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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4197; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
CARBON AND CERTAIN ALLOY STEEL WIRE ROD (“WIRE ROD”) FROM BRAZIL,
INDONESIA, MEXICO, MOLDOVA, AND TRINIDAD AND TOBAGO
This questionnaire must be received by the Commission by April 10, 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 review of the antidumping and countervailing duty orders concerning carbon and certain alloy steel
wire rod (“wire rod”) from Brazil, Indonesia, Mexico, Moldova, and Trinidad and Tobago (Inv. Nos. 701‐TA‐417 and 731‐
TA‐953, 957‐959 and 961 (Third Review)). The information requested in the questionnaire is requested under the
authority of the Tariff Act of 1930, title VII.
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced wire rod (as defined on the next page) or 1080 tire cord/bead (as defined on the next
page) at any time since January 1, 2014?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: WROD)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐ On October 22, 2002, the Department of Commerce (“Commerce”) issued a
countervailing duty order on imports of wire rod from Brazil. On October 29, 2002, Commerce issued
antidumping duty orders on imports of wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad
and Tobago. On June 3, 2019, the Commission instituted reviews pursuant to section 751(c) of the Tariff
Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine whether revocation of the orders would be likely
to lead to continuation or recurrence of material injury to the domestic industry within a reasonably
foreseeable time. If both the Commission and Commerce make affirmative determinations, the orders
will remain in place. If either the Commission or Commerce makes negative determinations, Commerce
will revoke the orders. Questionnaires and other information pertinent to this proceeding are available
at
https://www.usitc.gov/investigations/701731/2019/carbon_steel_wire_rod_brazil_indonesia_mexico/t
hird_review_full.htm.
Wire rod covered by these reviews is certain hot‐rolled products of carbon steel and alloy steel, in coils,
of approximately round cross section, 5.00 mm or more, but less than 19.00 mm, in solid cross‐sectional
diameter.
Specifically excluded are steel products possessing the above‐noted physical characteristics and meeting
the Harmonized Tariff Schedule of the United States (HTSUS) definitions for (a) stainless steel; (b) tool
steel; (c) high nickel steel; (d) ball bearing steel; and (e) concrete reinforcing bars and rods. Also
excluded are (f) free machining steel products (i.e., products that contain by weight one or more of the
following elements: 0.03 percent or more of lead, 0.05 percent or more of bismuth, 0.08 percent or
more of sulfur, more than 0.04 percent of phosphorus, more than 0.05 percent of selenium, or more
than 0.01 percent of tellurium).
Also excluded from the scope are 1080 grade tire cord quality wire rod and 1080 grade tire bead quality
wire rod. Grade 1080 tire cord quality rod is defined as: (i) grade 1080 tire cord quality wire rod
measuring 5.0 mm or more but not more than 6.0 mm in cross‐sectional diameter; (ii) with an average
partial decarburization of no more than 70 microns in depth (maximum individual 200 microns); (iii)
having no non‐deformable inclusions greater than 20 microns and no deformable inclusions greater than
35 microns; (iv) having a carbon segregation per heat average of 3.0 or better using European Method
NFA 04‐114; (v) having a surface quality with no surface defects of a length greater than 0.15 mm; (vi)
capable of being drawn to a diameter of 0.30 mm or less with 3 or fewer breaks per ton, and (vii)
containing by weight the following elements in the proportions shown: (1) 0.78 percent or more of
carbon, (2) less than 0.01 percent of aluminum, (3) 0.040 percent or less, in the aggregate, of
phosphorus and sulfur, (4) 0.006 percent or less of nitrogen, and (5) not more than 0.15 percent, in the
aggregate, of copper, nickel and chromium.
Grade 1080 tire bead quality rod is defined as: (i) grade 1080 tire bead quality wire rod measuring 5.5
mm or more but not more than 7.0 mm in cross‐sectional diameter; (ii) with an average partial
decarburization of no more than 70 microns in depth (maximum individual 200 microns); (iii) having no
non‐deformable inclusions greater than 20 microns and no deformable inclusions greater than 35
microns; (iv) having a carbon segregation per heat average of 3.0 or better using European Method NFA
04‐114; (v) having a surface quality with no surface defects of a length greater than 0.2 mm; (vi) capable
of being drawn to a diameter of 0.78 mm or larger with 0.5 or fewer breaks per ton; and (vii) containing
by weight the following elements in the proportions shown: (1) 0.78 percent or more of carbon, (2) less
than 0.01 percent of soluble aluminum, (3) 0.040 percent or less, in the aggregate, of phosphorus and
sulfur, (4) 0.008 percent or less of nitrogen, and (5) either not more than 0.15 percent, in the aggregate,
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
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of copper, nickel and chromium (if chromium is not specified), or not more than 0.10 percent in the
aggregate of copper and nickel and a chromium content of 0.24 to 0.30 percent (if chromium is
specified).
For purposes of grade 1080 tire cord quality wire rod and grade 1080 tire bead quality wire rod, an
inclusion will be considered to be deformable if its ratio of length (measured along the axis ‐ that is, the
direction of rolling ‐ of the rod) over thickness (measured on the same inclusion in a direction
perpendicular to the axis of the rod) is equal to or greater than three. The size of an inclusion for
purposes of the 20 microns and 35 microns limitations is the measurement of the largest dimension
observed on a longitudinal section measured in a direction perpendicular to the axis of the rod. This
measurement methodology applies only to inclusions on certain grade 1080 tire cord quality wire rod
and certain grade 1080 tire bead quality wire rod that are entered, or withdrawn from warehouse, for
consumption on or after July 24, 2003.
The designation of the products as “tire cord quality” or “tire bead quality” indicates the acceptability of
the product for use in the production of tire cord, tire bead, or wire for use in other rubber
reinforcement applications such as hose wire. These quality designations are presumed to indicate that
these products are being used in tire cord, tire bead, and other rubber reinforcement applications, and
such merchandise intended for the tire cord, tire bead, or other rubber reinforcement applications is not
included in the scope. However, should petitioners or other interested parties provide a reasonable
basis to believe or suspect that there exists a pattern of importation of such products for other than
those applications, end‐use certification for the importation of such products may be required. Under
such circumstances, only the importers of record would normally be required to certify the end use of
the imported merchandise.
In its original determinations, the Commission found grade 1080 tire cord and tire bead wire rod to be
In its original determinations, the Commission found grade 1080 tire cord and tire bead wire rod to be
included in the same domestic like product definition as Commerce’s scope (which excluded grade 1080
included in the same domestic like product definition as Commerce’s scope (which excluded grade
tire cord and tire bead wire rod). Unless otherwise indicated, for purposes of reporting data in this U.S.
1080 tire cord and tire bead wire rod). Unless otherwise indicated, for purposes of reporting data in
Producers’ Questionnaire, please provide data for all wire rod, including grade 1080 tire cord and tire
this U.S. Producers’ Questionnaire, please provide data for all wire rod, including grade 1080 tire cord
bead wire rod.
and tire bead wire rod.
On October 1, 2012, the U.S. Department of Commerce published its final determination of
circumvention, finding that shipments of wire rod with an actual diameter of 4.75 mm to 5.00 mm
produced in Mexico and exported to the United States by Deacero S.A. de C.V. constitute merchandise
altered in form or appearance in such minor respects that it should be included within the scope of the
order on wire rod from Mexico (77 FR 59892). Deacero appealed the Department's final
determination, which was upheld on appeal by the U.S. Court of Appeals for the Federal Circuit.
Deacero S.A. de C. V. v. United States, 817 F.3d 1332, 1339 (Fed. Cir. 2016). On March 13, 2019, the
Department published its final determination of circumvention, finding that shipments of wire rod with
an actual diameter below 4.75 mm produced in Mexico and exported to the United States by Deacero
S.A. de C. V. constitute merchandise altered in form or appearance in such minor respects that it
should be included within the scope of the order on wire rod from Mexico (84 FR 9089).
All products meeting the physical description of subject merchandise that are not specifically excluded
are included in this scope.
Wire rod is currently imported under statistical reporting numbers 7213.91.3000, 7213.91.3010,
7213.91.3011, 7213.91.3015, 7213.91.3020, 7213.91.3090, 7213.91.3091, 7213.91.3092, 7213.91.3093,
7213.91.4500, 7213.91.4510, 7213.91.4590, 7213.91.6000, 7213.91.6010, 7213.91.6090, 7213.99.0030,
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7213.99.0031, 7213.99.0038, 7213.99.0090, 7227.20.0000, 7227.20.0010, 7227.20.0020, 7227.20.0030,
7227.20.0080, 7227.20.0090, 7227.20.0095, 7227.90.6010, 7227.90.6020, 7227.90.6030, 7227.90.6035,
7227.90.6050, 7227.90.6051, 7227.90.6053, 7227.90.6058, 7227.90.6059, 7227.90.6080, and
7227.90.6085 of the Harmonized Tariff Schedule of the United States (HTSUS). Although the HTSUS
subheadings are provided for convenience and customs purposes, the written description of the scope
of this order is dispositive.
Reporting of information.‐‐If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all of your files, worksheets, and
supporting documents used in the preparation of the questionnaire response. Please also retain a copy
of the final document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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.
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 5
I‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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.
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I‐2a. 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 wire rod, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
City, State
Zip (5 digit)
Description
Covered1
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I‐2b.
I‐2c.
I‐3.
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).
Law firm:
Lead attorney(s):
Position regarding continuation of orders.‐‐Does your firm support or oppose continuation of
the following antidumping and countervailing duty orders currently in place for wire rod?
Country
Support
Oppose
Take no position
Brazil (CVD)
Brazil (AD)
Indonesia (AD)
Mexico (AD)
Moldova (AD)
Trinidad and Tobago (AD)
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I‐4.
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.
Extent of
ownership
(percent)
Firm name
Country
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing wire rod into the United States or that are engaged in
exporting wire rod to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
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I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wire rod?
No
Yes‐‐List the following information.
I‐7.
Firm name
Country
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for wire rod?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
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PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [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‐2a. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of wire rod since January 1, 2014.
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)
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II‐2b. Anticipated changes in operations.—Does your firm anticipate any changes in in the character
of its operations or organization relating to the production of wire rod in the future?
No
Yes
If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions, along with relevant
portions of business plans or other supporting documentations that
address this issue.
II‐3a. Production using same machinery.‐‐ Please report your firm’s production of products made
using the same equipment, machinery, or employees as used to produce wire rod, 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.
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II‐3a. Production using same machinery.—Continued
“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 year
Item
2017
1
Overall production capacity
2018
2019
0
0
0
Other bar/rod products
Subtotal, out‐of‐scope
production
0
0
0
0
0
0
Production of:
Wire rod 2
Out‐of‐scope production.‐‐
Rebar
3
Total production using same
machinery or workers
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of wire rod will populate here once reported in question II‐4a.
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
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.
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II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between wire rod 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:
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
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II‐4. Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of wire rod (including grade 1080 tire cord and
tire bead wire rod) in its U.S. establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related 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 – WIRE ROD (Third Review)
II‐4a. Production, shipment, and inventory data. ‐‐Continued
Quantity (in short tons) and value (in $1,000)
Page 14
Calendar year
Item
2017
1
2018
2019
Average production capacity (quantity) (A)
Beginning‐of‐period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
2
Internal consumption:
quantity (F)
value (G)
2
Transfers to related firms:
quantity (H)
value (I)
3
Export shipments:
quantity (J)
value (K)
End‐of‐period inventories (quantity) (L)
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 (use
additional pages as necessary). .
2 Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.): (however, provide
the data above at fair market value).
3 Identify your firm’s principal export markets: .
1
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II‐4a. Production, shipment, and inventory data.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
2017
B + C – D – F – H – J – L = should equal zero
("0") or provide an explanation.1
2018
0
2019
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐4b. Historical U.S. shipment data. ‐‐Report the quantity and value of your firm’s U.S. shipments
(including commercial U.S. shipments, internal consumption, and transfers, but not including
exports) of wire rod produced in your U.S. establishment(s) during the specified periods.
Quantity (in short tons)
Item
Historical U.S. shipments
Quantity
Value
2014
2015
2016
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II‐4c. Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in short tons)
Calendar year
Item
2017
Channels of distribution:
U.S. shipments—
to distributors (M)
to end users (N)
2018
2019
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. commercial shipments (i.e.,
lines D, F, and H) in each time period. If the calculated fields below return values other than zero (i.e.,
“0”), the data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation item
M + N – D – F – H = zero ("0"), if not
revise.
2017
2018
0
2019
0
0
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
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II‐5. U.S. shipments by product type.—Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of wire rod by
product type.
Quantity (in short tons) and value (in $1,000 dollars)
Calendar year
Item
2017
U.S. shipments. Wire rod‐‐
Low/medium‐low carbon
industrial/standard quality wire rod
Quantity (O)
Value (P)
High/medium‐high carbon
industrial/standard quality wire rod
Quantity (Q)
Value (R)
Tire cord quality wire rod and tire bead
quality wire rod (other than grade 1080)
Quantity (S)
Value (T)
1080 Tire cord/bead
Quantity (U)
Value(V)
Welding quality wire rod
Quantity (W)
Value (X)
Cold heading quality (“CHQ”) wire rod
Quantity (Y)
Value (Z)
Other specialty carbon and alloy quality
wire rod
Quantity (AA)
Value (AB)
2018
2019
0
0
0
0
0
0
1
All other wire rod shipments
Quantity (AC)
Value (AD)
U.S. shipments
Quantity
Value
1
Describe these types of wire rod and describe their uses:
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
II‐5. U.S. shipments by product type.‐‐Continued
Page 18
RECONCILIATION OF SHIPMENTS BY PRODUCT TYPE.‐‐Please ensure that the quantities and values
reported for U.S. shipments by product type (i.e., lines O through AD) in each time period equal the
quantity and value reported for U.S. shipments (i.e., lines D through I) in each time period as reported in
part “a” of this question. 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 year
Reconciliation
Quantity: O + Q + S + U + W + Y + AA + AC – D – F
– H = zero ("0"), if not revise
Value: P + R + T + V + X + Z + AB + AD – E – G – I =
zero ("0"), if not revise
2017
2018
2019
0
0
0
0
0
0
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 19
II‐6. Employment data.‐‐Report your firm’s employment‐related data related to the production of
wire rod 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 year
Item
Employment data:
Average number of
PRWs (number) (O)
Hours worked by PRWs
(1,000 hours) (P)
Wages paid to PRWs
($1,000) (Q)
Explanation of trends:
2017
2018
2019
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II‐7. Transfers to related firms.‐‐If your firm reported transfers to related firms in question II‐4,
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.
II‐8.
Purchases.‐‐Has your firm purchased wire rod produced in the United States or in other
countries since January 1, 2014? (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:
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
II‐8. Purchases.‐‐Continued
Page 21
Quantity (in short tons)
Calendar years
Item
2017
Purchases from U.S.
importers1 of wire rod
from—
Brazil
2018
2019
Indonesia
Mexico
Moldova
Trinidad and Tobago
All other sources
Purchases from
domestic producers2
Purchases from other
sources3
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‐9.
Imports.‐‐Since January 1, 2014, has your firm imported wire rod?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes
If yes‐‐ COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
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II‐10. Toll production.‐‐Since January 1, 2014, has your firm been involved in a toll agreement
regarding the production of wire rod?
“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—skip to next question.
Yes—For all such agreements entered into by your firm, please indicate whether your firm
was the toller or tollee.
Our firm
Other firm(s)
Toller
Please name the tollee(s):
Tollee1
Please name the toller(s):
1
Identify the raw material input(s) that your firm provided the toller(s):
Is the percentage of your U.S. production using a toll agreement more than five percent of your
total production in 2019?
No
Yes
If yes‐‐Please estimate the percent of toll agreement as a share of your
2019 production.
percent
II‐11. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce wire rod in and/or admit wire rod 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 firm’s 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 wire rod into a foreign trade zone (FTZ) for use in distribution of wire rod and/or
the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
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For questions II‐12 and II‐13, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II‐12. Effect of order(s).‐‐Describe the significance of the existing antidumping and countervailing duty
orders covering imports of wire rod from Brazil, Indonesia, Mexico, Moldova, and Trinidad and
Tobago in terms of its effect on your firm’s production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, and asset values. You may wish to compare your firm’s
operations before and after the imposition of the order(s).
II‐13. Likely impact of revocation.‐‐Would your firm anticipate any changes in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of wire rod
in the future if the antidumping and countervailing duty orders on wire rod from Brazil,
Indonesia, Mexico, Moldova, and Trinidad and Tobago were to be revoked?
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.
II‐14. Other explanations:‐‐If your firm would like to explain further 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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PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Joanna Lo (202‐205‐1888, [email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part III.
Name
Title
Email
Telephone
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain below:
Note.‐‐Please note that we are requesting that your firm report financial data on a
calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for which
financial statements are prepared that include wire rod:
2.
Does your firm prepare profit/loss statements for wire rod:
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: 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 wire rod, 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.). If your firm uses standard cost, how often does your firm review
variances from standard cost (e.g. monthly, yearly)?
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III‐4. Allocation basis and methodology.‐‐Briefly describe your firm’s allocation basis, if any, for
COGS, SG&A, and interest expense and other income and expenses. Please also describe the
method and types of documents/records used to compile your financial data.
III‐5.
Product listing.‐‐Please list the products your firm produces in the facilities in which it produces
wire rod, and provide the share of net sales accounted for by these products in 2019.
Products
III‐6.
Share of sales in 2019
Wire rod (including grade 1080 tire cord and tire bead wire rod)
%
Rebar (out‐of‐scope)
%
Other products (out‐of‐scope)
%
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of wire rod from any related suppliers (e.g., inclusive of transactions between
related firms, divisions and/or other components within the same company)?
Yes‐‐Continue to question III‐7.
III‐7.
No‐‐Continue to question III‐9a.
Inputs from related suppliers.‐‐Please identify the inputs used in the production of wire rod
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 in 2019. For
“Input valuation” please describe the basis, as recorded in the company’s own accounting
system, of the purchase cost from the related supplier; e.g., the related supplier’s actual cost,
cost plus, negotiated transfer price to approximate fair market value.
Input
Related supplier
Share of total COGS in 2019
Input valuation as recorded in the firm’s accounting books and records:
III‐8.
Inputs from related suppliers at cost.‐‐Please confirm that the inputs purchased from related
suppliers, as identified in III‐7, were reported in III‐9a (financial results on wire rod) in a manner
consistent with the firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a.
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U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
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III‐9a. Operations on wire rod .‐‐Report the revenue and related cost information requested below on
the wire rod operations (including grade 1080 tire cord and tire bead wire rod) of your firm’s
U.S. establishment(s).1 Do not report resales of products. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books and
records. Provide data for 2017, 2018, and 2019. If your firm was involved in tolling operations
(either as the toller or as the tollee) and reported this in question II‐10 above, please contact
Joanna Lo at (202) 205‐1888 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
2017
2018
2019
2
Net sales quantities:
Commercial sales (“CS”) (A)
Internal consumption (“IC”) (B)
Transfers to related firms (“Transfers”) (C)
0
0
0
Internal consumption (F)
Transfers to related firms (G)
Total net sales values (H)
0
0
0
Energy costs (J)
Direct labor (K)
Other factory costs (L)
0
0
0
0
0
0
0
0
0
0
0
0
All other expense items (S)
All other income items (T)
0
0
0
Total net sales quantities (D)
2
Net sales values:
Commercial sales (E)
3
Cost of goods sold (COGS):
Raw materials (I)
Total COGS (M)
Gross profit or (loss)
Selling, general, and administrative (“SG&A”) expenses:
Selling expenses (N)
General and administrative expenses (O)
Total SG&A expenses (P)
Operating income (loss) (Q)
Other expenses and income:
Interest expense (R)
Net income or (loss) (U)
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. Please confirm that the value of net sales (row H) excludes discounts, returns,
allowances, and prepaid freight: Yes No, explain:
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note: The table above contains calculations that will appear when you have entered data in the MS Word form fields.
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III‐9b. Financial data checklist.‐‐Please check that the financial data in question III‐9a have been
correctly reported.
Confirm the following regarding your financial data in question III‐9a:
√ if Yes
In $1,000 dollars (not actual dollars)?
Include only the in‐scope wire rod and grade 1080 tire cord/tire bead wire rod?
Did not include any resales of wire rod?
IC and transfers to related firms reported at fair market value?
Net Sales (CS, IC, and Transfers) exclude discounts, returns, allowances,
prepaid freight, and all freight out to customers?
COGS excludes finished goods freight to customers?
SG&A excludes finished goods freight to customers?
All costs exclude finished goods freight to customers?
If you did not √ Yes in any of the boxes above, go back to V‐9a and revise your responses.
III‐9c. Financial data reconciliation.‐‐ The calculable line items from question III‐9a (i.e., total net sales
quantities (row D) and values (row H), total COGS (row M), gross profit (or loss) (row N), total
SG&A (Q), operating income (or loss) (row R), and net income (or loss) (row V)) 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 immaterial differences that may
arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
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III‐9d. Raw materials.‐‐Please report the share of total raw material costs in 2019 (reported in III‐9a,
row I) for the following raw material inputs:
Note: Costs for energy should be reported in question III‐9a (row J) and not in raw materials.
Procurement method
Input
Share of total raw
material costs in
2019 (percent)
Billets
Pig iron, ferrous scrap, and/or direct
reduced iron (“DRI”)
Alloy agents or other refining materials
1
Other material inputs
Total (should sum to 100 percent)
Primarily
produced by
your firm
Primarily
purchased by
your firm
0.0
1
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:
III‐9e. Raw materials checklist.‐‐Please check that the raw materials information in question III‐9d has
been correctly reported.
Confirm the following regarding your responses in question III‐9d:
√ if Yes
Include only raw materials used for wire rod?
Reflect the raw materials reported in question III‐9a, row I?
Inputs “produced from your firm” are from the facilities listed in question I‐2
and not other legal entities with common ownership or other affiliation?
Inputs from affiliated companies are purchases listed in question III‐7?
“Other” raw materials, if any, are specified and listed in question III‐9d, footnote 1?
Total sums to 100 percent in question III‐9d?
If you did not √ Yes in any of the boxes above, go back to V‐9d and revise your responses.
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III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III‐9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III‐9a; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9a, only the allocated value amount included in question III‐9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III‐9a.
Calendar year
2017
2018
Item
2019
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific row letter in table III‐9a where the nonrecurring item is classified.
Income statement
classification of the
nonrecurring item
(row letter in III‐9a)
Description of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
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.
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III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of wire rod. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for wire rod 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 2017, 2018, and 2019.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Calendar year
Item
2017
1 2
Total assets (net)
2018
2019
1
List the top assets (e.g. accounts receivables, inventories, PP&E, intangibles)
Describe substantial changes in asset values
2
III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for wire rod. Provide data for 2017,
2018, and 2019.
Value (in $1,000)
Calendar year
Item
2017
1
Capital expenditures
2
R&D expenses
2018
2019
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.
III‐14. Assets, capital expenditures, and R&D checklist.‐‐Please check that the assets, capital
expenditures, and R&D information in questions III‐12 and III‐13 are complete.
Confirm the following regarding your responses in questions III‐12 and III‐13:
√ if Yes
Top assets are listed in question III‐12, footnote 1?
Substantial changes in assets are described in question III‐12, footnote 2?
Capital expenses are described in question III‐13, footnote 1, if applicable?
R&D are described in question III‐13, footnote 2, if applicable?
Provided explanations if your firm did not have capital expenditures or R&D?
If you did not √ Yes in any of the boxes above, go back to III‐12 and/or III‐13 and revise your
responses.
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III‐15. Data completeness, consistency, and reconciliation.‐‐For the data provided in “PART II: TRADE
DATA” and “PART III: FINANCIAL DATA”, please check that all responses, if relevant, were
entered and that the data provided are consistent and reconcile. For example, the quantities
and values reported in question III‐9a should reconcile with the data reported in question II‐4
(including export shipments) since both are to be reported on the same calendar year basis.
Confirm the following to ensure that your responses are complete for
PART II and PART III:
√ if Yes
All periods requested have been accounted for (no blank columns or
rows) unless your firm was not a U.S. producer for that period?
All footnotes, if relevant, have been filled out?
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. 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.
Calendar years
Reconciliation
2017
2018
2019
Quantity: Trade data from question II‐4 (rows D, F,
H, and J) less financial total net sales quantity data
from question III‐9a (row D) = zero ("0").
0
0
0
Value: Trade data from question II‐4 (rows E, G, I,
and K) less financial total net sales value data from
question III‐9a (row H) = zero ("0").
0
0
0
Do these data in question III‐9a reconcile with data in question II‐4?
Yes
No
If no, please explain.
III‐16. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
III: Financial Information 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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PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Kyle Westmoreland (202‐
205‐2184, [email protected]).
IV‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part IV.
Name
Title
Email
Telephone
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products produced by your firm.
Product 1.‐‐Industrial quality wire rod, grade C1006, 5.5 mm (7/32 inch) through 12 mm (15/32
inch) in diameter, for hangers, chain link fencing, collated nails and staples, grates,
and other formed products (in green condition, e.g., NOT cleaned, coated, etc.).
Product 2.‐‐Industrial quality wire rod, grade C1008 through C1010, 5.5 mm (7/32 inch) through
12 mm (15/32 inch) in diameter, for hangers, chain link fencing, collated nails and
staples, grates, and other formed products (in green condition, e.g., NOT cleaned,
coated, etc.).
Product 3.‐‐Mesh quality wire rod, grades C1006 through C1015, 5.5 mm (7/32 inch) through 14
mm (9/16 inch) in diameter, for the manufacturing of concrete reinforcement
products such as wire for A‐82 applications (in green condition, e.g., NOT cleaned,
coated, etc.).
Product 4.‐‐Grades C1050 through C1070, 5.5 mm (7/32 inch) through 6.5 mm (1/4 inch) in
diameter, for spring applications excluding valve spring (in green condition, e.g.,
NOT cleaned, coated, etc.).
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 tables as appropriate.
No.‐‐Skip to question IV‐3.
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IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value Quantity
Value
Product 4
Period of shipment
Quantity
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
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IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(a) has been correctly
reported.
Are the price data reported above:
√ if Yes
In dollars (not $1,000) and 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‐4a 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.
IV‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales of wire rod
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 35
IV‐5. Pricing terms.‐‐On what basis are your firm’s prices of domestic wire rod 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 wire
rod in 2019 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐term
contract basis, and (4) spot sales basis?
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)
Share of 2019
sales
IV‐7.
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced wire rod (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)
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
1
Please identify the indexes used:
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
365
%
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 36
IV‐8. Lead times.‐‐What is the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.‐produced wire rod?
Share of 2019 Lead time (average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV‐9.
0.0 %
Shipping information.‐‐
(a)
(b)
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 wire rod that are delivered
the following distances from your firm’s production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced wire rod since January 1, 2014 (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 – WIRE ROD (Third Review)
Page 37
IV‐11. Inland transportation costs.—What is the approximate percentage of the cost of U.S.‐produced
wire rod that is accounted for by U.S. inland transportation costs? percent
IV‐12. End uses.‐‐Have there been any changes in the end uses of wire rod since January 1, 2014? Do
you anticipate any future changes?
Changes in end
uses
No
Yes
Changes since
January 1, 2014
Anticipated
changes
Explain
IV‐13. Substitutes.‐‐Have there been any changes in the number or types of products that can be
substituted for wire rod since January 1, 2014? Do you anticipate any future changes?
Changes in
substitutes
No Yes
Changes since
January 1, 2014
Anticipated
changes
Explain
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 38
IV‐14. Availability of supply.‐‐Has the availability of wire rod in the U.S. market changed since January
1, 2014? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2014:
U.S.‐produced product
Imports from Brazil,
Indonesia, Mexico,
Moldova, and Trinidad
and Tobago
Imports from all other
countries
U.S.‐produced product
Imports from Brazil,
Indonesia, Mexico,
Moldova, and Trinidad
and Tobago
Imports from all other
countries
Anticipated changes:
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 39
IV‐15. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for wire rod has changed since January 1, 2014, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors that have
affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2014
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States
IV‐16. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of wire rod since January 1, 2014? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2014
Anticipated
changes
Explain
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 40
IV‐17. Conditions of competition.‐‐
(a) Is the wire rod market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to wire rod?
Check all that apply.
Please describe.
No
Skip to question IV‐18.
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
wire rod since January 1, 2014?
No
Yes
If yes, describe.
IV‐18. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply wire rod since
January 1, 2014 (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‐19. Raw materials.‐‐ Indicate how wire rod raw material prices have changed since January 1, 2014,
and how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no
clear
Overall
No
Overall
increase change decrease trend
Explain, noting how raw material
price changes have affected your
firm’s selling prices for wire rod.
Changes since
January 1,
2014
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 41
IV‐20. Price comparisons.‐‐Please compare market prices of wire rod in U.S. and non‐U.S. markets, if
known. Provide specific information as to time periods and regions for any price comparisons.
IV‐21. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss wire rod supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including Brazil, Indonesia, Mexico, Moldova,
and Trinidad and Tobago, and (3) the world as a whole. Of particular interest is such data from
2014 to the present and forecasts for the future.
IV‐22. Export constraints.‐‐Describe how easily your firm can shift its sales of wire rod between the
U.S. market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints that would prevent or retard your firm from
shifting wire rod between the U.S. and alternative country markets within a 12‐month period.
IV‐23. Barriers to trade.‐‐Are your firm’s exports of wire rod subject to any tariff or non‐tariff barriers
to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2014, or that are expected to occur in the future.
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 42
IV‐24. Impact of the Section 232 tariffs.—
(a)
Did the imposition of tariffs on imported steel/aluminum products under Section 232
have an impact on the wire rod market in the United States?
Yes— Please indicate the
impact in the table below.
No
Don’t know
Fluctuate Explain, noting how the imposition
with no of tariffs under Section 232 affected
each factor of the wire rod market
clear
Overall
No
Overall
in the United States.
trend
increase change decrease
Factor
Supply of U.S.‐
produced wire rod
Supply of imported
wire rod
Prices for wire rod
Overall U.S. demand
for wire rod
Raw material costs for
wire rod
(b)
Did the subsequent agreement between the United States and Mexico to eliminate all
tariffs imposed under Section 232 on imports of steel products from Mexico have an
impact on imports of wire rod from Mexico?
No
Yes
If yes, please discuss any impacts (e.g. supply, demand, price) on imports of
wire rod from Mexico.
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
IV‐25. Interchangeability.‐‐Is wire rod 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
Page 43
Brazil
Indonesia
Mexico
Moldova
Trinidad
and Tobago
Other
countries
Brazil
Indonesia
Mexico
Moldova
Trinidad and Tobago
For any country‐pair producing wire rod which is sometimes or never interchangeable, please identify the
country‐pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 44
IV‐26. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wire rod 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
United States
Brazil
Indonesia
Mexico
Moldova
Trinidad
and Tobago
Other
countries
Brazil
Indonesia
Mexico
Moldova
Trinidad and Tobago
For any country‐pair for which factors other than price always or frequently are a significant factor in your
firm’s purchases of wire rod, identify the country‐pair and report the advantages or disadvantages
imparted by such factors:
IV‐26. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – WIRE ROD (Third Review)
Page 45
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/701731/2019/carbon_steel_wire_rod_brazil_indo
nesia_mexico/third_review_full.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: WROD
• 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 - Carbon Steel Wire Rod (Rev3)--PRO |
Author | jordan.harriman |
File Modified | 2020-02-28 |
File Created | 2020-02-28 |