20-3-4263 U.S. purchasers' questionnaire

OMB No. 3117-0016/USITC No. 20-3-4263; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
PHOSPHATE FERTILIZERS FROM MOROCCO AND RUSSIA
This survey 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 survey is requested under the authority of the
Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other
order to compel the submission of records or information in your possession (19 U.S.C. § 1333(a)). Further information
on this survey can be obtained from Cindy Cohen (202-205-3230, [email protected]).

Name of firm
Address
City

State

Zip Code

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

YES

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

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: FERT)
CERTIFICATION
I certify that the information herein supplied in this survey is complete and correct to the best of my knowledge and belief and
understand that the information submitted is subject to audit and verification by the Commission. By submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
and throughout this proceeding in any other import-injury proceedings conducted by the Commission on the same or similar
merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Signature

Phone

Email address

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Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

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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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Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

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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.
Confidentiality.--The data furnished in response to this survey that reveal the individual operations of
your firm will be treated as confidential by the Commission to the extent that such data are not
otherwise available to the public and will not be disclosed except as may be required by law (see 19
U.S.C. 1677f). Such confidential information will not be published in a manner that will reveal the
individual operations of your firm; however, general characterizations of numerical business proprietary
information (such as discussion of trends) will be treated as confidential business information only at the
request of the submitter for good cause shown.
Release of information.--The information provided by your firm in response to this survey, as well as
any other business proprietary information submitted by your firm to the Commission in connection
with this proceeding, may become subject to, and released under, the administrative protective order
provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the Commission’s Rules of
Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and other authorized
individuals may temporarily be given access to the information for use in connection with this
proceeding or other import-injury proceedings conducted by the Commission on the same or similar
merchandise; those individuals would be subject to severe penalties if the information were divulged to
unauthorized individuals. Please also retain a copy of the final document that you submit.
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.

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Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

Page 4

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

2018

Item

January-March
2020

2019

Quantity (in short tons dry weight)

Purchases of phosphate
fertilizers produced in—
United States
Morocco
Russia
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

0

0

Imports of phosphate
fertilizers from—
Morocco
Russia
All other countries1
Total imports3

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

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Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

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

Did not
purchase Decreased Increased

Constant Fluctuated

Explanation for trend

United States

Morocco

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

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Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

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

Since January 1, 2017, did your firm import and/or purchase imports of phosphate
fertilizers from Morocco and/or Russia instead of purchasing U.S.-produced phosphate
fertilizers? Respond for each subject country.

Source

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

No
(If “No” for all countries, skip to next
question)

Morocco
Russia
(b)

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

Yes

No

Morocco
Russia
(c)

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

Source

Morocco
Russia

Yes

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

No

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

Business Proprietary
Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

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

Since January 1, 2017, in connection with a sale or offer to sell phosphate fertilizers to
your firm, did U.S. producers reduce their prices of domestically produced phosphate
fertilizers in order to compete with lower-priced imports of phosphate fertilizers from
the subject countries? Respond for each subject country.
Yes (also respond to
question part (b))

Source

No (If “No” for all countries,
skip to next question)

Don’t know

Morocco
Russia
(b)

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

Source

Estimated
reduction in U.S.
prices
(percent)

Morocco

%

Russia

%

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

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

7. Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the stock
exchange and trading symbol:
.
8. External counsel.-- If your firm or parent firm is represented by external counsel in relation to this
proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):

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Lost Sales and Lost Revenue Survey- Phosphate fertilizers (Preliminary)

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

Dollars

The questions in this survey have been reviewed with market participants to ensure that issues of
concern are adequately addressed and that data requests are sufficient, meaningful, and as limited
as possible. Public reporting burden for this survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey or cannot use one of the electronic methods
of submission, please contact the Commission for further instructions.
• Upload via Secure Drop Box.—Upload the MS Word survey along with a scanned copy of the signed
certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: FERT

• E-mail.—E-mail the MS Word survey to [email protected]; include a scanned copy of the signed
certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents that are
electronically transmitted to the Commission to protect your sensitive information from unauthorized
disclosure. The USITC secure drop-box system and the Electronic Document Information System (EDIS)
use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to encrypt data in
transit. Submitting your nonpublic documents by a means that does not use these encryption algorithms
(such as by email) may subject your firm’s nonpublic information to unauthorized disclosure during
transmission. If you choose a non-encrypted method of electronic transmission, the Commission warns
you that the risk of such possible unauthorized disclosure is assumed by you and not by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.