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pdfOMB No. 3117‐0016/USITC No. 20‐4‐4320; Expiration Date: 6/30/2023
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FOREIGN PRODUCERS’/EXPORTERS’ 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.
Name of firm
Address
Website
Has your firm produced or exported R‐32 (as defined on next page) in or from China at any time since January 1,
2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: 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
Foreign 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,
purchaser and/or foreign producer questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. §1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
Page 3
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.‐‐If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Ahdia
Bavari (202‐205‐3191, [email protected]).
I‐1.
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
20 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐2.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”‐‐Each facility of a firm in China involved in the production or export of R‐32,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities. Firms operating more than one establishment in China should combine the
data for all establishments into a single report.
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
I‐3.
I‐4.
I‐5.
I‐6.
I‐7.
Page 4
Related producers.‐‐Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce R‐32 in the United States or other countries?
No
Yes
If yes, please name the firm(s) and country(ies) below and, if U.S.
producer(s), ensure that they complete the Commission’s producer
questionnaire.
Related U.S. importers.‐‐Does your firm or any related firm import or have any plans to import
R‐32 into the United States?
No
Yes
If yes, please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.
Stock symbol information.‐‐ If your firm or any of the entities reported in questions I‐2 through
I‐4 are publicly traded in the United States, please specify the stock exchange and trading
symbol (including American Depository Receipts, if applicable): .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):
U.S. importers.‐‐Please provide the names, contacts, telephone numbers, and e‐mail addresses
of the FIVE largest U.S. importers of your firm’s R‐32 in 2019.
Importer’s name
Contact person
Email
Telephone
Share of your
firm’s 2019 U.S.
exports (%)
1
2
3
4
5
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
Page 5
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
Foreign Producers’ Questionnaire – R‐32 (Final)
Page 6
II‐2b. Anticipated changes in operations.‐‐Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of R‐32 in the future?
II‐2c.
No
Yes
If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions.
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, and sales (including exports to the
United States) 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 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.
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
II‐5.
Page 7
Share of sales.‐‐What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of R‐32? percent.
II‐6a. Firm's estimated share of production in China.‐‐Please estimate the percentage of total production
of R‐32 in the country specified on the certification page accounted for by your firm’s production in
2019. percent.
II‐6b. Firm's estimated share of country's exports.‐‐Please estimate the percentage of total exports to
the United States of R‐32 from the country specified on the certification page accounted for by
your firm’s exports in 2019. percent.
II‐7. Third country trade actions.‐‐Is the R‐32 exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?
No
Yes
If yes‐‐List the products(s), countries affected, and the date of such
findings/remedies/proceedings.
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
II‐8.
Page 8
Trade data.‐‐Report your firm’s production capacity, production, shipments, and inventories
related to the production of R‐32 in your establishment(s) in China during the specified periods.
Do not include resales of R‐32 that your firm did not produce in this question; those data to the
degree they are exported to the United States should only be reported in question II‐9.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” ‐‐All production in your establishment(s) in China, including production consumed
internally within your firm.
“Shipments”‐‐Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”‐‐Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”‐‐Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”‐‐Shipments to destinations outside of the country indicated on page 1
(China), including shipments to related firms.
“Inventories”‐‐Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
II‐8.
Page 9
Trade data.‐‐Continued.
Quantity (in short tons)
Actual experience
Calendar year
Item
2017
2018
Projections1
January‐September
2019
2019
2020
Calendar year
2020
2021
2
Average production capacity
(A)
Beginning‐of‐period
inventories (B)
Production (C)
Home market shipments:
Internal consumption/
transfers (D)
Total exports (H)
(should equal F+G)
0
0
0
0
0
0
0
Total shipments (I)
(should equal D+E+F+G)
0
0
0
0
0
0
0
Commercial shipments (E)
Exports to the United States
(F)
3
Exports to all other markets
(G)
End‐of‐period inventories (J)
1
Please explain the basis for your firm’s projections. .
The production capacity reported is based on operating hours per week, weeks per year. Please describe
the methodology used to calculate production capacity, and explain any changes in reported capacity. .
3
Identify principal other export markets. .
2
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
Page 10
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line J) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, E, F, and G). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Actual experience
Projections
Calendar year
Item
2017
2018
January‐September
2019
2019
2020
Calendar year
2020
2021
B + C – D – E – F –G – J = should
equal zero ("0") or provide an
explanation.1
0
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐9. Exports to the United States not produced by your firm.‐‐Report your firm’s exports to the
United States of R‐32 that was produced in China but not by your firm during the specified
periods. Note these data should not be included in question II‐8.
Quantity (in short tons)
Actual experience
Calendar year
Item
Exports of R‐32 to the United
States not produced by your
firm1
2017
2018
Projections
January‐September
2019
0
2019
2020
Calendar year
2020
2021
1
List the producer(s). .
II‐10. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
Page 11
Correcting Valid number error messages.‐‐If you are completing a Commission
questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The U.S. International Trade Commission’s
questionnaires are set‐up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)
When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.
Business Proprietary
Foreign Producers’ Questionnaire – R‐32 (Final)
Page 12
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
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 your questionnaire to [email protected]; include a scanned copy of the signed
certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents that are
electronically transmitted to the Commission to protect your sensitive information from unauthorized
disclosure. The USITC secure drop‐box system and the Electronic Document Information System (EDIS)
use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to encrypt data in
transit. Submitting your nonpublic documents by a means that does not use these encryption algorithms
(such as by email) may subject your firm’s nonpublic information to unauthorized disclosure during
transmission. If you choose a non‐encrypted method of electronic transmission, the Commission warns
you that the risk of such possible unauthorized disclosure is assumed by you and not by the Commission.
If your firm did not produce or export this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, you are required to serve a copy of
the completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - DRAFT Foreign producer questionnaire--R-32(F) |
| Author | ahdia.bavari |
| File Modified | 2020-09-18 |
| File Created | 2020-09-18 |