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pdfOMB No. 3117‐0016/USITC No. 20‐2‐4274; Expiration Date: 6/30/2023
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U.S. IMPORTERS’ 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 imported SRC pipe and tube (as defined on next page) from any country 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
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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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
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This definition excludes all seamless circular hollows of refined copper less than 12 inches in length
whose OD (actual) exceeds its length.
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.
Importer.‐‐Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing SRC pipe and tube (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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 Jordan
Harriman (202‐205‐2610, [email protected]).
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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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‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
I‐2a.
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”‐‐Each facility of a firm involved in the importation of SRC pipe and tube,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
I‐2b.
I‐2c.
Page 5
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.
I‐4.
Law firm:
Lead attorney(s):
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
Firm name
Country
(percent)
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.
Firm name
Country
Affiliation
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
I‐5.
I‐6.
Page 6
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
Importing operations.‐‐Please indicate the nature of your firm’s importing operations of SRC
pipe and tube. More than one answer may be applicable.
Importer of record
I‐7.
Takes title to the
imported product(s)
Consignee of the
imported products(s)
Customs broker or
freight forwarder
Consignee.‐‐If your firm is an importer of record of SRC pipe and tube but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).
Firm name
Address
Contact person
and phone
number
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
I‐8.
Page 7
FTZ, TIB, or bonded warehouses.‐‐Please indicate whether your firm enters SRC pipe and tube
into, or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also
indicate whether your firm imports SRC pipe and tube under the TIB (temporary importation
under bond) program.
“Foreign trade zone” is a designated location in the United States where firms utilize special
procedures that allow delayed or reduced customs duty payments on foreign merchandise, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re‐export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item
I‐9.
No
Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond
Other trade actions.‐‐To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No
Yes
If yes, Yes–Please specify.
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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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 importation of SRC pipe and tube since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
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II‐3a. Arranged imports.‐‐Has your firm imported or arranged for the importation of SRC pipe and
tube for delivery after March 31, 2020?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No
Yes
If yes, fill out the table below.
Period
Source
Apr‐Jun 2020
Jul‐Sept 2020
Oct‐Dec 2020
Jan‐Mar 2021
Quantity (in 1,000 pounds)
Vietnam
All other sources
II‐3b. Imports in the 12 month period preceding the petition.‐‐Has your firm imported SRC pipe and
tube from any source between June 1, 2019 and May 31, 2020? (i.e., the last seven months in
2019 and first five months in 2020 combined)
No
Yes
If yes, report the quantity of such import below by source.
Quantity (in 1,000 pounds)
Source
Vietnam
All other sources
II‐4.
June 2019 through May 2020
Reasons for importing if producer.‐‐If your firm also produces SRC pipe and tube in the United
States, please indicate the reasons for importing this product. If your firm’s reasons differ by
source, please elaborate.
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“Commercial U.S. shipments”— Shipments made within the United States as a result of an
arm’s length commercial transaction in the ordinary course of business. Report net values (i.e.,
gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods) in U.S. dollars, f.o.b. your point of shipment.
“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. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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II‐5a. U.S. imports from Vietnam.–Report your firm’s imports and your firm’s shipments and
inventories of SRC pipe and tube imported from Vietnam by your firm during the specified
periods.
Vietnam
Quantity (in 1,000 pounds), value (in $1,000)
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
Beginning‐of‐period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
2
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
2
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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II‐5a. U.S. imports from Vietnam.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
January‐March
Reconciliation
2017
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2018
0
2019
0
0
2019
2020
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐5b. Channels of distribution: Vietnam.‐‐Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Vietnam by channel of distribution during the specified periods.
Vietnam
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
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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II‐6a. Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of SRC pipe and tube imported from all other sources by your firm during the
specified periods.
All other sources
(list sources:
)
Quantity (in 1,000 pounds), value (in $1,000)
Calendar years
Item
2017
Beginning‐of‐period inventories
(quantity) (A)
2018
January‐March
2019
2019
2020
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
Value2 (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
Export shipments:3
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
2
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
2
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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II‐6a. Imports from all other sources.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
January‐March
Reconciliation
2017
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2018
0
2019
0
0
2019
2020
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐6b. Channels of distribution: All other sources.‐‐Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution during the specified periods.
All other sources
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
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
II‐7.
Page 15
Transfers to related firms.‐‐If your firm reported transfers to related firms in any of the data
tables in part II, please identify the firm(s) and indicate the nature of the relationship between
your firm and the related firms (e.g., joint venture, wholly owned subsidiary) and whether the
transfers were priced at market value or by a non‐market formula.
II‐8.
Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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PART III.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (202‐205‐2049,
[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
PRICE DATA
III‐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 your firm imported
from Vietnam:
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).
III‐2a. During January 2017‐March 2020, did your firm import from Vietnam 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 table(s) as appropriate.
No.‐‐Skip to question III‐3.
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
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III‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 imported from Vietnam
and sold by your firm.
Vietnam
Report data in pieces (products 1‐2) and pounds (products 3‐5) and actual dollars (not 1,000s).
Period of shipment
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
April‐June
July‐September
October‐December
2020:
January‐March
(Quantity in pieces, value in dollars)
Product 1
Product 2
Quantity
Quantity
(pieces)
Value
(pieces)
Value
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 III.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 18
III‐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 III.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 3:
Product 4:
Product 5:
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 19
III‐2b. Price data checklist.‐‐Please check that the pricing data in question III‐2(a) 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?
III‐2c. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
III‐3.
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
III‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
III‐5.
Page 20
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of imported SRC pipe and tube from
Vietnam usually quoted (check one)?
Delivered
F.o.b.
III‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of SRC pipe and tube
imported from Vietnam 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
%
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
III‐7.
Page 21
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
SRC pipe and tube imported from Vietnam (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: .
III‐8.
Lead times.‐‐What is your firm’s share of sales of SRC pipe and tube imported from Vietnam
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 SRC pipe and tube?
Lead time
(Average number
of days)
Source
Share of 2019 sales
From your firm’s U.S. inventory
%
From foreign manufacturers’ inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
III‐9.
Page 22
Shipping information.—
(a)
(b)
(c)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
When your firm sells SRC pipe and tube imported from Vietnam, from where is it
shipped?
Point of importation Storage facility (check one)
Indicate the approximate percentage of your firm’s sales of SRC pipe and tube imported
from Vietnam that are delivered the following distances from your firm’s U.S. point of
shipment.
Distance from your firm’s U.S. point of shipment
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
III‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold SRC pipe
and tube imported from subject countries since January 1, 2017 (check all that apply)?
Geographic area
Vietnam
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.
III‐11. Inland transportation costs.—What is the approximate percentage of the cost of SRC pipe and
tube imported from Vietnam that is accounted for by U.S. inland transportation costs?
percent.
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 23
III‐12. End uses.‐‐List the end uses of the SRC pipe and tube that your firm imports. 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 %
III‐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.
III‐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.
Overall
No
Overall Fluctuate with
increase change decrease no clear trend
Market
Explanation and factors
Within the United States
Outside the United States
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U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 24
III‐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.
III‐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?
Check all that apply.
Please describe.
No
Skip to question III‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
SRC pipe and tube since January 1, 2017?
No
Yes
If yes, describe.
III‐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.
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 25
III‐18. Raw materials.‐‐How have SRC pipe and tube raw material prices changed since January 1,
2017?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for SRC
pipe and tube.
III‐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. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 26
III‐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. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 27
III‐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
III‐22. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 28
Correcting Valid number error messages.‐‐If you are completing a Commission questionnaire in a
country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would appear as
$1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than 999 in
numeric form fields. This issues stem from your computer number formatting setting (e.g., not the MS
Word document itself, but the computer from which you are opening up the document). In the United
States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one. Many EU
countries use the reverse where multiples of 1000 are delineated with periods (.) and fractions less than
one are delineated with commas (,). The U.S. International Trade Commission’s questionnaires are set‐
up in the United States with the U.S. number formatting. When this formatting interacts with a
computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)
When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.
Business Proprietary
U.S. Importers’ Questionnaire – SRC Pipe and Tube (Preliminary)
Page 29
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: SRCP
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (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 importers--Copper Tube (P) |
Author | jordan.harriman |
File Modified | 2020-07-01 |
File Created | 2020-07-01 |