Form 20-1-4285 U.S. producers' questionnaire

OMB No. 3117-0016/USITC No. 20-1-4285; Expiration Date: : 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
METAL LOCKERS AND PARTS FROM CHINA
This questionnaire must be received by the Commission by July 23, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations metal lockers from China (Inv. Nos. 731-TA-656
and 701-TA-1533 (Preliminary)). The information requested in the questionnaire is requested under the authority of the
Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other
order to compel the submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced metal lockers (as defined on next page) at any time since January 1, 2017?

NO

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

YES

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

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: LOCK)
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

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on July 9, 2020, by List
Industries, Inc., Deerfield Beach, Florida; Lyon LLC, Montgomery, Illinois; Penco Products, Inc.,
Greenville, North Carolina; and Tennsco Corp., Dickson, Tennessee. Countervailing and/or 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/metal_lockers_and_parts_thereof_people%E2%80
%99s_republic/preliminary.htm.
Metal lockers covered by these investigations are metal lockers, with or without doors, and parts
thereof (“metal lockers”). The subject metal lockers are metal storage devices less than 27 inches wide
and less than 27 inches deep, whether floor standing, installed onto a base or wall-mounted. In a
multiple locker assembly (whether a welded locker unit, otherwise assembled locker unit or knocked
down unit or kit), the width measurement shall be based on the width of an individual locker not the
overall unit dimensions. The subject metal lockers typically include the bodies (back, side, shelf, top and
bottom panels), door frames with or without doors which can be integrated into the sides or made
separately, and doors. The subject metal lockers typically are made of flat-rolled metal, metal mesh
and/or expanded metal, which includes but is not limited to alloy or non-alloy steel (whether or not
galvanized or otherwise metallically coated for corrosion resistance), stainless steel, or aluminum, but
the doors may also include transparent polycarbonate, Plexiglas or similar transparent material or any
combination thereof. The doors are configured with or for a handle or other device that permit the use
of a mechanical or electronic lock or locking mechanism, including, but not limited to: a combination
lock, a padlock, a key lock, lever or knob lock, and a wireless lock. The doors or body panels may also
include vents (including wire mesh or expanded metal mesh vents) or perforations. The bodies, body
components and doors are typically powder coated, otherwise painted or epoxy coated or may be
unpainted. The subject merchandise includes metal lockers imported either as welded or otherwise
assembled units (ready for installation or use) or as knocked down units or kits (requiring assembly prior
to installation or use).
The subject lockers may be shipped as individual or multiple locker units preassembled, welded, or
combined into banks or tiers for ease of installation or as sets of component parts, bulk packed (i.e., all
backs in one package, crate, rack, carton or container and sides in another package, crate, rack, carton
or container) or any combination thereof. The knocked down lockers are shipped unassembled requiring
a supplier, contractor or end-user to assemble the individual lockers and locker banks prior to
installation.
The scope also includes all parts and components of lockers made from flat-rolled metal or expanded
metal (e.g., doors, frames, shelves, tops, bottoms, backs, side panels, etc.) as well as accessories that are
attached to the lockers when installed (e.g., slope tops, bases, expansion filler panels, dividers, recess
trim, decorative end panels and end caps) that may be imported together with other locker components
or on their own. It also includes all hardware for assembly and installation of the lockers and locker
banks that are imported with or shipped, invoiced or sold with the imported locker or locker system. The
subject metal lockers are typically used for storage in schools, fitness centers, apartment buildings,
offices, condominiums, single family homes, athletic facilities, public private, and government buildings,
warehouses, factories, transportation hubs, healthcare facilities, amusement parks, military
installations, retail businesses, and other commercial and industrial establishments.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 3

Excluded from the scope are wire mesh lockers. Wire mesh lockers are those with each of the following
characteristics:
(1) at least three sides, including the door, made from wire mesh;
(2) the width and depth each exceed 25 inches; and
(3) the height exceeds 90 inches.
Also excluded are lockers with bodies made entirely of plastic, wood or any nonmetallic material.
Also excluded are exchange lockers with multiple individual locking doors mounted on one master
locking door to access multiple units. Excluded exchange lockers have multiple individual storage spaces,
typically arranged in tiers, with access doors for each of the multiple individual storage space mounted
on a single frame that can be swung open to allow access to all of the individual storage spaces at once.
For example, uniform or garment exchange lockers are designed for the distinct function of securely and
hygienically exchanging clean and soiled uniforms. Thus, excluded exchange lockers are a multi-access
point locker whereas covered lockers are a single access point locker for personal storage.
Also excluded are metal lockers that are imported with an installed electronic, internet-enabled locking
device that permits communication or connection between the locker’s locking device and other
internet connected devices.
Also excluded are hardware and accessories for assembly and installation of the lockers, locker banks
and storage systems that are separately imported in bulk and are not incorporated into a locker, locker
system or knocked down kit at the time of importation. Such excluded hardware and accessories include
but are not limited to bulk imported rivets, nuts, bolts, hinges, door handles, locks, door/frame latching
components, and coat hooks. Accessories of sheet metal, including but not limited to end panels, bases,
dividers and sloping tops, are not excluded accessories.
Metal lockers are currently imported under statistical reporting number 9403.20.0078 of the
Harmonized Tariff Schedule of the United States (HTSUS). Parts of metal lockers that are subject to these
investigations enter under HTSUS 9403.90.8041. Prior to July 1, 2019, metal lockers were classified
under HTSUS statistical reporting number 9403.20.0080. The HTSUS provisions are for convenience and
customs purposes; the written description of the scope is dispositive.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing metal lockers (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.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Celia
Feldpausch (202-205-2387, [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.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
I-1a.

Page 5

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes

I-2a.

No

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 metal lockers, 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:

.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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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.

Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No

I-4.

I-5.

Yes

Petition support.--Does your firm support or oppose the petition?
Country
China

Investigation type
Antidumping duty

China

Countervailing duty

Support

Oppose

Take no
position

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

Firm name

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

Country

Extent of
ownership
(percent)

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
I-6.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing metal lockers from China into the United States or that
are engaged in exporting metal lockers from China to the United States?
No
Firm name

I-7.

Page 7

Yes--List the following information.
Country

Affiliation

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained Celia Feldpausch (202-205-2387,
[email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of metal lockers since January 1, 2017.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-3a.

Page 9

Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce metal lockers, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Quantity (in pounds)
Calendar years
Item

Overall production capacity

2017

2019

2019

2020

1

Production of:
Metal lockers2
Other products

2018

January-March

0

0

0

0

0

0

0

0

0

0

3

Total production using same
machinery or workers
1

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of metal lockers will populate here once reported in question II-7.
3
Please identify these products:
.
2

II-3b.

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

Weeks per year

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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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-4.

Product shifting.—
(a)

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

No

(b)

II-5.

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.

Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of metal lockers?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.

No

Yes

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

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-6.

Page 11

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce metal lockers in and/or admit metal
lockers into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.

No

(b)

Yes

If yes--Describe the nature of your firm’s 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 metal lockers into a foreign trade zone (FTZ) for use in distribution of metal
lockers and/or the production of downstream articles?
No

Yes

If yes--Identify the firms and the FTZs.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-7.

Page 12

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of metal lockers 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/ including for own retail sale” --Product consumed internally by your
firm, which includes merchandise that your firm transferred to your own firm’s retail
establishments. Such transactions are to be valued at fair market value and not the total value
of final downstream processed merchandise in the case of internal consumption, nor the retail
sale value in the case of your firm owning and operating its own retail establishments.
“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. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-7.

Page 13

Production, shipment, and inventory data.--Continued
Quantity (in pounds) and value (in dollars)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

1

Average production capacity (quantity)
(A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption / including
product for own retail sale: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

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

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

2017

2018
0

January-March
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:
.

0

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-8.

Page 14

Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in pounds)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (N)
To retailers users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M through O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D - F- H = zero ("0"), if
not revise.

2017

2018
0

January-March
2019

0

2019
0

2020
0

0

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-9.

Page 15

U.S. shipments by level of assembly. --Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by level of
assembly during the specified periods.
Quantity (in pounds); Value (in dollars)
Item

Calendar years
2017

2019

January-March
2019

2019

2020

U.S. shipments:
Sold as preconstructed locker(s):
Quantity (P)
Value (Q)
Sold within kit /ready-to-assemble
package:1
Quantity (R)
Value (S)
Sold as component:
Quantity (T)
Value (U)
1

The kit/package includes all necessary parts for installation

RECONCILIATION OF U.S. SHIPMENTS BY LEVEL OF PROCESSING. Please ensure that the quantities and values
reported for U.S. shipments in this question (i.e., lines P through U) in each time period equal the quantities
and values reported for U.S. shipments reported in question II-7 (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 years
Reconciliation

2017

2018

January-March
2019

2019

2019

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

0

0

0

0

0

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

0

0

0

0

0

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-10.

Page 16

Product mix.--Does your firm produce and ship the following products? (check all that apply):

Width (down) / Depth (across)

Less than
12" deep

>=12" deep >=16" deep >=20" deep >=24" deep
to <16" deep to <20" deep to <24" deep to <27" deep

Less than 12" wide
>=12" wide to <16" wide
>=16" wide to <20" wide
>=20" wide to <24" wide
>=24" wide to <27" wide
Standing type
Floor standing
Mounted, intended for mounting
Other:
.
Latching type
Gravity lift type
Single point, finger pull
Other:
.
Finishing type
Painted
Galvanized
Stainless steel
Non-galvanized, non-stainless pickled oiled
Epoxy or plastic
Other:
.
Describe any other unique characteristics or customizations of the metal lockers your firm
produces and sells:

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-11.

Page 17

Employment data.--Report your firm’s employment-related data related to the production of
metal lockers and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations. Average number employed may be computed by adding the
number of employees, both full time and part time, for the 12 pay periods ending closest to the
15th of the month and divide that total by 12. For the January to March periods, calculate
similarly and divide by 3.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:

II-12.

Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-13.

Page 18

Purchases.--Has your firm purchased metal lockers produced in the United States or in other
countries since January 1, 2017? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.

No

Yes

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

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

2017

2018

January-March
2019

2019

2020

1

Purchases from U.S. importers of
metal lockers from—
China
All other sources
Purchases from domestic producers2
Purchases from other sources3
1

Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-14.

Page 19

Comparability of metal locker parts/components and finished metal lockers/or kits.--Please
answer the following questions regarding the differences and similarities in unfinished (e.g.,
metal locker parts/components) and finished metal lockers or kits
(a) Is the upstream article (the metal locker parts/components) dedicated to the production
of the downstream article (finished metal locker/ metal locker kit)?
Yes, all metal locker parts/components are ultimately converted into finished metal
lockers.
No, there are other end uses for unfinished metal locker parts/components besides ultimate
conversion to finished metal lockers.
What percentage of unfinished metal locker parts/components did your firm use in the
production of downstream finished metal lockers?
percent. What were the other
end uses for which your firm used metal locker parts/components?
(b) Do you perceive the metal locker parts/components to be a separate market than the
finished metal lockers/metal locker kit market?
Yes, they are perceived as a distinct market.
No, they are perceived as one market.
(c) Are there differences in the physical characteristics and functions of the upstream (metal
locker parts/components) and downstream articles (finished metal lockers/ metal locker kit)?
No
Yes, please describe these differences:
(d) Is there a significant difference in the cost or value between metal locker
parts/components and finished metal lockers/metal locker kits?
No
Yes, please describe these differences:
(e) Would you describe the processes used to transform the upstream metal locker
parts/components into the downstream finished metal locker/kit product as significant and
particularly labor or capital intensive?
No
Yes, please describe this process:

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
II-15.

Page 20

Imports.--Since January 1, 2017, has your firm imported metal lockers?
No

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

II-16.

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

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 21

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[email protected]).
III-1.

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

III-2.

Accounting system.—Please provide the following information on your firm’s financial
accounting system.
A.

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

B.1.

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

2.
3.

4.

Does your firm prepare profit/loss statements for metal lockers:
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 metal lockers, as well as
specific statements and worksheets) used to compile these data.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 22

III-3.

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

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 produced in the facilities in which your firm
produced metal lockers and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Metal lockers

Share of sales
%
%
%
%
%

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of metal lockers 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.

Page 23

No—Skip to question III-9a.

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

Related supplier

Share of total COGS

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

III-8.

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

Yes

No

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

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 24

III-9a. Operations on metal lockers.--Report the revenue and related cost information requested
below on the metal lockers operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed 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
Jennifer Brinckhaus at (202) 205-3188 before completing this section of the questionnaire.
Quantity (in pounds) and value (in dollars)
Fiscal years ended-Item

2017

2018

January-March
2019

2019

2020

2

Net sales quantities:
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

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense and income items, net 4
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.
4 If the total reported amount is net other expenses, report as a positive number. If the total reported amount is net other
income, report as a negative number. Please check the calculated “Net income or (loss) before income taxes” to ensure proper
reporting of these items.
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 – Metal Lockers from China (Preliminary)

Page 25

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, 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

III-9c.

No

If no--If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs of
the line item “All other expense and income items, net.” If the net value of
the all other items reported here is an expense/loss, it should be reported
as a positive number. If the net value is an income/gain it should be
reported as a negative value. 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.

Raw materials.--Please report the share of total raw material costs in 2018 (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

Cold-rolled steel
Hot-rolled steel
Zinc coated galvanized steel
Stainless steel
All flat-rolled steel
Other material inputs

0.0
1

Total (should sum to 100 percent)
1

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 each account for:
.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 26

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 dollars), 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-Item

2017

2018

January-March
2019

2019

2020

Value (in dollars)
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

Income statement classification 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
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.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 27

III-12a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of metal lockers. If your firm does not maintain some or
all of the specific asset information necessary to calculate total assets for metal lockers in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III-9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Value (in dollars)
Fiscal years ended-Item

2017

2018

2019

Total assets (net)
III-12b. Description of asset values.-- Please describe the main asset categories (both current and longterm assets) in the above response. Provide a brief explanation if there are any substantial
changes in total asset value during the period; e.g., due to asset write-offs, revaluation, and
major purchases.

III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for metal lockers. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years ended-Item
Capital expenditures

2017
1

Research and development
expenses2

2018

January-March
2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 28

III-13b. Description of reported capital expenditures.-- Please describe the nature, focus, and
significance of your firm’s reported capital expenditures. If no capital expenditure data were
reported, please explain the reason.

III-13c. Description of reported R&D expenses.-- Please describe the nature, focus, and significance of
your firm’s reported R&D expenses. If no R&D expenses were reported, please explain the
reason.

III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12a, and 13a are based on a calendar year or on 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-7 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in Part II equal the quantities and values reported for total net sales in Part III of this
questionnaire in each time period 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

2017

2018

January-March
2019

2019

2020

Quantity: Trade data from question
II-7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").

0

0

0

0

0

Value: Trade data from question II-7
(lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").

0

0

0

0

0

Do these data in question III-9a reconcile with data in question II-7?
Yes

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 29

III-15. Effects of imports on investment.--Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of metal lockers from China?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 30

III-16. Effects of imports on growth and development.--Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of metal lockers from China?
No

Yes
If yes, my firm has experienced actual negative effects as follows.

(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the
issue of stocks or bonds
Ability to service debt

Other

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 31

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
metal lockers from China?
No

Yes

If yes, my firm anticipates negative effects as follows.

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 32

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from James Horne (202-205-2722,
[email protected]).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in Part IV.
Name
Title
Email
Telephone

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products produced by your
firm.
Product 1.-- 12” wide x 18” deep x 72” high 1-Tier (one full height door within a single frame,
one opening) locker, knockdown (KD), 24 gauge solid body, 16 gauge frame, 16
gauge louvered door, recessed or projecting die-cast handle, 3-point (multi-point)
gravity lift-type latching, lock not included, with or without 6” legs (legs increase
frame height to 78”), nut/bolt or rivet assembly required.
Product 2.-- 12” wide x 12” deep x 36”/72” high 2-Tier (two half-height doors stacked within a
single frame, two openings) locker, knock-down (KD), 24 gauge solid body, 16 gauge
frame, 16 gauge louvered door, recessed or projecting die-cast handle, 2-point
(multi-point) gravity lift type latching, lock not included, with or without 6” legs (legs
increase frame height to 78”), nut/bolt or rivet assembly required.
Product 3.-- 12” wide x 18” deep x 36”/72” high 2-Tier (two half-height doors stacked within a
single frame, two openings) locker, knock-down (KD), 24 gauge solid body, 16 gauge
frame, 16 gauge louvered door, recessed or projecting die-cast handle, 2-point
(multi-point) gravity lift-type latching, lock not included, with or without 6” legs
(legs increase frame height to 78”), nut/bolt or rivet assembly required.
Product 4.-- 12” wide x 12” deep x 12”/72” high 6-Tier (six 12” high doors stacked within a single
frame, 6 openings) locker, 24 knock-down (KD), 24 gauge solid body, 16 gauge
frame, 18 gauge louvered door, single-point latching with thru-the-door finger pull
handle, lock not included, with or without 6” legs (legs increase frame height to
78”), nut/bolt or rivet assembly required.

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).

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 33

IV-2a. During January 2017-March 2020, did your firm produce and sell to unrelated U.S. customers any
of the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question IV-3.
IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual lockers and actual dollars (not 1,000s).
(Quantity in lockers, value in dollars)
Product 1
Period of shipment

Quantity

Value

Product 2
Quantity

Value

Product 3
Quantity

Value

Product 4
Quantity

Value

2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
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.
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:
Product 4:

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
IV-2c.

Page 34

Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Are the price data reported above:

√ if Yes

In actual dollars (not $1,000) and actual units (actual lockers)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Quantities do not exceed commercial shipments in question II-7 in each year?
IV-2d.

Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.

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

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
IV-3.

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

IV-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 domestic metal lockers usually quoted
(check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 35

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 metal
lockers 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

%

Business Proprietary
U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
IV-7.

Page 36

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced metal lockers (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

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

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:

IV-8.

.

Lead times.--What share of your firm’s sales is from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced metal lockers?

Source

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

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)
IV-9.

Page 37

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 metal lockers that are
delivered the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced metal lockers since January 1, 2017 (check all that apply)?
Geographic area

√ if applicable

Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
IV-11. Inland transportation costs.—What is the approximate percentage of the cost of U.S.-produced
metal lockers that is accounted for by U.S. inland transportation costs?
percent

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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

Metal lockers

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-13. Substitutes.--Can other products be substituted for metal lockers?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

Have changes in the price of this substitute
affected the price for metal lockers?
No Yes

Explanation

1.
2.
3.
IV-14. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for metal lockers has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand.

Overall
increase

Market

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within the United States
Outside the United States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of metal lockers since January 1, 2017?
No

Yes

If yes, please describe and quantify if possible.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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IV-16. Conditions of competition.-(a) Is the metal lockers market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to metal lockers? If yes,
describe.
Check all that apply.

Please describe.

No

Skip to question IV-16.

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
metal lockers since January 1, 2017?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply metal lockers
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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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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IV-18. Raw materials.—
(a) How have metal lockers 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 metal
lockers.

(b) How did the imposition of tariffs under section 232 on imported steel or aluminum products
impact raw material costs for metal lockers?

Factor

Overall increase

No change

Overall decrease

Fluctuate with
no clear trend

Cost of raw materials after
section 232 tariffs imposed
(c) How did the imposition of tariffs under section 232 on imported steel or aluminum products
impact your firm’s sales price for metal lockers?

Factor
Prices for metal lockers

Overall
Increase

No change

Fluctuate
Overall
with no
Decrease clear trend

Explanation

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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IV-19. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products under
section 301 have an impact on the metal lockers market in the United States?
Yes— Please indicate the
impact in the table below.

Factor
Supply of U.S.produced metal
lockers
Supply of metal
lockers imported from
China
Supply of metal
lockers imported from
other countries
Prices for metal
lockers
Overall U.S. demand
for metal lockers
Raw material costs for
metal lockers

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 metal lockers
trend
market in the United States.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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IV-20. Interchangeability.--Is metal lockers 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

Other countries

United States
China
For any country-pair producing metal lockers that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between metal lockers 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

Other countries

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

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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IV-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for metal lockers since January 1, 2017. Indicate the share of the quantity of your
firm’s total shipments of metal lockers that each of these customers accounted for in 2019.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2019
sales
(%)

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

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IV-23. Competition from imports.-(a)

Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling metal
lockers from China, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2017: Did your firm lose sales of metal lockers to imports of
this product from China?
No

(c)

Yes

If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: LOCK)

IV-24. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.

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U.S. Producers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 45

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/metal_lockers_and_parts_thereof_
people%E2%80%99s_republic/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: LOCK

• 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.