20-2-4286 U.S. importers' questionnaire

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

US importers--Metal lockers (P)

Metal lockers from China (Inv. nos. 701-TA-656 and 731-TA-1533) Prelim

OMB: 3117-0016

⚠️ Notice: This form may be outdated.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

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

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OMB No. 3117-0016/USITC No. 20-2-4286; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ 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 concerning 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 imported metal lockers (as defined on next page) from any country at any time since January 1,
2017?

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

YES

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

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: 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. Importers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 2

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. Importers’ 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. Importers’ Questionnaire – Metal Lockers from China (Preliminary)

Page 4

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. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
I-1.

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
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2a.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm involved in the importation of metal lockers, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

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):

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

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

Firm name

I-4.

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

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing 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-5.

Page 6

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

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

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

I-7.

Page 7

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of metal lockers but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).

Firm name

Address

Contact person
and phone
number

Business Proprietary
U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
I-8.

Page 8

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters metal lockers into,
or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports metal lockers under the TIB (temporary importation under bond)
program.
“Foreign trade zone” is a designated location in the United States where firms utilize special
procedures that allow delayed or reduced customs duty payments on foreign merchandise, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item

Yes

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

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes

If yes, Yes–Please specify.

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U.S. Importers’ Questionnaire – 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 from Celia Feldpausch (202-2052387, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the importation of metal lockers since January 1, 2017.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

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

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

Page 10

Arranged imports.--Has your firm imported or arranged for the importation of metal lockers for
delivery after March 31, 2020
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes
If yes, fill out the table below.

Period
Source

Apr-Jun 2020

Jul-Sept 2020

Oct-Dec 2020

Jan-Mar 2021

Quantity (in pounds)
China
All other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported metal lockers
from any source between July 1, 2019 and June 30, 2020? (i.e., the last six months in 2019 and
first six months in 2020 combined)
No

Yes
If yes, report the quantity of such import below by source.

Quantity (in pounds)
Source

July 2019 through June 2020

China
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces metal lockers in the United
States, please indicate the reasons for importing this product. If your firm’s reasons differ by
source, please elaborate.

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

Page 11

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“Commercial U.S. shipments”— Shipments made within the United States as a result of an
arm’s length commercial transaction in the ordinary course of business. Report net values (i.e.,
gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption/ 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.

Business Proprietary
U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
II-5a.

Page 12

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

China
Quantity (in pounds), value (in dollars)
Calendar years
Item

2017

2018

January-March
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption /
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

Please identify the foreign producers, if known:
.
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
2

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U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
II-5a.

Page 13

U.S. imports from China.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation

2017

2018

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

January-March
2019

2019
0

2020
0

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

Channels of distribution: China.--Report your firm’s U.S. shipments (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) of imports from China by
channel of distribution during the specified periods.

China
Calendar years
Item

2017

2018

January-March
2019

2019

2020

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

2017

2018
0

January-March
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
II-5c.

Page 14

U.S. imports by level of assembly: China.--Report your firm’s U.S. imports from China of metal
lockers, by level of assembly.

China
Quantity (in pounds); Value (in dollars)
Calendar years
Item

2017

2019

January-March
2019

2019

2020

U.S. imports:
Imported as preconstructed
locker(s):
Quantity (P)
Value (Q)
Imported within kit /ready-toassemble package:1
Quantity (R)
Value (S)
Imported as component:
Quantity (T)
Value (U)
1

The kit/package includes all necessary parts for installation

RECONCILIATION FOR IMPORTS BY LEVEL OF ASSEMBLY: Please ensure that the quantities and values
reported for U.S. imports from China by level of assembly (i.e., lines P through U) in each time period equal
the quantity and value reported for U.S. imports (i.e., lines B and C) from part "a" of this question 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

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

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

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U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
II-5d.

Page 15

Product mix: China.--Does your import the following products from China? (check all that
apply):

Width (down) / Depth (across)

Less than 12" >=12" deep >=16" deep >=20" deep >=24" deep
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
imports from China:

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

Page 16

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

All other sources
(list sources:

)
Quantity (in pounds), value (in dollars)
Calendar years

Item

2017

2018

January-March
2019

2019

2020

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

Page 17

Imports from all other sources.–Continued

2017

2018

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

January-March
2019

2019
0

2020
0

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

Channels of distribution: All other sources.-- Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution during the specified periods.

All other sources
Calendar years
Item

2017

2018

January-March
2019

2019

2020

2017

2018
0

January-March
2019

2019
0

2020
0

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

Page 18

U.S. imports by level of assembly: All other sources.--Report your firm’s U.S. imports from all
other sources of metal lockers, by level of assembly.

All other sources
Quantity (in pounds); Value (in dollars)
Calendar years
Item

2017

2019

January-March
2019

2019

2020

U.S. imports:
Imported as preconstructed
locker(s):
Quantity (P)
Value (Q)
Imported within kit /ready-toassemble package:1
Quantity (R)
Value (S)
Imported as component:
Quantity (T)
Value (U)
1

The kit/package includes all necessary parts for installation

2017

2018

January-March
2019

2019

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

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

Business Proprietary
U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
II-6d.

Page 19

Product mix: all other sources.--Does your import the following products from all other
sources? (check all that apply):

Width (down) / Depth (across)

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

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

Page 20

Comparability of metal locker parts/components and finished metal lockers/kits.--Please
answer the following questions regarding the differences and similarities in unfinished (e.g.,
metal locker parts/components) and finished metal lockers/metal locker kits.
(a) Is the upstream article (the metal locker parts/components) dedicated to the production
of the downstream article (finished metal locker/metal locker kits)?
Yes, all metal locker parts/components are ultimately converted into finished metal
lockers/kits.
No, there are other end uses for unfinished metal locker parts/components besides ultimate
conversion to finished metal lockers/kits.
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 kits)?
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/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/ metal locker kit product as
significant and particularly labor or capital intensive?
No
Yes, please describe this process:

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

Page 21

II-8.

Transfers to related firms.--If your firm reported transfers to related firms in any of the data
tables in part II, please identify the firm(s) and indicate the nature of the relationship between
your firm and the related firms (e.g., joint venture, wholly owned subsidiary) and whether the
transfers were priced at market value or by a non-market formula.

II-9.

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

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

Page 22

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

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products your firm imported
from China:
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).

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

Page 23

III-2a. During January 2017-March 2020, did your firm import from China 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 III-3.
III-2b. Price data.--Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.

China

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
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part III.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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

Page 24

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

√ if Yes

In actual dollars (not $1,000) and 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?
III-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. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
III-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

III-4.

Contracts

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported metal lockers from China
usually quoted (check one)?
Delivered

III-6.

Set
price
lists

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

Quantity
discounts

III-5.

Page 25

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of metal lockers imported
from China in 2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) longterm 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. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
III-7.

Page 26

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

III-8.

Lead times.--What is your firm’s share of sales of metal lockers imported from China 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 metal lockers?

Source

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

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

Business Proprietary
U.S. Importers’ Questionnaire – Metal Lockers from China (Preliminary)
III-9.

Page 27

Shipping information.—
(a)

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

(b)

When your firm sells metal lockers imported from China, from where is it shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of metal lockers imported from
China that are delivered the following distances from your firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

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

China

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

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

Page 28

III-12. End uses.--List the end uses of the metal lockers that your firm imports. 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

Other inputs

Total
(should sum to
100.0% across)

0.0 %

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

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

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

Explanation

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

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

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

Page 29

III-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.

III-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?
Check all that apply.

Please describe.

Skip to question III-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.

III-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.

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

Page 30

III-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

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

Page 31

III-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

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.

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

Page 32

III-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:

III-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:

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

Page 33

III-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

Contact person

Telephone

City

State

Share
of
2019
sales
(%)

1
2
3
4
5
6
7
8
9
10
III-23. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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

Page 34

Correcting Valid number error messages.--If you are completing a Commission questionnaire in a
country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would appear as
$1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than 999 in
numeric form fields. This issues stem from your computer number formatting setting (e.g., not the MS
Word document itself, but the computer from which you are opening up the document). In the United
States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one. Many EU
countries use the reverse where multiples of 1000 are delineated with periods (.) and fractions less than
one are delineated with commas (,). The U.S. International Trade Commission’s questionnaires are setup in the United States with the U.S. number formatting. When this formatting interacts with a
computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):






START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.

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

Page 35

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 did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	Microsoft Word - US importers--Metal lockers (P).doc
Author	Charles.Cummings
File Modified	2020-07-13
File Created	2020-07-13