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pdfOMB No. 3117‐0016/USITC No. 20‐2‐4298; Expiration Date: 6/30/2023
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U.S. IMPORTERS’ QUESTIONNAIRE
CHASSIS AND SUBASSEMBLIES FROM CHINA
This questionnaire must be received by the Commission by August 13, 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 certain chassis and subassemblies
thereof (“chassis”) from China (Inv. Nos. 701‐TA‐657 and 731‐TA‐1537 (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 chassis (as defined on next page) from any country at any time since January 1, 2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: CHAS)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on July 30, 2020, by the
Coalition of American Chassis Manufacturers, consisting of Cheetah Chassis Corporation, Fairless Hills,
Pennsylvania, Hercules Enterprises, LLC, Hillsborough, New Jersey, Pitts Enterprises, Inc., Pittsview,
Alabama, Pratt Industries, Inc., Bridgman, Michigan, and Stoughton Trailers, LLC, Stoughton, Wisconsin.
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/701731/2019/chassis_and_subassemblies_china/preliminary.htm.
Chassis are chassis and subassemblies thereof, whether finished or unfinished, whether assembled or
unassembled, whether coated or uncoated, regardless of the number of axles, designed primarily for
use in the carriage of containers, or other payloads (including self‐supporting payloads) that can be
attached by twistlocks, slide pins or similar attachment devices, for road, marine roll‐on/roll‐off (RORO)
and/or rail transport. Chassis are typically, but are not limited to, rectangular framed trailers with a
suspension and axle system, wheels and tires, brakes, a lighting and electrical system, a coupling for
towing behind a truck tractor, and a locking system or systems to secure the shipping container or
containers attached to the chassis. Subject merchandise includes, but is not limited to, the following
subassemblies:
Chassis frames, or sections of chassis frames, including kingpins or kingpin assemblies, bolsters
consisting of transverse beams with locking or support mechanisms, goosenecks, drop
assemblies, extension mechanisms and/or rear impact guards;
Running gear assemblies or axle assemblies for connection to the chassis frame, whether fixed
in nature or capable of sliding fore and aft or lifting up and lowering down, which may or may
not include suspension(s) (mechanical or pneumatic), wheel end components, slack adjusters,
axles, brake chambers, locking pins, and tires and wheels;
Landing gear (legs) or landing gear assemblies, for connection to the chassis frame, capable of
supporting the chassis when it is not engaged to a tractor; and
Assemblies and/or components that connect to the chassis frame or a section of the chassis
frame, such as, but not limited to, pintle hooks or B‐trains (which include a fifth wheel), which
are capable of connecting a chassis to a converter dolly or another chassis.
Importation of any of these subassemblies, whether assembled or unassembled, constitutes an
unfinished chassis for purposes of this investigation.
Subject merchandise also includes chassis, whether finished or unfinished, entered with or for further
assembly with components such as, but not limited to: hub and drum assemblies, brake assemblies
(either drum or disc), axles, brake chambers, suspensions and suspension components, wheel end
components, landing gear legs, spoke or disc wheels, tires, brake control systems, electrical harnesses
and lighting systems.
Processing of finished and unfinished chassis and components such as trimming, cutting, grinding,
notching, punching, drilling, painting, coating, staining, finishing, assembly, or any other processing
either in the country of manufacture of the in‐scope product or in a third‐country does not remove the
product from the scope. Inclusion of other components not identified as comprising the finished or
unfinished chassis does not remove the product from the scope.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 3
This scope excludes dry van trailers, refrigerated trailers and flatbed trailers.
The finished and unfinished chassis subject to this investigation are typically classified in the Harmonized
Tariff Schedule of the United States (HTSUS) at subheadings: 8716.39.0090 and 8716.90.5060. While the
HTSUS subheadings are provided for convenience and customs purposes, the written description of the
merchandise under investigation is dispositive.
Importer.‐‐Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing chassis (as defined above) into the United States from a foreign manufacturer or through its
selling agent.
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.‐‐If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Jordan
Harriman (202‐205‐2610, [email protected]).
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 4
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
I‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
I‐2a.
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”‐‐Each facility of a firm involved in the importation of chassis, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
I‐2b.
I‐2c.
Page 5
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
I‐3.
I‐4.
Law firm:
Lead attorney(s):
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Extent of
ownership
Firm name
Country
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing chassis from China into the United States or that are
engaged in exporting chassis from China to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
I‐5.
I‐6.
Page 6
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of chassis?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Importing operations.‐‐Please indicate the nature of your firm’s importing operations of chassis.
More than one answer may be applicable.
Importer of record
I‐7.
Takes title to the
imported product(s)
Consignee of the
imported products(s)
Customs broker or
freight forwarder
Consignee.‐‐If your firm is an importer of record of chassis 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 ‐ Chassis (Preliminary)
I‐8.
Page 7
FTZ, TIB, or bonded warehouses.‐‐Please indicate whether your firm enters chassis into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports chassis under the TIB (temporary importation under bond) program.
“Foreign trade zone” is a designated location in the United States where firms utilize special
procedures that allow delayed or reduced customs duty payments on foreign merchandise, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re‐export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item
I‐9.
No
Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond
Other trade actions.‐‐To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No
Yes
If yes, Yes–Please specify.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, [email protected]). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the importation of chassis since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 9
II‐3a. Arranged imports.‐‐Has your firm imported or arranged for the importation of chassis 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 units)
China
All other sources
II‐3b. Imports in the 12‐month period preceding the petition.‐‐Has your firm imported chassis 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 units)
Source
China
All other sources
II‐4.
July 2019 through June 2020
Reasons for importing if producer.‐‐If your firm also produces chassis in the United States,
please indicate the reasons for importing this product. If your firm’s reasons differ by source,
please elaborate.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 10
Definitions
“Unit” – For purposes of this questionnaire, a unit can be either a complete chassis imported in
fully assembled form; a set of imported subassembly parts intended for assembly into a
complete chassis; or a subassembly (see page 2) imported for individual use or sale.
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“Commercial U.S. shipments”— Shipments made within the United States as a result of an
arm’s length commercial transaction in the ordinary course of business. Report net values (i.e.,
gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” –Product consumed internally by your firm. Such transactions are
valued at fair market value. If your firm is a transportation services provider, please report
your U.S. shipments as internal consumption based on first period of time in which you put
your imported chassis to use. Do not report your fleet of chassis in the line for inventories.
“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 ‐ Chassis (Preliminary)
Page 11
II‐5a. U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of chassis imported from China by your firm during the specified periods.
China
Quantity (in units), value (in $1,000)
Calendar years
Item
2017
Beginning‐of‐period inventories
(quantity) (A)
2018
January‐March
2019
2019
2020
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
2
Value (G)
Transfers to related firms:
Quantity (H)
Value2 (I)
2
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value. If your firm is a transportation services provider,
please report your U.S. shipments as internal consumption based on first period of time in which you put your imported
chassis to use. Do not report your fleet of chassis in the line for inventories.
3
Identify your firm’s principal export markets: .
2
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
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II‐5a. 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
January‐March
Reconciliation
2017
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2018
0
2019
0
2019
0
2020
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐5b. Channels of distribution: 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 units)
Channels of distribution:
U.S. shipments:
To trucking companies and
other end users (M)
To distributors and dealers
(N)
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
January‐March
Reconciliation item
M + N – D – F – H = zero ("0"), if not
revise.
2017
2018
0
2019
0
2019
0
0
2020
0
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
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II‐5c. U.S. imports by product type: China.‐‐Report your firm’s U.S. imports from China by product
type during the specified periods.
“Finished chassis” – A complete chassis (whether assembled or unassembled).
“Subassembly” – A component of a chassis. Please see page 2 for a complete description of the
specified subassemblies below.
China
Calendar years
Item
U.S. imports:
Finished chassis:
Quantity in units (O)
2017
2018
January‐March
2019
2019
2020
Quantity in short tons(P)
Value in $1,000 (Q)
Quantity in short tons (S)
Value in $1,000 (T)
Quantity in short tons (V)
Value in $1,000 (W)
Landing gear subassemblies:
Quantity in units (X)
Quantity in short tons (Y)
Value in $1,000 (Z)
Quantity in short tons (AB)
Value in $1,000 (AC)
Subassemblies:
Chassis frames:
Quantity in units (R)
Running gear/ axle subassemblies:
Quantity in units (U)
All other subassemblies:
Quantity in units (AA)
RECONCILIATION OF IMPORTS.—Please ensure that the quantities (in units) and values reported for U.S.
imports in this question (i.e., lines O through AC) in each time period equal the quantity and values
reported for U.S. shipments in previous question II‐5a (i.e., lines B and C) 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
2020
Quantity: B – O – R – U – X – AA = zero
(“0”), if not revise
0
0
0
0
0
Value: C – Q – T – W – Z – AC = zero,
(“0”), if not revise.
0
0
0
0
0
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 14
II‐6a. Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of chassis imported from all other sources by your firm during the specified periods.
All other sources
(list sources:
)
Quantity (in units), value (in $1,000)
Calendar years
Item
2017
Beginning‐of‐period inventories
(quantity) (A)
2018
January‐March
2019
2019
2020
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
2
Value (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
2
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value. If your firm is a transportation services provider,
please report your U.S. shipments as internal consumption based on first period of time in which you put your imported
chassis to use. Do not report your fleet of chassis in the line for inventories.
3
Identify your firm’s principal export markets: .
2
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 15
II‐6a. Imports from all other sources.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
January‐March
Reconciliation
2017
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2018
0
2019
0
2019
0
2020
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐6b. Channels of distribution: All other sources.‐‐ Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution during the specified periods.
All other sources
Calendar years
Item
2017
2018
January‐March
2019
2019
2020
Quantity (in units)
Channels of distribution:
U.S. shipments:
To trucking companies and
other end users (M)
To distributors and dealers
(N)
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
January‐March
Reconciliation item
M + N ‐ D – F – H= zero ("0"), if not
revise.
2017
2018
0
2019
0
2019
0
0
2020
0
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 16
II‐6c. U.S. imports by product type: All other sources.‐‐Report your firm’s U.S. imports from all other
sources by product type during the specified periods.
“Finished chassis” – A complete chassis (whether assembled or unassembled).
“Subassembly” – A component of a chassis. Please see page 2 for a complete description of the
specified subassemblies below.
All other sources
Calendar years
Item
U.S. imports:
Finished chassis:
Quantity in units (O)
2017
2018
January‐March
2019
2019
2020
Quantity in short tons(P)
Value in $1,000 (Q)
Quantity in short tons (S)
Value in $1,000 (T)
Quantity in short tons (V)
Value in $1,000 (W)
Landing gear subassemblies:
Quantity in units (X)
Quantity in short tons (Y)
Value in $1,000 (Z)
Quantity in short tons (AB)
Value in $1,000 (AC)
Subassemblies:
Chassis frames:
Quantity in units (R)
Running gear/ axle subassemblies:
Quantity in units (U)
All other subassemblies:
Quantity in units (AA)
RECONCILIATION OF IMPORTS.—Please ensure that the quantities (in units) and values reported for U.S.
imports in this question (i.e., lines O through AC) in each time period equal the quantity and values
reported for U.S. shipments in previous question II‐5a (i.e., lines B and C) 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
2020
Quantity: B – O – R – U – X – AA = zero
(“0”), if not revise
0
0
0
0
0
Value: C – Q – T – W – Z – AC = zero,
(“0”), if not revise.
0
0
0
0
0
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
II‐7.
Page 17
Semi‐finished product analysis.‐‐Please answer the following questions regarding the
differences and similarities in complete unfinished product(s) and finished product(s) in this
proceeding as defined below:
“Finished product(s)” ‐ Complete chassis that are ready for use on road/rail/water.
“Unfinished product(s)” ‐ In‐scope subassemblies of chassis that need to be further attached to
form a complete chassis and become road/rail/water ready.
(a) Are there uses for the unfinished product(s) other than for the production of the finished
product(s)
No
Yes
If yes‐‐Please describe these uses.
(b) Is the market for unfinished product(s) separate and distinct from the market for finished
product(s)?
No
Yes
If yes‐‐Please describe how they are
separate and distinct.
(c) Are there differences in the physical characteristics and functions of the unfinished
product(s) and finished products(s)?
No
Yes
If yes‐‐Please describe these differences.
(d) Is there a significant difference in the cost or value between unfinished product(s) and
finished product(s)?
No
Yes
If yes‐‐Please describe these differences.
(e) Would you describe the processes used to transform the unfinished product(s) into the
finished product(s) as significant and particularly labor or capital intensive?
No
Yes
If yes‐‐Please describe the labor or capital
intensively of the conversion process.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
II‐8.
Page 18
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 ‐ Chassis (Preliminary)
Page 19
PART III.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Benedetto (202‐205‐
3270, [email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
PRICE DATA
III‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products your firm imported
from China:
Product 1.‐‐tandem axle gooseneck chassis for carriage of 53’ domestic containers
Product 2.‐‐tandem axle gooseneck chassis for carriage of 40’ ISO containers
Product 3.‐‐extendable tandem axle chassis for carriage of 20’ ISO containers
Product 4.‐‐triaxle chassis capable of extension for carriage of heavy 20’ up to 40’ containers
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 also be net of Federal Excise Tax. Values should reflect the final
net amount paid to your firm (i.e., should be net of all deductions for discounts or rebates).
During January 2017‐March 2020, did your firm import from 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(s) as appropriate.
No.‐‐Skip to question III‐3.
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 20
III‐2a. Price data.‐‐Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.
China
Report data in units and actual dollars (not 1,000s).
Period of shipment
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
April‐June
July‐September
October‐December
2020:
January‐March
(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity Value Quantity Value
Quantity
Value
Product 4
Quantity Value
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment. Values should also be net of Federal Excise Tax.
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:
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 21
III‐2b. Price data checklist.‐‐Please check that the pricing data in question III‐2(a) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000) and units?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in which the sale occurred?
Quantities do not exceed commercial shipments in question II‐7 in each year?
III‐2c. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
III‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales of chassis
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
III‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
III‐5.
Page 22
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of imported chassis from China usually
quoted (check one)?
Delivered
F.o.b.
III‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of chassis imported from
China in 2019 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐term
contract basis, and (4) spot sales basis?
Item
Share of 2019
sales
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
III‐7.
Page 23
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
chassis 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 Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
III‐8.
Lead times.‐‐What is your firm’s share of sales of chassis 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 chassis?
Lead time
(Average number
of days)
Source
Share of 2019 sales
From your firm’s U.S. inventory
%
From foreign manufacturers’ inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
III‐9.
Page 24
Shipping information.—
(a)
(b)
(c)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
When your firm sells chassis imported from China, from where is it shipped?
Point of importation Storage facility (check one)
Indicate the approximate percentage of your firm’s sales of chassis 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
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
III‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold chassis
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 chassis
imported from China that is accounted for by U.S. inland transportation costs? percent.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 25
III‐12. End uses.‐‐List the end uses of the chassis that your firm imports. For each end‐use product or
service, what percentage of the total cost is accounted for by chassis and other inputs?
Share of total cost of end‐use product or
service accounted for by
Total
(should sum to
End‐use product or
100.0% across)
service
Chassis
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
III‐13. Substitutes.‐‐Can other products be substituted for chassis?
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 chassis?
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 chassis has changed since January 1, 2017. Explain any trends and describe
the principal factors that have affected these changes in demand.
Overall
No
Overall Fluctuate with
increase change decrease no clear trend
Market
Explanation and factors
Within the United States
Outside the United States
III‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix or
marketing of chassis since January 1, 2017?
No
Yes
If yes, please describe.
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 26
III‐16. Conditions of competition.—
(a) Is the chassis market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to chassis?
Check all that apply.
Please describe.
No
Skip to question III‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
chassis since January 1, 2017?
No
Yes
If yes, describe.
III‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply chassis 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 ‐ Chassis (Preliminary)
Page 27
III‐18. Raw materials.—
(a) How have chassis raw material costs changed since January 1, 2017?
Factor
Overall
increase
Cost of raw materials
No
change
Explain, noting how raw
Fluctuate material price changes have
Overall with no clear affected your firm’s selling
prices for chassis.
trend
decrease
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for chassis?
Factor
Overall increase
Cost of raw materials after
section 232 tariffs imposed
No change
Fluctuate with
Overall decrease no clear trend
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for chassis?
Factor
Prices for chassis
Fluctuate
Overall
Overall
with no
Increase No change Decrease clear trend
Explanation
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 28
III‐19. Interchangeability.‐‐Are chassis produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing chassis that is sometimes or never interchangeable, identify the
country‐pair and explain the factors that limit or preclude interchangeable use:
III‐20. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between chassis produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant factor
in your firm’s sales of chassis, identify the country‐pair and report the advantages or disadvantages
imparted by such factors:
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 29
III‐21. Impact of section 301 tariffs.‐‐ Did the imposition of tariffs on Chinese‐origin products under
section 301 have an impact on the chassis market in the United States?
Yes— Please indicate the
impact in the table below.
No
Don’t know
Factor
Fluctuate Explain, noting how the imposition
with no of tariffs under section 301 affected
each factor of the chassis market in
clear
Overall
No
Overall
the United States.
trend
increase change decrease
Supply of U.S.‐
produced chassis
Supply of chassis
imported from China
Supply of chassis
imported from other
countries
Prices for chassis
Overall U.S. demand
for chassis
Raw material costs for
chassis
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U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 30
III‐22. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for chassis since January 1, 2017. Indicate the share of the quantity of your firm’s
total shipments of chassis that each of these customers accounted for in 2019.
Customer’s name
Contact person
Email
Telephone
City
State
Share
of
2019
sales
(%)
1
2
3
4
5
6
7
8
9
10
III‐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 ‐ Chassis (Preliminary)
Page 31
Correcting valid number error messages.‐‐If you are completing a Commission questionnaire
in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would appear as
$1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than 999 in
numeric form fields. This issues stem from your computer number formatting setting (e.g., not the MS
Word document itself, but the computer from which you are opening up the document). In the United
States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one. Many EU
countries use the reverse where multiples of 1000 are delineated with periods (.) and fractions less than
one are delineated with commas (,). The U.S. International Trade Commission’s questionnaires are set‐
up in the United States with the U.S. number formatting. When this formatting interacts with a
computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)
When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.
Business Proprietary
U.S. Importers’ Questionnaire ‐ Chassis (Preliminary)
Page 32
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at: LINK
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: CHAS
• E‐mail.—E‐mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non‐encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US importers--Chassis (P) |
| Author | jordan.harriman |
| File Modified | 2020-08-03 |
| File Created | 2020-08-03 |