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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4273; Expiration Date: 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
SEAMLESS REFINED COPPER PIPE AND TUBE FROM VIETNAM
This questionnaire must be received by the Commission by July 14, 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 antidumping investigation concerning seamless refined copper pipe and tube (“SRC pipe and tube”)
from Vietnam (Inv. No. 731‐TA‐1528 (Preliminary)). The information requested in the questionnaire is requested under
the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a
subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced SRC pipe and tube (as defined on next page) at any time since January 1, 2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: SRCP)
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
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on June 30, 2020, by the
American Copper Tube Coalition, consisting of Mueller Group, Collierville, Tennessee, and Cerro Flow
Products, LLC, Chicago, Illinois. 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 dumping. Questionnaires and other information pertinent to this proceeding are
available at
https://www.usitc.gov/investigations/701731/2020/seamless_refined_copper_pipe_and_tube_vietnam
/preliminary.htm.
SRC pipe and tube: This definition covers all seamless circular refined copper pipes and tubes, including
redraw hollows, greater than or equal to 6 inches (152.4 mm) in length and measuring less than 12.130
inches (308.102 mm) (actual) in outside diameter (“OD”), regardless of wall thickness, bore (e.g.,
smooth, enhanced with inner grooves or ridges), manufacturing process (e.g., hot finished, cold‐drawn,
annealed), outer surface (e.g., plain or enhanced with grooves, ridges, fins, gills), end finish (e.g., plain
end, swaged end, flared end, expanded end, crimped end, threaded), coating (e.g., plastic, paint),
insulation, attachments (e.g., plain, capped, plugged, with compression or other fitting), or physical
configuration (e.g., straight, coiled, bent, wound on spools).
This definition covers, but is not limited to, seamless refined copper pipe and tube produced or
comparable to the American Society for Testing and Materials (“ASTM”) ASTM‐B42, ASTM‐B68, ASTM‐
B75, ASTM‐B88, ASTM‐B88M, ASTM‐B188, ASTM‐B251, ASTM‐B251M, ASTM‐B280, ASTM‐B302, ASTM‐
B306, ASTM‐359, ASTM‐B743, ASTM‐B819, and ASTM‐B903 specifications and meeting the physical
parameters described therein. This definition includes all sets of covered products, including “line sets”
of seamless refined copper tubes (with or without fittings or insulation) suitable for connecting an
outdoor air conditioner or heat pump to an indoor evaporator unit. The phrase “all sets of covered
products” denotes any combination of items put up for sale that is comprised of merchandise subject to
the scope.
“Refined copper” is defined as: (1) metal containing at least 99.85 percent by weight of copper; or (2)
metal containing at least 97.5 percent by weight of copper, provided that the content by weight of any
other element does not exceed the following limits:
ELEMENT
LIMITING CONTENT PERCENT BY WEIGHT
Ag – Silver
0.25
As – Arsenic
0.5
Cd – Cadmium
1.3
Cr – Chromium
1.4
Mg – Magnesium
0.8
Pb – Lead
1.5
S – Sulfur
0.7
Sn – Tin
0.8
Te – Tellurium
0.8
Zn – Zinc
1.0
Zr – Zirconium
0.3
Other elements (each)
0.3
This definition excludes all seamless circular hollows of refined copper less than 12 inches in length
whose OD (actual) exceeds its length.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 3
SRC pipes and tubes are currently classifiable under statistical reporting numbers 7411.10.1030 and
7411.10.1090 of the Harmonized Tariff Schedule of the United States (“HTSUS”). SRC pipes and tubes
may also enter under HTSUS statistical reporting numbers 7407.10.1500, 7419.99.5050, 8415.90.8065,
and 8415.90.8085. Although the HTSUS statistical reporting numbers are provided for convenience and
customs purposes, the written description above 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,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of SRC pipe and tube and your responses to the questions in
Part I of the producer questionnaire will be provided to the U.S. Department of Commerce, upon its
request, for use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 4
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b.
TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
I‐2a.
Page 5
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of SRC pipe and tube,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
I‐2c.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
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).
I‐3.
Law firm:
Lead attorney(s):
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Petition support.‐‐Does your firm support or oppose the petition?
Country
Vietnam
Investigation type
Antidumping duty
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
I‐5.
I‐6.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Extent of
ownership
(percent)
Firm name
Country
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing SRC pipe and tube from Vietnam into the United States or
that are engaged in exporting SRC pipe and tube from Vietnam to the United States?
No
Yes‐‐List the following information.
Page 6
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
I‐7.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of SRC pipe and tube?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [email protected]). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part II.
Name
Title
Email
Telephone
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of SRC pipe and tube since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 9
II‐3a. Production using same machinery.‐‐Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce SRC pipe and tube, and the
combined production capacity on this shared equipment, machinery, or employees in the
periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.‐‐If your firm does not produce any out‐of‐scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II‐7. If, however, your firm does produce out‐of‐scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II‐7 should exclude the portion of "overall production capacity" that was
used to produce this out‐of‐scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in 1,000 pounds)
Calendar years
Item
2017
1
Overall production capacity
Production of:
SRC pipe and tube2
3
Other products
Total production using
same machinery or workers
2018
January‐March
2019
2019
2020
0
0
0
0
0
0
0
0
0
0
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of SRC pipe and tube will populate here once reported in question II‐7.
3
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
2
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐3c.
Page 10
Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
II‐4.
Product shifting.—
(a)
Is your firm able to switch production (capacity) between SRC pipe and tube and other
products using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
(b)
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.
Tolling.‐‐Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of SRC pipe and tube?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐6.
Page 11
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce SRC pipe and tube in and/or admit SRC
pipe and tube into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐Describe the nature of your firm’s operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import SRC pipe and tube into a foreign trade zone (FTZ) for use in distribution of SRC
pipe and tube and/or the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐7.
Page 12
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of SRC pipe and tube in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐7.
Page 13
Production, shipment, and inventory data.‐‐Continued
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
1
Average production capacity (quantity)
(A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
2
Value (G)
Transfers to related firms:
Quantity (H)
2
2
Value (I)
Export shipments:
Quantity (J)
3
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2017
0
2018
0
January‐March
2019
0
2019
2020
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
0
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐8.
Page 14
Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in 1,000 pounds)
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
Channels of distribution:
U.S. shipments:
To distributors for use in:
Plumbing applications (M)
Industrial applications (N)
All other applications (O)
To end users for use in:
Plumbing applications (P)
Industrial applications (Q)
1
1
All other applications (R)
1
Please describe these applications: .
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution (i.e.,
lines M through R) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O + P + Q + R – D – F – H =
zero ("0"), if not revise.
2017
2018
0
January‐March
2019
0
2019
0
0
2020
0
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐9.
Page 15
Employment data.‐‐Report your firm’s employment‐related data related to the production of
SRC pipe and tube and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to March periods, calculate similarly and divide by 3.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan‐Mar (Q1), Jan‐June (Q1+Q2), or Jan‐Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐10. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non‐market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 16
II‐11. Purchases.‐‐Has your firm purchased SRC pipe and tube produced in the United States or in
other countries since January 1, 2017? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in 1,000 pounds)
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
1
Purchases from U.S. importers of
SRC pipe and tube from—
Vietnam
All other sources
Purchases from domestic producers2
3
Purchases from other sources
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the U.S. producer(s) from which your firm purchased this product: .
3
Please list the name of the firm(s) from which your firm purchased this product: .
II‐12. Imports.‐‐Since January 1, 2017, has your firm imported SRC pipe and tube?
No
Yes
If yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II‐13. 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
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 17
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202‐205‐3247, [email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part III.
Name
Title
Email
Telephone
III‐2. Accounting system.—Please provide the following information on your firm’s financial
accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain
below:
Note.—Please report all financial data in part III on a calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include SRC pipe and tube:
2. Does your firm prepare profit/loss statements for SRC pipe and tube:
Yes
No
3. How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: U.S. GAAP, IFRS, cash, tax, or other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes SRC pipe and tube, as
well as specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
III‐4.
Page 18
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced SRC pipe and tube and provide the share of net sales accounted for by these products
in your firm’s most recent fiscal year.
Products
III‐6.
Share of sales
SRC pipe and tube
%
%
%
%
%
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of SRC pipe and tube from any related suppliers (e.g.,
inclusive of transactions between related firms, divisions and/or other components within the
same company)?
Yes‐‐Continue to question III‐7a
No—Skip to question III‐8a.
III‐7a. Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of SRC
pipe and tube that your firm purchases from related suppliers and that are reflected in question
III‐9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
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III‐7b. Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7a, are reported in III‐9a (financial results on SRC pipe and
tube) in a manner consistent with your firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a.
III‐8a. Scrap/by‐products.—Does your firm have any scrap or other by‐product sales revenue
associated with its SRC pipe and tube operations? If yes, identify the scrap/by‐product(s) in the
space below, and complete table III‐8b. If no, please continue to question III‐9a.
Yes No
III‐8b. Scrap/by‐product revenue.‐‐Report your firm’s total scrap/by‐product sales revenue associated
with the SRC pipe and tube operations of your U.S. establishment(s). Provide data for the three
most recently completed calendar years, and for the specified interim periods. Note: the data
provided below will appear in question III‐9a as a reduction to COGS.
Value (in $1,000)
Calendar years
Item
2017
1
Scrap/by‐product sales revenue
1
2018
January‐March
2019
2019
2020
Please describe how your firm classifies these scrap/by‐product revenues in the normal course of business
(e.g., included in net sales values, as a reduction to COGS, included in “all other income”).
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III‐9a. Operations on SRC pipe and tube.‐‐Report the revenue and related cost information requested
below on the SRC pipe and tube operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed calendar years, and for the specified interim periods.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
Total net sales values
0
0
0
0
0
Direct labor
Other factory costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
3
Cost of goods sold (COGS):
Raw materials
Less: scrap/by‐product revenue
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), operating income (or loss), and net
income (or loss)) have been calculated from the data submitted in the other line items. Do the
calculated fields return the correct data according to your firm's financial records ignoring non‐
material differences that may arise due to rounding?
Yes
No
If no‐‐If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative‐‐instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
III‐9c. Raw materials.‐‐Please report the share of total raw material costs in 2019 (reported in III‐9a)
for the following raw material inputs:
Procurement method
Input
Share of total raw
material costs
(percent)
Primarily
purchased by
your firm
Primarily
produced by
your firm
Cathode copper
Copper ingots
Copper scrap
1
Other material inputs
Total (should sum to 100 percent)
0.0
1
Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that they account for: .
III‐9d. Active management of copper costs.—Does your firm actively manage its metal costs (i.e., the
price of acquiring copper) used in the production of SRC pipe and tube?
Yes
No
If yes, please describe.
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III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III‐9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III‐9a; i.e., if an aggregate nonrecurring item has been allocated to question
III‐9a, only the allocated value amount included in question III‐9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III‐9a.
Calendar years
January‐March
Item
2017
2018
2019
2019
2020
Value (in $1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III‐9a where the nonrecurring item is classified.
Description of the
Income statement classification of the
nonrecurring item
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
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III‐12a. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of SRC pipe and tube. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for SRC pipe and
tube in the normal course of business, please estimate this information based upon a method
(such as production, sales, or costs) that is consistent with relevant cost allocations in question
III‐9a. Provide data as of the end of your firm’s three most recently completed calendar years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted. Total assets should be allocated to the subject products if these assets are also
related to other products.
Value (in $1,000)
Calendar years
Item
Total assets (net)
2017
2018
2019
III‐12b. Description of reported assets.‐‐ Please describe the main asset categories (both current and
long‐term assets) in the above response. Provide a brief explanation if there are any substantial
changes in total asset value during the period; e.g., due to asset write‐offs, revaluation, and
major purchases.
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III‐13a. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for SRC pipe and tube. Provide data for
the three requested calendar years, and for the specified interim periods.
Value (in $1,000)
Calendar years
Item
2017
2018
January‐March
2019
2019
Capital expenditures
Research and development
expenses
III‐13b. Description of reported capital expenditures.‐‐ Please describe the nature, focus, and
significance of your firm’s reported capital expenditures in the above response. If no capital
expenditure data were reported, please explain the reason.
III‐13c. Description of reported R&D expenses.‐‐ Please describe the nature, focus, and significance of
your firm’s reported R&D expenses in the response above. If no R&D expenses were reported,
please explain the reason.
2020
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III‐14. Data consistency and reconciliation.‐‐ Please note that we are requesting your firm’s financial
data for questions III‐9a, III‐12a, and III‐13a on a calendar year basis. Please confirm that your
firm reported these data on a calendar‐year basis:
Yes
No
If no, please explain.
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in Part II equal the quantities and values reported for total net sales in Part III of this
questionnaire in each time period. If the calculated fields below return values other than zero (i.e., “0”)
and both are being reported on a calendar basis, please explain the discrepancy below.
Calendar years
January‐March
Reconciliation
2017
Quantity: Trade data from question
II‐7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III‐9a, = zero ("0").
2018
0
2019
0
2019
0
Value: Trade data from question II‐7
(lines E, G, I, and K) less financial
total net sales value data from
question III‐9a, = zero ("0").
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
2020
0
0
0
0
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III‐15. Effects of imports on investment.‐‐Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of SRC pipe and tube from Vietnam?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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III‐16. Effects of imports on growth and development.‐‐Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of SRC pipe and tube from Vietnam?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
SRC pipe and tube from Vietnam?
No
Yes
If yes, my firm anticipates negative effects as follows.
III‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (202‐205‐2049,
[email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in Part IV.
Name
Title
Email
Telephone
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products produced by your
firm.
Product 1.‐‐ Seamless refined copper pipe and tube, 3/8" OD, ACR/RST Coil, 50' Length.
Product 2.‐‐ Seamless refined copper pipe and tube, 3/4" OD, ACR/RST Coil, 50' Length.
Product 3.‐‐ Seamless refined copper pipe and tube, 3/8" OD, Inner‐Grooved LWC, 0.0110" ‐
0.0144" bottom wall thickness.
Product 4.— Seamless refined copper pipe and tube, 3/8" OD, Smooth Bore LWC, 0.0249"‐
0.0327" bottom wall thickness.
Product 5.— Seamless refined copper pipe and tube, 3/4" OD, Smooth Bore LWC, 0.0327"‐
0.0430" bottom wall thickness.
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV‐2a. During January 2017‐March 2020, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data tables as appropriate.
No.‐‐Skip to question IV‐3.
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IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pieces (products 1‐2) and pounds (products 3‐5) and actual dollars (not 1,000s).
(Quantity in pieces, value in dollars)
Product 1
Product 2
Quantity
Quantity
(pieces)
Value
(pieces)
Value
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
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b.
your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
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IV‐2b. Price data.—(continued) Report below the quarterly price data1 for pricing products2 produced
and sold by your firm.
Report data in pieces (products 1‐2) and pounds (products 3‐5) and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 3
Product 4
Product 5
Quantity
Quantity
Quantity
(pounds)
Value
(pounds)
Value
(pounds)
Value
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
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 3:
Product 4:
Product 5:
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IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
Quantities for products 1‐2 are reported in pieces?
Quantities for products 3‐5 are reported in pounds (not 1,000s of pounds)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Quantities do not exceed commercial shipments in question II‐7 in each year?
IV‐2d. 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.
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IV‐3.
Page 32
Price setting.‐‐How does your firm determine the prices that it charges for sales of SRC pipe and
tube (check all that apply)? If your firm issues price lists, please submit sample pages of a recent
list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic SRC pipe and tube usually
quoted (check one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced SRC
pipe and tube 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
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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Page 33
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced SRC pipe and tube (or check “not applicable” if your firm does not sell on a short‐
term, annual and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
IV‐8.
Lead times.‐‐What share of your firm’s sales is from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.‐produced SRC pipe and tube?
Lead time (Average
Source
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
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U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
IV‐9.
Page 34
Shipping information.‐‐
(a)
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of SRC pipe and tube that are
delivered the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced SRC pipe and tube since January 1, 2017 (check all that apply)?
Geographic area
√ if applicable
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
IV‐11. Inland transportation costs.—What is the approximate percentage of the cost of U.S.‐produced
SRC pipe and tube that is accounted for by U.S. inland transportation costs? percent
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IV‐12. End uses.‐‐List the end uses of the SRC pipe and tube that your firm manufactures. For each
end‐use product, what percentage of the total cost is accounted for by SRC pipe and tube and
other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
End‐use product
SRC pipe and tube
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐13. Substitutes.‐‐Can other products be substituted for SRC pipe and tube?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for SRC pipe and tube?
No Yes
Explanation
1.
2.
3.
IV‐14. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for SRC pipe and tube has changed since January 1, 2017. Explain any trends
and describe the principal factors that have affected these changes in demand.
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Market
Explanation and factors
Within the United States
Outside the United States
IV‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of SRC pipe and tube since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
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IV‐16. Conditions of competition.‐‐
(a) Is the SRC pipe and tube market subject to business cycles (other than general economy‐
wide conditions) and/or other conditions of competition distinctive to SRC pipe and tube?
If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
SRC pipe and tube since January 1, 2017?
No
Yes
If yes, describe.
IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply SRC pipe and
tube since January 1, 2017 (examples include placing customers on allocation or “controlled
order entry,” declining to accept new customers or renew existing customers, delivering less
than the quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐18. Raw materials.‐‐How have SRC pipe and tube raw material prices changed since January 1,
2017?
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for SRC
pipe and tube.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 37
IV‐19. Interchangeability.‐‐Is SRC pipe and tube 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
United States
Vietnam
Vietnam
Other countries
For any country‐pair producing SRC pipe and tube that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that limit or preclude
interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 38
IV‐20. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between SRC pipe and tube
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
United States
Vietnam
Vietnam
Other countries
For any country‐pair for which factors other than price always or frequently are a
significant factor in your firm’s sales of SRC pipe and tube, identify the country‐pair
and report the advantages or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 39
IV‐21. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for SRC pipe and tube since January 1, 2017. Indicate the share of the quantity of
your firm’s total shipments of SRC pipe and tube that each of these customers accounted for in
2019.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2019
sales
(%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 40
IV‐22. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2017: To avoid losing sales to competitors selling SRC
pipe and tube from Vietnam, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2017: Did your firm lose sales of SRC pipe and tube to
imports of this product from Vietnam?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: SCRP)
IV‐23. Other explanations.‐‐If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 41
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/seamless_refined_copper_pipe_an
d_tube_vietnam/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: SCRP
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). 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 | Microsoft Word - US producers--Copper Tube (P) |
| Author | jordan.harriman |
| File Modified | 2020-07-01 |
| File Created | 2020-07-01 |