Form 20-1-4261 U.S. producers' questionnaire

OMB No. 3117-0016/USITC No. 20-1-4261; Expiration Date: : 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
PHOSPHATE FERTILIZERS FROM MOROCCO AND RUSSIA
This questionnaire must be received by the Commission by July 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 countervailing duty investigations concerning phosphate fertilizers from Morocco and Russia (Inv.
Nos. 701-TA-650-651 (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 phosphate fertilizers (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: FERT)
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

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

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on June 26, 2020, by The
Mosaic Company, Plymouth, Minnesota. Countervailing duties may be assessed on the subject imports
as a result of these proceedings if the Commission makes an affirmative determination of injury, threat,
or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative
determination of subsidization. Questionnaires and other information pertinent to this proceeding are
available at
https://usitc.gov/investigations/701731/2020/phosphate_fertilizers_morocco_and_russia/preliminary.h
tm.
Phosphate fertilizers covered by these investigations is phosphate fertilizers in all physical forms (i.e.,
solid or liquid form), with or without coating or additives such as anti-caking agents. Phosphate
fertilizers in solid form are covered whether granular, prilled (i.e., pelletized), or in other solid form (e.g.,
powdered).
The covered merchandise includes, but is not limited to, phosphate fertilizers in the following forms:
•
•
•
•
•

Ammonium dihydrogenorthophosphate or monoammonium phosphate (MAP);
Chemical formula NH4H2PO4; diammonium hydrogenorthophosphate or diammonium
phosphate (DAP);
Chemical formula (NH4)2HPO4; normal superphosphate (NSP), also known as ordinary
superphosphate or single superphosphate, chemical formula Ca(H2PO4)2·CaSO4;
Concentrated superphosphate, also known as double, treble, or triple superphosphate (TSP),
chemical formula Ca(H2PO4)2·H2O;
And proprietary formulations of MAP, DAP, NSP, and TSP.

The covered merchandise also includes other fertilizer formulations incorporating phosphorous and
non-phosphorous plant nutrient components, whether chemically-bonded, granulated (e.g., when
multiple components are incorporated into granules through, e.g., a slurry process), or compounded
(e.g., when multiple components are compacted together under high pressure), including:
•
•
•

Nitrogen, phosphate, sulfur (NPS) fertilizers;
Nitrogen, phosphorous, potassium (NPK) fertilizers;
And proprietary formulations thereof that may or may not include other nonphosphorous plant
nutrient components.

For phosphate fertilizers that contain non-phosphorous plant nutrient components, such as nitrogen,
potassium, sulfur, zinc, or other non-phosphorous components, the entire article is covered, including
the non-phosphorous content, provided that the phosphorous content (measured by diphosphorous
pentaoxide, chemical formula P2O5) is at least 5% by weight.
Phosphate fertilizers that are otherwise subject to this investigation are included when commingled (i.e.,
mixed or blended) with phosphate fertilizers from sources not subject to this investigation. Phosphate
fertilizers that are otherwise subject to this investigation are included when commingled with
substances other than phosphate fertilizers subject to this investigation (e.g., granules containing only
non-phosphate fertilizers such as potash or urea). Only the subject component of such commingled
products is covered by the scope of this investigation.

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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 3

The Chemical Abstracts Service (CAS) numbers for covered phosphate fertilizers include, but are not
limited to: 7722-76-1 (MAP); 7783-28-0 (DAP); and 65996-95-4 (TSP). The covered products may also be
identified by Nitrogen-Phosphate-Potash composition, including but not limited to: NP 11-52-0 (MAP);
NP 18-46-0 (DAP); and NP 0-46-0 (TSP).
The covered merchandise is currently classified in the Harmonized Tariff Schedule of the United States
(“HTSUS”) at subheadings 3103.11.0000; 3103.19.0000; 3105.20.0000; 3105.30.0000; 3105.40.0010;
3105.40.0050; 3105.51.0000; and 3105.59.0000. Phosphate fertilizers subject to these investigations
may also enter under subheadings 3103.90.0010, 3105.10.0000, 3105.60.0000, 3105.90.0010, and
3105.90.0050. Although the HTSUS subheadings and CAS registry numbers are provided for convenience
and customs purposes, the written description of the scope is dispositive.
Short tons dry weight – Short tons dry weight contained phosphate.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of phosphate fertilizers 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.

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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 4

D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
I-1a.

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes

No

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
I-2a.

Page 5

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of phosphate fertilizers,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

I-2b.

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

I-2c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):

I-3.

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

I-4.

Yes

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

Investigation type

Morocco

Countervailing duty

Russia

Countervailing duty

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
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 phosphate fertilizers from Morocco or Russia into the
United States or that are engaged in exporting phosphate fertilizers from Morocco or Russia to
the United States?
No
Firm name

I-7.

Page 6

Yes--List the following information.
Country

Affiliation

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Calvin Chang (202-205-3062,
[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 phosphate fertilizers 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)

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (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 phosphate fertilizers, 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 short tons dry weight)
Calendar years
Item

Overall production capacity

2017

2019

2019

2020

1

Production of:
Phosphate fertilizers2
Other products

2018

January-March

0

0

0

0

0

0

0

0

0

0

3

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 phosphate fertilizers 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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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 9

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 phosphate fertilizers 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 phosphate fertilizers?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

Yes

If yes--Please describe the toll arrangement(s) and name the firm(s)
involved.

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-6.

Page 10

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce phosphate fertilizers in and/or admit
phosphate fertilizers 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 firm’s 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 phosphate fertilizers into a foreign trade zone (FTZ) for use in distribution of
phosphate fertilizers and/or the production of downstream articles?

(b)

No

Yes

If yes--Identify the firms and the FTZs.

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (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 phosphate fertilizers 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. Unless otherwise stated, report value in
1,000s of dollars.
“Internal consumption/ including product shipped to own firm's retail establishments”-Product consumed internally by your firm, which includes merchandise that your firm
transferred to your own firm’s retail establishments (i.e., shipped to either a bricks-and-mortar
store or to an online order fulfillment center). Such transactions are to be valued at fair market
value and not the total value of final downstream processed merchandise in the case of internal
consumption, nor the retail sale value in the case of your firm owning and operating its own
retail establishments or using a third-party fulfillment center to place retail level sales.
“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.

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-7.

Page 12

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

2017

2018

January-March
2019

2019

2020

Average production capacity (quantity)
(A)
1

Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including
product shipped to your firm’s retail
establishments:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod 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

January-March
2019

0

2019
0

2020
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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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
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 short tons dry weight)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Channels of distribution:
U.S. shipments:
To distributors/wholesalers (M)
To retailers (N)
To end users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M, N, and 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

January-March
2019

0

2019
0

2020
0

0

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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-9

Page 14

U.S. shipments by type.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of phosphate fertilizers by
product type in 2019.
Quantity (in short tons dry weight)
Calendar year
Item

2019

U.S. shipments:
MAP (P)
DAP (Q)
NSP (R)
TSP (S)
NPS (T)
NPK (U)
Other1 (V)
1

Please describe these products:

.

RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantity reported for U.S. shipments in
this question (i.e., lines P through V) in 2019 equal the quantity reported for U.S. shipments in question II7 (i.e., lines D, F, and H) in 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 + V – D – F – H = zero ("0"), if not revise.

2019
0

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-10.

Page 15

U.S. shipments by form.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of phosphate fertilizers by form
in 2019.
Quantity (in short tons dry weight)
Calendar year
Item

2019

U.S. shipments:
In solid form (W)
In liquid form (X)
RECONCILIATION OF U.S. SHIPMENTS.--Please ensure that the quantity reported for U.S. shipments in
this question (i.e., lines W and X) in 2019 equal the quantity reported for U.S. shipments in question II-7
(i.e., lines D, F, and H) in 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
W + X – D – F – H = zero ("0"), if not revise.

2019
0

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-11.

Page 16

Employment data.--Report your firm’s employment-related data related to the production of
phosphate fertilizers 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. For the January to March periods, calculate similarly and divide by 3.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“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

January-March
2019

2019

2020

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

II-12.

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.

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-13.

Page 17

Purchases.--Has your firm purchased phosphate fertilizers 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 short tons dry weight)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Purchases from U.S. importers of
phosphate fertilizers from—
Morocco
1

Russia
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-14.

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

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

II-15.

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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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 18

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Emily Kim (202-205-1800, [email protected]).
Supply all data requested on a calendar-year basis.
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:
Note.—Regardless of your firm’s fiscal year, please report financial data on a
calendar year basis.

B.1.
2.
3.

4.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include phosphate fertilizers:
Does your firm prepare profit/loss statements for phosphate fertilizers:
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:
U.S. GAAP,
IFRS,
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 phosphate fertilizers, as
well as specific statements and worksheets) used to compile these data.

III-3.

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

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Page 19

III-4.

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

III-5.

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

Share of sales
%
%
%
%
%

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

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of phosphate fertilizers 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 20

No—Skip to question III-9a.

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
phosphate fertilizers 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 of your most recently completed calendar 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 phosphate
fertilizers) 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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III-9a. Operations on phosphate fertilizers.--Report the revenue and related cost information
requested below on the phosphate fertilizers 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 calendar 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
Emily Kim at (202) 205-1800 before completing this section of the questionnaire.
Quantity (in short tons dry weight) and value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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

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

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Net sales values:
Commercial sales
2

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

3

Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

2

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 reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?

Yes

III-9c.

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.

Raw materials.--Report the share of total raw material costs in 2019 (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

Phosphate rock
Sulfuric acid
Ammonia
Other material inputs1
Total (should sum to 100 percent)

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:
.

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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 years
Item

2017

2018

January-March
2019

2019

2020

Value (in $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

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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

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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-12a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of phosphate fertilizers. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for phosphate
fertilizers 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
calendar 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.
Value (in $1,000)
Calendar years
Item
Total assets (net)
1

Describe

2017

2018

2019

1

.

III-12b. Description of reported assets.--Describe the main asset categories (both current and long-term
assets) in the above response. 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.

III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for phosphate fertilizers.
Provide data for your firm’s three most recently completed calendar years, and for the
specified interim periods.
Value (in $1,000)
Calendar years
Item
Capital expenditures
R&D expenses

2017

2018

January-March
2019

2019

2020

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Page 25

III-13b. Description of reported capital expenditures.-- Describe the nature, focus, and significance of
your firm’s reported capital expenditures. If no capital expenditure data were reported, explain
the reason.

III-13c. Description of reported R&D expenses.-- Describe the nature, focus, and significance of your
firm’s reported R&D expenses. If no R&D expenses were reported, explain the reason.

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) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in Part II equal the quantities and values reported for total net sales in Part III of this
questionnaire in each time period. 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

January-March
2019

2019

2020

Quantity: Trade data from question
II-7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").

0

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, = zero ("0").

0

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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Page 26

If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of phosphate fertilizers from Morocco or Russia?
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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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 27

III-16. Effects of imports on growth and development.--Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of phosphate fertilizers from Morocco or Russia?
No

Yes

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

(check as many as appropriate)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other

(please describe)

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Page 28

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
phosphate fertilizers from Morocco or Russia?
No

Yes

If yes, my firm anticipates negative effects as follows.

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 29

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[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 bulk commercial
shipments to unrelated U.S. agricultural customers located in the New Orleans (NOLA) area.
Data is request for shipments since January 1, 2017 of the following products produced by your
firm:
Product 1.-- Standard-grade monoammonium phosphate (MAP), chemical formula NH4H2PO4,
granular, excluding high-purity MAP.
Product 2.-- Standard-grade diammonium phosphate (DAP), chemical formula (NH4)2(HPO4),
granular.

Please report only shipments for MAP and DAP, bulk (i.e., barge-load), selling point to New Orleans
(NOLA) area, arm’s-length customers, loaded-on-barge. Do not include shipments to customers
outside the NOLA area.
Values should reflect the final net amount paid to your firm (i.e., should be net of all deductions for
discounts, rebates, or other allowances). If rebates are paid retroactively based on sales volume
targets, base these deductions on estimates of rebates based on historical experience with customers.
Report shipments only to agricultural sector customers (exclude industrial or feed sector shipments).
IV-2a. During January 2017-March 2020, did your firm produce and sell in bulk to unrelated U.S.
agricultural customers in the NOLA area either of the above listed products?
Yes.--Please complete the following pricing data table as appropriate.
No.—Please explain below (e.g., no sales of listed products, no sales to NOLA, no bulk
sales, etc.). Then 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 to agricultural customers in the NOLA area.
Report data in short tons and actual 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
2020:
January-March

(Quantity in short tons dry weight, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), delivered NOLA.
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:

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

Page 31

Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
√ if Yes

Are the price data reported above:
In actual dollars (not $1,000) and short tons?
Include only shipments to NOLA area?
Bulk (i.e., barge-load), selling point to New Orleans (NOLA) area?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Include only agricultural sector sales?
Quantities do not exceed commercial shipments in question II-7 in each year?

III-2d. Pricing data rebates.—Does your firm give rebates to customers based on annual sales volume?
If yes, please describe how such rebates were applied in your reported pricing data and indicate
the average unit values of rebates excluded from pricing product values for 2019.

No

IV-2e.

Describe how rebates applied in
Yes pricing data.

Rebates excluded from pricing data, 2019
(dollars per short ton)
MAP

DAP

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 - Phosphate fertilizers (Preliminary)
IV-3.

Page 32

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

Set
price
lists

Contracts

Other

If other, describe

(b) Does your firm refer to prices published in trade publications (e.g., Argus, CRU, Green
Markets) in determining selling prices for phosphate fertilizers?

No

IV-4.

Yes

If yes, please describe how your firm’s price indexing works including: 1.
trade publications referenced, 2. formulas used, 3. whether formulas
differ by customer, 4. whether prices can change between shipment and
delivery, and 5. approximate percent of sales with price indexing.

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

Quantity
discounts

Annual
total
volume
discounts

No
discount
policy

Rebates

Other

Describe

If your firm provides rebates to customers for phosphate fertilizer sales, please explain how
rebates are determined and when they are paid to the customer.

IV-5.

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

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
IV-6.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
phosphate fertilizers 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
IV-7.

Page 33

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

%

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced phosphate fertilizers (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 phosphate fertilizers?
Source

Share of 2019 sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

Lead time (Average
number of days)

Business Proprietary
U.S. Producers’ Questionnaire - Phosphate fertilizers (Preliminary)
IV-9.

Page 34

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 phosphate fertilizers 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 phosphate fertilizers 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
phosphate fertilizers that is accounted for by U.S. inland transportation costs?
percent
IV-12. End uses.--List the end uses of the phosphate fertilizers that your firm manufactures. For each
end-use product, what percentage of the total cost is accounted for by phosphate fertilizers and
other inputs?
Share of total cost of end use product
accounted for by
End-use product

Phosphate fertilizers

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

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IV-13. Substitutes.--Can other products be substituted for phosphate fertilizers?
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 phosphate fertilizers?
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 phosphate fertilizers 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 phosphate fertilizers 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 phosphate fertilizers market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to
phosphate fertilizers? 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
phosphate fertilizers since January 1, 2017?
No

Yes

If yes, describe.

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

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IV-19. Interchangeability.--Is phosphate fertilizers 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

Morocco

Russia

Other countries

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

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

Morocco

Russia

Other countries

United States
Morocco
Russia
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of phosphate fertilizers, 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 phosphate fertilizers since January 1, 2017. Indicate the share of the quantity of
your firm’s total shipments of phosphate fertilizers 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
phosphate fertilizers from Morocco or Russia, 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 phosphate fertilizers to
imports of this product from Morocco or Russia?
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: FERT)

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://usitc.gov/investigations/701731/2020/phosphate_fertilizers_morocco_and_russ
ia/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: FERT

• 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.