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pdfOMB No. 3117‐0016/USITC No. 20‐4‐4300; Expiration Date: 6/30/2023
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FOREIGN PRODUCERS’/EXPORTERS’ 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.
Name of firm
Address
Website
Has your firm produced or exported chassis (as defined on next page) from China 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 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
Foreign Producers’ 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
Foreign Producers’ 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.
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,
purchaser and/or foreign producer 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]).
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
I‐1.
Page 4
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
20 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‐2.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”‐‐Each facility of a firm in China involved in the production or export of chassis,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities. Firms operating more than one establishment in China should combine the
data for all establishments into a single report.
I‐3.
I‐4.
Related producers.‐‐Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce chassis in the United States or other countries?
No
Yes
If yes, please name the firm(s) and country(ies) below and, if U.S.
producer(s), ensure that they complete the Commission’s producer
questionnaire.
Related U.S. importers.‐‐Does your firm or any related firm import or have any plans to import
chassis into the United States?
No
Yes
If yes, please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
I‐5.
I‐6.
I‐7.
Page 5
Stock symbol information.‐‐ If your firm or any of the entities reported in questions I‐2 through
I‐4 are publicly traded in the United States, please specify the stock exchange and trading
symbol (including American Depository Receipts, if applicable): .
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):
U.S. importers.‐‐Please provide the names, contacts, telephone numbers, and e‐mail addresses
of the FIVE largest U.S. importers of your firm’s chassis in 2019.
Importer’s name
Contact person
Email
Telephone
Share of your
firm’s 2019 U.S.
exports (%)
1
2
3
4
5
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
Page 6
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‐2a. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of chassis since January 1, 2017.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
Page 7
II‐2b. Anticipated changes in operations.‐‐Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of chassis in the
future?
No
Yes
If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions.
II‐3a. Production using same machinery.‐‐Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce chassis, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.‐‐If your firm does not produce any out‐of‐scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II‐8. If, however, your firm does produce out‐of‐scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II‐8 should exclude the portion of "overall production capacity" that was
used to produce this out‐of‐scope merchandise.
“Production” ‐‐All production in your establishment(s) in China, including production consumed
internally within your firm.
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
Page 8
II‐3a. Production using same machinery.‐‐Continued.
Quantity (in short tons)
Calendar years
Item
2017
1
Overall production capacity
Production of:
Chassis2
Out‐of‐scope production.‐‐
Specifically excluded chassis3
4
Other products
Subtotal, out‐of‐scope
production
Total production using
same machinery or workers
2018
January‐March
2019
2019
2020
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of chassis will populate here once reported in question II‐8.
3
Specifically excluded chassis includes dry van trailers, refrigerated trailers and flatbed trailers.
4
Please identify these products: .
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on the following
operating paramaters:
Hours per week
Weeks per year
2
II‐3c.
Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
II‐4.
Page 9
Product shifting.—
(a).
Is your firm able to switch production (capacity) between chassis and other products using
the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
(b).
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐5.
Share of sales.‐‐What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of chassis? percent.
II‐6a. Firm's estimated share of production in China.‐‐Please estimate the percentage of total production
of chassis in China accounted for by your firm’s production in 2019. percent.
II‐6b. Firm's estimated share of country's exports.‐‐Please estimate the percentage of total exports to
the United States of chassis from China accounted for by your firm’s exports in 2019.
percent.
II‐7. Third country trade actions.‐‐Is the chassis exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?
No
Yes
If yes‐‐List the products(s), countries affected, and the date of such
findings/remedies/proceedings.
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
II‐8.
Page 10
Trade data.‐‐Report your firm’s production capacity, production, shipments, and inventories
related to the production of chassis in your establishment(s) in China during the specified
periods. Do not include resales of chassis that your firm did not produce in this question; those
data to the degree they are exported to the United States should only be reported in question II‐
9.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” ‐‐All production in your establishment(s) in China, including production consumed
internally within your firm.
“Shipments”‐‐Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”‐‐Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”‐‐Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”‐‐Shipments to destinations outside of the country indicated on page 1
(China), 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
Foreign Producers’ Questionnaire – Chassis (Preliminary)
II‐8.
Page 11
Trade data.‐‐Continued.
Quantity (in short tons)
Actual experience
Calendar year
Item
2017
2
2018
Projections1
January‐March
2019
2019
2020
Calendar year
2020
2021
Average production capacity (A)
Beginning‐of‐period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
(D)
Total exports (H)
(should equal F+G)
0
0
0
0
0
0
0
Total shipments (I)
(should equal D+E+F+G)
0
0
0
0
0
0
0
Commercial shipments (E)
Exports to the United States (F)
3
Exports to all other markets (G)
End‐of‐period inventories (J)
1
Please explain the basis for your firm’s projections. .
The production capacity reported is based on operating hours per week, weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity. .
3
Identify principal other export markets. .
2
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line J) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, E, F, and G). 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.
Actual experience
Projections
Calendar year
Item
2017
2018
January‐March
2019
2019
2020
Calendar year
2020
2021
B + C – D – E – F –G – J = should equal
zero ("0") or provide an explanation.1
0
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
0
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
II‐9.
Page 12
Exports to the United States not produced by your firm.‐‐Report your firm’s exports to the
United States of chassis that was produced in China but not by your firm during the specified
periods. Note these data should not be included in question II‐8.
Quantity (in short tons)
Actual experience
Calendar year
Item
Exports of chassis to the United
States not produced by your
firm1
2017
2018
Projections
January‐March
2019
2019
2020
Calendar year
2020
2021
1
List the producer(s). .
II‐10. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
Page 13
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 USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.
Business Proprietary
Foreign Producers’ Questionnaire – Chassis (Preliminary)
Page 14
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 your 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 produce or export 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, you are 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 - Foreign producers--Chassis (P) |
Author | jordan.harriman |
File Modified | 2020-08-03 |
File Created | 2020-08-03 |