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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4169; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
DIFLUROMETHANE (R‐32) FROM CHINA
This questionnaire must be received by the Commission by February 6, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping investigation concerning difluoromethane (“R‐32”) from China (Inv. No. 731‐TA‐1472
(Preliminary)). The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930,
title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the
submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced R‐32 (as defined on next page) at any time since January 1, 2017?
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: DIFLU)
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
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on January 23, 2020, by
Arkema Inc., King of Prussia, Pennsylvania. 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 dumping. Questionnaires and other information pertinent to this proceeding are
available at
http://wwwadmin.usitc.gov/investigations/701731/2020/difluoromethane_r_32_china/preliminary.htm
_0.
Difluoromethane (“R‐32”) covered by this investigation is difluoromethane (“R‐32”) or its chemical
equivalent, regardless of form, type or purity level. R‐32 has the Chemical Abstracts Service (“CAS”)
registry number of 75‐10‐5 and the chemical formula CH2F2. R‐32 is also referred to as difluoromethane,
HFC‐32, FC‐32, Freon‐32, methylene difluoride, methylene fluoride, carbon fluoride hydride, halocarbon
R32, fluorocarbon R32, and UN 3252.
Subject merchandise also includes R‐32 and unpurified R‐32 that are processed in a third country or the
United States, including, but not limited to, purifying or any other processing that would not otherwise
remove the merchandise from the scope of this investigation if performed in the country of
manufacture of the in‐scope R‐32. R‐32 that has been blended with products other than
pentafluoroethane (R‐125) is included within this scope if such blends contain 85% or more by volume
on an actual percentage basis of R‐32. In addition, R‐32 that has been blended with any amount of R‐125
is included within this scope if such blends contain more than 52% by volume on an actual percentage
basis ofR‐32. Whether R‐32 is blended with R‐125 or other products, only the R‐32 component of the
mixture is covered by the scope of these orders. The scope also includes R‐32 that is commingled with R‐
32 from sources not subject to this investigation. Only the subject component of such commingled
products is covered by the scope of this order.
Excluded is merchandise covered by the scope of the antidumping order on Hydrofluorocarbon Blends
from the People's Republic of China. See Hydrofluorocarbon Blends from the People's Republic of China,
81 Fed. Reg. 55436 (Aug. 19, 2016).
R‐32 is currently imported under statistical reporting numbers 2903.39.2035 of the Harmonized Tariff
Schedule of the United States (HTSUS). It may also be imported under HTSUS statistical reporting
numbers 2903.39.2045 and 3824.78.0020. 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, 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 3
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of R‐32 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 4
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 macro‐
enabled 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.
I‐1a. 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, contact person’s
title, 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
No
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
I‐2a.
Page 5
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. 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 R‐32, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
I‐2c.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
I‐3.
Law firm:
Lead attorney(s):
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Petition support.‐‐Does your firm support or oppose the petition?
Country
China
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
I‐5.
I‐6.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Firm name
Country
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing R‐32 from China into the United States or that are
engaged in exporting R‐32 from China to the United States?
No
Yes‐‐List the following information.
Page 6
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
I‐7.
I‐8.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of R‐32?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Regulatory changes to R‐32 on production.‐‐Please describe any regulatory changes to the
production of R‐32 since January 1, 2017. Include both domestic regulations required by the EPA
and international agreements, if any, that may affect the production of R‐32.
I‐9.
Development of R‐32 replacements.‐‐ Since January 1, 2017, has your firm been involved in
developing and/or producing more environmentally friendly replacements for R‐32? Please
discuss the product(s) that may be under development and/or production to replace R‐32.
Please include information on the availability of the product(s) in the market today (indicate the
year when the product(s) was/were available), whether existing equipment needs to be
adjusted/retrofitted from R‐32 for the replacement(s), whether the replacement product(s)
is/are under patent protection, and any additional information on the replacement(s) for R‐32.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Ahdia Bavari (202‐205‐3191,
[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 R‐32 since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 9
II‐3a. Production using same machinery.‐‐Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce R‐32, 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 merchandise, 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 short tons)
Calendar years
Item
2017
1
Overall production capacity
Production of:
R‐322
3
Other products
Total production using same
machinery or workers
2018
2019
0
0
0
0
0
0
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of R‐32 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 ‐ R‐32 (Preliminary)
II‐3c.
Page 10
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‐4.
Product shifting.—
(a)
Is your firm able to switch production (capacity) between R‐32 and other products using the
same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other products)
Please identify other actual or potential products.
(b)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐5.
Tolling.‐‐Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of R‐32?
“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 ‐ R‐32 (Preliminary)
II‐6.
Page 11
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce R‐32 in and/or admit R‐32 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 designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐Describe the nature of your firms operations in FTZs and identify the
specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import R‐32 into a foreign trade zone (FTZ) for use in distribution of R‐32 and/or the
production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
II‐7.
Page 12
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of R‐32 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. This excludes
commercial arms‐length transactions that involve, at least in part, non‐monetary “in kind”
transactions (a.k.a., swap transactions). Report net values (i.e., gross sales values less all
discounts, allowances, rebates, prepaid freight, and the value of returned goods) in U.S. dollars,
f.o.b. your point of shipment.
“Internal consumption” –Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Swaps” –Shipments made commercially in arms‐length transactions that involve, at least in
part, non‐monetary “in kind” transfer of product.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
II‐7.
Page 13
Production, shipment, and inventory data.‐‐Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2017
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)
2
Value (G)
2
Transfers to related firms:
Quantity (H)
2
Value (I)
3
Swaps :
Quantity (J)
4
Value (K)
Export shipments:
Commercial shipments:
Quantity (L)
Value (M)
Other (internal consumption, transfers to
related firms, or swap) shipments:
Quantity (N)
2
Value (O)
End‐of‐period inventories (quantity) (P)
1
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Please (1) identify the companies from which your firm receives the goods or services in‐kind, (2) indicate the
particular goods or services in‐kind received pursuant to your swap transactions, and (3) quantify any net monetary
exchange included in the swap transactions in each calendar year: .
4
Report the value inclusive of the “in kind” value of any goods or services received plus the net monetary transferred in
the swap transactions.
5
Identify your firm’s principal export markets: .
2
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 14
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐
period inventories (i.e., line P) 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
2017
B + C – D – F – H – J – L– N– P = should equal
zero ("0") or provide an explanation.1
2018
2019
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐8.
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.
Calendar years
Item
2017
2018
2019
Quantity (in short tons)
Channels of distribution:
U.S. shipments:
To distributors and service
companies (Q)
To HFC component
blenders (R)
To OEMs and other non‐
blender end users (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 U.S. shipments (i.e., line D, F, H,
and J) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data
reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
Q + R + S ‐ D ‐F ‐ H‐ J = zero ("0"), if
not revise.
2017
2018
0
2019
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 15
II‐9. Employment data.‐‐Report your firm’s employment‐related data related to the production of R‐
32 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
2017
2018
2019
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐10. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 16
II‐11. Purchases.‐‐Has your firm purchased R‐32 produced in the United States or in other countries
since January 1, 2017? (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 short tons)
Calendar years
Item
2017
2018
2019
1
Purchases from U.S. importers of R‐32
from—
China
All other sources
Purchases from domestic producers
3
Purchases from other sources
2
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 U.S. producer(s) from which your firm purchased this product: .
3
Please list the name of the firm(s) from which your firm purchased this product: .
II‐12. Imports.‐‐Since January 1, 2017, has your firm imported R‐32?
No
Yes
If yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 17
II‐13. Internal consumption/transfers to related firms — In 2019, did your firm internally consume,
transfer to a related firm, and/or swap any portion of its R‐32 production, as reported in lines F,
H, and J of question II‐7?
No‐ Do not complete question II‐14
Yes‐ Complete question II‐14.
II‐14. Captive production use. — Please report the share of your firm’s 2019 internal consumption,
transfers to related firms, and/or swaps for the uses identified below. These data should
reconcile with the 2019 quantities reported in question II‐7 (lines F, H, and J).
Internal consumption
Swaps
Transfers to related firms
2019
2019
2019
Products
(short tons)
(short tons)
(short tons)
Sold as is (Re‐entry
into merchant
market)
N/A
Assembled into
other products1
1
Please describe these products: .
RECONCILIATION OF CAPTIVE PRODUCTION USE.— The sum of the data
reported above should be equal to the data reported in lines A and C of question
II‐7 of each calendar year and interim period.
Calendar years
Reconciliation
2019
Internal consumption (line F in II‐7)
reconciliation.
0
Transfers to related parties (line H in II‐7)
reconciliation.
0
Swaps (line J in II‐7) reconciliation.
0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐15. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 18
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[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.—Please provide the following information on 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 R‐32:
2. Does your firm prepare profit/loss statements for R‐32:
Yes
No
3. 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
4. Accounting basis: U.S. GAAP, IFRS 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 (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes R‐32, as well as specific
statements and worksheets) used to compile these data.
III‐3a. Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 19
III‐3b. Swap accounting.‐‐From the perspective of revenue and cost, please describe the company’s
routine accounting treatment of R‐32 swaps. As applicable, please describe how the company’s
routine accounting treatment differs from the manner in which swaps are reported in table III‐
9a. Please confirm that swap values reported in table III‐9a reflect fair market value and provide
a general description of how that value was determined.
III‐3c. Swap value.‐‐In the space below, please confirm that R‐32 swap values reported in table III‐9a
represent fair market value. Please provide a general description of swap valuation basis in table
III‐9a.
III‐3d. Swap ratios.‐‐Please identify the counterparties to R‐32 swap arrangements during the period
examined, components exchanged for R‐32, relevant swap ratios, and how the basis of reported
ratios. Please also describe the extent to which relevant swap ratios and/or other important
aspects of swap arrangements changed during the period and the reason for the changes.
III‐3e. Changes in swap arrangements.‐‐Please describe the extent to which relevant swap ratios
and/or other important aspects of swap arrangements changed during the period and the
reason for the changes.
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 ‐ R‐32 (Preliminary)
III‐5.
Page 20
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced R‐32, and provide the share of net sales accounted for by these products in your firm’s
most recent fiscal year.
Products
III‐6.
Share of sales
R‐32
%
%
%
%
%
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of R‐32 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—Skip to question III‐9a.
Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of R‐
32 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
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
Input valuation as recorded in the firm’s accounting books and records
Share of total COGS
III‐8.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, are reported in III‐9a and III‐9b 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 21
III‐9a. Overall operations on R‐32.‐‐Report the revenue and related cost information requested below
on the R‐32 operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that transfers to related firms, internal consumption, and swaps (R‐32 given up in
exchange for another HFC component and reported in the revenue section of this table) 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.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2017
2018
2019
Net sales quantities:2
Commercial sales (“CS”)
Transfers to related firms (“Transfers”)
Internal consumption (“IC”)
Swaps
0
0
0
Commercial sales
Internal consumption
Total net sales quantities
Net sales values:2
Transfers to related firms
Swaps
0
0
0
Raw materials
Direct labor
Other factory costs
Less: byproduct revenue
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
Total net sales values
Cost of goods sold (COGS):3
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
0
0
0
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.
2 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, Transfers, IC, and swaps. Costs
associated with input purchases from related suppliers should be consistent with and based on information in the firm’s
accounting books and records.
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 ‐ R‐32 (Preliminary)
Page 22
III‐9b. Open market operations (U.S. commercial shipments and commercial exports only) on R‐32.‐‐
Report the revenue and related cost information requested below on the R‐32 operations of
your firm’s U.S. establishment(s).1 Include both the domestic and export commercial sales of R‐
32 producer by your firm, but do not report the resale of R‐32. 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.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2017
2018
2019
Net sales quantities:2
Commercial sales (“CS”)
0
0
0
0
0
0
Direct labor
Other factory costs
Less: byproduct revenue
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
Net sales values:2
Commercial sales
Cost of goods sold (COGS):3
Raw materials
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
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.
2 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. Commercial sales quantities and commercial sales values
reported here will be populated from data entered into question III‐9a.
3 COGS (whether for domestic or export sales) should include costs associated with commercial sales only, Costs associated with
input purchases from related suppliers should be consistent with and based on information in the firm’s accounting books and
records.
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 ‐ R‐32 (Preliminary)
Page 23
III‐9c. Financial data reconciliation.‐‐The calculable line items from question III‐9a and III‐9b (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 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‐9d. Raw materials.‐‐Please identify and report the share of raw material costs in 2019 (reported in
III‐9a):
Source
Input
Share of total raw
material costs
(percent)
Chlorinated compounds:
Hydrofluoric acid
Other material inputs
Total (should sum to 100 percent)
0.0
Primarily
produced by
your firm
Primarily
purchased by
your firm
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 24
III‐10a. Nonrecurring items (charges and gains) included in III‐9a (overall operations on R‐32).‐‐For
each annual 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 reported in III‐9a.
Fiscal years ended‐‐
Item
2017
2018
2019
Value ($1,000)
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
Income statement classification 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
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 25
III‐10b. Nonrecurring items (charges and gains) included in III‐9b (open market operations on R‐32).‐‐
For each annual period for which financial results are reported in question III‐9b, please specify
all material (significant) nonrecurring items (charges and gains) in the schedule below, the
specific question III‐9b 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‐9b; i.e., if an aggregate nonrecurring item has been allocated to question III‐9b, only
the allocated value amount included in question III‐9b 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 financial results reported in III‐9b.
Fiscal years ended‐‐
Item
2017
2018
2019
Value ($1,000)
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‐9b where the nonrecurring item is classified.
Description of the
nonrecurring item
Income statement classification 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
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 26
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‐10a and III‐10b
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‐10a and III‐10b
identify where these items are reported in question III‐9a and III‐9b, respectively.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of R‐32. If your firm does not maintain some or all of the
specific asset information necessary to calculate total assets for R‐32 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 R‐32 operations if these assets are also related to other
products. As reported in table III‐12, 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
2017
Total assets (net) 1
1
III‐13.
2018
2019
Describe .
Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for R‐32. Provide data for your firm’s
three most recently completed fiscal years.
Value (in $1,000)
Item
Fiscal years ended‐‐
2017
1
Capital expenditures
2
R&D expenses
1
2018
2019
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 ‐ R‐32 (Preliminary)
Page 27
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9b, III‐12, and III‐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
2017
2018
2019
Quantity: Trade data from question II‐7
(lines D, F, H, J, and L) less financial total
net sales quantity data from question III‐
9a, = zero ("0").
0
0
0
Value: Trade data from question II‐7
(lines E, G, I, K, and M) less financial total
net sales value data from question III‐9a,
= zero ("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 ‐ R‐32 (Preliminary)
Page 28
III‐15. Effects of imports on investment.‐‐Since January 1, 2017, 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 R‐32 from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
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
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 29
III‐16. Effects of imports on growth and development.‐‐Since January 1, 2017, 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 R‐32 from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the issue
of stocks or bonds
Ability to service debt
Other
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 30
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
R‐32 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
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 31
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (202‐205‐2049,
[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, 2017 of the following products produced by your
firm.
Product 1.—R‐32, sold in bulk to blenders
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‐2a. During January 2017‐December 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 as appropriate.
No.‐‐Skip to question IV‐3.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 32
IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Quantity
Period of shipment
Value
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
April‐June
July‐September
October‐December
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the
value of returned goods), f.o.b. your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with
the specified product, provide a description of your firm’s product. Also, please explain any anomalies
in your firm’s reported pricing data.
Product 1:
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 33
IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
In pounds (not short tons)?
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‐2d. 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 ‐ R‐32 (Preliminary)
IV‐3.
Page 34
Price setting.‐‐How does your firm determine the prices that it charges for sales of R‐32 (check
all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic R‐32 usually quoted (check
one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced R‐32
in 2019 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐term contract
basis, and (4) spot sales basis?
Item
Share of 2019
sales
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
IV‐7.
Page 35
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced R‐32 (or check “not applicable” if your firm does not sell on a short‐term, annual
and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period) 1
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs2
Not applicable
365
1
Please explain how contract terms are renegotiated (i.e., meet or release clause):
Please identify the indexes used: .
2
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 R‐32?
Lead time (Average
Source
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
IV‐9.
Page 36
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the cost of U.S.‐produced R‐32 that is accounted
for by U.S. inland transportation costs? percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of R‐32 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 R‐32 since January 1, 2017 (check all that apply)?
Geographic area
√ if applicable
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 37
IV‐11. End uses.‐‐List the end uses of the R‐32 that your firm manufactures. For each end‐use product,
what percentage of the total cost is accounted for by R‐32 and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
R‐32
Other inputs
End‐use product
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐12. Substitutes.‐‐Can other products be substituted for R‐32?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for R‐32?
No Yes
Explanation
1.
2.
3.
IV‐13. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for R‐32 has changed since January 1, 2017. Explain any trends and describe
the principal factors that have affected these changes in demand.
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Market
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 R‐32 since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 38
IV‐15. Conditions of competition.‐‐
(a) Is the R‐32 market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to R‐32? 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
R‐32 since January 1, 2017?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply R‐32 since
January 1, 2017 (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‐17. Raw materials.‐‐How have R‐32 raw material prices changed since January 1, 2017?
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for R‐32.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 39
IV‐18. Interchangeability.‐‐Is R‐32 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
United States
China
China
Other countries
For any country‐pair producing R‐32 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 ‐ R‐32 (Preliminary)
Page 40
IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between R‐32 produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
China
Other countries
United States
China
For any country‐pair for which factors other than price always or
frequently are a significant factor in your firm’s sales of R‐32, identify
the country‐pair and report the advantages or disadvantages imparted
by such factors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 41
IV‐20. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for R‐32 since January 1, 2017. Indicate the share of the quantity of your firm’s total
shipments of R‐32 that each of these customers accounted for in 2019.
Customer’s name
Contact person
Email
Telephone
City
State
Share of
2019
sales (%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 42
IV‐21. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2017: To avoid losing sales to competitors selling R‐32
from China, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2017: Did your firm lose sales of R‐32 to imports of this
product from China?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: DIFLU)
IV‐22. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Preliminary)
Page 43
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
http://wwwadmin.usitc.gov/investigations/701731/2020/difluoromethane_r_32_china/
preliminary.htm_0.
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: DIFLU
• 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 (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
File Type | application/pdf |
File Title | Microsoft Word - US producers questionnaire--R-32(P) |
Author | ahdia.bavari |
File Modified | 2020-01-24 |
File Created | 2020-01-24 |