OMB FR notice 2 (2020) - Supporting statement - Part B

Part B.

Collections of Information Employing Statistical Methods

The Commission does not use statistical sampling methodology for information collections
conducted under this generic clearance; instead, it typically sends questionnaires to the entire
population or to a substantial portion of the population of firms producing, importing, or
purchasing the product in question. In most proceedings, the petitioning domestic producer is
required to identify all domestic producers and importers of the relevant product known to it,
as well as the foreign producers in the subject country(ies). Domestic producers and importers
provide purchaser names to the Commission. The Commission supplements this information
with publicly available sources (for domestic and foreign producers) and accesses confidential
information from U.S. Customs and Border Protection (for importers and foreign producers) to
compile the lists of firms to receive questionnaires. (Section (16) above of this statement
provides information on how the Commission maximizes response rates.)
For a specific investigation, the Commission typically sends producer questionnaires to all U.S.
firms manufacturing the product(s) in question. In most investigations, there are no more than
a total of 20 to 30 firms in the United States, and often far fewer, that produce the relevant
product(s). Some of the information contained in the producers’ questionnaire (e.g., questions
as to the impact of imports on firms’ operations) is relevant for the Commission’s
determinations regardless of the responding firm’s size. Similarly, the Commission attempts to
obtain data from all foreign manufacturers of the subject product, particularly if they are
exporting the product to the United States. Typically, there are fewer than 10 foreign
manufacturers per country involved in any Commission investigation.12
In contrast to domestic and foreign producers, the Commission often does not attempt to
obtain data from every U.S. importer and purchaser of the relevant product(s). Rather,
Commission staff issue importer and purchaser questionnaires to the most substantial firms
that import or purchase from the countries where the subject merchandise is produced.
Concentrating staff effort on a smaller group of firms permits the Commission to edit and
review fully the returned questionnaires and minimize the burden on smaller respondents.
Where possible, the Commission uses official Commerce statistics to determine import levels,
in some cases adjusting those statistics on the basis of importer questionnaire responses.
Further, a key purpose of the purchasers’ questionnaire is not to estimate population totals,
but to obtain an objective assessment of market conditions and competition between
domestically produced and imported products. The Commission report indicates the number of
firms in each category surveyed and notes the coverage by the responding firms of the
estimated total firms in each category

12

The Commission compiles separate data for each country considered.

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