20-3-4259 U.S. purchasers' questionnaire

OMB No. 3117-0016/USITC No. 20-3-4259; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
TWIST TIES FROM CHINA
This survey must be received by the Commission by July 10, 2020
See last page for filing instructions.
The information called for in this survey is for use by the United States International Trade Commission in connection
with its countervailing duty/antidumping investigations concerning twist ties from China (Inv. Nos. 701-TA-649 and 731TA-1523 (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 Lauren Gamache ([email protected], 202-205-3489).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased twist ties (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: TIES)
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

Business Proprietary
Lost Sales and Lost Revenue Survey- Twist ties (Preliminary)

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GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 26, 2020, by Bedford
Industries Inc., Worthington, Minnesota. Countervailing and antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and dumping. Questionnaires and other information
pertinent to this proceeding are available at:
https://www.usitc.gov/investigations/701731/2020/twist_ties_china/preliminary.htm
Twist ties covered by these investigations are consists of twist ties, which are thin, bendable ties for
closing containers, such as bags, bundle items, or identifying objects. A twist tie is comprised of one or
more metal wires encased in a covering material, which allows the tie to retain its shape and bind
against itself. The metal wire in a twist tie is typically stainless or galvanized steel and typically measures
between the gauges of 19 (.0410” diameter) and 31 (.0132”) (American Standard Wire Gauge). A twist
tie usually has a width between .075” and 1” in the cross-machine direction (width of the tie –
measurement perpendicular with the wire); a thickness between .015” and .045” over the wire or other
metal; and a thickness between .002” and .020” in areas without wire or other metal. Twist ties are
commonly available individually in pre-cut lengths (“singles”), wound in large spools to be cut later by
machine or hand, or in perforated sheets of spooled or single twist ties that are later slit by machine or
by hand (“gangs”).
The covering material of a twist tie may be paper (metallic or plain), plastic, or polyethylene, and can be
dyed in a variety of colors with or without printing. A twist tie may have the same covering material on
both sides or one side of paper and one side of plastic. When comprised of two sides of paper, the
paper material is bound together with an adhesive or plastic. A twist tie also may have a tag or label
attached to it or a pre-applied adhesive attached to it.
The scope includes ties used for television cable, computer cords, other appliances and household ties,
all of which are manufactured by Petitioner. Twist ties without metal wire also are covered in the scope.
An all plastic tie contains a plastic core as well as a plastic covering (the wing) over the core, just like
paper and/or plastic in a metal tie. The scope does not include products with wire and plastic material
(e.g., pipe cleaners used in craft activities, wire bristle brushes), or plastic “zip” ties.
Twist ties are imported into the United States under Harmonized Tariff System of the United States
(“HTSUS”) subheadings 8309.90.0000 and 5609.00.3000. Subject merchandise may also enter under
HTSUS subheadings 3906.90.2000, 3920.51.5000, 3923.90.0080, 3926.90.9990, 4811.59.6000,
4821.10.4000, 4821.90.2000, and 4823.90.8600. These HTSUS subheadings are provided for reference
only. The written description of the scope of the investigations is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates.
Confidentiality.--The data furnished in response to this survey that reveal the individual operations of
your firm will be treated as confidential by the Commission to the extent that such data are not
otherwise available to the public and will not be disclosed except as may be required by law (see 19
U.S.C. 1677f). Such confidential information will not be published in a manner that will reveal the
individual operations of your firm; however, general characterizations of numerical business proprietary

Business Proprietary
Lost Sales and Lost Revenue Survey- #PRODUCT

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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.

Business Proprietary
Lost Sales and Lost Revenue Survey- #PRODUCT

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PURCHASE INFORMATION
1. Purchases and imports.— Report separately your firm’s domestic purchases and imports of twist
ties.
“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
Item

2018

2019

Quantity (in 1,000 twist ties)

Purchases of twist ties produced in—
United States
China
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

Imports of twist ties from—
China
All other countries1
Total imports3
1

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

Business Proprietary
Lost Sales and Lost Revenue Survey- #PRODUCT

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

Did not
purchase

Decreased Increased

Constant Fluctuated

Explanation for trend

United States

China
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 twist ties.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

Business Proprietary
Lost Sales and Lost Revenue Survey- #PRODUCT

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

Since January 2017, did your firm import and/or purchase imports of twist ties from
China instead of purchasing U.S.-produced twist ties?
Source

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

No
(If “No”, skip to next question)

China
(b)

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

Yes

No

China
(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

China

Yes

If Yes, estimate the quantity
of imports purchased and/or
imported instead of domestic
product since January 2017
(in 1,000 twist ties)

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- #PRODUCT

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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 twist ties to your firm, did
U.S. producers reduce their prices of domestically produced twist ties in order to
compete with lower-priced imports of twist ties from the subject countries?
Yes (also respond to
question part (b))

Source

No (If “No”, skip to next
question)

Don’t know

China
(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)

China

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):

Business Proprietary
Lost Sales and Lost Revenue Survey- #PRODUCT

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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: TIES

• 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.