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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4317; Expiration Date: : 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
DIFLUOROMETHANE (R‐32) FROM CHINA
This questionnaire must be received by the Commission by November 6, 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 antidumping investigation concerning difluoromethane (“R‐32”) from China (Inv. No. 731‐TA‐1472
(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 R‐32 (as defined on next page) at any time since January 1, 2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: DIFLU)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐ This proceeding was instituted in response to a petition filed on January 23, 2020, by
Arkema Inc., King of Prussia, Pennsylvania. 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 dumping. Questionnaires and other information pertinent to this proceeding are
available at https://www.usitc.gov/investigations/701731/2020/difluoromethane_r_32_china/final.htm.
Difluoromethane (“R‐32”) covered by this investigation is difluoromethane (“R‐32”) or its chemical
equivalent, regardless of form, type or purity level. R‐32 has the Chemical Abstracts Service (“CAS”)
registry number of 75‐10‐5 and the chemical formula CH2F2. R‐32 is also referred to as difluoromethane,
HFC‐32, FC‐32, Freon‐32, methylene difluoride, methylene fluoride, carbon fluoride hydride, halocarbon
R32, fluorocarbon R32, and UN 3252.
Subject merchandise also includes R‐32 and unpurified R‐32 that are processed in a third country or the
United States, including, but not limited to, purifying or any other processing that would not otherwise
remove the merchandise from the scope of this investigation if performed in the country of
manufacture of the in‐scope R‐32. R‐32 that has been blended with products other than
pentafluoroethane (R‐125) is included within this scope if such blends contain 85% or more by volume
on an actual percentage basis of R‐32. In addition, R‐32 that has been blended with any amount of R‐125
is included within this scope if such blends contain more than 52% by volume on an actual percentage
basis ofR‐32. Whether R‐32 is blended with R‐125 or other products, only the R‐32 component of the
mixture is covered by the scope of these orders. The scope also includes R‐32 that is commingled with R‐
32 from sources not subject to this investigation. Only the subject component of such commingled
products is covered by the scope of this order.
Excluded is merchandise covered by the scope of the antidumping order on Hydrofluorocarbon Blends
from the People's Republic of China. See Hydrofluorocarbon Blends from the People's Republic of China,
81 Fed. Reg. 55436 (Aug. 19, 2016).
R‐32 is currently imported under statistical reporting number 2903.39.2035 of the Harmonized Tariff
Schedule of the United States (HTSUS). It may also be imported under HTSUS statistical reporting
numbers 2903.39.2045 or 3824.78.0020. The HTSUS provisions are for convenience and customs
purposes; the written description of the scope is dispositive.
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 3
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 macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
I‐1a.
Page 4
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b.
TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes
I‐2a.
No
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of R‐32, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
I‐2b.
I‐2c.
Page 5
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
I‐3.
Law firm:
Lead attorney(s):
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Petition support.‐‐Does your firm support or oppose the petition?
Country
China
I‐5.
I‐6.
Oppose
Take no position
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Extent of
ownership
(percent)
Firm name
Country
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing R‐32 from China into the United States or that are
engaged in exporting R‐32 from China to the United States?
No
Yes‐‐List the following information.
Support
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
I‐7.
Page 6
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of R‐32?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 7
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Ahdia Bavari (202‐205‐3191,
[email protected]). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part II.
Name
Title
Email
Telephone
II‐2a. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of R‐32 since January 1, 2017.
(check as many as appropriate)
(If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 8
II‐2b. COVID‐19 pandemic.‐‐ Since January 1, 2020, has the COVID‐19 pandemic or have any
government actions taken to contain the spread of the COVID‐19 virus resulted in changes in
relation to your firm's supply arrangements, production, employment, and sales relating to R‐
32?
II‐3.
No
Yes
If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) production and sales impact, and (c)
employment impact of the COVID‐19 pandemic.
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 R‐32 and other products using the
same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
(b)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
II‐5.
Tolling.‐‐Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of R‐32?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes‐‐Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
II‐6.
Page 9
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce R‐32 in and/or admit R‐32 into a foreign
trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import R‐32 into a foreign trade zone (FTZ) for use in distribution of R‐32 and/or the
production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
II‐7.
Page 10
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of R‐32 in its U.S. establishment(s) during
the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“U.S. shipments” –Shipments made within the U.S., either as a result of an arm’s length
commercial transaction (see “commercial shipments”), consumed internally by your firm (see
“internal consumption”), or shipments made to any related U.S. firms (see “transfers to related
firms”)
“Commercial shipments” –Shipments made as a result of an arm’s length commercial
transaction in the ordinary course of business. Report net values (i.e., gross sales values less all
discounts, allowances, rebates, prepaid freight, and the value of returned goods) in U.S. dollars,
f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Swaps” –Shipments made commercially in arms‐length transactions that involve, at least in
part, non‐monetary “in kind” transfer of product.
“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.
“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 ‐ R‐32 (Final)
II‐7.
Page 11
Production, shipment, and inventory data.‐‐Continued
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
2017
2018
January‐September
2019
2019
2020
1
Average production capacity (quantity)
(A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Swaps:
Quantity3 (J)
Value4 (K)
Value (O)
Swaps:
Quantity3 (P)
Value (E)
Internal consumption:
Quantity (F)
2
2
Value (G)
Transfers to related firms:
Quantity (H)
2
2
Value (I)
5
Export shipments :
Commercial shipments:
Quantity (L)
Value (M)
Transfers to related firms:
Quantity (N)
2
4
Value (Q)
End‐of‐period inventories (quantity) (R)
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
Please (1) identify the companies from which your firm receives the goods or services in‐kind, (2) indicate the
particular goods or services in‐kind received pursuant to your swap transactions, and (3) quantify any net monetary
exchange included in the swap transactions in each calendar year: .
4
Report the value inclusive of the “in kind” value of any goods or services received plus the net monetary transferred in
the swap transactions.
5
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 12
II‐7. Production, shipment, and inventory data.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line R) 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, J, L, N, and P). 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 year
January‐September
Reconciliation
2017
B + C – D – F – H – J – L – N – P – R =
should equal zero ("0") or provide an
explanation.1
2018
0
2019
0
2019
0
2020
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐8.
Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, transfers to related firms, and swaps) by channel of
distribution in the specified periods.
Quantity (in short tons)
Calendar year
Item
U.S. shipments:
to Distributors and service
companies (S)
To HFC component
blenders (T)
2017
2018
January‐September
2019
2019
2020
To OEMs and other non‐
blender end users (U)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines S, T, and U) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H,
and J) 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 year
January‐September
Reconciliation item
S + T + U ‐ D ‐F ‐ H‐ J = zero ("0"), if
not revise.
2017
0
2018
2019
0
2019
0
0
2020
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
II‐9.
Page 13
Employment data.‐‐Report your firm’s employment‐related data related to the production of R‐
32 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 September periods, calculate
similarly and divide by 9.
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 year
Item
2017
2018
January‐September
2019
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐10. 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 ‐ R‐32 (Final)
Page 14
II‐11. Purchases.‐‐Has your firm purchased R‐32 produced in the United States or in other countries
since January 1, 2017? (Do not include imports for which your firm was the importer of record.
These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in short tons)
Calendar years
Item
2017
2018
January‐September
2019
2019
2020
1
Purchases from U.S. importers of R‐
32 from—
China
All other sources
Purchases from domestic producers2
3
Purchases from other sources
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the U.S. producer(s) from which your firm purchased this product: .
3
Please list the name of the firm(s) from which your firm purchased this product: .
II‐12. Imports.‐‐Since January 1, 2017, has your firm imported R‐32?
No
Yes
If yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 15
II‐13. Captive production use. — Please report the share of your firm’s U.S. shipments of internal
consumption, transfers to related firms, and/or swaps for the uses identified below in 2019.
These data should reconcile with the 2019 quantities reported in question II‐7 (lines F, H, and
J).
Calendar year 2019
Internal consumption
Products
Swaps
Transfers to related firms
(Quantity in short tons)
Sold as is (Re‐entry
into merchant
market)
N/A
Blended into other
products
1
Please describe these products: .
RECONCILIATION OF CAPTIVE PRODUCTION USE.— The sum of the data reported above should be
equal to the data reported in question II‐7, lines F, H, and J, in 2019.
Reconciliation
Calendar year 2019
Internal consumption (line F in II‐7)
reconciliation.
0
Transfers to related parties (line H in II‐7)
reconciliation.
0
Swaps (line J in II‐7) reconciliation.
0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
II‐14a. R‐32's share contribution to R‐410A.‐‐Does your firm or a related firm produce R‐410 using your
firm's U.S.‐produced R‐32?
No
Yes
If yes‐‐ please report the share that R‐32 accounts for of R‐410.
Material inputs used in R‐410A production
R‐32
All other material inputs
0.0
0.0
Total (should sum to 100.0%)
Share of value
Share of the quantity
accounted for in R‐410A accounted for in R‐410A
(percent)
(percent)
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 16
II‐14b. R‐32's share contribution to other downstream products.‐‐Does your firm or a related firm
produce products other than R‐410A out of your firm's production of R‐32? If yes, describe
these downstream products and report the share that R‐32 accounts for of those products on
both a value and quantity basis.
No
Yes
If yes‐‐ Please describe these downstream products and then report the
share that R‐32 accounts for of these products.
Material inputs used in products other than R‐
410A
Share of value
Share of the quantity
accounted for of the
accounted for of the
downstream product(s) downstream product(s)
(percent)
(percent)
R‐32
All other material inputs
Total (should sum to 100.0%)
0.0
0.0
II‐15. 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 ‐ R‐32 (Final)
Page 17
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to David Boyland (202‐708‐4725,
[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 R‐32:
2. Does your firm prepare profit/loss statements for R‐32:
Yes
No
3. 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
4. Accounting basis: U.S. GAAP, IFRS, cash, tax, or other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes R‐32, as well as specific
statements and worksheets) used to compile these data.
III‐3a. 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 ‐ R‐32 (Final)
Page 18
III‐3b. Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐4a. Swap accounting.‐‐From the perspective of revenue and cost, please describe the company’s
routine accounting treatment of R‐32 swaps. As applicable, please describe how the company’s
routine accounting treatment differs from the manner in which swaps are reported in tables III‐
9a and III‐9c.
Please identify the counterparties to R‐32 swap arrangements during the period examined,
components exchanged for R‐32, and relevant swap ratios.
Please describe the underlying basis of the swap ratio; e.g., does it represent a physical
relationship (storage‐related or otherwise) that is essentially static? With respect to swap
negotiations, please identify the factor (swap ratio or value) that is most subject to change in
negotiation and why that is the case.
III‐4b. Swap transactions and related activity.‐‐Please provide a general description of how swap
activity is routinely conducted between the company and its swap partner; e.g., the
determination of volume to be shipped, logistics, and reconciliation of swap obligations. In your
response, please describe the extent to which swaps are evenly distributed and equal
throughout a given period or whether swap volumes in the short run are unequal. How are
differences in the partners’ swap volume (given/received) accounted for and how are these
differences generally resolved over longer periods?
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 19
III‐4c. Swap volume and out‐of‐swap volume.‐‐Please describe the extent to which period‐specific
volumes for swap transactions and out‐of‐swap transactions are predetermined, the presence
of swap volume thresholds beyond which relevant swap values and/or ratios change, and
impact, if any, on reported pattern of swap and out‐of‐swap volume during the period
examined.
Please describe how out‐of‐swap sales fit into the overall swap agreement and the
circumstances when out‐of‐swap transactions generally take place.
III‐4d. Swap value.‐‐Please confirm that R‐32 swap values reported in tables III‐9a and III‐9c represent
fair market value. Please provide a general description of swap valuation basis.
III‐4e. Out‐of‐swap value.‐‐Please describe the valuation basis of out‐of‐swap sales and how this value
was determined in the swap agreement.
III‐4f. Changes in swap agreement.‐‐Please describe the extent to which relevant swap ratios and/or
other important aspects of swap arrangements changed during the period examined and the
reason for the changes.
III‐4g. Basis of renegotiation of swap values and/or swap ratios.‐‐In the recent past to include the
period examined, has your swap partner agreed to increase the HFC component amount
swapped for R‐32 and/or the assigned R‐32 value? If so, please describe the circumstances.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
III‐5.
Page 20
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced R‐32 and provide the share of net sales accounted for by these products in your firm’s
most recent fiscal year.
Products
III‐6.
Share of sales
R‐32
%
%
%
%
%
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of R‐32 from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes‐‐Continue to question III‐7
III‐7.
No—Skip to question III‐9a.
Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of R‐
32 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
Input valuation as recorded in the firm’s accounting books and records
Share of total COGS
III‐8.
Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, are reported in III‐9a, III‐9b, and III‐9c in a manner
consistent with your firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs purchased
from related suppliers as reported in III‐9a, III‐9b, and III‐9c.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 21
III‐9a. Overall operations on R‐32.‐‐Report the revenue and related cost information requested below
on the R‐32 operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that transfers to related firms, internal consumption, and swaps (R‐32 given up in
exchange for another HFC component and reported in the revenue section of this table) 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 specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2017
2018
January‐September
2019
2019
2020
Net sales quantities:2
Out‐of‐swap commercial
sales
All other commercial sales
0
0
0
0
0
Total net commercial
sales quantities (“CS”)
Transfers to related firms
(“Transfers”)
Internal consumption (“IC”)
Swaps
0
0
0
0
0
Out‐of‐swap commercial
sales
All other commercial sales
0
0
0
0
0
Total net sales
quantities
Net sales values:2
Total net commercial
sales values
Internal consumption
Transfers to related firms
Swaps
0
0
0
0
0
Di‐methylene chloride
Other raw materials
0
0
0
0
0
Direct labor
Other factory costs
Less: byproduct revenue
Total net sales values
Cost of goods sold (COGS):3
Hydrofluoric acid
Total raw material costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Table continued on following page.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 22
III‐9a. Overall operations on R‐32.—Continued
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
Selling, general, and
administrative (SG&A)
expenses
2017
2018
January‐September
2019
2019
2020
0
0
0
0
0
All other expense items
All other income items
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before
income taxes
0
0
0
0
0
Depreciation/amortization
included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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, Transfers, IC, and Swaps. Costs
associated with input purchases from related suppliers should be consistent with and based on information in the firm’s
accounting books and records.
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 ‐ R‐32 (Final)
Page 23
III‐9b. Open market operations (U.S. commercial shipments and commercial exports only) on R‐32.‐‐
Report the revenue and related cost information requested below on the R‐32 operations of
your firm’s U.S. establishment(s).1 Include both the domestic and export commercial sales of R‐
32 producer by your firm, but do not report the resale of R‐32. 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 specified
interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2017
2018
January‐September
2019
2019
2020
Total net commercial sales
quantities (“CS”)2
0
0
0
0
0
Total net commercial sales
values2
0
0
0
0
0
Hydrofluoric acid
Di‐methylene chloride
Other raw materials
0
0
0
0
0
Direct labor
Other factory costs
Less: byproduct revenue
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
All other expense items
All other income items
Cost of goods sold (COGS):3
Total raw material costs
Selling, general, and
administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before
income taxes
0
0
0
0
0
Depreciation/amortization
included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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. Total commercial sales quantity and value amounts
reported in this table will auto populate from corresponding total commercial sales quantity and value amounts reported in
table III‐9a.
3 COGS (whether for domestic or export sales) should include costs associated with CS. Costs associated with input purchases
from related suppliers should be consistent with and based on information in the firm’s accounting books and records.
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 ‐ R‐32 (Final)
Page 24
III‐9c. Swap operations on R‐32.‐‐Report the revenue and related cost information requested below
on the R‐32 swap operations of your firm’s U.S. establishment(s).1 Do not report the resale of R‐
32. 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 specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended‐‐
Item
2017
2018
January‐September
2019
2019
2020
Net swap sales quantities2
0
0
0
0
0
Net swap sales values2
0
0
0
0
0
Hydrofluoric acid
Di‐methylene chloride
Other raw materials
0
0
0
0
0
Direct labor
Other factory costs
Less: byproduct revenue
Cost of goods sold (COGS):3
Total raw material costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
All other expense items
All other income items
Net income or (loss) before
income taxes
0
0
0
0
0
Depreciation/amortization
included above
Selling, general, and
administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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. Swap sales quantity and value amounts reported in this
table will auto populate from corresponding swap sales quantity and value amounts reported in table III‐9a.
3 COGS (whether for domestic or export sales) should include costs associated with Swaps. Costs associated with input
purchases from related suppliers should be consistent with and based on information in the firm’s accounting books and
records.
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 ‐ R‐32 (Final)
Page 25
III‐9d. Financial data reconciliation.‐‐The calculable line items from question III‐9a, III‐9b, and III‐9c
(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 non‐material 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.
III‐9e. Effects on financial performance of COVID‐19.‐‐Please describe how the COVID‐19 pandemic
has affected the financial performance of your firm’s operations on R‐32 as reported in III‐9a, III‐
9b, and III‐9c.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 26
III‐10. Nonrecurring items (charges and gains) included in reported financial results.‐‐For each annual
and interim period for which financial results are reported in question III‐9a, III‐9b, and III‐9c
please specify all material (significant) nonrecurring items (charges and gains) in the schedules
below, the specific 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 each
table; i.e., if an aggregate nonrecurring item has been allocated, only the allocated value
amount included in tables III‐9a, III‐9b, and III‐9c should be reported in the schedules below.
Note: The Commission’s objective here is to gather information only on material (significant)
nonrecurring items which impacted reported financial results.
Nonrecurring items (charges and gains) included in III‐9a (Overall operations on R‐32):
Fiscal years ended‐‐
January‐September
Item
2017
2018
2019
2019
2020
Value ($1,000)
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.
Item
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
Continued on following page.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 27
III‐10. Nonrecurring items (charges and gains) included in reported financial results.—Continued
Nonrecurring items (charges and gains) included in III‐9b (Open market operations on R‐32):
Fiscal years ended‐‐
January‐September
Item
2017
2018
2019
2019
2020
Value ($1,000)
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‐9b where the nonrecurring item is classified.
Item
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
Nonrecurring items (charges and gains) included in III‐9c (Swap operations on R‐32):
Fiscal years ended‐‐
January‐September
Item
2017
2018
2019
2019
2020
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Continued on following page.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 28
III‐10. Nonrecurring items (charges and gains) included in reported financial results.—Continued
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‐9c where the nonrecurring item is classified.
Fiscal years ended‐‐
Item
2017
2018
January‐September
2019
2019
2020
Value ($1,000)
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, III‐9b, and III‐9c, respectively.
III‐12a. Asset values.‐‐Report the total assets (i.e., both current and non‐current assets) associated with
the production, warehousing, and sale of R‐32. If your firm does not maintain some or all of the
specific asset information necessary to calculate total assets for R‐32 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 R‐32 operations if these assets are also related to other
products. As reported in table III‐12, 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 $1,000)
Fiscal years ended‐‐
Item
Total assets (net)
2017
2018
2019
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 29
III‐12b. Description of reported assets.‐‐ Please 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.
III‐13a. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for R‐32. Provide data for your firm’s
three most recently completed fiscal years and the specified interim periods.
Value (in $1,000)
Fiscal years ended‐‐
Item
2017
Capital expenditures
2018
January‐September
2019
2019
2020
R&D expenses
III‐13b. Description of reported capital expenditures.‐‐ Please describe the nature, focus, and
significance of your firm’s reported capital expenditures in the above response. If no capital
expenditure data were reported, please explain the reason.
III‐13c. Description of reported R&D expenses.‐‐ Please describe the nature, focus, and significance of
your firm’s reported R&D expenses in the response above. If no R&D expenses were reported,
please explain the reason.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 30
III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, III‐9b, III‐9c, III‐12, and III‐13 are based on a calendar year or on your firm’s
fiscal year:
Calendar year
Fiscal year
Specify fiscal year
Please note that the quantities and values reported in table III‐9a (and by extension tables III‐9b
and III‐9c) should reconcile with the data reported in question II‐7 (including export shipments)
as long as they are reported on the same calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
January‐September
Fiscal years ended‐‐
Reconciliation
2018
2017
2019
2019
2020
Quantity: Trade data from
question II‐7 (lines D, F, H,
and J) less financial total net
sales quantity data from
question III‐9a, = zero ("0").
0
0
0
0
0
Value: Trade data from
question II‐7 (lines E, G, I, and
K) less financial total net sales
value data from question III‐
9a, = zero ("0").
0
0
0
0
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 31
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 R‐32 from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
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
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 32
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 R‐32 from 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
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
R‐32 from China?
No
Yes
If yes, my firm anticipates negative effects as follows.
III‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 33
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Tyler Martin (202‐205‐3198,
[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.‐‐R‐32 sold in bulk to blenders
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).
IV‐2a. During January 2017‐September 2020, did your firm produce and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.‐‐Please complete the following pricing data table as appropriate.
No.‐‐Skip to question IV‐3.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 34
IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to blenders.
Report data in short tons and actual dollars (not 1,000s).
(Quantity in short tons, value in dollars)
Product 1
Quantity
Value
Period of shipment
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
April‐June
July‐September
October‐December
2020:
January‐March
April‐June
July‐September
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:
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 35
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
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Have discounts, rebates, and returns been credited to the quarter in which
the sale occurred?
Net of all discounts and rebates?
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.
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 ‐ R‐32 (Final)
IV‐3.
Page 36
Price setting.‐‐How does your firm determine the prices that it charges for sales of R‐32 (check
all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic R‐32 usually quoted (check
one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced R‐32
in 2019 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐term contract
basis, and (4) spot sales basis?
Item
Share of 2019
sales
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
IV‐7.
Page 37
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced R‐32 (or check “not applicable” if your firm does not sell on a short‐term, annual
and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
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 R‐32?
Lead time (Average
Source
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 ‐ R‐32 (Final)
IV‐9.
Page 38
Shipping information.‐‐
(a)
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of R‐32 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 R‐32 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
R‐32 that is accounted for by U.S. inland transportation costs? percent
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 39
IV‐12. End uses.‐‐List the end uses of the R‐32 that your firm manufactures. For each end‐use product,
what percentage of the total cost is accounted for by R‐32 and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
100.0% across)
R‐32
Other inputs
End‐use product
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐13. Substitutes.‐‐Can other products be substituted for R‐32?
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 R‐32?
No Yes
Explanation
1.
2.
3.
IV‐14. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for R‐32 has changed since January 1, 2017. Explain any trends and describe
the principal factors that have affected these changes in demand.
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Market
Explanation and factors
Within the United States
Outside the United States
IV‐15. Effect of out‐of‐scope products on R‐32. Does out‐of‐scope product (e.g., R‐22) influence the
price or demand of R‐32? Explain any influence that out‐of‐scope product has on R‐32.
Out‐of‐scope product
Any impact on R‐32?
No
Yes
Explanation of impact
R‐22
Other:
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 40
IV‐16. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of R‐32 since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
IV‐17. Conditions of competition.‐‐
(a) Is the R‐32 market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to R‐32? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV‐18.
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
R‐32 since January 1, 2017?
No
Yes
If yes, describe.
IV‐18. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply R‐32 since
January 1, 2017 (examples include not selling product due to prioritizing internal blending,
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.
IV‐19. Raw materials.‐‐How have R‐32 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 R‐32.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 41
IV‐20. Interchangeability.‐‐Is R‐32 produced in the United States and in other countries interchangeable
(i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing R‐32 that is sometimes or never interchangeable, identify the
country‐pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 42
IV‐21. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between R‐32 produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of R‐32, identify the country‐pair and report the advantages or
disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 43
IV‐22. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for R‐32 since January 1, 2017. Indicate the share of the quantity of your firm’s total
shipments of R‐32 that each of these customers accounted for in 2019.
Customer’s name
City
State
Share of 2019 sales
(%)
1
2
3
4
5
6
7
8
9
10
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 44
IV‐23. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2017: To avoid losing sales to competitors selling R‐32
from China, did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2017: Did your firm lose sales of R‐32 to imports of this
product from 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ R‐32 (Final)
Page 45
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2020/difluoromethane_r_32_china/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: DIFLU
• 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 (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - DRAFT US producer questionnaire--R-32(F) |
| Author | ahdia.bavari |
| File Modified | 2020-09-18 |
| File Created | 2020-09-18 |