Form 20-1-4185 U.S. producers' questionnaire

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

US producers--Corrosion inhibitors (P)

Corrosion inhibitors from China (Inv. nos. 701-TA-638 and 731-TA-1473) Prelim

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 20-1-4185; Expiration Date: : 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
CORROSION INHIBITORS FROM CHINA
This questionnaire must be received by the Commission by February 19, 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 and countervailing duty investigations concerning corrosion inhibitors from China (Inv.
Nos. 701-TA-638 and 731-TA-1473 (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 corrosion inhibitors (as defined on next page) at any time since January 1, 2017?

(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: CORR)
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

Signature

Title of Authorized Official

Phone

Date

Email address

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background. --This proceeding was instituted in response to petitions filed on February 5, 2020, by
Wincom Incorporated, Blue Ash, Ohio. Countervailing and/or antidumping duties may be assessed on
the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce
(“Commerce”) makes an affirmative determination of subsidization and/or dumping. Questionnaires
and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2020/corrosion_inhibitors_china/preliminary.htm.
Corrosion inhibitors covered by these investigations is tolyltriazole (“TTA”) and benzotriazole (“BTA”).
This includes tolyltriazole and benzotriazole of all grades and forms, including their sodium salt forms.
Tolyltriazole is technically known as Tolyltriazole IUPAC 4,5 methyl benzotriazole. It can also be
identified as methyl benzotriazole, tolutriazole, TTA, and TTZ.
Benzotriazole is technically known as IUPAC 1,2,3-Benzotriazole. It can also be identified as 1,2,3Benzotriazole, 1,2-Aminozophenylene, 1H-Benzotriazole, and BTA.
All forms of tolyltriazole and benzotriazole, including but not limited to flakes, granules, pellets, prills,
needles, powder, or liquids, are included within the scope of these petitions.
The scope includes tolyltriazole/sodium tolyltriazole and benzotriazole/sodium benzotriazole that are
combined or mixed with other products. For such combined products, only the tolyltriazole/sodium
tolyltriazole and benzotriazole/sodium benzotriazole component is covered by the scope of these
investigations. Tolyltriazole and sodium tolyltriazole that have been combined with other products is
included within the scope, regardless of whether the combining occurs in third countries.
Tolyltriazole, sodium tolyltriazole, benzotriazole and sodium benzotriazole that is otherwise subject to
these investigations is not excluded when commingled with tolyltriazole, sodium tolyltriazole,
benzotriazole, or sodium benzotriazole from sources not subject to these investigations. Only the
subject merchandise component of such commingled products is covered by the scope of these
investigations.
Tolyltriazole has the Chemical Abstracts Service (“CAS”) registry number 299385-43-1. Tolyltriazole is
classified under Harmonized Tariff Schedule of the United States (“HTSUS”) 2933.99.82.20.
Sodium Tolyltriazole has the CAS registry number 64665-57-2 and is classified under HTSUS subheading
2933.99.82.90.
Benzotriazole has the CAS registry number #95-14-7 and is classified under HTSUS 2933.99.82.10.
Sodium Benzotriazole has the CAS registry number 15217-42-2. Sodium Benzotriazole is classified under
HTSUS 2933.99.82.90.
Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs
purposes, the written description of the scope of these investigations is dispositive.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 3

Corrosion inhibitors are currently imported under statistical reporting numbers 2933.99.8210 of the
Harmonized Tariff Schedule of the United States (HTSUS). They may also be imported under HTSUS
statistical reporting numbers 2933.99.8220 and 2933.99.8290. In their solid form, tolyltriazole and
benzotriazole are imported under HTS numbers 2933.99.8210 and 2933.99.8220, respectively. The
liquid forms of tolyltriazole and benzotriazole are imported under the “other” HTS category, i.e. HTS
2933.99.8290. 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.
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.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (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 macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
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

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (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 corrosion inhibitors,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

I-2b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-2c.

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).
Law firm:
Lead attorney(s):

I-3.

Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No

I-4.

Yes

Petition support.--Does your firm support or oppose the petition?
Country
China (AD)
China (CVD)

Support

Oppose

Take no position

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
I-5.

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

Firm name

I-6.

Page 6

Yes--List the following information, relating to the ultimate parent/owner.

Country

Extent of
ownership
(percent)

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
I-7.

Page 7

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 8

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [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 or processing of corrosion inhibitors since January 1, 2017.
(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)

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-3a.

Page 9

Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce corrosion inhibitors, 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 pounds, dry weight)
Calendar years
Item

Overall production capacity

2017

Production of:
Corrosion inhibitors 2
Other products

2018

2019

Total production using same machinery or
workers
1

Data reported for capacity (first line) should be greater than data reported for total production (last
line).
2
Data entered for production of corrosion inhibitors will populate here once reported in question II-7
and II-9.
3
Please identify these products:
.
II-3b.

Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week

Weeks per year

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Page 10

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-4.

Product shifting.—
(a)

Is your firm able to switch production (capacity) between corrosion inhibitors and other
products using the same equipment and/or labor?

(b)

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-5.

Page 11

Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of corrosion inhibitors?
“Toll agreement”--Agreement between two firms whereby the first firm (“TOLLEE”) furnishes
the raw materials and the second firm (“TOLLER”) 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- For all such agreements entered into by your firm, please indicate whether your firm
was the Toller (the producer of corrosion inhibitors) or tollee (the firm that furnished
the
inputs to the Toller).
Our firm
Toller

Other firm(s)
Please name the tollee(s):

Special instruction
Provide data on your firm's toll
production and shipments in
question II-7
1
Tollee
Please name the toller(s):
Provide data on shipments into
the market of merchandise that
was toll produced in question II-8
1
Please describe the toll arrangement(s) and identify the raw material input that your firm
provided the toller(s):

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-6.

Page 12

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce corrosion inhibitors in and/or admit
corrosion inhibitors 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.

(b)

Yes

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

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import corrosion inhibitors into a foreign trade zone (FTZ) for use in distribution of
corrosion inhibitors and/or the production of downstream articles?
No

Yes

If yes--Identify the firms and the FTZs.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-7.

Page 13

Production, shipment, and inventory data.-- PRODUCER/TOLLER.--Report your firm’s
production capacity, production, shipments, and inventories related to the production of
corrosion inhibitors in its U.S. establishment(s) during the specified periods, whether your firm
produced corrosion inhibitors for its own account or toll produced corrosion inhibitors for
another firm. Do not report data in this grid if your firm is the tollee for corrosion inhibitors
produced by a toll producer.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“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.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-7a.

Page 14

Production, shipment, and inventory data.—PRODUCER/TOLLER
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item

2017

2018

2019

Average production capacity1 (quantity)
(A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Tolled merchandise returned to
tollee:
Quantity (J)
Value3 (K)

Export shipments:4
Quantity (L)
Value (M)
End-of-period inventories (quantity) (N)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Value of tolled merchandise returned to tollee should reflect the toll conversion fee received for production of
subject merchandise.
4
Identify your firm’s principal export markets:
.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-7a.

Page 15

Production, shipment, and inventory data.—PRODUCER/TOLLER

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line N) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, J, and L). 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

2018

B + C – D – F – H – J – L -N = should
equal zero ("0") or provide an
explanation.1

2019

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

II-7b.

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.

PRODUCER/TOLLER
Quantity (in pounds, dry weight)
Calendar years
Item

2017

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (O)
To end users (P)
To processers (R)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines O, P, and R) 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
O + P + R – D - F- H - J = zero ("0"), if
not revise.

2017

2018
0

2019
0

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-7c.

Page 16

Employment data.--Report your firm’s employment-related data related to the production of
corrosion inhibitors 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.

PRODUCER/TOLLER
Calendar years
Item
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs( dollars)
Explanation of trends:

2017

2018

2019

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-8.

Page 17

Conversion operations.-- Since January 1, 2017, has your firm further processed or refined or
purified corrosion inhibitors or converted solid corrosion inhibitors into liquid corrosion
inhibitors?

Yes

If yes--Please describe the nature and extent of the following items in
relation to your firm’s refining/purifying/conversion operations in the
United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type, and
source of parts
Costs and activities

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-9a.

Page 18

Production, shipment, and inventory data.--PROCESSOR/TOLLEE — Report your firm’s capacity,
production, shipments, and inventories related to the processing of corrosion inhibitors,
whether toll-produced by another firm or purchased from another firm, in its U.S.
establishment(s) during the specified periods. Do not report data in this grid if your firm
produces the corrosion inhibitor chemicals.

PROCESSOR/TOLLEE
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item

2017

2018

2019

Beginning-of-period inventories (quantity) (S)
Processing of corrosion inhibitors. -Domestic toll produced (quantity) (T)
Purchased domestic (quantity) (U)
Purchased subject imports (quantity) (V)
Purchased nonsubject imports (quantity) (W)
Total production (quantity) (X)

U.S. shipments:
Commercial shipments:
Quantity (Y)
Value (Z)
Internal consumption:
Quantity (AA)
Value1 (AB)
Transfers to related firms:
Quantity (AC)
Value1 (AD)
Export shipments:2
Quantity (AE)
Value (AF)
End-of-period inventories (quantity) (AG)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-9a.

Page 19

Production, shipment, and inventory data.--PROCESSOR/TOLLEE —

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line AG) should be equal to the beginning-of-period inventories (i.e., line
S), plus production (i.e., lines T, U, V, and W), less total shipments (i.e., lines Y, AA, AC, and AE). 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
S + T + U + V + W – Y – AA – AC – AE – AG =
should equal zero ("0") or provide an
explanation.1
1

2017

2018

2019

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

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II-9b.

Page 20

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.

PROCESSOR/TOLLEE
Quantity (in pounds, dry weight)
Calendar years
Item

2017

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (AH)
To end users (AI)
To processers (AJ)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines AH, AI, and AJ) in each time period equal the quantity reported for U.S. shipments (i.e., line Y, AA, AC) 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
AH + AI + AJ - Y- AA -AC = zero ("0"), if
not revise.

2017

2018
0

2019
0

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II-9c.

Page 21

U.S. shipments by type.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by product type.

PROCESSOR/TOLLEE
Quantity (in pounds, dry weight); value (in dollars)
Calendar years
Item

2017

2018

2019

U.S. shipments:
Tolyltriazole / sodium
tolytriazole:
Quantity (AK)
Value (AL)
Benzotriazole / sodium
benzotriazole:
Quantity (AM)
Value (AN)
RECONCILIATION OF US SHIPMENTS BY TYPE--Please ensure that the quantities and value reported for U.S.
shipments by type (i.e., lines AK through AN) in each time period equal the quantities and values reported for
U.S. shipments (i.e., lines Y through AD) 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

2017

2018

2019

Quantity: AK + AM - Y- AA - AC =
zero ("0"), if not revise.

Value: AL + AN - Z- AB - AD = zero
("0"), if not revise.

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II-9d.

Page 22

PROCESSOR/TOLLEE
Calendar years
Item

2017

2018

2019

Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
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.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-11.

Page 23

Purchases.--Has your firm purchased corrosion inhibitors 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.

If yes--Report such purchases in the table below and explain the reasons
for your firms' purchases.

Yes

Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in pounds, dry weight and Value in dollars)
Calendar years
Item

2017

2018

2019

Purchases from U.S. importers1 of corrosion
inhibitors from—
China.—
Quantity
Value
All other sources.—
Quantity
Value
Purchases from domestic producers2 .—
Quantity
Value
Purchases from other sources3
Quantity
Value
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 corrosion inhibitors?
No

Yes
If yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
II-13.

Page 24

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.

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Page 25

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Samuel Varela-Molina (202-205-3429,
[email protected]).
III-1.

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 corrosion inhibitors:

Does your firm prepare profit/loss statements for corrosion inhibitors:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

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 corrosion inhibitors, as
well as specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

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Page 26

III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced corrosion inhibitors and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products
corrosion inhibitors

Share of sales
%
%
%
%
%

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of corrosion inhibitors from any related suppliers (e.g.,
inclusive of transactions between related firms, divisions and/or other components within the
same company)?
Yes--Continue to question III-7

III-7.

Page 27

No—Skip to question III-9a(i).

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
corrosion inhibitors that your firm purchases from related suppliers and that are reflected in
question III-9a(i). For “Share of total COGS” please report this information by relevant input on
the basis of your most recently completed fiscal year. For “Input valuation” please describe the
basis, as recorded in your company’s own accounting system, of the purchase cost from the
related supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input

Related supplier

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records

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(i) (financial results on corrosion
inhibitors) in a manner consistent with your firm’s accounting books and records.

Yes

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

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Page 28

III-9a(i). Operations on corrosion inhibitors: Producers/tollers.--Report the revenue and related cost
information requested below on the corrosion inhibitors operations of your firm’s U.S.
establishment(s) if your firm produces the corrosion inhibitors, either for your own account or
for the account of a tollee.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.
Quantity (in pounds, dry weight) and value (in dollars)
Fiscal years ended-Item

2017

2018

2019

Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Shipments to Tollees
Total net sales quantities

Net sales values:2
Commercial sales
Internal consumption
Transfers to related firms
Shipments to Tollees (tolling fee
received)
Total net sales values
Cost of goods sold (COGS):
Raw materials

Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
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.
1

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

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Page 29

III-9a(ii). Operations on corrosion inhibitors: Processors/tollees.--Report the revenue and related cost
information requested below on the corrosion inhibitors operations of your firm’s U.S.
establishment(s) if your firm processes the corrosion inhibitors (e.g., refining, purifying, or
liquifying). Do not report resales of products. Provide data for your firm’s three most recently
completed fiscal years.
Quantity (in pounds, dry weight) and value (in dollars)
Fiscal years ended-Item

2017

2018

2019

Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials

Direct labor
Other factory costs
Tolling fees paid
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
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.
1

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

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Page 30

III-9b. Financial data reconciliation.--The calculable line items from question III-9a(i) or III-9a(ii) (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 nonmaterial differences that may arise due to rounding?

Yes

III-9c.

If no--If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative--instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.

Raw materials.--Please report the share of total raw material costs in 2019 (reported in III-9a(i)
or III-9a(ii)) for the following raw material inputs:
Procurement method

Input

Share of total raw
material costs
(percent)

Primarily
produced by
your firm

Primarily
purchased by
your firm

Orthotoluene diamine
Sodium nitrite
Other material inputs1
Total (should sum to 100 percent)
1

0.0

Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that they account for:
.

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Page 31

III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual period for which financial results are reported in question III-9a(i) or III-9a(ii), please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a(i) or III-9a(ii) line item where the nonrecurring items are included, a
brief description of the relevant nonrecurring items, and the associated values (in dollars), as
reflected in question III-9a(i) or III-9a(ii); i.e., if an aggregate nonrecurring item has been
allocated to question III-9a(i) or III-9a(ii), 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(i) or III-9a(ii).
Fiscal years ended-Item

2017

2018

2019

Value (dollars)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III-9a(i) or III-9a(ii) where the nonrecurring item is
classified.
Description of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Income statement classification of the
nonrecurring item

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Page 32

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(i) or III-9a(ii).

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of corrosion inhibitors. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for corrosion
inhibitors 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(i) or III-9a(ii). Provide data as of the end of your firm’s three most recently
completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in dollars)
Fiscal years ended-Item
Total assets (net)
1

III-13.

Describe

2017

2018

2019

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for corrosion inhibitors. Provide data for
your firm’s three most recently completed fiscal years.
Value (in dollars)
Fiscal years ended-Item
Capital expenditures

2017

2018

2019

Research and development
expenses2
1

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.
.

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Page 33

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a(i) or III-9a(ii), 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a(i) should reconcile with the
data reported in question II-7a (including export shipments), and tolling quantities and values
reported in question III-9a(ii) should reconcile with the data reported in question II-9a and 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. 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-7a (lines D, F, H, and J) less
financial total net sales quantity data
from question III-9a(i), = zero ("0").

Value: Trade data from question II7a (lines E, G, I, and K) less financial
total net sales value data from
question III-9a(i), = zero ("0").

Do these data in question III-9a(i) reconcile with data in question II-7a?
Yes

If no, please explain.

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Page 34

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 tolling fees in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis. 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-9a (lines D, F, H, and J) less
financial total net sales quantity data
from question III-9a(ii), = zero ("0").

Value: Trade data from question II9a (lines E, G, I, and K) less financial
total net sales value data from
question III-9a(ii), = zero ("0").

Do these data in question III-9a(ii) reconcile with data in question II-9a?
Yes

If no, please explain.

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Page 35

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 corrosion inhibitors from China?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

(please describe)

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Page 36

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 corrosion inhibitors from China?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the
issue of stocks or bonds
Ability to service debt

Other

(please describe)

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Page 37

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
corrosion inhibitors 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.

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Page 38

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, [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.—Sodium Tolyltriazole in totes of 2,400 to 2,600 pounds net weight
Product 2.-- Sodium Tolyltriazole in drums of 450 to 550 pounds net weight
Product 3.—Tolyltriazole in supersacks 1,000 to 1,200 pounds net weight

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.

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Page 39

IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds contained weight and actual dollars (not 1,000s).

Period of shipment
2017:
January-March
April-June
July-September
OctoberDecember
2018:
January-March
April-June
July-September
OctoberDecember
2019:
January-March
April-June
July-September
OctoberDecember

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

Product 3
Quantity
Value

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.
1

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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IV-2c.

Page 40

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)?
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.

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
IV-3.

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

IV-4.

Contracts

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of domestic corrosion inhibitors usually
quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 41

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
corrosion inhibitors 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

Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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IV-7.

Page 42

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced corrosion inhibitors (or check “not applicable” if your firm does not sell on a
short-term, annual and/or long-term 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

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

IV-8.

Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced corrosion inhibitors?

Source

Lead time (Average
Share of 2019 sales number of days)

From inventory

Produced to order

Total (should sum to 100.0%)

0.0

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
IV-9.

Page 43

Shipping information.-(a)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(b)

Indicate the approximate percentage of your firm’s sales of corrosion inhibitors that are
delivered the following distances from its production facility.
Distance from production facility

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 corrosion inhibitors 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.
IV-11. Inland transportation costs.—What is the approximate percentage of the cost of U.S.-produced
corrosion inhibitors that is accounted for by U.S. inland transportation costs?
percent

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IV-12. End uses.--List the end uses of the corrosion inhibitors that your firm manufactures. For each
end-use product, what percentage of the total cost is accounted for by corrosion inhibitors and
other inputs?
Share of total cost of end use product
accounted for by
End-use product

corrosion inhibitors

Total
(should sum to
100.0% across)

Other inputs

0.0 %

IV-13. Substitutes.--Can other products be substituted for corrosion inhibitors?
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 corrosion inhibitors?
No Yes

Explanation

1.
2.
3.

IV-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for corrosion inhibitors has changed since January 1, 2017. Explain any trends
and describe the principal factors that have affected these changes in demand.

Overall
increase

Market

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within the United States
Outside the United States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of corrosion inhibitors since January 1, 2017?
No

Yes

If yes, please describe and quantify if possible.

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IV-16. Conditions of competition.-(a) Is the corrosion inhibitors market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to corrosion
inhibitors? If yes, describe.
Check all that apply.

Please describe.

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
corrosion inhibitors since January 1, 2017?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply corrosion
inhibitors 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-18. Raw materials.--How have corrosion inhibitors raw material prices changed since January 1,
2017?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

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

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Page 46

IV-19. Interchangeability.--Is corrosion inhibitors produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair

Country-pair

China

Other countries

United States
China
For any country-pair producing corrosion inhibitors that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

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Page 47

IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between corrosion inhibitors
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 corrosion inhibitors, identify the country-pair and report the
advantages or disadvantages imparted by such factors:

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)

Page 48

IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for corrosion inhibitors since January 1, 2017. Indicate the share of the quantity of
your firm’s total shipments of corrosion inhibitors that each of these customers accounted for in
2019.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Telephone

City

State

Share
of
2019
sales
(%)

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Page 49

IV-22. Competition from imports.-(a)

Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling
corrosion inhibitors from China, did your firm:
Item

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2017: Did your firm lose sales of corrosion inhibitors to
imports of this product from China?
No

(c)

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
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: CORR)

IV-23. 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.

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Page 50

PART V.--ALTERNATIVE PRODUCT INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [email protected]).
V-1.

Comparability of types of corrosion inhibitors.--For each of the following indicate whether
listed products are: fully comparable or the same, i.e., have no differentiation between them;
mostly comparable or similar; somewhat comparable or similar; never or not-at-all comparable
or similar; or no familiarity with products.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and End Uses.--The differences and similarities in the physical
characteristics and end uses.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:

In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole
(b) Interchangeability.--The ability to substitute the products in the same application.

Product-pair
In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:

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U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
V-1.

Page 51

Comparability of types of Corrosion inhibitors.--Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(c) Manufacturing facilities, production processes, and production employees.--Whether
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:

In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

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

Product-pair
In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:

Contains Business Proprietary Information
U.S. Producers’ Questionnaire – Corrosion Inhibitors (Preliminary)
V-1.

Page 52

Comparability of types of Corrosion inhibitors.--Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(e) Customer and producer perceptions.--Perceptions as to the differences and/or
similarities in the market (e.g., sales/marketing practices).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:

In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole
(f) Price.--Whether prices are comparable or differ between the products.

Product-pair
In-scope tolyltriazole/sodium
tolytriazole vs. in-scope
benzotriazole/sodium
benzotriazole

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:

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Page 53

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/701731/2020/corrosion_inhibitors_china/prelimi
nary.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: CORR

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	Microsoft Word - US producers--Corrosion inhibitors (P)
Author	lawrence.jones
File Modified	2020-02-07
File Created	2020-02-07