20-4-4260 Foreign producers' / exporters' questionnaire

OMB No. 3117-0016/USITC No. 20-4-4260; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
TWIST TIES FROM CHINA
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 and antidumping investigations concerning twist ties from China (Inv.
Nos. 701-TA-649 and 731-TA-1523 (Preliminary)). The information requested in the questionnaire is requested
under the authority of the Tariff Act of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported twist ties (as defined on next page) from China 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 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 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

Title of Authorized Official

Date

Signature

Phone

Email address

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)

Page 2

PART I.—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 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. If your firm is completing more than one questionnaire (i.e., a producer, importer,
purchaser and/or foreign producer 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.

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)

Page 3

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.
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 Andres
Andrade (202-205-2078, [email protected]).
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
20 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.

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
I-2.

Page 4

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm in China involved in the production or export of twist
ties, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities. Firms operating more than one establishment in China should
combine the data for all establishments into a single report.

I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce twist ties in the United States or other countries?

No

I-4.

Yes

If yes, please name the firm(s) and country(ies) below and, if U.S.
producer(s), ensure that they complete the Commission’s producer
questionnaire.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
twist ties into the United States?

No

Yes

If yes, please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

I-5.

Stock symbol information.-- If your firm or any of the entities reported in questions I-2 through
I-4 are publicly traded in the United States, please specify the stock exchange and trading
symbol (including American Depository Receipts, if applicable):
.

I-6.

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
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
I-7.

U.S. importers.--Please provide the names, contacts, telephone numbers, and e-mail addresses
of the FIVE largest U.S. importers of your firm’s twist ties in 2019.

Importer’s name
1
2
3
4
5

Page 5

Contact person

Email

Telephone

Share of your
firm’s 2019 U.S.
exports (%)

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Andres Andrade (202-2052078, [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-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of twist ties 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
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
II-2b.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of twist ties in the
future?

No

II-3a.

Page 7

Yes

If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions.

Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce twist ties, 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 for all
products manufactured in that establishment using the same manufacturing equipment.
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-8. 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-8 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” --All production in your establishment(s) in China, including production consumed
internally within your firm.

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
II-3a.

Page 8

Production using same machinery.--Continued.
Quantity (in 1,000 pounds)
Calendar years
Item

Overall production capacity

2017

2018

January-March
2019

2019

2020

1

Production of:
Twist ties
Other products2
Total production using
same machinery or workers
1
2

0

0

0

0

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Please identify these products:
.

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week

Weeks per year

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.

0

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
II-4.

Page 9

Product shifting.—
(a).

Is your firm able to switch production (capacity) between twist ties and other products using
the same equipment and/or labor?

No

(b).

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.

II-5.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of twist ties?
percent.

II-6a.

Firm's estimated share of production in China.--Please estimate the percentage of total production
of twist ties in the country specified on the certification page accounted for by your firm’s
production in 2019.
percent.

II-6b.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of twist ties from the country specified on the certification page accounted for
by your firm’s exports in 2019.
percent.

II-7.

Third country trade actions.--Is the twist ties exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?

No

Yes

If yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
II-8.

Page 10

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of twist ties in your establishment(s) in China during the specified
periods. Do not include resales of twist ties that your firm did not produce in this question;
those data to the degree they are exported to the United States should only be reported in
question II-9.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s) in China, including production consumed
internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”--Shipments to destinations outside of the country indicated on page 1
(China), 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
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
II-8.

Page 11

Trade data.--Continued.
Quantity (in 1,000 twist ties)
Projections1

Actual experience
Calendar year
Item

2017

2018

January-March
2019

2019

Calendar year

2020

2020

2021

2

Average production capacity (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
(D)
Commercial shipments (E)
Exports to the United States (F)
Exports to all other markets3 (G)
Total exports (H)
(should equal F+G)

0

0

0

0

0

0

0

Total shipments (I)
(should equal D+E+F+G)

0

0

0

0

0

0

0

End-of-period inventories (J)
1

Please explain the basis for your firm’s projections.
.
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.
3
Identify principal other export markets.
.
2

.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line J) 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, E, F, and G). 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.
Actual experience
Calendar year
Item

2017

2018

Projections
January-March

2019

2019

2020

Calendar year
2020

2021

B + C – D – E – F –G – J = should equal
zero ("0") or provide an explanation.1
0
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.

0

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)
II-9.

Page 12

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of twist ties that was produced in China but not by your firm during the specified
periods. Note these data should not be included in question II-8.
Quantity (in 1,000 twist ties)
Actual experience
Calendar year
Item

2017

2018

Projections
January-March

2019

2019

2020

Calendar year
2020

2021

Exports of twist ties to the
United States not produced by
your firm1
1

List the producer(s).

II-10.

.

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.

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)

Page 13

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 setup 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 USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

Business Proprietary
Foreign Producers’ Questionnaire – Twist Ties (Preliminary)

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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://www.usitc.gov/investigations/701731/2020/twist_ties_china/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: TIES

• E-mail.—E-mail your 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 produce or export 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, you are 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.