Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
Quantity data in pounds?
Value data in dollars?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-2 (d). Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of steel racks
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Annual
total
volume
discounts
Other
No
discount
policy
If other, describe
Other
Describe
Pricing terms.--On what basis are your firm’s prices of imported steel racks from China usually
quoted (check one)?
Delivered
IV-6.
Set
price
lists
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV-5.
Page 36
F.o.b.
If f.o.b., specify point
Contract versus spot.-- Approximately what share of your firm’s sales of steel racks imported
from China in 2018 was on a (1) short-term contract basis, (2) annual contract basis, (3) longterm contract basis, and (4) spot sales basis?
Item
Share of 2018
sales
Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
Short-term
contracts
(multiple
deliveries for
less than 12
months)
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
IV-7.
Page 37
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced steel racks (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
Indexed to raw
material costs1
Yes
No
Not applicable
1
Please identify the indexes used:
IV-8.
.
Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced steel racks?
Source
Lead time (Average
Share of 2018 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
IV-9.
Page 38
Shipping information.-(a)
What is the approximate percentage of the cost of U.S.-produced steel racks that is
accounted for by U.S. inland transportation costs?
percent
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(c)
Indicate the approximate percentage of your firm’s sales of steel racks that are
delivered the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0
%
IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced steel racks since January 1, 2016 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
√ if applicable
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 39
IV-11. End uses.--List the end uses of the steel racks that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by steel racks and other inputs?
Share of total cost of end use product
accounted for by
End-use product
Other inputs,
assembly, or
installation costs
Steel racks
Total
(should sum to
100.0% across)
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-12. Substitutes.--Can other products be substituted for steel racks?
No
Substitute
1.
2.
3.
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for steel racks?
No Yes
Explanation
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 40
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for steel racks has changed since January 1, 2016. Explain any trends and
describe the principal factors that have affected these changes in demand.
Overall
increase
Market
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Within the United States
Outside the United States
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of steel racks since January 1, 2016?
No
Yes
If yes, please describe and quantify if possible.
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U.S. Producers’ Questionnaire - Steel racks (Final)
Page 41
(a) Is the steel racks market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to steel racks? If yes,
describe.
Check all that apply.
Please describe.
No
Skip to question IV-16.
Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
steel racks since January 1, 2016?
No
Yes
If yes, describe.
IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply steel racks since
January 1, 2016 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 42
IV-17. Raw materials.—
(a) How have steel racks raw material prices changed since January 1, 2016?
Fluctuate
with no Explain, noting how raw material price changes
Overall
No
Overall
clear
have affected your firm’s selling prices for steel
increase change decrease trend
racks.
Steel costs
Other
materials
(b) Have raw material price changes affected your firm’s selling prices for steel racks?
No
Yes
If yes, please describe.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 43
IV-18. Impact of the section 232 investigation.--This question concerns the section 232 investigation
and subsequent tariffs imposed on imported steel products.
(a) Did the announcement of the section 232 investigation in April 2017 or the subsequent
imposition of tariffs on imported steel products beginning in March 2018 have an impact on
the steel rack market?
Yes—Please fill out table below and
answer part (b)
No
Item
Response
Don’t know
Impact on your firm1
Impact on overall U.S. market1
1
Please identify the magnitude and timing of any effects, and compare your firm's operations/overall market
before and after the application of additional tariffs on imported steel products.
(b)
Assessment of impact of the section 232 tariffs.--Please indicate the impact of the 232
investigation and subsequent imposition on imported steel products beginning in March
2018.
Item
Overall demand for
steel racks in the U.S.
market
Supply of steel racks in
the U.S. market
Prices for steel racks in
the U.S. market
Raw material costs for
steel racks in the U.S.
market
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 44
IV-19. Impact of the section 301 investigation.--This question concerns the section 301 investigation
and subsequent announcement of additional tariffs that include steel racks proposed and
implemented by the United States in response to Chinese trade practices.
(a) Did the announcement of the section 301 investigation in June 2018 or the subsequent
imposition of tariffs on Chinese-origin products have an impact on the steel rack market?
Yes—Please fill out table below and
answer part (b)
No
Item
Response
Don’t know
Impact on your firm1
Impact on overall U.S. market1
1
Please identify the magnitude and timing of any effects, and compare your firm's operations/overall market
before and after the announcement of the section 301 measures.
(b)
Assessment of impact of the section 301 investigation.--Please indicate the impact of
the announcements and subsequent imposition of duties under the section 301
investigation.
Item
Overall demand for
steel racks in the U.S.
market
Supply of steel racks in
the U.S. market
Prices for steel racks in
the U.S. market
Raw material costs for
steel racks in the U.S.
market
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 45
IV-20. Interchangeability.--Are steel racks 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
Mexico
Other countries
United States
China
Mexico
For any country-pair producing steel racks that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:
.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 46
IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between steel racks 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
Mexico
Other countries
United States
China
Mexico
For any country-pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of steel racks, identify the country-pair and report the advantages or disadvantages
imparted by such factors:
.
Business Proprietary
U.S. Producers’ Questionnaire - Steel racks (Final)
Page 47
IV-22. Competition from imports
(a)
Lost revenue.--Since January 1, 2016: To avoid losing sales to competitors selling steel
racks from China, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2016: Did your firm lose sales of steel racks to imports of
this product from China?
No
Yes
IV-23. Other explanations.--If your firm would like to further explain a response to a question in Part
IV 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. Producers’ Questionnaire - Steel racks (Final)
Page 48
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/steel_racks_china/final.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: RACKS
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Modified | 2019-04-01 |
| File Created | 2019-04-01 |