Form 20-1-4309 U.S. producers' questionnaire

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

US producers--Wood mouldings (F)

Wood mouldings and millwork products from Brazil and China (Inv. nos. 701-TA-636 and 731-TA-1469-1470) Final

OMB: 3117-0016

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U.S. PRODUCERS’ QUESTIONNAIRE
WOOD MOULDINGS AND MILLWORK PRODUCTS FROM BRAZIL AND CHINA
This questionnaire must be received by the Commission by October 5, 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 and antidumping duty investigations concerning wood mouldings and millwork
products from Brazil and China (Inv. Nos. 701-TA-636 and 731-TA-1469-1470 (Final)). The information requested in the
questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to
reply as directed can result in a subpoena or other order to compel the submission of records or information in your
firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced wood mouldings and millwork products (as defined on pages 2-3) or MDF mouldings
and millwork products (as defined on page 3) 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: WOOD)
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

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

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PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to petitions filed on January 8, 2020, by the
Coalition of American Millwork Producers. 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/wood_mouldings_and_millwork_products_brazil_a
nd/final.htm.
Wood mouldings and millwork products (WMMP) covered by these investigations consist of wood
mouldings and millwork products that are made of wood (regardless of wood species), bamboo,
laminated veneer lumber (LVL), or of wood and composite materials (where the composite materials
make up less than 50 percent of the total merchandise), and which are continuously shaped wood or
finger-jointed or edge-glued moulding or millwork blanks (whether or not resawn). The merchandise
subject to these investigations can be continuously shaped along any of its edges, ends, or faces.
The percentage of composite materials contained in a wood moulding or millwork product is measured
by length, except when the composite material is a coating or cladding. Wood mouldings and millwork
products that are coated or clad, even along their entire length, with a composite material, but that are
otherwise comprised of wood, LVL, or wood and composite materials (where the non-coating composite
materials make up 50 percent or less of the total merchandise) are covered by the scope.
The merchandise subject to these investigations consists of wood, LVL, bamboo, or a combination of
wood and composite materials that is continuously shaped throughout its length (with the exception of
any endwork/dados), profiled wood having a repetitive design in relief, similar milled wood architectural
accessories, such as rosettes and plinth blocks, and fingerjointed or edge-glued moulding or millwork
blanks (whether or not resawn). The scope includes continuously shaped wood in the forms of dowels,
building components such as interior paneling and jamb parts, and door components such as rails, stiles,
interior and exterior door frames or jambs (including split, flat, stop applied, single- or doublerabbeted), frame or jamb kits, and packaged door frame trim or casing sets, whether or not the door
components are imported as part of a door kit or set.
The covered products may be solid wood, laminated, finger-jointed, edge-glued, face-glued, or
otherwise joined in the production or remanufacturing process and are covered by the scope whether
imported raw, coated (e.g., gesso, polymer, or plastic), primed, painted, stained, wrapped (paper or
vinyl overlay), any combination of the aforementioned surface coatings, treated, or which incorporate
rot-resistant elements (whether wood or composite). The covered products are covered by the scope
whether or not any surface coating(s) or covers obscures the grain, textures, or markings of the wood,
whether or not they are ready for use or require final machining (e.g., endwork/dado, hinge/strike
machining, weatherstrip or application thereof, mitre) or packaging.
All wood mouldings and millwork products are included within the scope even if they are trimmed; cutto-size; notched; punched; drilled; or have undergone other forms of minor processing.
Subject merchandise also includes wood mouldings and millwork products that have been further
processed in a third country, including but not limited to trimming, cutting, notching, punching, drilling,
coating, or any other processing that would not otherwise remove the merchandise from the scope of
the investigations if performed in the country of manufacture of the in-scope product.

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Excluded from the scope of these investigations are countertop/butcherblocks, exterior fencing, exterior
decking and exterior siding products (including solid wood siding, non-wood siding (e.g., composite or
cement), and shingles) that are not LVL or finger jointed; finished and unfinished doors; flooring; parts of
stair steps (including newel posts, balusters, easing, gooseneck, risers, treads, rail fittings and stair
stringers); picture frame components three feet and under in individual lengths; and lumber whether
solid, finger-jointed, or edge-glued. To be excluded from the scope, finger-jointed or edge-glued lumber
must have a nominal thickness greater than 1.5 inches and a certification stamp from an American
Lumber Standard Committee-certified grading bureau. The exclusion for lumber whether solid, fingerjointed, or edge-glued does not apply to screen/”surfaced on 4 sides” (S4S) and/or “surface 1 side, 2
edges” (SlS2E) stock (also called boards) that are finger-jointed, edge-glued mouldings, or millwork
blanks (whether or not resawn).
Excluded from the scope of these investigations are all products covered by the scope of the
antidumping duty order on Hardwood Plywood from the People’s Republic of China. See Certain
Hardwood Plywood Products from the People’s Republic of China: Amended Final Determination of Sales
at Less Than Fair Value, and Antidumping Duty Order, 83 FR 504 (January 4, 2018).
Excluded from the scope of these investigations are all products covered by the scope of the
antidumping duty order on Multilayered Wood Flooring from the People’s Republic of China. See
Multilayered Wood Flooring from the People’s Republic of China: Amended Final Determination of Sales
at Less Than Fair Value and Antidumping Duty Order, 76 FR 76690 (December 8, 2011).
Excluded from the scope of these investigations are all products covered by the scope of the
antidumping duty order on Wooden Cabinets and Vanities from the People’s Republic of China. See
Wooden Cabinets and Vanities and Components Thereof from the People’s Republic of China:
Antidumping Duty Order, 85 FR 22126 (April 21, 2020).
Excluded from the scope of these investigations are all products covered by the scope of the
antidumping duty order on Wooden Bedroom Furniture from the People’s Republic of China. See Notice
of Amended Final Determination of Sales at Less Than Fair Value and Antidumping Duty Order: Wooden
Bedroom Furniture from the People’s Republic of China, 70 FR 329 (January 4, 2005).
Imports of wood mouldings and millwork products are primarily entered under the following
Harmonized Tariff Schedule of the United States (HTSUS) numbers: 4409.10.4010, 4409.10.4090,
4409.10.4500, 4409.10.5000, 4409.22.4000, 4409.22.5000,4409.29.4100, and 4409.29.5100. Imports of
wood mouldings and millwork products may also enter under HTSUS numbers:
4409.10.6000,4409.10.6500, 4409.22.6000, 4409.22.6500, 4409.29.6100, 4409.29.6600, 4418.20.4000,
4418.20.8030, 4418.20.8060, 4418.99.9095 and 4421.99.9780. While the HTSUS subheadings are
provided for convenience and customs purposes, the written description of the scope of these
investigations is dispositive.
Laminated veneer lumber (LVL) wood mouldings and millwork products are manufactured by
laminating thin wood veneers with the grains parallel to the length of the billet; glue is applied, veneers
are fed into a press, and then formed into a stack that is subjected to pressure and heat for curing. The
cured LVL billets are then ripped and crosscut to ready them for further processing. In this
questionnaire, data for LVL wood mouldings and millwork products should be included in the overall
data for wood moulding and millwork products as reported on in parts II, III and IV of this questionnaire,
as well as separately reported by themselves in part VI of this questionnaire.
Medium density fiberboard (MDF) mouldings and millwork products (MMP) are engineered wood
products made with sawdust and shavings, the byproducts of industrial milling, broken down into fibers.

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These fibers are mixed with resin and wax and under heat and pressure, they are formed into uniform
panels. In this questionnaire, data for MDF mouldings and millwork products should not be included in
the overall data for wood moulding and millwork products as reported on in parts II, III and IV of this
questionnaire, and solely separately reported by themselves in part VII of this questionnaire.
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.
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.

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

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Firm type
Producers

Definitions
Firms that mill their own wood blanks for use in the production of wood
mouldings and millwork products.
Finisher (back end)
Firms that do not mill their own wood blanks but rather domestically purchase
only
and/or import wood blanks for use in the production of wood mouldings and
millwork products.
Both producer and
Firms that mill their own wood blanks for use in the production of wood
finisher (back end)
mouldings and millwork products as well as domestically purchase and/or import
only
wood blanks for use the production of wood mouldings and millwork products.
LVL WMMP producer Firms that produce laminated veneer lumber (LVL) wood mouldings and millwork
products.
MDF MMP producer
Firms that produce medium density fiberboard (MDF) mouldings and millwork
products (MMP).
Using the definitions above, please complete the questionnaire sections as checked in the matrix below.

Producers
Part I: General information
Part II: Trade/ related information
Part III: Financial information
Part IV: Pricing/ Market Factors






Part V: Finisher (back end only)

1

Finisher
(back end
only)2






Producer
and
Finisher
(back end
only)3


*
*
*
**

LVL
WMMP
producer4










Part VI: LVL WMMP information
Part VII: MDF MMP information
Part VIII: Product Comparability

MDF MMP
producer5









†


For firms that are producers and do not produce LVL WMMP or MDF MMP, please only complete parts I
through IV and part VIII.
2.
For firms that only domestically purchase and/or import wood blanks and do not produce their own wood
blanks, please only complete parts I, IV, V, and VIII.
3.
For firms that mill their own wood blanks and domestically purchase and/or import wood blanks, please
only report data for which your firm milled its own blanks in parts II, III, and IV (*) and only report data for
which your firm domestically purchased or imported blanks in part V (**), and complete part VIII.
3.
For firms that produce LVL MMP, parts II, III, and IV should contain data for both LVL MMP and all other in
scope WMMP (♦) and part VI should contain data only related to LVL MMP production (♦♦). Please also
complete part VIII.
4.
For firms that produce MDF MMP, data related to MDF MMP production should only be reported in part
VII (†). If your firm also produces in scope WMMP, please complete the other sections following the instructions
in the other columns. Please also complete part VIII.
1.

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
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Page 6

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

Dollars

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

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

No

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
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Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of wood mouldings and
millwork products, including auxiliary facilities operated in conjunction with (whether or not
physically separate from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
7
8
9
10
1

Additional discussion on establishments consolidated in this questionnaire:

.

I-2b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-2c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):

I-3.

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

Yes

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
I-4.

Page 8

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

Support

Oppose

Take no position

Brazil AD
China AD
China CVD
I-5.

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

Firm name

I-6.

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

Country

Extent of
ownership
(percent)

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

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
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Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of wood mouldings and millwork products?
No
Firm name

Yes--List the following information.
Country

Affiliation

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PART II. —TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202-2052136, [email protected]). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of wood mouldings and millwork products since January 1,
2017.
(If checked, please describe the nature, date(s), and significance
of any such reported changes as well as the business reasons for
(check as many as appropriate) them; leave completely blank if not applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

Overall production capacity

2017

2018

January-June
2019

2019

2020

1

Production of:
Wood mouldings and millwork
products2

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Out-of-scope production.-MDF mouldings and millwork
products3
Other products4
Subtotal, out-of-scope
production
Total production using
same machinery or workers

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of wood mouldings and millwork products will populate here once reported in
question II-7.
3
If your firm produces MDF mouldings and millwork products, please also complete section VII of this questionnaire.
If your firm produces MDF mouldings and millwork products on the same machinery or using the same employees as
wood mouldings and millwork products, the data reported in this question and section VII of this questionnaire should
match. Do the data in this question and in section VII match?
Yes
No. If no, please describe:
.
4
Please identify these products:
.
1
2

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

Weeks per year

II-3c.

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

II-3d.

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

II-4.

Product shifting.—
(a)

Is your firm able to switch production (capacity) between wood mouldings and millwork
products 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.

(c)

Is your firm able to shift between LVL WMMP and all other WMMP and/or other products?

No

Yes

If yes, please describe this ability to shift between these two groups of inscope wood mouldings and millwork products, and indicate the degree to
which there are any factors that enhance or constrain such ability.

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

No

II-6.

Yes

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

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

(a)

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

No

Yes

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

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

(b)

No

Yes

If yes--Identify the firms and the FTZs.

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
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Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of wood mouldings and millwork products
in its U.S. establishment(s) during the specified periods. Please exclude any production using
unfinished wood mouldings and millwork products (blanks), those data are to be reported in
part V.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption/ including product shipped to firm’s own retail establishments”-Product consumed internally by your firm, which includes merchandise that your firm
transferred to your own firm’s retail establishments (i.e., shipped to either a bricks-and-mortar
store or to an online order fulfillment center). 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 or using a third-party fulfillment center to place retail level sales.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

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

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II-7.

Page 15

Production, shipment, and inventory data.
Quantity (in board feet) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Average production capacity (quantity)
(A)
1

Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including for
own retail establishments: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)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1

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

2017

2018
0

January-June
2019

0

2019
0

2020
0

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

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-8.

Page 16

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

2017

2018

January-June
2019

2019

2020

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 through O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D – F – H = zero ("0"), if
not revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-9.

Page 17

U.S. shipments by material.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of wood mouldings and
millwork products, by material in the specified periods.
Quantity (in board feet), Value (dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

U.S. shipments:
Pine1
Quantity (P)
Value (Q)
Fir

2

Quantity (R)
Value (S)

Other softwoods3
Quantity (T)
Value (U)
Hardwoods4
Quantity (V)
Value (W)
Other (non-MDF
wood/composite materials)5
Quantity (X)
Value (Y)
Please identify the pine species:
Please identify the fir species:
3.
Please identify the other softwood species:
4.
Please identify the hardwood species:
3.
Please identify the other non-MDF wood/composite material types (e.g., LVL, combination/composites):
Note that MDF products should not be reported in these lines. MDF data should only be reported in Part VII.
1.
2.

.

RECONCILIATION OF U.S. SHIPMENTS BY MATERIAL.--Please ensure that the quantities and values
reported for U.S. shipments by material (i.e., lines P through Y) in each time period equal the quantity
and value reported for U.S. shipments (i.e., lines D through I) in each time period. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to submission to
the Commission.

Reconciliation
Quantity: P + R + T + V + X – D - F- H =
zero ("0"), if not revise.
Value: Q+ S + U + W +Y – E - G- I = zero
("0"), if not revise.

Calendar year
2018

2017

January-June
2019
2020

2019

0

0

0

0

0

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-10.

Page 18

U.S. shipments by product.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) of wood mouldings and
millwork products, by product.
Quantity (in board feet), Value (dollars)
Calendar years
Item

2017

2018

U.S. shipments:
Blanks:1
Quantity (Z)
Value (AA)
Door frames/jambs:
Quantity (AB)
Value (AC)
Door/window casings, trim
(excluding S1S2E), and base
boards:
Quantity (AD)
Value (AE)
S1S2E:
Quantity (AF)
Value (AG)
Crown/cove mouldings:
Quantity (AH)
Value (AI)
Base caps/corner guards:
Quantity (AJ)
Value (AK)
Corbels, plinths, rosettes, and
appliques:
Quantity (AL)
Value (AM)
Custom milled pieces:
Quantity (AN)
Value (AO)
Other in-scope products2
Quantity (AP)
Value (AQ)
1
2

Please identify your firm’s largest purchasers of blanks:
Please identify these products:
.

.

January-June
2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-10.

Page 19

U.S. shipments by product. —Continued.

RECONCILIATION OF U.S. SHIPMENTS BY PRODUCT.--Please ensure that the quantities and values
reported for U.S. shipments by material (i.e., lines Z through AQ) in each time period equal the quantity
and value reported for U.S. shipments (i.e., lines D through I) in each time period. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to submission to
the Commission.
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Quantity: Z + AB + AD + AF + AH +
AJ + AL + AN + AP – D – F – H = zero
("0"), if not revise.

0

0

0

0

0

Value: AA + AC +AE + AG + AI + AK
+AM +AO + AQ – E – G– I = zero
("0"), if not revise.

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-11.

Page 20

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

2017

2018

January-June
2019

2019

2020

Average number of PRWs (number)
Hours worked by PRWs (hours).-Relating to milling operations
(i.e., creating blanks)
Relating to finishing operations
(i.e., processing blanks)
Wages paid to PRWs (hours)
Explanation of trends:

II-12.

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-13.

Page 21

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

No

Yes

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-13.

Page 22

Purchases. —Continued.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
Quantity (in board feet), Value (dollars)

Calendar years
Item

2017

2018

January-June
2019

2019

2020

Purchases from U.S. importers of
wood mouldings and millwork
products from—
Brazil: Araupel S.A.
Quantity
1

Value
Brazil: Braslumber Industria de
Molduras Ltda./ BrasPine
Madeiras Ltda.
Quantity
Value
Brazil: All other firms
Quantity
Value
China
Quantity
Value
Chile
Quantity
Value
All other sources
Quantity
Value
Purchases from domestic producers2
Quantity
Value
Purchases from other sources3
Quantity
Value
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.
1

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
II-14

Page 23

Conversion into board feet.--Are the quantity data reported in part II properly reported in board
feet?
No.--Please revise your questionnaire to report your firm’s data in the requested measure
(board feet) prior to submission to the Commission.
Yes.--Please indicate how your firm came up with its quantity data in the requested measure
(board feet).
Method

Description of methodology

Firm’s records maintained in
board feet

Not applicable

Firm specific conversion
factor or estimates based on
specific products produced
Other
II-15.

Imports.--Since January 1, 2017, has your firm imported wood mouldings and millwork
products?
No

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

II-16.

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 24

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

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

III-2.

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

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

B.1.

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

2.
3.

4.

Does your firm prepare profit/loss statements for wood mouldings and millwork
products:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
IFRS,
cash,
tax, or
other
comprehensive basis of accounting (specify)

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes wood mouldings and
millwork products, as well as specific statements and worksheets) used to compile these data.

III-3.

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 25

III-4.

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

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced wood mouldings and millwork products and provide the share of net sales accounted
for by these products in your firm’s most recent fiscal year.
Products

Share of sales

Wood mouldings and millwork products

%
%
%
%
%

III-6.

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

No—Skip to question III-8.

III-7a. Inputs from related suppliers detailed.--Please identify the inputs used in the production of
wood mouldings and millwork products that your firm purchases from related suppliers and that
are reflected in question III-9a. For “Share of total COGS” please report this information by
relevant input on the basis of your most recently completed fiscal year. For “Input valuation”
please describe the basis, as recorded in your company’s own accounting system, of the
purchase cost from the related supplier; e.g., the related supplier’s actual cost, cost plus,
negotiated transfer price to approximate fair market value.
Input

Related supplier

Share of total COGS

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 26

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

Yes

III-8.

No

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

By-products—Producers.—State how your firm classifies revenues from the sales of residual
wood chips, barks, shavings, sawdust, and other products produced during the course of
producing wood mouldings and millwork products as:
Co-Product or
By-Product
If your answer is “By-Product”, report the revenues associated with the sale or transfer of such
by-products for your firm’s three most recently completed fiscal years, and for the specified
interim periods. Note: the data provided below will appear in question III-9a as a reduction to
COGS
Value (in dollars)
Fiscal years
Item
By-product sales revenue

2017

2018

January-June
2019

2019

2020

1

Please describe how your firm classifies these by-product revenues in the normal course
of business (e.g., included in net sales values, as a reduction to COGS, included in “all other
income”).
1

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 27

III-9a. Operations on wood mouldings and millwork products—Producers.--Report the revenue and
related cost information requested below on the wood mouldings and millwork products
operations of your firm’s U.S. establishment(s).1 Do not report resales of products and do not
report operations relating to the finishing of purchased or imported blanks. Note that internal
consumption and transfers to related firms must be valued at fair market value. Input
purchases from related suppliers should be consistent with and based on information in the
firm’s accounting books and records. Provide data for your firm’s three most recently
completed fiscal years, and for the specified interim periods. If your firm was involved in tolling
operations (either as the toller or as the tollee), please contact Emily Kim at (202) 205-1800
before completing this section of the questionnaire.
Quantity (in board feet) and value (in dollars)
January-June

Fiscal years
Item

2017

2018

2019

2019

2020

Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

Net sales values:2
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Direct labor
Other factory costs
Less: by-product revenue

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

2

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

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

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

Input

Share of total
raw material
costs (percent)

Primarily
produced by
your firm

Primarily
purchased by
your firm

Pine
Fir
Wood inputs Other softwood
Hardwood
Other1
Adhesives
Primer/coating materials
Other material inputs2
Total (should sum to 100 percent)

0.0

Please indicate any other notable "other" wood inputs not expressly identified above (e.g.,
LVL, combination/composites) and provide the share of the total raw material costs that they
account for:
.
2
Please indicate any other notable "other" raw materials not expressly identified above and
provide the share of the total raw material costs that they account for:
.
1

III-9c.

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

Yes

No

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

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 29

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

2017

2018

January-June
2019

2019

2020

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

Income statement classification
of the nonrecurring item

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.

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

2017

2018

2019

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

III-13a. Capital expenditures and research and development expenses—Producers.--Report your
firm’s capital expenditures and research and development (“R&D”) expenses for wood
mouldings and millwork products. Provide data for your firm’s three most recently completed
fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years
Item

2017

2018

January-June
2019

2019

2020

Capital expenditures
R&D expenses
III-13b. Description of reported capital expenditures.--Describe the nature, focus, and significance of
your firm’s reported capital expenditures. If no capital expenditure data were reported, explain
the reason.

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

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

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on the same
fiscal year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in Part II equal the quantities and values reported for total net sales in Part III of this
questionnaire in each time period unless the financial data from Part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years
Reconciliation

2017

2018

January-June
2019

2019

2020

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

0

0

0

0

0

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

0

0

0

0

0

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

No

If no, please explain.

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 32

If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of wood mouldings and millwork products from Brazil and China?
No

Yes

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

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

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

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

Yes

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

(check as many as appropriate)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other

(please describe)

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U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

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III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
wood mouldings and millwork products from Brazil and China?
No

Yes

If yes, my firm anticipates negative effects as follows.

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

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PART IV. —PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Andrew Knipe (202-2052390, [email protected]).
IV-1.

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

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2017 of the following products produced by your
firm.
Product 1.--Finger-jointed lineal board, made of pine/ fir, with dimensions of 23/32” x 5- 1/2”,
S4S, primed or coated.
Product 2.--Finger-jointed lineal trim, made of pine/fir, nominal 11/16” x nominal 2-1/4”,
WM356 casing, primed or coated.
Product 3.--Finger-jointed lineal trim, made of pine/fir, 11/16” x 11/16”, WM-106, primed or
coated.
Product 4.--Jamb: Exterior door frame, made of pine/fir, nominally 1-1/4” thick with a nominal
½” rabbeted drop for door stop x nominal 4-9/16” width x nominal 7’ long and
machined with end dadoes for threshold and head attachment, primed or coated,
without a composite or otherwise rot-proof bottom.
Product 5.--Jamb: Adjustable interior door frame (split jambs), made of pine/fir, consisting of
two pieces, one called female and the other called male, nominally 1-1/16” thick x
nominal 4-9/16” width x nominal 7’ long and machined with end top dado for
threshold and head attachment, primed or coated.
Product 6.--Brick moulding: Casing, made of pine/fir, that attaches to exterior edge of door
frame, nominally 1-1/4” thick x 2” wide and 7’ long with moulded profile on face,
primed or coated, without a composite or otherwise rot-proof bottom.

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

(Quantity in lineal feet, value in dollars)
Product 2
Value
Quantity
Value

Product 3
Period of shipment
Quantity
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
April-June
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment. Please subtract any discounts, rebates, and returns from the quarter in which the sale occurred.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:

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IV-2b. Price data.—Continued. Report below the quarterly price data1 for pricing products2 produced
and sold by your firm. NOTE: Please report the quantity of pricing products 4-6 in number of
units.
Report data in number of units and actual dollars (not 1,000s).
(Quantity in number of units, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Period of shipment
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
April-June
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment. Please subtract any discounts, rebates, and returns from the quarter in which the sale occurred.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
Product 6:

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

√ if Yes

Values in actual dollars (not $1,000)?
Quantities of products 1-3 in lineal feet ?
Quantities of products 4-6 in number of 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?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-2d. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data. Include in your description how you converted the
quantity data to lineal feet if your firm normally prices using board feet or pieces.

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
IV-3.

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

IV-4.

Contracts

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of domestic wood mouldings and millwork
products usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 39

F.o.b.

If f.o.b., specify point

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

Item
Share of 2019
sales

Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)

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

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
IV-7.

Page 40

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

IV-8.

.

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

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

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
IV-9.

Page 41

Shipping information.-(a)

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

(b)

Indicate the approximate percentage of your firm’s sales of wood mouldings and
millwork products that are delivered the following distances from its production facility.
Distance from production facility

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

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

√ if applicable

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

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Page 42

IV-12. Substitutes.--Can other products be substituted for wood mouldings and millwork products?
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 wood mouldings and
millwork products?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.-(a)

Indicate how demand within the United States and outside of the United States (if
known) for wood mouldings and millwork products has changed since January 1, 2017.
Explain any trends and describe the principal factors that have affected these changes in
demand (i.e. product changes, increase/decrease in the use of substitutes, the COVID-19
pandemic, other economic factors, etc.).

Overall
increase

Market

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within the U.S.
Outside the U.S.
(b)

Indicate how demand within the United States and outside of the United States (if
known) for MDF mouldings and millwork products has changed since January 1, 2017.
Explain any trends and describe the principal factors that have affected these changes in
demand (i.e. product changes, increase/decrease in the use of substitutes, the COVID-19
pandemic, other economic factors, etc.).

Market
Within the U.S.
Outside the U.S.

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of wood mouldings and millwork products since January 1, 2017?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a)

Is the wood mouldings and millwork products market subject to business cycles (other
than general economy-wide conditions) and/or other conditions of competition
distinctive to wood mouldings and millwork products? If yes, describe.

Check all that apply.

Please describe.

No

Skip to question IV-16.

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

If yes, have there been any changes in the business cycles or conditions of competition
for wood mouldings and millwork products since January 1, 2017?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply wood mouldings
and millwork products 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. Please also identify the reason(s) your firm
experienced supply constraints (i.e. limited capacity, unscheduled
shutdown in operations, the COVID-19 pandemic, etc.).

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IV-17. Raw materials.--How have wood mouldings and millwork products 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 wood
mouldings and millwork products.

IV-18. Interchangeability.--Are wood mouldings and millwork products 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

Brazil

China

Chile

Other countries

United States
Brazil
China
Chile
For any country-pair producing wood mouldings and millwork products that are
sometimes or never interchangeable, identify the country-pair and explain the factors
that limit or preclude interchangeable use:

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Page 45

IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wood mouldings and
millwork products 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

Brazil

China

Chile

Other countries

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

IV-20. Gesso coating.--Approximately what percentage are of your 2019 sales of wood mouldings and
millwork products were offered with an extruded gesso coating?
percent
IV-21. Species importance.--How important is wood species to your customers?
Very
Somewhat
Not
important important important

Explanation and factors

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IV-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for wood mouldings and millwork products since January 1, 2017. Indicate the share
of the quantity of your firm’s total shipments of wood mouldings and millwork products that
each of these customers accounted for in 2019.
Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2019
sales (%)

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Page 47

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

Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling wood
mouldings and millwork products from Brazil and China, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2017: Did your firm lose sales of wood mouldings and
millwork products to imports of this product from Brazil and China?
No

Yes

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

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PART V.—FINISHER (BACK END) ONLY OPERATIONS
Address questions on this part of the questionnaire to Keysha Martinez (202-205-2136,
[email protected]) and/or Emily Kim (202-205-1800, [email protected]).
V-1.

Production, shipment, and inventory data for finishing production activities.--Report your
firm’s production capacity, production, shipments, and inventories related to the production of
wood mouldings and millwork products in its U.S. establishment(s) using imported and/or
domestic blanks or unfinished wood mouldings or millwork products during the specified
periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption/ including product shipped to firm’s own retail establishments”-Product consumed internally by your firm, which includes merchandise that your firm
transferred to your own firm’s retail establishments (i.e., shipped to either a bricks-and-mortar
store or to an online order fulfillment center). 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 or using a third-party fulfillment center to place retail level sales.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

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

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V-1.

Page 49

Production, shipment, and inventory data for finishing production activities
Quantity (in board feet) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Average production capacity (quantity)
(A)
1

Beginning-of-period inventories
(quantity) (B)
Production (finishing).—
Using purchased domestic blanks
(quantity) (C)
Using purchased/imported Chinese
blanks (quantity) (D)
Using purchased/imported Brazilian
blanks (quantity) (E)
Using purchased/imported Other
blanks (quantity) (F)
Total production (finishing)
(quantity)

0

0

0

0

0

U.S. shipments:
Commercial shipments:
Quantity (G)
Value (H)
Internal consumption:2
Quantity (I)
Value2 (J)
Transfers to related firms:2
Quantity (K)
Value2 (L)
Export shipments:3
Quantity (M)
Value (N)
End-of-period inventories (quantity) (O)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1

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Page 50

Production, shipment, and inventory data for finishing production activities—Continued.

V-1.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line O) should be equal to the beginning-of-period inventories (i.e., line B), plus total
production (i.e., line F), less total shipments (i.e., lines G, I, K, and M). Please ensure that any differences are
not due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also
provide explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation

2017

2018

B+C+D+E+F–G–I–K–M–O=
should equal zero ("0") or provide an
explanation.1

0

January-June
2019

0

2019

0

2020

0

0

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

V-2.

Channels of distribution for production activities involving domestic and/or imported blanks
or unfinished wood mouldings or millwork products.--Report your firm’s U.S. shipments
produced with unfinished wood mouldings or millwork products (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in board feet)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Channels of distribution:
U.S. shipments:
To distributors (P)
To retailers (Q)
To end users (R)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines P through R) in each time period equal the quantity reported for U.S. shipments (i.e., lines G, I, K) 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
P + Q + R – G – I– K = zero ("0"), if not
revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

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V-3.

Page 51

U.S. shipments by material for finishing production activities.--Report your firm’s U.S.
shipments produced with domestic and/or imported blanks or unfinished wood mouldings or
millwork products (i.e. inclusive of commercial U.S. shipments, internal consumption, and
transfers to related firms) of wood mouldings and millwork products, by material in the
specified periods.
Quantity (in board feet), Value (dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

U.S. shipments:
Pine1
Quantity (S)
Value (T)
Fir

2

Quantity (U)
Value (V)

Other softwoods3
Quantity (W)
Value (X)
Hardwoods4
Quantity (Y)
Value (Z)
Other (non-MDF
wood/composite materials)5
Quantity (AA)
Value (AB)
Please identify the pine species:
Please identify the fir species:
3.
Please identify the other softwood species:
4.
Please identify the hardwood species:
5.
Please identify the other non-MDF wood/composite material types (e.g., LVL, combination/composites):
Note that MDF products should not be reported in these lines. MDF data should only be reported in Part VII.
1.
2.

.

RECONCILIATION OF SHIPMENTS BY MATERIAL.--Please ensure that the quantities and values reported
for shipments by material (i.e., lines S through AB) in each time period equal the quantity and value
reported for U.S. shipments (i.e., lines G through N) 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.

Reconciliation
Quantity: S + U + W + Y + AA – G –
I– K = zero ("0"), if not revise.
Value: T + V + X + Z + AB – H – J – L
= zero ("0"), if not revise.

Calendar year
2018

2017

January-June
2019
2020

2019

0

0

0

0

0

0

0

0

0

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-4.

Page 52

U.S. shipments by product for finishing production activities.--Report your firm’s U.S.
shipments produced with domestic and/or imported blanks or unfinished wood mouldings or
millwork products (i.e. inclusive of commercial U.S. shipments, internal consumption, and
transfers to related firms) of wood mouldings and millwork products, by product.
Quantity (in board feet), Value (dollars)
Calendar years
Item

2017

U.S. shipments:
Door frames/jambs
Quantity (AC)
Value (AD)
Door/window casings, trim (excluding S1S2E),
and base boards
Quantity (AE)
Value (AF)
S1S2E
Quantity (AG)
Value (AH)
Crown/cove mouldings
Quantity (AI)
Value (AJ)
Base caps/corner guards
Quantity (AK)
Value (AL)
Corbels, plinths, rosettes, and appliques
Quantity (AM)
Value (AN)
Custom milled pieces
Quantity (AO)
Value (AP)
Other in-scope products1
Quantity (AQ)
Value (AR)
1

Please identify these products:

.

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 53

RECONCILIATION OF U.S. SHIPMENTS BY PRODUCT.--Please ensure that the quantities and values
reported for U.S. shipments by material (i.e., lines X through AC) in each time period equal the quantity
and value reported for U.S. shipments (i.e., lines G through N) 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.

Reconciliation
Quantity: AC + AE + AG + AI + AK + AM + AO
+ AQ + – G – I– K = zero ("0"), if not revise.
Value: AD + AF + AH +AJ + AL + AN + AP +
AR + – H – J – L = zero ("0"), if not revise.
V-5.

Calendar year
2018

2017

January-June
2019
2020

2019

0

0

0

0

0

0

0

0

0

0

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

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

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 54

V-5.

Employment data.—Continued.
Explanation of trends:

V-6.

Operations on wood mouldings and millwork products—Finishers only.--Report the revenue
and related cost information requested below on the wood mouldings and millwork products
operations of your firm’s U.S. establishment(s).1 Do not report resales of blanks on which your
firm did not conduct any moulding and finishing activities. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books and
records. Provide data for your firm’s three most recently completed fiscal years, and for the
specified interim periods. If your firm was involved in tolling operations (either as the toller or as
the tollee), please contact Emily Kim at (202) 205-1800 before completing this section of the
questionnaire.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-6.

Page 55

Operations on wood mouldings and millwork products—Finishers only.—Continued.
Quantity (in board feet) and value (in dollars)
Fiscal years
Item

2017

January--June

2018

2019

2019

2020

quantities:2

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

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

values:2

Net sales
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
(COGS):3

Cost of goods sold
Raw materials.—
Purchases of domestically manufactured blanks
Purchases or imports of blanks from Brazil
Purchases or imports of blanks from China
Purchases or imports of blanks from other
sources (i.e., sources other than Brazil and
China)4
Cost of blanks
Other raw material

costs4

Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 Please indicate any other notable "other" raw materials not expressly identified above and provide the share of the total raw
material costs that they account for:
.
1

2

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-7.

Page 56

Nonrecurring items (charges and gains) included in the subject product financial results—
Finishers only.--For each annual and interim period for which financial results are reported in
question V-6, please specify all material (significant) nonrecurring items (charges and gains) in
the schedule below, the specific question V-6 line item where the nonrecurring items are
included, a brief description of the relevant nonrecurring items, and the associated values (in
$1,000), as reflected in question V-6; i.e., if an aggregate nonrecurring item has been allocated
to question V-6, only the allocated value amount included in question V-6 should be reported in
the schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in question V-6.
Fiscal years
Item

2017

2018

January-June
2019

2019

2020

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

Income statement classification
of the nonrecurring item

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
V-8.

Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question V-7 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question V-7 identify where these items are
reported in question V-6.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-9a.

Page 57

Asset values—Finishers only.--Report the total assets (i.e., both current and long-term assets)
associated with the finishing, warehousing, and sale of wood mouldings and millwork products.
If your firm does not maintain some or all of the specific asset information necessary to
calculate total assets for wood mouldings and millwork products in the normal course of
business, please estimate this information based upon a method (such as production, sales, or
costs) that is consistent with relevant cost allocations in question V-6. Provide data as of the
end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in dollars)
Fiscal years
Item

2017

2018

2019

Total assets (net) 1
1

V-9b.

V-10a.

Describe

.

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

Capital expenditures and research and development expenses—Finishers only.--Report your
firm’s capital expenditures and research and development (“R&D”) expenses for wood
mouldings and millwork products. Provide data for your firm’s three most recently completed
fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years
Item
Capital expenditures

2017

2018

January-June
2019

2019

2020

1

R&D expenses2
Please describe the nature, focus, and significance of your firm’s capital expenditures on the
subject product.
.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject
product.
.
1

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 58

V-10b.

Description of reported capital expenditures.--Describe the nature, focus, and significance of
your firm’s reported capital expenditures. If no capital expenditure data were reported, explain
the reason.

V-10c.

Description of reported R&D expenses.--Describe the nature, focus, and significance of your
firm’s reported R&D expenses. If no R&D expense data were reported, explain the reason.

V-11.

Data consistency and reconciliation—Finishers only.--Please indicate whether your firm’s
financial data for questions V-6, V-9a, and V-10a are based on a calendar year or on your firm’s
fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question V-6 should reconcile with the data
reported in question V-1 (including export shipments) as long as they are reported on the same
fiscal year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in Part V-1 equal the quantities and values reported for total net sales in V-6 of this
questionnaire in each time period unless the financial data from V-6 are reported on a fiscal year basis, in
which case only the interim periods must reconcile. If the calculated fields below return values other than
zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy below.
Fiscal years
Reconciliation

2017

2018

January-June
2019

2019

2020

Quantity: Trade data from
question V-1 (lines G, I, K, and M)
less financial total net sales
quantity data from question V-6, =
zero ("0").

0

0

0

0

0

Value: Trade data from question
V-1 (lines H, J, L, and N) less
financial total net sales value data
from question V-6, = zero ("0").

0

0

0

0

0

Do these data in question V-6 reconcile with data in question V-1?
Yes

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-12.

Page 59

Finishing (back end) only activities.--Since January 1, 2017, has your firm purchased (not
produced) wood blanks (either domestic or imported) and further processed those purchases
into products that still match the definition of WMMP?
No

Yes

If yes--Please describe the nature and extent of the following items in
relation to your firm’s finishing (back end) operations in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity and type of parts sourced
in the United States
Any other costs and activities
related to your finishing operations
V-12b.

Finishing (back end) only finishing operations’ complexity and importance.--On a scale of 1 to
5, please provide your firm’s subjective opinion as to the complexity, intensity, and importance
of finishing only activities, with 1 being minimally complex, intense, and important and 5 being
extremely complex, intense, and important.
1:

2

3

4

Minimally
complex,
intense, and
important

5:
Extremely
complex,
intense, and
important

Please describe the reason for your rating.

If your responses to any of the items in questions V-11, V-12, and V-13 differ by country, please describe
these differences and, as applicable, indicate which country or countries your response refers to in the
relevant form fields. Note: If your company reports its responses in III-15, III-16, and III-17, do not
repeat the same responses in V-11, V-12, and V-13.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-13.

Page 60

Effects of imports on investment—Finishers only.--Since January 1, 2017, has your firm
experienced any actual negative effects on its return on investment or the scale of capital
investments as a result of imports of wood mouldings and millwork products from Brazil and
China?
No

Yes

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

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

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
V-14.

Page 61

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

Yes

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

(check as many as appropriate)

(please describe)

Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other

V-15.

Anticipated effects of imports—Finishers only.--Does your firm anticipate any negative effects
due to imports of wood mouldings and millwork products from Brazil and China?
No

Yes

If yes, my firm anticipates negative effects as follows.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 62

PART VI.—LAMINATED VENEER LUMBER (LVL) WMMP INFORMATION
Address questions on this part of the questionnaire to Keysha Martinez (202-205-2136,
[email protected]) and/or Emily Kim (202-205-1800, [email protected]).
VI-1.

LVL WMMP Production, shipment, and inventory data.--Report your firm’s production capacity,
production, shipments, and inventories related to the production of LVL wood mouldings and
millwork products in its U.S. establishment(s) during the specified periods. Please exclude any
production using unfinished wood mouldings and millwork products.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption/ including product shipped to firm’s own retail establishments”-Product consumed internally by your firm, which includes merchandise that your firm
transferred to your own firm’s retail establishments (i.e., shipped to either a bricks-and-mortar
store or to an online order fulfillment center). 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 or using a third-party fulfillment center to place retail level sales.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VI-1.

Page 63

LVL WMMP Production, shipment, and inventory data.
Quantity (in board feet) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Average production capacity (quantity)
(A)
1

Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including for
own retail establishments:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

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

2017

2018
0

January-June
2019

0

2019
0

2020
0

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

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VI-2.

Page 64

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

2017

2018

January-June
2019

2019

2020

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 through O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D – F– H = zero ("0"), if
not revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VI-3.

Page 65

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

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

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 66

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

VI-4.

Quantity (in board feet) and value (in dollars)
January-June

Fiscal years
Item

2017

2018

2019

2019

2020

Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

values:2

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

(COGS):3

Direct labor
Other factory costs
Less: by-product revenue

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 67

VI-5a. LVL WMMP Asset values.--Report the total assets (i.e., both current and long-term assets)
associated with the production, warehousing, and sale of LVL wood mouldings and millwork
products. If your firm does not maintain some or all of the specific asset information necessary
to calculate total assets for LVL wood mouldings and millwork products in the normal course of
business, please estimate this information based upon a method (such as production, sales, or
costs) that is consistent with relevant cost allocations in question VI-4. Provide data as of the
end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in dollars)
Fiscal years
Item

2017

2018

2019

Total assets (net) 1
1

Describe

.

VI-5b. Description of reported assets.--Describe the main asset categories (both current and longterm assets) in the above response. Provide a brief explanation if there are any substantial
changes in total asset value during the period; e.g., due to asset write-offs, revaluation, and
major purchases.

VI-6a.

LVL WMMP Capital expenditures and research and development expenses.--Report your
firm’s capital expenditures and research and development (“R&D”) expenses for LVL wood
mouldings and millwork products. Provide data for your firm’s three most recently completed
fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years
Item

2017

2018

January-June
2019

2019

2020

Capital expenditures
R&D expenses
VI-6b.

Description of reported capital expenditures.--Describe the nature, focus, and significance of
your firm’s reported capital expenditures. If no capital expenditure data were reported, explain
the reason.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VI-6c.

VI-7.

Page 68

Description of reported R&D expenses.--Describe the nature, focus, and significance of your
firm’s reported R&D expenses. If no R&D expense data were reported, explain the reason.

Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
question VI-4, VI-5a, and VI-6a are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question VI-4 should reconcile with the data
reported in question VI-1 (including export shipments) as long as they are reported on the same
fiscal year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in Part VI-1 equal the quantities and values reported for total net sales in VI-4 of this
questionnaire in each time period unless the financial data from VI-4 are reported on a fiscal year basis,
in which case only the interim periods must reconcile. If the calculated fields below return values other
than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years
Reconciliation

2017

2018

January-June
2019

2019

2020

Quantity: Trade data from
question VI-1 (lines D, F, H, and J)
less financial total net sales
quantity data from question VI-4,
= zero ("0").

0

0

0

0

0

Value: Trade data from question
VI-1 (lines E, G, I, and K) less
financial total net sales value data
from question VI-4, = zero ("0").

0

0

0

0

0

Do these data in question VI-4 reconcile with data in question VI-1?
Yes

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 69

PART VII.—MEDIUM DENSITY FIBERBOARD (MDF) MMP INFORMATION
Address questions on this part of the questionnaire to Keysha Martinez (202-205-2136,
[email protected]) and/or Emily Kim (202-205-1800, [email protected]).
VII-1.

MDF MMP Production, shipment, and inventory data.--Report your firm’s production capacity,
production, shipments, and inventories related to the production of MDF mouldings and
millwork products in its U.S. establishment(s) during the specified periods. Please exclude any
production using unfishinshed wood mouldings and millwork products.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption/ including product shipped to firm’s own retail establishments”-Product consumed internally by your firm, which includes merchandise that your firm
transferred to your own firm’s retail establishments (i.e., shipped to either a bricks-and-mortar
store or to an online order fulfillment center). 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 or using a third-party fulfillment center to place retail level sales.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VII-1.

Page 70

MDF MMP production, shipment, and inventory data.
Quantity (in board feet) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Average production capacity (quantity)
(A)
1

Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption/ including for
own retail establishments: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)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1

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

2017

2018
0

January-June
2019

0

2019
0

2020
0

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

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VII-2.

Page 71

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

2017

2018

January-June
2019

2019

2020

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 through O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D – F– H = zero ("0"), if
not revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VII-3.

Page 72

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

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

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VII-4.

Page 73

Operations on MDF MMP mouldings and millwork products.--Report the revenue and related
cost information requested below on the MDF MMP wood mouldings and millwork products
operations of your firm’s U.S. establishment(s).1 Do not report resales of products. Note that
internal consumption and transfers to related firms must be valued at fair market value. Input
purchases from related suppliers should be consistent with and based on information in the
firm’s accounting books and records. Provide data for your firm’s three most recently
completed fiscal years, and for the specified interim periods. If your firm was involved in tolling
operations (either as the toller or as the tollee), please contact Emily Kim at (202) 205-1800
before completing this section of the questionnaire.
Quantity (in board feet) and value (in dollars)
January-June

Fiscal years
Item

2017

2018

2019

2019

2020

Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

values:2

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

(COGS):3

Direct labor
Other factory costs
Less: by-product revenue

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

2

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

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 74

VII-5a. MDF MMP asset values.--Report the total assets (i.e., both current and long-term assets)
associated with the production, warehousing, and sale of MDF MMP wood mouldings and
millwork products. If your firm does not maintain some or all of the specific asset information
necessary to calculate total assets for MDF MMP wood mouldings and millwork products in the
normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question VII-4.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in dollars)
Fiscal years
Item

2017

2018

2019

Total assets (net) 1
1

Describe

.

VII-5b. Description of reported assets.--Describe the main asset categories (both current and long-term
assets) in the above response. Provide a brief explanation if there are any substantial changes in
total asset value during the period; e.g., due to asset write-offs, revaluation, and major
purchases.

VII-6a.

MDF MMP capital expenditures and research and development expenses.--Report your firm’s
capital expenditures and research and development (“R&D”) expenses for MDF MMP wood
mouldings and millwork products. Provide data for your firm’s three most recently completed
fiscal years, and for the specified interim periods.
Value (in dollars)
Fiscal years
Item

2017

2018

January-June
2019

2019

2020

Capital expenditures
R&D expenses
VII-6b.

Description of reported capital expenditures.--Describe the nature, focus, and significance of
your firm’s reported capital expenditures. If no capital expenditure data were reported, explain
the reason.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)
VII-6c.

VII-7.

Page 75

Description of reported R&D expenses.--Describe the nature, focus, and significance of your
firm’s reported R&D expenses. If no R&D expense data were reported, explain the reason.

Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions VII-4, VII-5a, and VII-6a are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question VII-4 should reconcile with the data
reported in question VII-1 (including export shipments) as long as they are reported on the same
fiscal year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in Part VII-1 equal the quantities and values reported for total net sales in VII-4 of this
questionnaire in each time period unless the financial data from VII-5 are reported on a fiscal year basis,
in which case only the interim periods must reconcile. If the calculated fields below return values other
than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Fiscal years
Reconciliation

2017

2018

January-June
2019

2019

2020

Quantity: Trade data from
question VII-1 (lines D, F, H, and J)
less financial total net sales
quantity data from question VII-4,
= zero ("0").

0

0

0

0

0

Value: Trade data from question
VII-1 (lines E, G, I, and J) less
financial total net sales value data
from question VII-4, = zero ("0").

0

0

0

0

0

Do these data in question VII-4 reconcile with data in question VII-1?
Yes

No

If no, please explain.

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 76

PART VIII.—COMPARABILITY OF TYPES OF MOULDINGS AND MILLWORK PRODUCTS
Address questions on this part of the questionnaire to Keysha Martinez (202-205-2136,
[email protected]).
VIII-1. Comparability of types of mouldings and millwork products.--For each of the following indicate
whether listed products are: fully comparable or the same, i.e., have no differentiation between
them; mostly comparable or similar; somewhat comparable or similar; never or not-at-all
comparable or similar; or no familiarity with products.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and End Uses.--The differences and similarities in the physical
characteristics and end uses.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:

Out-of-scope MDF mouldings and
millwork products vs in-scope
wood mouldings and millwork
products
(b) Interchangeability.--The ability to substitute the products in the same application.

Product-pair
Out-of-scope MDF mouldings and
millwork products vs in-scope
wood mouldings and millwork
products

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 77

VIII-1. Comparability of types wood mouldings and millwork products. —Continued.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(c) Manufacturing facilities, production processes, and production employees.--Whether
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:

Out-of-scope MDF mouldings and
millwork products vs in-scope wood
mouldings and millwork products

(d) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).

Product-pair
Out-of-scope MDF mouldings and
millwork products vs in-scope wood
mouldings and millwork products

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 78

VIII-1. Comparability of types wood mouldings and millwork products.—Continued.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(e) Customer and producer perceptions.--Perceptions as to the differences and/or
similarities in the market (e.g., sales/marketing practices).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:

Out-of-scope MDF mouldings and
millwork products vs in-scope wood
mouldings and millwork products
(f) Price.--Whether prices are comparable or differ between the products.

Product-pair
Out-of-scope MDF mouldings and
millwork products vs in-scope
wood mouldings and millwork
products

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 79

VIII-2. Comparability of types of mouldings and millwork products.--For each of the following indicate
whether listed products are: fully comparable or the same, i.e., have no differentiation between
them; mostly comparable or similar; somewhat comparable or similar; never or not-at-all
comparable or similar; or no familiarity with products.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and End Uses.--The differences and similarities in the physical
characteristics and end uses.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:

Out-of-scope MDF mouldings and
millwork products vs in-scope
wood mouldings and millwork
products
(b) Interchangeability.--The ability to substitute the products in the same application.

Product-pair
Out-of-scope MDF mouldings and
millwork products vs in-scope
wood mouldings and millwork
products

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 80

VIII-2. Comparability of types wood mouldings and millwork products. —Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Manufacturing facilities, production processes, and production employees.--Whether
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:

Out-of-scope MDF mouldings and
millwork products vs in-scope wood
mouldings and millwork products

(b) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).

Product-pair
Out-of-scope MDF mouldings and
millwork products vs in-scope wood
mouldings and millwork products

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 81

VIII-2. Comparability of types wood mouldings and millwork products. —Continued
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(c) Customer and producer perceptions.--Perceptions as to the differences and/or
similarities in the market (e.g., sales/marketing practices).

Product-pair

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:

Out-of-scope MDF mouldings and
millwork products vs in-scope wood
mouldings and millwork products
(d) Price.--Whether prices are comparable or differ between the products.

Product-pair
Out-of-scope MDF mouldings and
millwork products vs in-scope
wood mouldings and millwork
products

Comparison

Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:

Business Proprietary
U.S. Producers’ Questionnaire - Wood Mouldings and Millwork Products (Final)

Page 82

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/wood_mouldings_and_millwork_pr
oducts_brazil_and/final.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: WOOD

• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.


File Typeapplication/pdf
File TitleUS producer questionnaire
SubjectTitle 7 investigations
AuthorCummings, Charles
File Modified2020-08-31
File Created2020-08-31

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