Form 20-1-4253 U.S. producers' questionnaire

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

US producers--NOES (R1)

Non-oriented electrical steel (NOES) from China, Germany, Japan, Korea, Sweden, and Taiwan (Inv. nos. 701-TA-506 and 508 and 731-TA-1238-1243) Review 1

OMB: 3117-0016

Document [pdf]
Download: pdf | pdf
OMB No. 3117-0016/USITC No. 20-1-4253; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
NON-ORIENTED ELECTRICAL STEEL FROM
CHINA, GERMANY, JAPAN, KOREA, SWEDEN, AND TAIWAN
This questionnaire must be received by the Commission by August 10, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its reviews of the countervailing duty orders concerning non-oriented electrical steel (“NOES”) from
China and Taiwan and the antidumping duty orders concerning NOES from China, Germany, Japan, Korea, Sweden, and
Taiwan (Inv. Nos. 701-TA-506 and 508 and 731-TA-1238-1243 (Review)). The information requested in the questionnaire
is requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as
directed can result in a subpoena or other order to compel the submission of records or information in your firm’s
possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced NOES (as defined on the next page) at any time since January 1, 2014?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: NOES)

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 or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Signature

Phone

Email address

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 2

PART I.—GENERAL INFORMATION
Background.--On December 3, 2014, the Department of Commerce (“Commerce”) issued countervailing
duty orders on imports of NOES from China and Taiwan. Also on December 3, 2014 Commerce issued
antidumping duty orders on imports of NOES from China, Germany, Japan, Korea, Sweden, and Taiwan.
On November 1, 2019, the Commission instituted reviews pursuant to section 751(c) of the Tariff Act of
1930 (19 U.S.C. § 1675(c)) (the Act) to determine whether revocation of the orders would be likely to
lead to continuation or recurrence of material injury to the domestic industry within a reasonably
foreseeable time. If both the Commission and Commerce make an affirmative determination, the orders
will remain in place. If either the Commission or Commerce makes a negative determination, Commerce
will revoke the orders. Questionnaires and other information pertinent to this proceeding are available
at
https://www.usitc.gov/investigations/701731/2019/non_oriented_electrical_steel_china_germany_jap
an/first_review_full.htm.
NOES covered by these investigations includes cold-rolled, flat-rolled, alloy steel products, whether or
not in coils, regardless of width, having an actual thickness of 0.20 mm or more, in which the core loss is
substantially equal in any direction of magnetization in the plane of the material. The term
‘‘substantially equal’’ means that the cross grain direction of core loss is no more than 1.5 times the
straight grain direction (i.e., the rolling direction) of core loss. NOES has a magnetic permeability that
does not exceed 1.65 Tesla when tested at a field of 800 A/m (equivalent to 10 Oersteds) along (i.e.,
parallel to) the rolling direction of the sheet (i.e., B800 value). NOES contains by weight more than 1.00
percent of silicon but less than 3.5 percent of silicon, not more than 0.08 percent of carbon, and not
more than 1.5 percent of aluminum. NOES has a surface oxide coating, to which an insulation coating
may be applied.
NOES is subject to the Order whether it is fully processed (i.e., fully annealed to develop final magnetic
properties) or semi-processed (i.e., finished to final thickness and physical form but not fully annealed to
develop final magnetic properties). Fully processed NOES is typically made to the requirements of ASTM
specification A 677, Japanese Industrial Standards (JIS) specification C 2552, and/or International
Electrotechnical Commission (IEC) specification 60404–8–4. Semiprocessed NOES is typically made to
the requirements of ASTM specification A 683. However, the scope of the Order is not limited to
merchandise meeting the ASTM, JIS, and IEC specifications noted immediately above.
NOES is sometimes referred to as cold-rolled non-oriented (CRNO), nongrain oriented (NGO), nonoriented (NO), or cold-rolled non-grain oriented (CRNGO) electrical steel. These terms are
interchangeable.
Excluded from the scope of the Order are flat-rolled products not in coils that, prior to importation into
the United States, have been cut to a shape and undergone all punching, coating, or other operations
necessary for classification in Chapter 85 of the Harmonized Tariff Schedule of the United States (HTSUS)
as a part (i.e., lamination) for use in a device such as a motor, generator, or transformer.
NOES is currently imported under statistical reporting numbers 7225.19.0000, 7226.19.1000, and
7226.19.9000 of the Harmonized Tariff Schedule of the United States (HTSUS). It may also be entered
under HTSUS statistical reporting numbers 7225.50.8085, 7225.99.0090, 7226.92.5000, 7226.92.7050,
7226.92.8050, 7226.99.0180 of the HTSUS. The HTSUS provisions are for convenience and customs
purposes; the written description of the scope is dispositive.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 3

Reporting of information.--If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 4

D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a 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
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
I-2a.

Page 5

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of NOES, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
Covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

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.

Position regarding continuation of order.--Does your firm support or oppose continuation of
the following antidumping and countervailing duty orders currently in place for NOES?
Country
China

Order type
Antidumping duty
Countervailing duty

Germany

Antidumping duty

Japan

Antidumping duty

Korea

Antidumping duty

Sweden

Antidumping duty

Taiwan

Antidumping duty
Countervailing duty

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
I-4.

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

Firm name

I-5.

Page 6

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 NOES into the United States or that are engaged in
exporting NOES to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
I-6.

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

Yes--List the following information.

Firm name

I-7.

Page 7

Country

Affiliation

Business plan.--In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for NOES?

No

Yes

If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 8

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Julie Duffy (202-708-2579,
[email protected]). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone

II-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of NOES since January 1, 2014.

Check as many as appropriate.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)

If checked, please describe; leave blank if not
applicable.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II -2b

Page 9

Anticipated changes in operations.—Does your firm anticipate any changes in the character of
its operations or organization relating to the production of NOES in the future?

No

Yes

If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions, along with relevant
portions of business plans or other supporting documentations that
address this issue.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-3a.

Page 10

Production using same machinery.-- Please report your firm’s production of products made
using the same equipment, machinery, or employees as used to produce NOES, and the
combined production capacity on this shared equipment, machinery, or employees in the
periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-4. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-4 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in short tons)
Calendar years

Item

2014

2015

2016

January-June

2017

2018

2019

2019

2020

Overall production
capacity1
Production of:
NOES2

0

0

0

0

0

0

0

0

Subtotal, out-ofscope production

0

0

0

0

0

0

0

0

Total
production
using same
machinery or
workers

0

0

0

0

0

0

0

0

Out-of-scope
production.-Grain-oriented
electrical steel
Cold-rolled
magnetic
lamination steel
Other products3

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of NOES will populate here once reported in question II-4.
3
Please identify these products:
.
1
2

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-3b.

Page 11

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

Weeks per year

II-3c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.

II-3d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-3e.

Product shifting.—
(i)

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

No

(ii)

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products:

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-4.

Page 12

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of NOES in its U.S. establishment(s) during the
specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-4.

Page 13

Production, shipment, and inventory data. --Continued
Quantity (in short tons) and value (in $1,000)
Calendar year
Item

2014

2015

2016

2017

January-June
2018

2019

2019

2020

Average production
capacity1 (Quantity) (A)
Beginning-of-period
inventories (Quantity) (B)
Production (Quantity) (C)
U.S. shipments:
Commercial
shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value (G)
Transfers to related
firms:2
Quantity (H)
Value (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories
(Quantity) (L)
1 The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity (use additional pages as necessary).
.

Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a different
basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide the data
above at fair market value).
2

3

Identify your firm’s principal export markets:

.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-4.

Page 14

Production, shipment, and inventory data.--Continued

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
B+C–D–F–H–J–L
= should equal zero
("0") or provide an
explanation.1

2014

2015

0

2016

0

January-June

2017

0

2018

0

2019

0

2019

0

2020

0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
1

0

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-5.

Page 15

Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
“Stampers/laminators” – a firm that stamps and/or laminates NOES and does not further
fabricate the part before selling it to another firm. Other end uses may stamp or laminate NOES
for use in their own production of other products.
“End users” –includes motor producers.
Quantity (in short tons)
Calendar year

Item

2014

2015

2016

January-June

2017

2018

2019

2019

2020

Channels of distribution:
U.S. shipments.-to Distributors/
slitters (M)
to Stampers/
laminators (N)
to End users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for U.S shipments (i.e., lines D, F,
and 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 year
Reconciliation item
M+N+O–D–F–H=
zero ("0"), if not revise.

2014

2015
0

2016
0

January-June

2017
0

2018
0

2019
0

2019
0

2020
0

0

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-6.

Page 16

Fully processed and semi-processed.—Report your firm’s U.S. shipments of fully processed and
semi-processed NOES (i.e. inclusive of commercial U.S. shipments, internal consumption, and
transfers to related firms) by level of processing.
Quantity (in short tons) and Value (in 1,000 dollars)
Calendar year

Item

2014

2015

2016

January-June

2017

2018

2019

2019

2020

U.S. shipments of.—
Fully processed NOES
Quantity (P)
Value (Q)
Semi-processed NOES
Quantity (R)
Value (S)
RECONCILIATION OF US SHIPMENTS.—Please ensure that the quantities and values reported for
U.S. shipments in this question (i.e., lines P through S) in each time period equal the quantities
and values reported for U.S. shipments in question II-4 (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.
Calendar year
Item

Quantity: P + R – D – F – H
= should equal zero ("0"), if
not revise.
Value: Q + S – E – G – I =
Should equal zero ("0"), if
not revise.

2014

2015

2016

January-June

2017

2018

2019

2019

2020

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-7.

Page 17

Employment data.--Report your firm’s employment-related data related to the production of
NOES and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations. Average number employed may be computed by adding the
number of employees, both full time and part time, for the 12 pay periods ending closest to the
15th of the month and divide that total by 12. For the January to June periods, calculate
similarly and divide by 6.
Note.--If your firm had the same number of PRWs in all calendar years and had not
experienced any changes in PRWs in the most recent interim period, you would have
the same number of PRWs for the interim periods, regardless of whether the interim
periods are Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item

2014

Employment data:
Average number of
PRWs (number) (T)
Hours worked by PRWs
(1,000 hours) (U)
Wages paid to PRWs
($1,000) (V)
Explanation of trends:

2015

2016

2017

January-June
2018

2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-8.

Page 18

Transfers to related firms.--If your firm reported transfers to related firms in question II-4,
please identify the firm(s) and indicate the nature of the relationship between your firm and the
related firms (e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at
market value or by a non-market formula, whether your firm retained marketing rights to all
transfers, and whether the related firms also processed inputs from sources other than your
firm.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 19

Purchases.--Has your firm purchased NOES produced in the United States or in other countries
since January 1, 2014? (Do not include imports for which your firm was the importer of record.
These should be reported in an importer questionnaire).

II-9.

“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.

No

Yes

If yes-- Report such purchases in the table below and explain the reasons
for your firms' purchases:

Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
Quantity (in short tons)
Calendar years
Item

2014

2015

2016

2017

January-June
2018

2019

2019

2020

Purchases from U.S.
importers1 of NOES
from—
China
Germany
Japan
Korea
Sweden
Taiwan
All other sources
Purchases from
domestic producers2
Purchases from other
sources3
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.
1

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
II-10.

Page 20

Imports.--Since January 1, 2014, has your firm imported NOES?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf.
No

Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

II-11.

Toll production.--Since January 1, 2014, has your firm been involved in a toll agreement
regarding the production of NOES?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

II-12.

Yes

If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce NOES in and/or admit NOES into a
foreign trade zone (FTZ)?

(a)

“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.

No

Yes

If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import NOES into a foreign trade zone (FTZ) for use in distribution of NOES and/or the
production of downstream articles?

(b)

No

Yes

If yes--Identify the firms and the FTZs.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 21

For questions II-13 and II-14, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II-13.

Effect of orders.--Describe the significance of the existing countervailing duty and antidumping
duty orders covering imports of NOES from China, Germany, Japan, Korea, Sweden, and/or
Taiwan in terms of its effect on your firm’s production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, and asset values. You may wish to compare your
firm’s operations before and after the imposition of the orders.

II-14.

Likely impact of revocation.--Would your firm anticipate any changes in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of NOES in
the future if the countervailing duty and antidumping duty orders on NOES from China,
Germany, Japan, Korea, Sweden, and/or Taiwan were to be revoked?

No

II-15.

Yes

If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.

Other explanations:--If your firm would like to explain further a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 22

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Emily Kim (202-205-1800, [email protected]).
III-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone

III-2.

Accounting system.--Briefly describe your firm’s financial accounting system.
A.

When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain below:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for which
financial statements are prepared that include NOES:

2.
3.

4.

Does your firm prepare profit/loss statements for NOES:
Yes
No
How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
U.S. GAAP,
IFRS,
cash,
tax, or
other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes NOES, as well as specific
statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 23

III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-5.

Product listing.--Please list the products your firm produces in the facilities in which it produces
NOES, and provide the share of net sales accounted for by these products in your firm’s most
recent fiscal year.
Products

Share of sales

NOES

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of NOES from any related suppliers (e.g., inclusive of transactions between related
firms, divisions and/or other components within the same company)?
Yes--Continue to question III-7.

III-7.

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of NOES that
your firm purchases from related suppliers and that are reflected in question III-9a. For “Share
of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
the company’s own accounting system, of the purchase cost from the related supplier; e.g., the
related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input

Related supplier

Input valuation as recorded in the firm’s accounting books and records

Share of total COGS

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
III-8.

Page 24

Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7, were reported in III-9a (financial results on NOES) in a manner
consistent with the firm’s accounting books and records.

Yes

No

If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 25

III-9a. Operations on NOES.--Report the revenue and related cost information requested below on the
NOES operations of your firm’s U.S. establishment(s).1 Do not report resales of products. Note
that internal consumption and transfers to related firms must be valued at fair market value.
Input purchases from related suppliers should be consistent with and based on information in
the firm’s accounting books and records. Provide data for your firm’s six most recently
completed fiscal years, and for the specified interim periods. If your firm was involved in tolling
operations (either as the toller or as the tollee), please contact Emily Kim at (202) 205-1800
before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2014

2015

2016

2017

2018

2019

quantities:2

Net sales
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms
(“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Net sales values:2
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold
Raw materials

(COGS):3

Direct labor
Other factory costs

Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative
expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income
taxes
Depreciation/amortization
included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 26

III-9a. Operations on NOES.--Continued
Quantity (in short tons) and value (in $1,000)
Item

January-June 2019

January-June 2020

quantities:3

Net sales
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)

0

0

0

0

Total COGS

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold
Raw materials

(COGS):4

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1

2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 27

III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, operating inome (or loss),
and net income (or loss)) have been calculated from the data submitted in the other line items.
Do the calculated fields return the correct data according to your firm's financial records
ignoring non-material differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

III-9c.

Raw materials.--Please report the share of total raw material costs in 2019 (reported in III-9a)
for the following raw material inputs:
Procurement method

Input

Share of total raw
material costs
(percent)

Primarily
produced by
your firm

Primarily
purchased by
your firm

Scrap steel
Ferrosilicon
Other material inputs1
Total (should sum to 100 percent)

0.0

Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that they account for:
1

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 28

III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in question III-9a; i.e., if an aggregate nonrecurring item has been allocated to question
III-9a, only the allocated value amount included in question III-9a should be reported in the
schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question III-9a.
Fiscal years ended-2014
Item

2015

2016

2017

January-June
2018

2019

2019

2020

Value ($1,000)

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item
reported above and indicate the specific line item in table III-9a where the nonrecurring item is
classified.
Description of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Income statement classification of
the nonrecurring item

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 29

III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.

III-12. Asset values.--Report the total assets (i.e., both CURRENT and LONG-TERM ASSETS) associated
with the production, warehousing, and sale of NOES. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for NOES in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9a. Provide data as
of the end of your firm’s six most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

Describe

2014

2015

2016

2017

2018

2019

1

.

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for NOES. Provide data for your
firm’s six most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended-Item
Capital expenditures

2014

2015

2016

2017

January-June
2018

2019

2019

2020

1

R&D expenses2
1
2

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.

.

.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 30

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year or your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-4 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years ended-Reconciliation

2014

2015

2016

2017

January-June
2018

2019

2019

2020

Quantity: Trade data
from question II-4
(lines D, F, H, and J)
less financial total net
sales quantity data
from question III-9a, =
zero ("0").

0

0

0

0

0

0

0

0

Value: Trade data
from question II-4
(lines E, G, I, and K) less
financial total net sales
value data from
question III-9a, = zero
("0").

0

0

0

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-4?
Yes

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 31

III-15. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 32

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Andrew Knipe (202-2052390, [email protected]).
IV-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 IV.
Name
Title
Email
Telephone

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products produced by your firm.
Product 1.--M-19, 0.45-0.50mm thickness, fully processed, maximum core loss 2.90 W/kg
(1.5T; 50Hz), 600mm or more wide, coated
Product 2.--M-22, 0.45-0.50mm thickness, fully processed, maximum core loss 3.10 W/kg
(1.5T; 50Hz), 900mm or more wide, coated
Product 3.--M-36, 0.60-0.65mm thickness, fully processed, maximum core loss 4.10 W/kg
(1.5T; 50Hz), 600mm or more wide, coated
Product 4.--M-43, 0.60-0.65mm thickness, fully processed, maximum core loss 4.35 W/kg
(1.5T; 50Hz), 600mm or more wide, coated
Product 5.--M-45, 0.60-0.65mm thickness, fully processed, maximum core loss 4.80 W/kg
(1.5T; 50Hz), 600mm or more wide, coated
Product 6.--0.20-0.35mm thickness, fully processed, maximum core loss 22.0 W/kg
(1.0T; 400Hz), 600mm or more wide, coated

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 2014-June 2020, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 33

IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Product 2
Product 3
Period of
shipment
Quantity
Value
Quantity
Value
Quantity
Value
2014:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2015:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2016:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2017:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2018:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2019:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2020:
Jan.-Mar.
Apr.-June
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 34

IV-2b. Price data.--Continued. Report below the quarterly price data1 for pricing products2 produced
and sold by your firm.
Report data in actual short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 4
Product 5
Product 6
Period of
shipment
Quantity
Value
Quantity
Value
Quantity
Value
2014:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2015:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2016:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2017:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2018:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2019:
Jan.-Mar.
Apr.-June
July-Sept.
Oct.-Dec.
2020:
Jan.-Mar.
Apr.-June
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
Product 6:

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 35

IV-2 c. Price data checklist.--Please check that the pricing data in question IV-2(a) has been correctly
reported.
√ if Yes

Are the price data reported above:
In actual dollars (not $1,000) and actual short tons?
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-4 in each year?

IV-2d. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.

IV-3.

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

IV-4.

Contracts

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

No
discount
policy

Other

Describe

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
IV-5.

Pricing terms.--On what basis are your firm’s prices of domestic NOES usually quoted (check
one)?
Delivered

IV-6.

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced NOES
in 2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) long-term contract
basis, and (4) spot sales basis?

Share of 2019
sales
IV-7.

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

%

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced NOES (or check “not applicable” if your firm does not sell on a short-term, annual
and/or long-term contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Page 36

Please identify the indexes used:

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

Annual contracts
(multiple
deliveries for 12
months)
365

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

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)
IV-8.

Lead times.--What is the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.-produced NOES?
Share of 2019 Lead time (average
sales
number of days)

Source
From inventory

%

Produced to order

%

Total (should sum to 100.0%)
IV-9.

Page 37

0.0 %

Shipping information.-(a)

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

(b)

Indicate the approximate percentage of your firm’s sales of NOES that are delivered the
following distances from your firm’s production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced NOES since January 1, 2014 (check all that apply)?
Geographic area
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.

√ if applicable

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 38

IV-11. Inland transportation costs.--What is the approximate percentage of the cost of U.S.-produced
NOES that is accounted for by U.S. inland transportation costs?
percent
IV-12. End uses.--Have there been any changes in the end uses of NOES since January 1, 2014? Do you
anticipate any future changes?
Changes in end
uses

No

Yes

Explain

Changes since
January 1, 2014
Anticipated
changes
IV-13. Substitutes.--Have there been any changes in the number or types of products that can be
substituted for NOES since January 1, 2014? Do you anticipate any future changes?
Changes in
substitutes
Changes since
January 1, 2014
Anticipated
changes

No

Yes

Explain

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 39

IV-14. Availability of supply.--Has the availability of NOES in the U.S. market changed since January 1,
2014? Do you anticipate any future changes?
Availability in the U.S.
market

No

Please explain, noting the countries and reasons for the
Yes changes.

Changes since January 1, 2014:
U.S.-produced product
Imports from China,
Germany, Japan, Korea,
Sweden, and/or Taiwan
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from China,
Germany, Japan, Korea,
Sweden, and/or Taiwan
Imports from all other
countries
IV-15. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for NOES has changed since January 1, 2014, and how you anticipate demand
will change in the future. Explain any trends and describe the principal factors that have
affected, and that you anticipate will affect, these changes in demand.

Market

Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Demand since January 1, 2014

Within the U.S.
Outside the U.S.
Anticipated future demand
Within the U.S.
Outside the U.S.

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 40

IV-16. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of NOES since January 1, 2014? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes

Explain

Changes since
January 1, 2014
Anticipated
changes
IV-17.

Conditions of competition.-(a)

Is the NOES market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to NOES?

Check all that apply.
No

Please describe.
Skip to question IV-18.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b)

No

If yes, have there been any changes in the business cycles or conditions of competition
for NOES since January 1, 2014?
Yes If yes, describe.

IV-18. Trends and developments in e-mobility sector.--Please identify trends and discuss
developments in the United States with respect to NOES products related to the production of
motors for electric vehicles (i.e. the e-mobility sector). In addition, please indicate your firm’s
ability to supply NOES for these applications (in particular NOES with a minimum of 3% Si
content, thickness range between 0.20mm and 0.35mm, magnetic characteristics measured and
guaranteed at 1.0T & 400Hz, and yield strength (Ys) above 390mpa).

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 41

IV-19. Supply constraints.--Has your firm refused, declined, or been unable to supply NOES since
January 1, 2014 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No

Yes If yes, please describe.

IV-20. Raw materials.--Indicate how NOES raw material prices have changed since January 1, 2014,
and how you expect they will change in the future.

Raw
materials
prices

Fluctuate
with no
clear
Overall
No
Overall
increase change decrease trend

Explain, noting how raw material
price changes have affected your
firm’s selling prices for NOES.

Changes since
January 1,
2014
Anticipated
changes
IV-21. Impact of the section 232 tariffs.--Did the imposition of tariffs on imported steel/aluminum
products under section 232 have an impact on the NOES market in the United States?
Yes— Please indicate the impact in the table below.

Factor
Supply of U.S.produced NOES
Supply of imported
NOES
Prices for NOES
Overall U.S. demand
for NOES
Raw material costs
for NOES

Overall
No
Overall
increase change decrease

No

Don’t know

Fluctuate Explain, noting how the imposition
with no
of tariffs under section 232
clear
affected each factor of the NOES
trend
market in the United States.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 42

IV-22. Impact of section 301 tariffs.--Did the imposition of tariffs on Chinese-origin products under
section 301 have an impact on the NOES market in the United States?
Yes— Please indicate the
impact in the table below.

Factor

No

Overall
No
Overall
increase change decrease

Don’t know

Fluctuate Explain, noting how the imposition
with no of tariffs under section 301 affected
clear
each factor of the NOES market in
trend
the United States.

Supply of U.S.produced NOES
Supply of NOES
imported from China
Supply of NOES
imported from other
countries
Prices for NOES
Overall U.S. demand
for NOES
Raw material costs
for NOES
IV-23. Price comparisons.--Please compare market prices of NOES in U.S. and non-U.S. markets, if
known. Provide specific information as to time periods and regions for any price comparisons.

IV-24. Market studies.--Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss NOES supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China, Germany, Japan, Korea,
Sweden, and Taiwan, and (3) the world as a whole. Of particular interest is such data from 2014
to the present and forecasts for the future.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 43

IV-25. Export constraints.--Describe how easily your firm can shift its sales of NOES between the U.S.
market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints that would prevent or retard your firm from
shifting NOES between the U.S. and alternative country markets within a 12-month period.

IV-26. Barriers to trade.--Are your firm’s exports of NOES subject to any tariff or non-tariff barriers to
trade in other countries?

No

Yes

If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2014, or that are expected to occur in the future.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 44

IV-27. Interchangeability.--Is NOES 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

China

Germany

Japan

Korea

Sweden

Taiwan

Other
countries

United States
China
Germany
Japan
Korea
Sweden
Taiwan
For any country-pair producing NOES that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 45

IV-28. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between NOES 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

China

Germany

Japan

Korea

Sweden

Taiwan

Other
countries

United States
China
Germany
Japan
Korea
Sweden
Taiwan
For any country-pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of NOES, identify the country-pair and report the advantages or disadvantages
imparted by such factors:

IV-29. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – NOES (Review)

Page 46

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/701731/2019/non_oriented_electrical_steel_chin
a_germany_japan/first_review_full.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: NOES

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (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 Typeapplication/pdf
File TitleUS Producer questionnaire - sunset
AuthorDuffy, Julie
File Modified2020-07-07
File Created2020-07-07

© 2024 OMB.report | Privacy Policy