20-2-4278 U.S. importers' questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

US importers--Silicon metal (P)

Silicon metal from Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia (Inv. nos. 701-TA-652 and 731-TA-1524-1526) Prelim

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

2023-04-18 - Extension without change of a currently approved collection

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OMB No. 3117-0016/USITC No. 20-2-4278; Expiration Date: 6/30/2023
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U.S. IMPORTERS’ QUESTIONNAIRE
SILICON METAL FROM BOSNIA-HERZEGOVINA,
ICELAND, KAZAKHSTAN, AND MALAYSIA
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 countervailing duty investigation concerning silicon metal from Kazakhstan and the antidumping
duty investigations concerning silicon metal from Bosnia-Herzegovina, Iceland, and Malaysia (Inv. Nos. 701-TA-652 and
731-TA-1524-1526 (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 silicon metal (as defined on next page) from any country at any time since January 1,
2017?

(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: BIKM)
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

Signature

Title of Authorized Official

Phone

Date

Email address

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 30, 2020, by Globe
Specialty Metals, Inc., Beverly, Ohio, and Mississippi Silicon LLC, Burnsville, Mississippi.
Countervailing/antidumping duties may be assessed on the subject imports as a result of these
proceedings if the Commission makes an affirmative determination of injury, threat, or material
retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative
determination of subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available at
https://www.usitc.gov/investigations/701731/2020/silicon_metal_bosnia_iceland_kazakhstan_and/prel
iminary.htm.
Silicon metal covered by these investigations is all forms and sizes of silicon metal, including silicon
metal powder. Silicon metal contains at least 85.00 percent but less than 99.99 percent silicon, and less
than 4.00 percent iron, by actual weight. Semiconductor grade silicon (merchandise containing at least
99.99 percent silicon by actual weight and classifiable under Harmonized Tariff Schedule of the United
States (HTSUS) statistical reporting number 2804.61.0000) is excluded from the scope of this
investigation.
Silicon metal is currently classifiable under statistical reporting numbers 2804.69.1000 and 2804.69.5000
of the HTSUS. While the HTSUS numbers are provided for convenience and customs purposes, the
written description of the scope remains dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing silicon metal (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

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)

Page 3

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
Lawrence Jones (202-205-3358, [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
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled 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

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.
I-2a.

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 silicon metal, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)

Page 4

I-2b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-2c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):

I-3.

Ownership.--Is your firm owned, in whole or in part, by any other firm?
No

Firm name

I-4.

Yes--List the following information, relating to the ultimate parent/owner.

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing silicon metal from Bosnia-Herzegovina, Iceland,
Kazakhstan, and Malaysia into the United States or that are engaged in exporting silicon metal
from Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
I-5.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of silicon metal?
No

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations of silicon
metal. More than one answer may be applicable.
Importer of record

I-7.

Page 5

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 silicon metal 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 - Silicon Metal (Preliminary)
I-8.

Page 6

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters silicon metal into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports silicon metal 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

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond
I-9.

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 - Silicon Metal (Preliminary)

Page 7

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [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 silicon metal since January 1, 2017.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-3a.

Page 8

Arranged imports.--Has your firm imported or arranged for the importation of silicon metal 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 short tons of contained silicon)
Bosnia-Herzegovina
Iceland
Kazakhstan
Malaysia
All other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported silicon metal
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 short tons of contained silicon)
Source

June 2019 through May 2020

Bosnia-Herzegovina
Iceland
Kazakhstan
Malaysia
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces silicon metal 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 - Silicon Metal (Preliminary)

Page 9

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).
“Admissions into FTZs” -- Note that any firm that “admits” silicon metal into a Free Trade Zone
(FTZ), processes those imports of silicon metal into a downstream product, and then classifies
those goods as the downstream product for purposes of clearance through Customs (i.e.,
“imports for consumption”), should report its “admissions” into its FTZ as imports in this
questionnaire, and its use of those admissions/imports as “internal consumption”.
“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.

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-5a.

Page 10

U.S. imports from Bosnia-Herzegovina.–Report your firm’s imports and your firm’s shipments
and inventories of silicon metal imported from Bosnia-Herzegovina by your firm during the
specified periods.

Bosnia-Herzegovina
Quantity (in short tons of contained silicon), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
Imports/FTZ admissions:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
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 - Silicon Metal (Preliminary)
II-5a.

Page 11

U.S. imports from Bosnia-Herzegovina.–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
Reconciliation

2017

January-March

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

2019
0

2020
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-5b.

Channels of distribution: Bosnia-Herzegovina. --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 Bosnia-Herzegovina by channel of distribution during the specified periods.

Bosnia-Herzegovina
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Quantity (in short tons of contained silicon)
Channels of distribution:
U.S. shipments:
To distributors (M)
To polysilicon and chemical
producers (N)
To primary aluminum producers
(O)
To secondary aluminum
producers (P)
To all other end users (Q)1
1

Identify other end users

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, O, P, and Q) 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 item
M + N + O + P + Q – D – F – H = zero
("0"), if not revise.

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-5c.

Page 12

U.S. shipments by product type: Bosnia-Herzegovina.--Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers tor related firms) of
imports from Bosnia-Herzegovina by product type during 2019.

Bosnia-Herzegovina

High purity grade silicon metal.--Silicon metal with a silicon (Si) content greater than or equal to 99.1,
iron (Fe) content less than or equal to 0.30, aluminum (Al) content less than or equal to 0.30, calcium
(Ca) content less than or equal to 0.05, titanium (Ti) content less than or equal to 0.05, and a carbon (C)
content less than or equal to 0.15.
Metallurgical grade silicon metal.--Silicon metal that does not met the definition of high purity grade
silicon metal (defined above).

Item

Quantity (in short tons contained silicon),
value (in 1,000 dollars)
Calendar year 2019

U.S. shipments.-High purity grade silicon metal.-Quantity (R)
Value (S)
Metallurgical grade silicon metal.-Quantity (T)
Value (U)
RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities and values reported for shipments
by form (i.e., lines R thru U) in each time period equal the quantities and values reported for U.S.
shipments from part “a” of this question (i.e., lines D through I) 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.

Reconciliation item

Calendar year
2019

Quantity reconcile: R + T – D – F - H = zero ("0"), if
not revise.

Value reconcile: S + U – E – G – I = zero ("0"), if
not revise.

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-6a.

Page 13

U.S. imports from Iceland.–Report your firm’s imports and your firm’s shipments and
inventories of silicon metal imported from Iceland by your firm during the specified periods.

Iceland
Quantity (in short tons of contained silicon), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-6a.

Page 14

U.S. imports from Iceland.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-March
2019

2019
0

2020
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-6b.

Channels of distribution: Iceland. --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 Iceland by channel of distribution during the specified periods.

Iceland
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Identify other end users

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-6c.

Page 15

U.S. shipments by product type: Iceland.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers tor related firms) of imports
from Iceland by product type during 2019.

Iceland

Item

Quantity (in short tons contained silicon),
value (in 1,000 dollars)
Calendar year 2019

Reconciliation item

Calendar year
2019

Quantity reconcile: R + T – D – F - H = zero ("0"), if
not revise.

Value reconcile: S + U – E – G – I = zero ("0"), if
not revise.

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-7a.

Page 16

U.S. imports from Kazakhstan.–Report your firm’s imports and your firm’s shipments and
inventories of silicon metal imported from Kazakhstan by your firm during the specified periods.

Kazakhstan
Quantity (in short tons of contained silicon), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-7a.

Page 17

U.S. imports from Kazakhstan.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-March
2019

2019
0

2020
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-7b.

Channels of distribution: Kazakhstan. --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 Kazakhstan by channel of distribution during the specified periods.

Kazakhstan
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Identify other end users

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-7c.

Page 18

U.S. shipments by product type: Kazakhstan.--Report your firm’s U.S. shipments (i.e., inclusive
of commercial U.S. shipments, internal consumption, and transfers tor related firms) of imports
from Kazakhstan by product type during 2019.

Kazakhstan

Item

Quantity (in short tons contained silicon),
value (in 1,000 dollars)
Calendar year 2019

Reconciliation item

Calendar year
2019

Quantity reconcile: R + T – D – F - H = zero ("0"), if
not revise.

Value reconcile: S + U – E – G – I = zero ("0"), if
not revise.

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-8a.

Page 19

U.S. imports from Malaysia.–Report your firm’s imports and your firm’s shipments and
inventories of silicon metal imported from Malaysia by your firm during the specified periods.

Malaysia
Quantity (in short tons of contained silicon), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-8a.

Page 20

U.S. imports from Malaysia.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-March
2019

2019
0

2020
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-8b.

Channels of distribution: Malaysia. --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 Malaysia by channel of distribution during the specified periods.

Malaysia
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Identify other end users

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire - Silicon Metal (Preliminary)
II-8c.

Page 21

U.S. shipments by product type: Malaysia.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers tor related firms) of imports
from Malaysia by product type during 2019.

Malaysia

Item

Quantity (in short tons contained silicon),
value (in 1,000 dollars)
Calendar year 2019

Reconciliation item

Calendar year
2019

Quantity reconcile: R + T – D – F - H = zero ("0"), if
not revise.

Value reconcile: S + U – E – G – I = zero ("0"), if
not revise.

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II-9a.

Page 22

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of silicon metal imported from all other sources by your firm during the specified
periods.

All other sources
(list sources:

)

Quantity (in short tons of contained silicon), value (in $1,000)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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II-9a.

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Imports from all other sources.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-March
2019

2019
0

2020
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
II-9b.

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
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Identify other end users

2017

2018
0

January-March
2019

2019
0

2020
0

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II-9c.

Page 24

U.S. shipments by product type: all other sources.--Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers tor related firms) of
imports from all other sources by product type during 2019.

All other sources

Item

Quantity (in short tons contained silicon),
value (in 1,000 dollars)
Calendar year 2019

Reconciliation item

Calendar year
2019

Quantity reconcile: R + T – D – F - H = zero ("0"), if
not revise.

Value reconcile: S + U – E – G – I = zero ("0"), if
not revise.

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II-10.

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-11.

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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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, [email protected]).
III-1.

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 Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia:
Product 1.-- Sold to primary aluminum producers; silicon metal less than 99.99% pure that
contains a minimum of 98.5% silicon, a maximum of 1.00% iron, a maximum of
0.07% calcium, and no restriction of the aluminum content.
Product 2.-- Sold to secondary aluminum producers; silicon metal less than 99.99% pure that
contains a minimum of 97.0% silicon, a maximum of 2.00% iron, a maximum of
0.4% calcium, and no restriction of the aluminum content.
Product 3.-- Sold to chemical and/or polysilicon manufacturers; silicon metal less than 99.99%
pure that contains a minimum of 98.0% silicon, a maximum of 1.50% iron, a
maximum of 0.2% calcium, and a maximum of 0.4% aluminum.

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).
During January 2017-March 2020, did your firm import from Bosnia-Herzegovina, Iceland,
Kazakhstan, and Malaysia 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 III-3.

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III-2a. Price data.--Report below the quarterly price data1 for pricing products2 imported from BosniaHerzegovina and sold by your firm.

Bosnia-Herzegovina

Report data in short tons of contained silicon and actual dollars (not 1,000s).
(Quantity in short tons of contained silicon, value in dollars)
Product 1
Product 2
Product 3
Period of shipment Quantity
Value
Quantity
Value
Quantity
Value
2017:
January-March
April-June
July-September
OctoberDecember
2018:
January-March
April-June
July-September
OctoberDecember
2019:
January-March
April-June
July-September
OctoberDecember
2020:
January-March
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.
1

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:
Product 3:

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III-2b. Price data.--Report below the quarterly price data1 for pricing products2 imported from Iceland
and sold by your firm.

Iceland

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III-2c.

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Price data.--Report below the quarterly price data1 for pricing products2 imported from
Kazakhstan and sold by your firm.

Kazakhstan

Report data in short tons of contained silicon and actual dollars (not 1,000s).

Period of shipment
2017:
January-March
April-June
July-September
OctoberDecember
2018:
January-March
April-June
July-September
OctoberDecember
2019:
January-March
April-June
July-September
OctoberDecember
2020:
January-March

(Quantity in short tons of contained silicon, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
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.

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III-2d. Price data.--Report below the quarterly price data1 for pricing products2 imported from Malaysia
and sold by your firm.

Malaysia

Report data in short tons of contained silicon and actual dollars (not 1,000s).

(Quantity in short tons of contained silicon, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

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III-2e.

Page 31

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) and short tons of contained silicon?
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-2f.

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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III-3.

Price setting.--How does your firm determine the prices that it charges for sales of silicon metal
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction

III-4.

Contracts

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported silicon metal from BosniaHerzegovina, Iceland, Kazakhstan, and Malaysia usually quoted (check one)?
Delivered

III-6.

Set
price
lists

Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).

Quantity
discounts

III-5.

Page 32

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of silicon metal imported
from Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia 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

Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

Short-term
contracts
(multiple
deliveries for
less than 12
months)
%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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III-7.

Page 33

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
silicon metal imported from Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia (or check
“not applicable” if your firm does not sell on a short-term, annual and/or long-term contract
basis).
Short-term contracts
(multiple deliveries
for less than 12
months)

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

Annual contracts
(multiple
deliveries for 12
months)

Long-term contracts
(multiple deliveries
for more than 12
months)

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

III-8.

Lead times.--What is your firm’s share of sales of silicon metal imported from BosniaHerzegovina, Iceland, Kazakhstan, and Malaysia 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 silicon metal?

Source

Lead time
(Average number
Share of 2019 sales
of days)

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

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III-9.

Page 34

Shipping information.—
(a)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(b)

When your firm sells silicon metal imported from Bosnia-Herzegovina, Iceland,
Kazakhstan, and Malaysia, from where is it shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of silicon metal imported from
Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia 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

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 silicon
metal imported from subject countries since January 1, 2017 (check all that apply)?

Geographic area

BosniaHerzegovina Iceland Kazakhstan Malaysia

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 silicon metal
imported from Bosnia-Herzegovina, Iceland, Kazakhstan, and Malaysia that is accounted for by
U.S. inland transportation costs?
percent.

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Page 35

III-12. End uses.--List the end uses of the silicon metal that your firm imports. For each end-use
product, what percentage of the total cost is accounted for by silicon metal and other inputs?
Share of total cost of end-use product
accounted for by
End-use product

Silicon metal

Other inputs

Total
(should sum to
100.0% across)

0.0 %

III-13. Substitutes.--Can other products be substituted for silicon metal?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for silicon metal?
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 silicon metal has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand.

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

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III-15. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of silicon metal since January 1, 2017?
No

Yes

If yes, please describe.

III-16. Conditions of competition.—
(a) Is the silicon metal market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to silicon metal?
Check all that apply.

Please describe.

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
silicon metal since January 1, 2017?
No

Yes

If yes, describe.

III-17. Supply constraints.--Has your firm refused, declined, or been unable to supply silicon metal
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.

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Page 37

III-18. Raw materials.--How have silicon metal 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 silicon
metal.

III-19. Interchangeability.--Is silicon metal 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

BosniaHerzegovina

Iceland

Kazakhstan

Malaysia

Other countries

United States
BosniaHerzegovina
Iceland
Kazakhstan
Malaysia
For any country-pair producing silicon metal that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

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III-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between silicon metal 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

BosniaHerzegovina

Iceland

Kazakhstan

Malaysia

Other countries

United States
BosniaHerzegovina
Iceland
Kazakhstan
Malaysia
For any country-pair for which factors other than price always or frequently are a significant factor
in your firm’s sales of silicon metal, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

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Page 39

III-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for silicon metal since January 1, 2017. Indicate the share of the quantity of your
firm’s total shipments of silicon metal that each of these customers accounted for in 2019.

Customer’s name

Contact person

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.

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Page 40

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.

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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/silicon_metal_bosnia_iceland_kaza
khstan_and/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: BIKM

• 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 (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	Microsoft Word - US importers--Silicon metal (P)
Author	lawrence.jones
File Modified	2020-07-02
File Created	2020-07-02