Form 20-1-4201 U.S. producers' questionnaire

OMB No. 3117-0016/USITC No. 20-1-4201; Expiration Date: : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
ULTRA-HIGH MOLECULAR WEIGHT POLYETHYLENE FROM KOREA
This questionnaire must be received by the Commission by March 17, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping investigation concerning ultra-high molecular height polyethylene (“UHMWPE”) from
Korea (Inv. No. 731-TA-1474 (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 UHMWPE (as defined on next page) at any time since January 1, 2017?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: POLY)

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 - UHMWPE (Preliminary)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed effective March 4, 2020, by
Celanese Corporation, Irving, Texas. Antidumping duties may be assessed on the subject imports as a
result of this proceeding if the Commission makes an affirmative determination of injury, threat, or
material retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative
determination of dumping. Questionnaires and other information pertinent to this proceeding are
available at:
https://www.usitc.gov/investigations/701731/2020/ultrahigh_molecular_plolyethelene/preliminary.ht
m
Ultra-High Molecular Weight Polyethylene (UHMWPE): The product covered by this investigation is
ultra-high molecular weight polyethylene (UHMWPE). UHMWPE is a linear polyethylene, in granular or
powder form. It is defined by its melt mass-flow rate of <0.1 g/10 min, measured at 190 °C and 21.6 kg
load, based on the methods and calculations set forth in the International Organization for
Standardization (ISO) standards 21304-1 and 21304-2. UHMWPE generally has a Chemical Abstract
Service (“CAS”) registration number of 9002-88-4.
The scope includes all UHMWPE in granular or powder forms meeting the above specifications
regardless of additives introduced in the manufacturing process. UHMWPE blended with other products
is included in the scope of this investigation where UHMWPE is the predominant material within the
blend.
Excluded from the scope of the investigation is medical-grade UHMWPE. Medical-grade
UHMWPE has a minimum viscosity of 2000 ml/g at a concentration of 0.02% at 135°C (275 °F) in
decahydronaphthalene and an elongational stress of 0.2 MPa or greater. Medical-grade UHMWPE is
further defined by its ash and trace element content, which shall not exceed the following maximum
quantities as set forth in ISO 5834-1: ash (125 mg/kg), titanium (40 mg/kg), calcium (5 mg/kg), chlorine
(30 mg/kg), and aluminum (20 mg/kg). ISO 5834-1 further defines medical-grade UHMWPE by its
particulate matter content, which requires that there shall be no more than three particles of
contaminant per 300 ± 20 g tested. Each of the above criteria is calculated based on the standards and
methods used in ISO 5834-1.
UHMWPE is currently imported under statistical reporting numbers 3901.10.10.00 and 3901.20.10.00 of
the Harmonized Tariff Schedule of the United States (HTSUS). 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.

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Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of UHMWPE and your responses to the questions in Part I of
the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for
use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
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.

Business Proprietary
U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
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

I-2a.

Page 4

No

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 UHMWPE, 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):

Business Proprietary
U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
I-3.

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

I-4.

Page 5

Yes

Petition support.--Does your firm support or oppose the petition?
Country

Support

Oppose

Take no position

Korea
I-5.

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

Firm name

I-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 UHMWPE from Korea into the United States or that are
engaged in exporting UHMWPE from Korea to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
I-7.

Page 6

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

Yes--List the following information.
Country

Affiliation

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Andres Andrade (202-2052078, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of UHMWPE 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 - UHMWPE (Preliminary)
II-3a.

Page 8

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

Overall production capacity

2017

2018

2019

1

Production of:
UHMWPE (excluding medical grade)2

0

0

0

0

0

0

0

0

0

Out-of-scope production.-Medical-grade UHMWPE
Other products3
Subtotal, out-of-scope production
Total production using same
machinery or workers

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of UHMWPE will populate here once reported in question II-7.
3
Please identify these products:
.
1
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

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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 UHMWPE and other products
using the same equipment and/or labor?

No

(b)

II-5.

Yes

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

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

Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of UHMWPE?
“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 2
Please name the toller(s):
1
Identify the raw material input(s) that your firm provided the toller(s):
2
Share of net sales accounted for by toll agreement(s) in 2019:
%

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U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
II-6.

Page 10

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

(a)

“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.

No

Yes

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

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

(b)

No

Yes

If yes--Identify the firms and the FTZs.

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U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
II-7.

Page 11

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of UHMWPE 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 - UHMWPE (Preliminary)
II-7.

Page 12

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

2017

2018

2019

Average production capacity (quantity) (A)
1

Beginning-of-period inventories (quantity) (B)
Production (quantity) (C)
U.S. shipments:2
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value3 (G)
Transfers to related firms:2
Quantity (H)
Value3 (I)
Export shipments:4
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
.
2
Indicate the share of your firm U.S. shipments that were sold compounded or blended:
percent.
3
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.
4
Identify your firm’s principal export markets:
.
1

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

2017

2018
0

2019
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1

0

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II-8.

Page 13

Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in pounds)
Calendar years
Item

2017

2018

2019

Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
To blenders/compounders (O)
1

Please identify your firms top blender/compounder customers:

.

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M through O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D - F- H = zero ("0"), if
not revise.

2017

2018
0

2019
0

0

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II-9

Page 14

Shipments by application.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by application for calendar year
2019.
Quantity (in pounds)
Calendar year
Item

2019

U.S. shipments by application:
Membranes (P)
Filtration (Q)
Batteries (R)
Fibers (S)
Additives (T)
Others1 (U)
1

Please identify these products:

.

RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities reported for shipments by application (i.e.,
lines P through U) in calendar year 2019 equal the quantity reported for U.S. shipments (i.e., line D, F, H) in
calendar year 2019. 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
P + Q + R + S + T + U – D – F – H = zero ("0"), if not revise.

2019
0

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U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
II-10.

Page 15

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

2017

2018

2019

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

II-11.

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 - UHMWPE (Preliminary)
II-12.

Page 16

Purchases.--Has your firm purchased UHMWPE produced in the United States or in other
countries since January 1, 2017? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.

No

Yes

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

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

2017

2018

2019

Purchases from U.S. importers of UHMWPE
from—
Korea
1

All other sources
Purchases from domestic producers2
Purchases from other sources3
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:
.
1

II-13.

Imports.--Since January 1, 2017, has your firm imported UHMWPE?
No

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

II-14.

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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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.—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 UHMWPE:

2.
3.

4.

Does your firm prepare profit/loss statements for UHMWPE:
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 UHMWPE, 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 produced in the facilities in which your firm
produced UHMWPE and provide the share of net sales accounted for by these products in your
firm’s most recent fiscal year.
Products
UHMWPE

Share of sales
%
%
%
%
%

Business Proprietary
U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of UHMWPE 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 19

No—Skip to question III-9a.

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
UHMWPE that your firm purchases from related suppliers and that are reflected in question III9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input

Related supplier

Share of total COGS

Input valuation 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 (financial results on UHMWPE) in a
manner consistent with your firm’s accounting books and records.

Yes

No

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

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Page 20

III-9a. Income statement on operations of UHMWPE.--Report the revenue and related cost
information requested below on the UHMWPE operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that internal consumption and transfers to related firms
must be valued at fair market value. Input purchases from related suppliers should be consistent
with and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact
Joanna Lo at (202) 205-1888 before completing this section of the questionnaire.
Quantity (in pounds) and value (in $1,000)
Fiscal years ended-Item

2017

2018

2019

Net sales quantities:
Commercial sales (“CS”) (A)
2

Internal consumption (“IC”) (B)
Transfers to related firms (“Transfers”) (C)
Total net sales quantities (D)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Net sales values:2
Commercial sales (E)
Internal consumption (F)
Transfers to related firms (G)
Total net sales values (H)
Cost of goods sold (COGS):
Raw materials (I)

3

Direct labor (J)
Other factory costs (K)
Total COGS (L)
Gross profit or (loss) (M)
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)
All other expense items (S)
All other income items (T)
Net income or (loss) before income taxes (U)
Depreciation/amortization included above (V)
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 UHMWPE manufactured by your company?
Did not include any resales of UHMWPE?
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 non-material differences that
may arise due to rounding?

Yes

No

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

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III-9d. Raw materials.--Please report the share of total raw material costs in your firm’s most recent
fiscal year (reported in III-9a) 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

Ethylene
Other material inputs1
Total (should sum to 100 percent)

0.0

Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs account for by each of these “other” raw materials:
.
1

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 UHMWPE?
Reflect the raw materials reported in question III-9a (row I)?
Inputs “produced by 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 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 row letter 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 III9a; i.e., if an aggregate nonrecurring item has been allocated to question III-9a, only the
allocated value amount included in question III-9a should be reported in the schedule below.
Note: The Commission’s objective here is to gather information only on material (significant)
nonrecurring items which impacted the reported financial results of the subject product in
question III-9a.
Fiscal years ended-Item

2017

2018

2019

Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III-9a where the nonrecurring item is classified.

Description of the nonrecurring item
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
(row letter in III-9a)

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III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of UHMWPE. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for UHMWPE in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9a. Provide data as
of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

2

2017

2018

2019

12

List the top assets (e.g. accounts receivables, inventories, PP&E, intangibles)
Describe substantial changes in asset values
.

.

Business Proprietary
U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
III-13.

Page 25

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for UHMWPE. Provide data for
your firm’s three most recently completed fiscal years.
Value (in $1,000)
Fiscal years ended-Item
Capital expenditures

2017

2018

2019

1

R&D expenses2
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.
.
1

Explanation of trends in capital expenditures and R&D expenses:

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

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) if 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 in III-9a 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-7 (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-7 (lines 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-7?
Yes

No

If no, please explain.

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III-15. Effects of imports on investment.--Since January 1, 2016, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of UHMWPE from Korea?
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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III-16. Effects of imports on growth and development.--Since January 1, 2016, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of UHMWPE from Korea?
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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III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
UHMWPE from Korea?
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: 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 (202205-2184, [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.--UHMWPE, with an average molecular weight/volume ranging from 6.7 to 7
106g/mol based on the producer’s advertised testing methodology; in individual
packaging with a net weight of 25kg.
Product 2.--UHMWPE, with an average molecular weight/volume ranging from 6.7 to 7
106g/mol based on the producer’s advertised testing methodology; in bulk
packaging with a net pallet weight of 130,000 lbs (59 MT) to 140,000 lbs (63.5 MT).
Product 3.--UHMWPE, with an average molecular weight/volume ranging from 8.7 to 9
106g/mol based on the producer’s advertised testing methodology; in individual
packaging with net weight greater than 453kg but less than 500 kg.
Product 4.--UHMWPE, with an average molecular weight/volume ranging from 8.7 to 9
106g/mol based on the producer’s advertised testing methodology; in individual
packaging with net weight ranging from 500 kg to 550 KG.

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

Period of shipment
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

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity
Value

1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
IV-2c.

Page 32

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.

Business Proprietary
U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
IV-3.

Price setting.--How does your firm determine the prices that it charges for sales of UHMWPE
(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 UHMWPE 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 33

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
UHMWPE 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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U.S. Producers’ Questionnaire - UHMWPE (Preliminary)
IV-7.

Page 34

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced UHMWPE (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 share of your firm’s sales is 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 UHMWPE?
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 - UHMWPE (Preliminary)
IV-9.

Page 35

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 UHMWPE that are delivered
the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced UHMWPE 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
UHMWPE 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 UHMWPE that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by UHMWPE and other inputs?
Share of total cost of end use product
accounted for by
End-use product

UHMWPE

Total
(should sum to
100.0% across)

Other inputs
%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-13. Substitutes.--Can other products be substituted for UHMWPE?
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 UHMWPE?
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 UHMWPE 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 UHMWPE 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 UHMWPE market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to UHMWPE? If yes,
describe.
Check all that apply.

Please describe.

No

Skip to question IV-17.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
UHMWPE since January 1, 2017?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply UHMWPE 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 UHMWPE 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
UHMWPE.

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IV-19. Interchangeability.--Is UHMWPE 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

Korea

Other countries

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

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IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between UHMWPE 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

Korea

Other countries

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

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

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2019
sales
(%)

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

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

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2017: Did your firm lose sales of UHMWPE to imports of
this product from Korea?
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: POLY)

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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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/ultrahigh_molecular_plolyethelene
/preliminary.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: POLY

• 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.