20-2-4262 U.S. importers' questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

Fertilizers (P) -- U.S. Importers' Questionnaire

Phosphate fertilizers from Morocco and Russia (Inv. nos. 701-TA-650-651)

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

2023-04-18 - Extension without change of a currently approved collection

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Download: pdf | pdf

OMB No. 3117-0016/USITC No. 20-2-4262; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ 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 imported phosphate fertilizers (as defined on next page) from any country at any time since
January 1, 2017?

(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. Importers’ 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. Importers’ 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.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing phosphate fertilizers (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
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.

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

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Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Calvin
Chang (202-205-3062, [email protected]).
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-1.

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 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-2a.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm involved in the importation of phosphate fertilizers,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.

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

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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.

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

Firm name

I-4.

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

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
I-5.

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

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations of
phosphate fertilizers. More than one answer may be applicable.
Importer of record

I-7.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of phosphate fertilizers but is not the
consignee, please list the consignees below (firm name, address, telephone number, and
individual to contact).
Firm name

Address

Contact person
and email

Business Proprietary
U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
I-8.

Page 7

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters phosphate
fertilizers into, or withdraws such merchandise from, foreign trade zones or bonded
warehouses. Also indicate whether your firm imports phosphate fertilizers under the TIB
(temporary importation under bond) program.
“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, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond
I-9.

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes

If yes, Yes–Please specify.

Business Proprietary
U.S. Importers’ 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 importation of phosphate fertilizers since January 1, 2017.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

Business Proprietary
U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-3a.

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Arranged imports.--Has your firm imported or arranged for the importation of phosphate
fertilizers for delivery after March 31, 2020?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes

If yes, fill out the table below.

Period
Source

Apr-Jun 2020

Jul-Sept 2020

Oct-Dec 2020

Jan-Mar 2021

Quantity (in short tons dry weight)
Morocco
Russia
All other sources
II-3b.

Imports in the 12-month period preceding the petition.--Has your firm imported phosphate
fertilizers from any source between June 1, 2019 and May 31, 2020? (i.e., the last seven months
in 2019 and first five months in 2020 combined)
No

Yes

If yes, report the quantity of such import below by source.

Quantity (in short tons dry weight)
Source

June 2019 through May 2020

Morocco
Russia
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces phosphate fertilizers in the
United States, please indicate the reasons for importing this product. If your firm’s reasons differ
by source, please elaborate.

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

Page 10

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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.

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-5a.

Page 11

U.S. imports from Morocco.–Report your firm’s imports and your firm’s shipments and
inventories of phosphate fertilizers imported from Morocco by your firm during the specified
periods.

Morocco
Quantity (in short tons dry weight), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (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)
Please identify the foreign producers, if known:
.
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:
.
1
2

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
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Page 12

U.S. imports from Morocco.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation

2017

2018

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

January-March
2019

2019

2020

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

II-5b.

Channels of distribution: Morocco.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Morocco by channel of distribution during the specified periods.

Morocco
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Quantity (in short tons dry weight)
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 item
M + N + O – D – F – H = zero ("0"), if
not revise.

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-5c.

Page 13

U.S. shipments by type (Morocco).--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
phosphate fertilizers from Morocco by product type in 2019.

Morocco
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 II5a (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

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-5d.

Page 14

U.S. shipments by form (Morocco).--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
phosphate fertilizers from Morocco by form in 2019.

Morocco
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-5a
(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

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-6a.

Page 15

U.S. imports from Russia.–Report your firm’s imports and your firm’s shipments and inventories
of phosphate fertilizers imported from Russia by your firm during the specified periods.

Russia
Quantity (in short tons dry weight), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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Page 16

U.S. imports from Russia.–Continued

2017

2018

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

January-March
2019

2019
0

2020
0

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

II-6b.

Channels of distribution: Russia.--Report your firm’s U.S. shipments (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) of imports from Russia by
channel of distribution during the specified periods.

Russia
Calendar years
Item

2017

2018

January-March
2019

2019

2020

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-6c.

Page 17

U.S. shipments by type (Russia).--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
phosphate fertilizers from Russia by product type in 2019.

Russia
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 II6a (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

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-6d.

Page 18

U.S. shipments by form (Russia).--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
phosphate fertilizers from Russia by form in 2019.

Russia
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-6a
(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

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-7a.

Page 19

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of phosphate fertilizers imported from all other sources by your firm during the
specified periods.

All other sources

(list sources:

)
Quantity (in short tons dry weight), value (in $1,000)
Calendar years

Item

2017

2018

January-March
2019

2019

2020

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-7a.

Page 20

Imports from all other sources.–Continued

2017

2018

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

January-March
2019

2019
0

2020
0

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

II-7b.

Channels of distribution: All other sources.-- Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution during the specified periods.

All other sources
Calendar years
Item

2017

2018

January-March
2019

2019

2020

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-7c.

Page 21

U.S. shipments by type (all other sources).--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
phosphate fertilizers from all other sources by product type in 2019.

All other sources
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 II7a (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

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
II-7d.

Page 22

U.S. shipments by form (all other sources).--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
phosphate fertilizers from all other sources by form in 2019.

All other sources
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-7a
(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

2019

W + X – D – F – H = zero ("0"), if not revise.

II-8.

Transfers to related firms.--If your firm reported transfers to related firms in any of the data
tables in part II, 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) and whether the
transfers were priced at market value or by a non-market formula.

II-9.

Other explanations.--If your firm would like to further explain a response to a question in Part II
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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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 23

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
III-1.

PRICE DATA
III-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 your firm
imported from Morocco and Russia:
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).
During January 2017-March 2020, did your firm import from Morocco or Russia 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 tables as appropriate.
No.—Please explain below (e.g., no imports from Morocco and Russia, no sales of
listed products, no sales to NOLA, no bulk sales, etc.). Then skip to question III-3.

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Page 24

III-2a. Price data (Morocco).--Report below the quarterly price data1 for pricing products2 imported
from Morocco and sold by your firm in bulk to agricultural customers in the NOLA area.

Morocco
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 III.

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:

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Page 25

III-2b. Price data (Russia).--Report below the quarterly price data1 for pricing products2 imported from
Russia and sold by your firm in bulk to agricultural customers in the NOLA area.

Russia
Report data in short tons and actual dollars (not 1,000s).
(Quantity in short tons dry weight, value in dollars)
Product 1
Product 2
Period of shipment
Quantity
Value
Quantity
Value
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
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 III.

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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
III-2c.

Page 26

Price data checklist.--Please check that the pricing data in question III-2(a) 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 questions II-5 and II-6 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.

Describe how rebates applied in
Yes pricing data.

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

DAP

III-2e. 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. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
III-3.

Page 27

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

Contracts

Set
price
lists

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?

III-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.

III-5.

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

F.o.b.

If f.o.b., specify point

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

Contract versus spot.--Approximately what share of your firm’s sales of phosphate fertilizers
imported from Morocco and/or Russia 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
III-7.

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
phosphate fertilizers imported from Morocco and/or Russia (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)

Quantity
Price
Both
Yes
No

Not applicable
Please identify the indexes used:

Annual contracts
(multiple
deliveries for 12
months)
365

Indexed to raw
material costs1

Page 28

Long-term contracts
(multiple deliveries
for more than 12
months)

Business Proprietary
U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)
III-8.

Lead times.--What is your firm’s share of sales of phosphate fertilizers imported from Morocco
and/or Russia 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 phosphate fertilizers?

Source

Lead time
(Average number
Share of 2019 sales
of days)

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)
III-9.

Page 29

0.0 %

Shipping information.—
(a)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(b)

When your firm sells phosphate fertilizers imported from Morocco and/or Russia, from
where is it shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of phosphate fertilizers
imported from Morocco and/or Russia that are delivered the following distances from
your firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold phosphate
fertilizers imported from subject countries since January 1, 2017 (check all that apply)?
Geographic area
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.

Morocco

Russia

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Page 30

III-11. Inland transportation costs.—What is the approximate percentage of the cost of phosphate
fertilizers imported from Morocco and/or Russia that is accounted for by U.S. inland
transportation costs?
percent.
III-12. End uses.--List the end uses of the phosphate fertilizers that your firm imports. 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

Total
(should sum to
100.0% across)

Other inputs

0.0 %

III-13. Substitutes.--Can other products be substituted for phosphate fertilizers?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for phosphate fertilizers?
No Yes

Explanation

1.
2.
3.
III-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.

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

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Page 31

III-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.

III-16. Conditions of competition.—
(a) Is the phosphate fertilizers market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to phosphate fertilizers?
Check all that apply.

Please describe.

Skip to question III-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.

III-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.

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

Page 32

III-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.

III-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:

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

Page 33

III-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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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 34

III-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

Contact person

Telephone

City

State

Share
of
2019
sales
(%)

1
2
3
4
5
6
7
8
9
10
III-22. Other explanations.--If your firm would like to further explain a response to a question in Part III
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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U.S. Importers’ Questionnaire - Phosphate fertilizers (Preliminary)

Page 35

Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The U.S. International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.

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

Page 36

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 did not import 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.

File Type	application/pdf
File Title	US importer questionnaire
Subject	Title 7 investigations
Author	Chang, Calvin
File Modified	2020-06-30
File Created	2020-06-30