17-1-3745 US producers' questionnaire

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

U.S. Producer Questionnaire

Cut-to-Length Carbon-Quality Steel Plate from India, Indonesia, and Korea (701-TA-388, 389, and 391 and 731-TA-817, 818, and 821)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 17-1-3745; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
CUT-TO-LENGTH CARBON STEEL PLATE (“CTL PLATE”) FROM
INDIA, INDONESIA, AND KOREA
This questionnaire must be received by the Commission by October 30, 2017
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 countervailing duty and antidumping duty orders concerning cut-to-length carbon steel
plate (“CTL plate”) from India, Indonesia, and Korea (Inv. Nos. 701-TA-388, 389, and 391 and 731-TA-817, 818, and 821
(Third Review)). 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 CTL plate (as defined on the next page) at any time since January 1, 2011?

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: CTLP)
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 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

Fax:

Email address

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 2

PART I.--GENERAL INFORMATION
Background.--On February 10, 2000, the Department of Commerce (“Commerce”) issued an
antidumping order on imports of CTL plate from Japan as well as countervailing and antidumping duty
orders on imports of CTL plate from France, India, Indonesia, Italy, and Korea (65 FR 6585 and 65 FR
6587). Following first five-year reviews by Commerce and the U.S. International Trade Commission
(“Commission”), effective December 6, 2005, Commerce issued continuations of the countervailing and
antidumping duty orders on CTL plate from India, Indonesia, Italy, Japan, and Korea (70 FR 72607).
Following second five-year reviews by Commerce and the Commission, effective January 4, 2012,
Commerce issued a second continuation of the countervailing and antidumping duty orders on CTL plate
from India, Indonesia, and Korea (77 FR 264). On December 1, 2016, the Commission instituted a review
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 a negative determination, Commerce will revoke the orders. Questionnaires and other
information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2016/cut_to_length_carbon_quality_steel_plate_india/th
ird_review_full.htm.
CTL plate covered by these reviews is certain hot-rolled carbon-quality steel: (1) Universal mill plates
(i.e., flat-rolled products rolled on four faces or in a closed box pass, of a width exceeding 150 mm but
not exceeding 1250 mm, and of a nominal or actual thickness of not less than 4 mm, which are cut-tolength (not in coils) and without patterns in relief), of iron or non-alloy-quality steel; and (2) flat-rolled
products, hot-rolled, of a nominal or actual thickness of 4.75 mm or more and of a width which exceeds
150 mm and measures at least twice the thickness, and which are cut-to-length (not in coils).
Steel products to be included in the scope are of rectangular, square, circular or other shape and of
rectangular or non-rectangular cross-section where such non-rectangular cross-section is achieved
subsequent to the rolling process (i.e., products which have been ‘‘worked after rolling’’)—for example,
products which have been beveled or rounded at the edges. Steel products that meet the noted physical
characteristics that are painted, varnished or coated with plastic or other non-metallic substances are
included within the scope. Also, specifically included in the scope are high strength, low alloy (‘‘HSLA’’)
steels. HSLA steels are recognized as steels with microalloying levels of elements such as chromium,
copper, niobium, titanium, vanadium, and molybdenum.
Steel products to be included in the scope, regardless of Harmonized Tariff Schedule of the United
States (‘‘HTSUS’’) definitions, are products in which: (1) Iron predominates, by weight, over each of the
other contained elements, (2) the carbon content is two percent or less, by weight, and (3) none of the
elements listed below is equal to or exceeds the quantity, by weight, respectively indicated: 1.80
percent of manganese, or 1.50 percent of silicon, or 1.00 percent of copper, or 0.50 percent of
aluminum, or 1.25 percent of chromium, or 0.30 percent of cobalt, or 0.40 percent of lead, or 1.25
percent of nickel, or 0.30 percent of tungsten, or 0.10 percent of molybdenum, or 0.10 percent of
niobium, or 0.41 percent of titanium or 0.15 percent of vanadium, or 0.15 percent zirconium. All
products that meet the written physical description, and in which the chemistry quantities do not equal
or exceed any one of the levels listed above, are within the scope unless otherwise specifically excluded.
The following products are specifically excluded from the orders:

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U.S. Producers’ Questionnaire – CTL plate

Page 3

(1) Products clad, plated, or coated with metal, whether or not painted, varnished or
coated with plastic or other non-metallic substances;
(2) SAE grades (formerly AISI grades) of series 2300 and above;
(3) products made to ASTM A710 and A736 or their proprietary equivalents;
(4) abrasion-resistant steels (i.e., USS AR 400, USS AR 500);
(5) products made to ASTM A202, A225, A514 grade S, A517 grade S, or their
proprietary equivalents;
(6) ball bearing steels;
(7) tool steels; and
(8) silicon manganese steel or silicon electric steel.
CTL plate is currently classifiable in the HTSUS under statistical reporting numbers: 7208.40.3030,
7208.40.3060, 7208.51.0030, 7208.51.0045, 7208.51.0060, 7208.52.0000, 7208.53.0000, 7208.90.0000,
7210.70.3000, 7210.90.9000, 7211.13.0000, 7211.14.0030, 7211.14.0045, 7211.90.0000, 7212.40.1000,
7212.40.5000, 7212.50.0000, 7225.40.3050, 7225.40.7000, 7225.50.6000, 7225.99.0090, 7226.91.5000,
7226.91.7000, 7226.91.8000, and 7226.99.0000.The HTSUS provisions are for convenience and customs
purposes; the written description of the scope is dispositive.
Reporting of information.--If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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
U.S. Producers’ Questionnaire – CTL plate
I-1.

Page 4

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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-2.

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 CTL plate, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
Covered1

City, State

Zip (5 digit)

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

Description

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U.S. Producers’ Questionnaire – CTL plate
I-3.

Page 5

Position regarding continuation of order.--Does your firm support or oppose continuation of
the following antidumping and countervailing duty orders currently in place for CTL plate?
Country

Support

Oppose

Take no position

India (AD)
India (CVD)
Indonesia (AD)
Indonesia (CVD)
Korea (AD)
Korea (CVD)

I-4.

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

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing CTL plate into the United States or that are engaged in
exporting CTL plate to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
I-6.

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

Yes--List the following information.

Firm name

I-7.

Page 6

Country

Affiliation

Business plan.--In Parts II and IV 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 market conditions for CTL plate?

No

Yes

If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Carolyn Carlson (202-2053002, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of CTL plate since January 1, 2011.

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 – CTL plate
II-3a.

Page 8

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce CTL plate, and the combined production
capacity on this shared equipment and machinery 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).
“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.
Calendar years
Item

2014

2015

January-September
2016

2016

2017

Quantity (in short tons)
REVERSING PLATE MILL
Overall production capacity
Production of:
CTL plate (A)
1

Other products

Total reversing plate mill production

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

COMBINATION (STECKEL) MILL
Overall production capacity
Production of:
CTL plate (B)
2

Other products

Total combination (steckel) mill
production
BAR MILL
Overall production capacity
Production of:
CTL plate (C)
3

Other products

Total bar mill production
PROCESSING/CUT-TO-LENGTH LINE
Overall production capacity
Production of:
CTL plate (D)
4

Other products

Total processing/cut-to-length
production
1

Please identify your firm's other reversing plate mill (i.e., rolled) products:
.
Please identify your firm's other combination (steckel) mill products:
.
3
Please identify your firm's other bar mill products:
.
4
Please identify your firm's other products produced on your firm's coil slitting machinery:
2

.

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U.S. Producers’ Questionnaire – CTL plate
II-3a.

Page 9

Production using same machinery.--Continued
RECONCILIATION OF PRODUCTION.--

Reconciliation
A + B + C + D - G = should equal zero, if
not revise prior to submission.

Calendar years
2015

2014
0

0

January-September
2016
2017

2016
0

0

0

II-3b.

Operating parameters.--The production capacity reported in II-4a is based on operating
per week,
weeks per year.

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.--Is your firm able to switch production (capacity) between CTL plate and other
products using the same equipment and/or labor?
No

II-3f.

Yes--(i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:

hours

.

Product shifting factors.--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.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
II-4.

Page 10

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of CTL plate 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.
“U.S. commercial 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 – CTL plate
II-4.

Page 11

Production, shipment, and inventory data.--Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2014

2015

January-September
2016

2016

2017

1

Average production capacity (quantity) (E)
Beginning-of-period inventories (quantity) (F)
Production (quantity) (G)
U.S. shipments:
Commercial shipments:
Quantity (H)
Value (I)
Internal consumption:
Quantity (J)
2

Value (K)
Transfers to related firms:
Quantity (L)
2

Value (M)
Export shipments:
Quantity (N)

3

Value (O)
End-of-period inventories (quantity) (P)
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. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above:
.
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 P) should be equal to the beginning-of-period inventories (i.e., line E), plus
production (i.e., line G), less total shipments (i.e., lines H, J, L, and N). 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.

Reconciliation
F + G – H – J – L – N – P = should equal
zero ("0") or provide an explanation.1
1

Calendar years
2015

2014

0

0

January-September
2016
2017

2016

0

0

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

0
.

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U.S. Producers’ Questionnaire – CTL plate

Page 12

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.

II-5.

Quantity (in short tons)
Calendar years
Item

2014

2015

January-September
2016

2016

2017

Channels of distribution:
Commercial U.S. shipments:
To distributors (Q)
To end users
Construction (R)
Other (S)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines Q, R, and S) in each time period equal the quantity reported for commercial U.S. shipments (i.e., line 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.

Reconciliation
Q + R + S – H = zero ("0"), if not
revise.

II-6.

Calendar years
2015

2014
0

January-September
2016
2017

2016

0

0

0

CTL plate historical U.S. shipments data (2011-13).--Report the quantity and value of your
firm’s U.S. shipments (include commercial shipments, internal consumption, and transfers, but
do not include exports) of CTL plate produced in your U.S. establishment(s) during the specified
periods.
Quantity (in short tons), value (in $1,000)
Item

CTL plate
Quantity
Value

2011

2012

2013

0

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
II-7.

Page 13

Employment data.--Report your firm’s employment-related data related to the production of
CTL plate and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) – includes working supervisors and all
nonsupervisory workers (including group leaders and trainees) engaged in fabricating,
processing, assembling, inspecting, receiving, storage, handling, packing, warehousing, shipping,
trucking, hauling, maintenance, repair, janitorial and guard services, product development,
auxiliary production for plant’s own use (e.g., power plant), recordkeeping, and other services
closely associated with the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to September periods, calculate similarly and divide by 9.
If your firm had the same number of PRWs in all calendar years and had not experienced any
changes in PRWs in the most recent interim period, you would have the same number of PRWs
for the interim periods, regardless of whether the interim periods are Jan-Mar (Q1), Jan-June
(Q1+Q2), or Jan-Sept (Q1+Q2+Q3).
“Hours worked” – includes time paid for sick leave, holidays, and vacation time. Include
overtime hours actually worked; do not convert overtime pay to its equivalent in straight time
hours.
“Wages paid” – Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item

Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:

2014

2015

January-September
2016

2016

2017

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
II-8.

Page 14

Product type.--Please indicate the type of CTL plate your firm produced in 2016.

Type of CTL plate

Production in 2016
(check all that apply)

Carbon/micro-alloy pressure vessel plate
Oil-drilling platform plate
Shipbuilding plate
X-70 (or higher) plate for line pipe having a width not
exceeding 120 inches
X-70 (or higher) plate for line pipe having a width greater than
120 inches1
Carbon/micro-alloy plate for line pipe other than X-70
Carbon/micro-alloy plate for sour service
Ultra high strength steel (UHSS) or advanced high strength
steel (AHSS) carbon/micro-alloy plate
1

Please report the maximum thickness of X-70 grade CTL plate your firm produced in 2016.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 15

II-9.

Transfers to related firms.--If your firm reported transfers to related firms in question II-4,
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
non-market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.

II-10.

Purchases.--Other than direct imports, has your firm otherwise purchased CTL plate since
January 1, 2014?
No

Yes--Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity and
value of such purchases below for the specified periods.

“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.
“Direct import” – A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
Reason for purchases:

(Quantity in short tons)
Calendar years
Item

2014

2015

January-September
2016

2016

2017

Purchases from U.S.
importers1 of CTL plate
from-India
Indonesia
Korea (excluding POSCO)
All other sources (including
from POSCO in Korea)
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:
.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
II-11.

Page 16

Toll production.--Since January 1, 2011, has your firm been involved in a toll agreement
regarding the production of CTL plate?
“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

II-12.

Yes

If yes--Please describe the toll arrangement(s) and name the firm(s)
involved.

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce CTL plate in and/or admit CTL plate into
a foreign trade zone (FTZ)?

(a)

“Foreign trade zone” – 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

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

(b)

No

II-13.

Yes

If yes--Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Yes

If yes--Identify the firms and the FTZs.

Direct imports.--Since January 1, 2011, has your firm imported CTL plate?
“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

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U.S. Producers’ Questionnaire – CTL plate

Page 17

For questions II-14 and II-15, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II-14.

Effect of orders.--Describe the significance of the existing countervailing duty and antidumping
duty orders covering imports of CTL plate from India, Indonesia, and Korea in terms of its effect
on your firm’s production capacity, production, U.S. shipments, inventories, purchases,
employment, revenues, costs, profits, cash flow, capital expenditures, research and
development expenditures, and asset values. You may wish to compare your firm’s operations
before and after the imposition of the orders.

II-15.

Anticipated changes in operations.--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 CTL plate
in the future? Please consider both anticipated changes if the countervailing duty and
antidumping duty orders on CTL plate from India, Indonesia, and Korea were to be revoked.
Please also note that imports from Korean firm POSCO are not subject to the orders and should
be considered as a part of your response if the orders were 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 CTL plate (in short tons) for 2017 and 2018.

If orders
remain in place
If orders are
revoked
II-16.

Other explanations.--If your firm would like to explain further 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 – CTL plate

Page 18

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
Fax

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 CTL plate:

2.
3.
4.

Does your firm prepare profit/loss statements for CTL plate:
Yes
No
What type of reports and how often does your firm prepare financial statements?
Please check relevant items below.
audited,
unaudited,
10Ks,
annual,
quarterly,
semi-annual
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive basis of
accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records 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.).

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.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

III-5.

Page 19

Product listing.--Please list the products your firm produces in the facilities in which it produces
CTL plate, and provide the share of net sales accounted for by these products in your firm’s most
recent fiscal year.
Products

Share of sales

CTL plate

%

Steel sheet/strip

%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of CTL plate 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.

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of CTL plate
that your firm purchases from related suppliers and that are reflected in question III-9a. For
“Share of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
the 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 as recorded in the firm’s accounting books and records

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
III-8.

Page 20

Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in III-9a (financial results on CTL plate) in a manner
consistent with the firm’s accounting books and records.
Yes

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

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 21

III-9a. Operations on CTL plate.--Report the revenue and related cost information requested below on
the CTL plate 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.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2014

2015

January-September

2016

2016

2017

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

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

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

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.
2

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

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 22

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

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.

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 $1,000), 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 ended--

2014

2015

January-September

2016

2016

2017

Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in question III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
Value ($1,000)
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 23

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 CTL plate. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for CTL plate 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 $1,000)
Fiscal years ended-Item
Total assets (net)
1

2014

2015

2016

1

Describe

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for CTL plate. Provide data for your firm’s
three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended--

Item

2014

2015

January-September

2016

2016

2017

1

Capital expenditures

2

Research and development expenses
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.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 24

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 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-6 (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 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.
Full year data
Reconciliation

2014

2015

Partial year periods
2016

2016

2017

Quantity: Trade data from question
II-4 (lines H, J, L, and N) less financial
total net sales quantity data from
question III-9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II-4
(lines I, K, M, and O) 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-6?
Yes

No

If no, please explain.

III-15. 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 – CTL plate

Page 25

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Fernando Gracia (202-2052747, [email protected]).
IV-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 IV.
Name
Title
Email
Telephone
Fax

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products produced by your firm.
Product 1.—Hot-rolled carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 96” in width,
0.250” thick.
Product 2.—Hot-rolled carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 96” in width,
0.3125” thick.
Product 3.—Hot-rolled carbon steel plate, ASTM A-36 or equivalent as rolled, mill edge, not
heat treated, not cleaned or oiled, in cut lengths, 72” through 120” in width,
0.375” through 3.00” in thickness.
Product 4.—Hot-rolled carbon steel plate, high strength low allow (HSLA), ASTM A-572, Grade
50, mill edge, not cleaned or oiled, in cut lengths, 72” through 120” in width,
0.5” through 1.5” in thickness.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 26

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).
(a) During January 2014 - September 2017, 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 tables as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 27

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

Product 3
Period of shipment
Quantity
Value
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 28

IV-2(b). Price data.--Continued
Report data in short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 4
Quantity
Value

Product 5
Period of shipment
Quantity
Value
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 29

IV-2(c). Price data checklist.--Please check that the pricing data in question IV-2(a) has been correctly
reported.
√ if Yes

Is the price data reported above:
In actual dollars (not $1,000)
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-6 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.

IV-3.

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

IV-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
IV-5.

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced CTL plate?
Net 30
days

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic CTL plate usually quoted (check one)?

(b)

Delivered

IV-6.

Page 30

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
CTL plate in 2016 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term
contract basis, and (4) spot sales basis?

Share of 2016
sales

Long-term
contracts
(multiple
deliveries for
more than 12
months)
%

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

%

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
IV-7.

Page 31

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced CTL plate (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

Fixed quantity
and/or price

Short-term contracts
(multiple deliveries
for less than 12
months)

Annual contracts
(multiple
deliveries for 12
months)

Long-term contracts
(multiple deliveries for
more than 12 months)

365

No
Quantity
Price
Both
Yes

Meet or release
provision

No

Not applicable
IV-8.

Lead times.--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 CTL plate?

Source

Share of 2016
sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Lead time (average
number of days)

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
IV-9.

Page 32

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced CTL plate that is
accounted for by U.S. inland transportation costs?
%

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm

(c)

Purchaser (check one)

Indicate the approximate percentage of your firm’s sales of CTL plate that are delivered
the following distances from your firm’s 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 CTL plate since January 1, 2011 (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 – CTL plate

Page 33

IV-11. End uses.-(a)

List the end uses of the CTL plate that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by CTL plate and other
inputs?
Share of total cost of end use product
accounted for by
End use product

(b)

CTL plate

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

Have there been any changes in the end uses of CTL plate since January 1, 2011? Do you
anticipate any future changes?

Changes in end
uses
Changes since
January 1, 2011
Anticipated
changes

No

Yes

Explain

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 34

IV-12. Substitutes.-(a)

Can other products be substituted for CTL plate?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for CTL plate?
No Yes

Explanation

1.
2.
3.

(b)

Have there been any changes in the number or types of products that can be
substituted for CTL plate since January 1, 2011? Do you anticipate any future changes?
Changes in
substitutes

Changes since
January 1, 2011
Anticipated
changes

No

Yes

Explain

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 35

IV-13. Availability of supply.--Has the availability of CTL plate in the U.S. market changed since January
1, 2011? Do you anticipate any future changes?
Availability in the U.S.
market

No

Changes since January 1, 2011:
U.S.-produced product
Imports from India,
Indonesia, and Korea
(Excluding POSCO)
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from India,
Indonesia, and Korea
(Excluding POSCO)
Imports from all other
countries

Yes

Please explain, noting the countries and reasons for
the changes.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 36

IV-14. Demand trends.—
(a)

Indicate how demand within the United States and outside of the United States (if
known) for CTL plate has changed since January 1, 2011. Explain any trends and describe
the principal factors that have affected these changes in demand. If not known for a
particular sector, please leave that row blank.
January 1, 2011-December 31, 2013

Market

Overall
increase

Within the United States
Within the United States
for the following sectors:
Agricultural and
electrical equipment
Automotive
Construction
Machinery, tools &
industrial equipment
Oil and gas industry
Rail transportation
Shipbuilding and
marine equipment
Wind towers
Other1
Outside the United
States
1

Please describe the "other" sectors:

No change

Overall
decrease

Since January 1, 2014
Overall
increase

No change

Overall
decrease

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

(b)

Page 37

Have any changes in raw material costs affected your firm’s price negotiations and/or
selling prices (including surcharges) since January 1, 2011? If there are relevant
surcharges, please identify them specifically.
No

(c)

Yes

Please explain.

Are your firm’s sales of CTL plate indexed to raw material costs?

No

Yes

Please explain, identifying the particular raw materials index or indices,
and how frequently prices are adjusted based on the index or indices.

IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of CTL plate since January 1, 2011? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
Changes since
January 1, 2011
Anticipated
changes

No

Yes

Explain

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate
IV-16.

Page 38

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

Please describe.

No

Skip to question IV-17.

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
CTL plate since January 1, 2011?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply CTL plate since
January 1, 2011 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

IV-18. Raw materials.--Indicate how CTL plate raw material prices have changed since January 1, 2011,
and how you expect they will change in the future.

Raw
materials
prices
Changes since
January 1,
2011
Anticipated
changes

Fluctuate
with no
clear
Overall
No
Overall
increase change decrease trend

Explain, noting how raw material
price changes have affected your
firm’s selling prices for CTL plate.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

Page 39

IV-19. Price comparisons.--Please compare market prices of CTL plate in U.S. and non-U.S. markets, if
known. Provide specific information as to time periods and regions for any price comparisons.

IV-20. 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 CTL plate supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including India, Indonesia, and Korea, and (3)
the world as a whole. Of particular interest is such data from 2011 to the present and forecasts
for the future.
IV-21. Export constraints.--Describe how easily your firm can shift its sales of CTL plate between the
U.S. market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints that would prevent or retard your firm from
shifting CTL plate between the U.S. and alternative country markets within a 12-month period.

IV-22. Barriers to trade.--Are your firm’s exports of CTL plate subject to any tariff or non-tariff barriers
to trade in other countries?

No

Yes

If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2011, or that are expected to occur in the future.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

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IV-23. Interchangeability.--Is CTL plate 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

India

Indonesia

Korea1

Other countries1

United States
India
Indonesia
Korea1
For any country-pair producing CTL plate that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

1

“Korea” includes CTL plate from all producers in Korea other than POSCO; “Other countries”
includes CTL plate from POSCO.

Business Proprietary
U.S. Producers’ Questionnaire – CTL plate

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IV-24. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between CTL plate 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

India

Indonesia

Korea1

Other countries1

United States
India
Indonesia
Korea1
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of CTL plate, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

1

“Korea” includes CTL plate from all producers in Korea other than POSCO; “Other countries”
includes CTL plate from POSCO.
IV-25. 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 – CTL plate

Page 42

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/701731/2016/cut_to_length_carbon_quality_stee
l_plate_india/third_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: CTLP

• 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 Typeapplication/pdf
File TitleUS Producer questionnaire - sunst
AuthorCarlson, Carolyn
File Modified2017-09-08
File Created2017-09-08

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