20-3-4203 U.S. purchasers' questionnaire

OMB No. 3117-0016/USITC No. 20-3-4203; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
ULTRA-HIGH MOLECULAR WEIGHT POLYETHYLENE FROM KOREA
This survey must be received by the Commission by March 17, 2020
See last page for filing instructions.
The information called for in this survey 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. 701-TA-1474 (Preliminary)). The information requested in the survey 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 possession (19 U.S.C. § 1333(a)). Further information on this
survey can be obtained from Kyle Westmoreland (202-205-2184, [email protected]).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased, or imported for its own use, 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 survey to the Commission)

YES

(Complete all parts of the survey, and return the entire survey 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 this survey 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 submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
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
investigation or other proceeding 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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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 these proceedings if the Commission makes an affirmative determination of injury, threat, or
material retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative
determination of dumping. U.S. producers of UHMWPE have provided the USITC with allegations about
sales or revenue that they have lost due to competition from imports of UHMWPE from Korea. One or
more domestic producer(s) have named your firm in such an allegation. Questionnaires and other
information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2020/ultrahigh_molecular_plolyethelene/preliminary.htm
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.
Confidentiality.--The data furnished in response to this survey 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.

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Release of information.--The information provided by your firm in response to this survey, 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. Please also retain a copy of the final document that you submit.
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.

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PURCHASE INFORMATION
1. Purchases and imports.— Report separately your firm’s domestic purchases and imports of
UHMWPE.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2017

2018

Item

2019

Quantity (in pounds)

Purchases of UHMWPE produced in—
United States
Korea
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

Imports of UHMWPE from—
Korea
All other countries1
Total imports3

Please identify these countries:
Please indicate the firm(s) from which you purchased this merchandise:
3
If your firm imported UHMWPE at any time since January 1, 2017, please also complete and return a
U.S. importers' questionnaire in this proceeding.
1
2

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2. Changes in purchasing patterns.—Please indicate how the shares of your firm’s purchases of
UHMWPE from different sources have changed since January 1, 2017.
Source of
purchases

Did not
purchase Decreased Increased

Constant Fluctuated

Explanation for trend

United States

Korea
All other
countries
Sources
unknown
3. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase UHMWPE.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

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4. Purchasing subject imports rather than domestic products.—
(a)

Since January 2017, did your firm import and/or purchase imports of UHMWPE from
Korea instead of purchasing U.S.-produced UHMWPE?

Yes
(also respond to parts (b) and (c))

(b)

No
(If “No” skip to next question)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Yes

(c)

No

If you responded “Yes” to part (a), was price a primary reason for importing and/or
purchasing subject imports rather than domestic product?

Yes

If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2017
(in pounds)

No

If No, please indicate the
reason your firm imported
and/or purchased imports
instead of domestic product

5. U.S. producers and import competition.—
(a)

Since January 1, 2017, in connection with a sale or offer to sell UHMWPE to your firm,
did U.S. producers reduce their prices of domestically produced UHMWPE in order to
compete with lower-priced imports of UHMWPE from Korea?

Yes
(also respond to question part (b))

(b)

No
(If “No” skip to next question)

Don’t know

If your firm responded “yes” to part (a), please provide an estimate of the reduction in
U.S. producers’ prices, and any additional explanations, such as timing (e.g.,
months/years), frequency of price reductions, or other market/competitive factors.

Estimated
reduction in U.S.
prices
(percent)
%

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

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6. Other explanations--Please provide any additional comments in this box.

7. Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the stock
exchange and trading symbol:
.
8. 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):

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

Dollars

The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey 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 survey 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 did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.