Form 20-1-4321 U.S. producers' questionnaire

OMB No. 3117-0016/USITC No. 20-1-4321; Expiration Date: : 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CORROSION INHIBITORS FROM CHINA
This questionnaire must be received by the Commission by November 2, 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 and countervailing duty investigations concerning corrosion inhibitors from China (Inv.
Nos. 701-TA-638 and 731-TA-1473 (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, refined, processed, and/or purified corrosion inhibitors (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: CIFC)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Signature

Title of Authorized Official

Phone

Date

Email address

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 2

PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to petitions filed on February 5, 2020, by
Wincom Incorporated, Blue Ash, Ohio. Countervailing and/or antidumping duties may be assessed on
the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce
(“Commerce”) makes an affirmative determination of subsidization and/or dumping. Questionnaires
and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2020/corrosion_inhibitors_china/preliminary.htm.
Corrosion inhibitors covered by these investigations is tolyltriazole and benzotriazole. This includes
tolyltriazole and benzotriazole of all grades and forms, including their sodium salt forms. Tolyltriazole is
technically known as Tolyltriazole IUPAC 4,5 methylbenzotriazole. It can also be identified as 4,5 methyl
benzotriazole, tolutriazole, TTA, and TTZ.
Benzotriazole is technically known as IUPAC 1,2,3-Benzotriazole. It can also be identified as 1,2,3
Benzotriazole, 1,2-Aminozophenylene, 1H-Benzotriazole, and BTA.
All forms of tolyltriazole and benzotriazole, including but not limited to flakes, granules, pellets, prills,
needles, powder, or liquids, are included within the scope of these petitions.
The scope includes tolyltriazole/sodium tolyltriazole and benzotriazole/sodium benzotriazole that are
combined or mixed with other products. For such combined products, only the tolyltriazole/sodium
tolyltriazole and benzotriazole/sodium benzotriazole component is covered by the scope of these
investigations. Tolyltriazole and sodium tolyltriazole that have been combined with other products is
included within the scope, regardless of whether the combining occurs in third countries.
Tolyltriazole, sodium tolyltriazole, benzotriazole and sodium benzotriazole that is otherwise subject to
these investigations is not excluded when commingled with tolyltriazole, sodium tolyltriazole,
benzotriazole, or sodium benzotriazole from sources not subject to these investigations. Only the
subject merchandise component of such commingled products is covered by the scope of these
investigations.
A combination or mixture is excluded from this investigation if the total tolyltriazole or benzotriazole
component of the combination or mixture (regardless of the source or sources) comprises less than 5
percent of the combination or mixture, on a dry weight basis.
Notwithstanding the foregoing language, a tolyltriazole or benzotriazole combination or mixture that is
transformed through a chemical reaction into another product, such that, for example, the tolyltriazole
or benzotriazole can no longer be separated from the other products through a distillation or other
process is excluded from this investigation.
Tolyltriazole has the Chemical Abstracts Service (‘‘CAS’’) registry number 29385–43–1. Tolyltriazole is
classified under Harmonized Tariff Schedule of the United States (‘‘HTSUS’’) subheading 2933.99.82.20.
Sodium Tolyltriazole has the CAS registry number 64665–57–2 and is classified under HTSUS subheading
2933.99.82.90. Benzotriazole has the CAS registry number
#95–14–7 and is classified under HTSUS subheading 2933.99.82.10.
Sodium Benzotriazole has the CAS registry number 15217–42–2. Sodium Benzotriazole is classified
under HTSUS subheading 2933.99.82.90.

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Although the HTSUS subheadings and CAS registry numbers are provided for convenience and customs
purposes, the written description of the scope of these investigations is dispositive.
Note: All references to sodium tolytriazole and sodium benzotriazole are referred to as liquid tolytriazole
and liquid benzotriazole or liquid TTA or liquid BTA.
If your firm combines, mixes, or blends corrosion inhibitors with other products in which the corrosion
inhibitors comprise 5 percent or more of the combination or mixture on a dry weight basis, please only
respond with respect to your firms’ operations with respect to the corrosion inhibitors component of the
combination or mixture.
For a table showing the specific chemical processes needed to produce these products, see p. 5.
Crude TTA in liquid form is the form of TTA that is produced when ortho toluene diamene and sodium
nitrite are reacted under the requisite pressure and temperature conditions and subsequently cooled.
Crude TTA in liquid form typically has a Gardner color value > 18, or is not otherwise capable of being
rated using the Gardner color scale. Color impurities present within this product intermediate are not
removed.
Crude TTA in solid form is the form of TTA that is produced when orthotoluene diamene and sodium
nitrite are reacted under the requisite pressure and temperature conditions and subsequently cooled. It
is then subjected to an acidification process and processed into the solid form. Crude TTA in solid form is
brown to black in color. It can be made into a sodium salt solution that can be analyzed on the Gardner
color scale. If analyzed as a liquid, Crude TTA in solid form typically has a Gardner color value > 18, or is
not otherwise capable of being rated using the Gardner color scale.
Purified TTA in liquid form is the form of TTA that is produced by processing crude TTA in a purification
process that greatly reduces impurities in the crude TTA and increases the purity level of the liquid TTA.
Purified TTA in liquid form typically has a Gardner color scale value lower than or equal to 12.
Purified TTA in solid form is the form of TTA that is produced by processing crude TTA in a purification
process that greatly reduces the impurities in the crude TTA and increases the purity level of the TTA. It
is then subjected to a process that produces the solid form of the product. The purified solid TTA is
typically light tan/yellow to off-white in color. If processed into a liquid form, it typically would have a
Gardner color scale rating lower than or equal to 12.
Crude BTA in liquid form is the form of BTA that is produced when orthophenylene diamene and
sodium nitrite are reacted under the requisite pressure and temperature conditions and subsequently
cooled. Crude BTA in liquid form is dark in color. Color impurities present within this prospective product
intermediate are not removed.
Crude BTA in solid form is the form of BTA that is produced when orthophenylene diamene and sodium
nitrite are reacted under the requisite pressure and temperature conditions and subsequently cooled. It
is then subjected to an acidification process and processed into the solid form. Crude BTA in solid form is
tan to dark in color.
Purified BTA in liquid form is the form of BTA that is produced by processing crude BTA in a purification
process that greatly reduces the impurities in the crude BTA and increases the purity level of the BTA.
Purified BTA in liquid form typically has a Gardner color scale value lower than 12.

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Purified BTA in solid form is the form of BTA that is produced by processing crude BTA in a purification
process that greatly reduces the impurities in the crude BTA and increases the purity level of the BTA. It
is then subjected to a process that produces the solid form of the product. The purified solid BTA is
typically light tan/yellow to off-white in color and, if put in a liquid form, would typically have a Gardner
color scale rating lower than or equal to 12.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.

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Corrosion Inhibitors: Tolyltriazole and Sodium Tolyltriazaole Manufacturing Process in China and
the United States

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Activity conducted by firm
Chemical manufacturer of crude BTA/TTA in the
United States ("producer/toller")

Entity that further refines, processes, or purifies
in the United States domestically manufactured
crude BTA/TTA ("processor")

Entity that further refines, processes, or purifies
in the United States imported BTA/TTA
("processor")
Entity that further refines, processes, or purifies
in the United States both domestically
manufactured and imported BTA/TTA

Data to be reported
Fill out parts:
 I
 II (except II-10a-d)
 III (except III-9a(ii))
 IV
Fill out parts:
 I
 II (except II-7a-c)
 III (except III-9a(i))
 IV
Fill out parts:
 I
 V
Fill out parts:
 I
 II (except II-7a-c)
 III (except III-9a(i))
 IV
 V (questions V-9a and V-9b)

Page 6

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
I-1a.

Page 7

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 corrosion inhibitors,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

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I-2b.

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

I-2c.

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

I-3.

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

I-4.

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

I-5.

Yes

China

Investigation type
Antidumping

China

Countervailing duty

Support

Oppose

Take no position

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

Firm name

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

Country

Extent of
ownership
(percent)

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
I-6.

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

I-7.

Page 9

Yes--List the following information.
Country

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of corrosion inhibitors?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 10

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [email protected] ). Supply all data requested on a calendar-year basis.
II-1.

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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of corrosion inhibitors since January 1, 2017.
(check as many as appropriate)

plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(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)

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-3a.

Page 11

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

2017

Overall production capacity

2019

2019

2020

1

Production of:
Corrosion inhibitors2
Other products

2018

January-June

0

0

0

0

0

0

0

0

0

0

3

Total production using same
machinery or workers
1

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of corrosion inhibitors will populate here once reported in question II-7.
3
Please identify these products:
.
2

II-3b.

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

Weeks per year

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II-3c.

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

II-3d.

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

II-4.

Product shifting.—
(a)

Is your firm able to switch production (capacity) between corrosion inhibitors and other
products using the same equipment and/or labor?

No

(b)

II-5.

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.

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.

Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of corrosion inhibitors?
“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.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-5.

Page 13

Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of corrosion inhibitors?
“Toll agreement”--Agreement between two firms whereby the first firm (“TOLLEE”) furnishes
the raw materials and the second firm (“TOLLER”) 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- For all such agreements entered into by your firm, please indicate whether your firm
was the Toller (the producer of corrosion inhibitors) or tollee (the firm that furnished
the inputs to the Toller).
Our firm
Toller

Other firm(s)
Please name the tollee(s):

Special instruction
Provide data on your firm's toll
production and shipments in
question II-7
1
Tollee
Please name the toller(s):
Provide data on shipments into
the market of merchandise that
was toll produced in question II-8
1
Please describe the toll arrangement(s) and identify the raw material input that your firm
provided the toller(s):

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-6.

Page 14

Foreign trade zones.-(a)

Firm's FTZ operations.--Does your firm produce corrosion inhibitors in and/or admit
corrosion inhibitors 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

(b)

Yes

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

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import corrosion inhibitors into a foreign trade zone (FTZ) for use in distribution of
corrosion inhibitors and/or the production of downstream articles?
No

Yes

If yes--Identify the firms and the FTZs.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-7.

Page 15

Production, shipment, and inventory data.-- PRODUCER/TOLLER.--Report your firm’s
production capacity, production, shipments, and inventories related to the crude process
production of corrosion inhibitors (see corrosion inhibitors production chart on page 4) in its
U.S. establishment(s) during the specified periods, whether your firm produced corrosion
inhibitors for its own account or toll produced corrosion inhibitors for another firm. Do not
report data in this grid if your firm is the tollee for corrosion inhibitors produced by a toll
producer.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – 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.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Please provide the data requested only for your operations involving the processing of the
corrosion inhibitors covered by this investigation. If necessary, you can use reasonable
estimates to provide the data requested for your corrosion inhibitor operations.

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

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-7a.

Page 16

Production, shipment, and inventory data.—PRODUCER/TOLLER
Quantity (in pounds dry weight) and value (in dollars)
Calendar years
Item

2017

2018

January-June
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)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Value of tolled merchandise returned to tollee should reflect the toll conversion fee received for production of subject
merchandise.
4
Identify your firm’s principal export markets:
.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-7a.

Page 17

Production, shipment, and inventory data.—PRODUCER/TOLLER

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

2017

B + C – D - F- H - J – L = zero ("0"), if
not revise.= zero ("0"), if not revise.

2018
0

January-June
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-7b.

Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.

PRODUCER/TOLLER
Quantity (in pounds dry weight)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

U.S. shipments:
to Distributors (M)
to Processors (N)
to End users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
M + N + O – D - F- H = zero ("0"), if
not revise.= zero ("0"), if not revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-7c.

Page 18

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

PRODUCER/TOLLER
Calendar years
Item
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:

2017

2018

January-June
2019

2019

2020

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 19

II-8a.

Detailed explanation of firm's domestic activities. --Please describe in detail your firms
domestic operations with respect to further processing, refining, or purifying domestically
manufactured crude corrosion inhibitors into further processed corrosion inhibitors.

II-8b.

Conversion operations.-- Since January 1, 2017, has your firm further processed, refined, or
purified domestically manufactured crude corrosion inhibitors into further processed corrosion
inhibitors?

No

Yes

If yes--Please describe the nature and extent of the following items in
relation to your firm’s processing, refining, and purifying operations
conducted in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type, and
source of parts
Costs and activities

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-9.

Page 20

Processing operations’ complexity and importance.--On a scale of 1 to 5, please provide your
firm’s subjective opinion as to the complexity, intensity, and importance of processing only
activities, with 1 being minimilly complex, intesnse, or important and 5 being extremely
complex, intense, and important.
1:

2

3

4

Minimally
complex,
intense, and
important

5:
Extremely
complex,
intense, and
important

Please describe the reason for your rating.

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Page 21

II-10a. Production, shipment, and inventory data: Processor/tollee.--Report your firm’s capacity,
production, shipments, and inventories related to the processing, refining, or purifying of
domestically manufactured crude corrosion inhibitors, whether toll-produced by another firm or
purchased from another firm, in its U.S. establishment(s) during the specified periods. Do not
report data in this grid if your firm produces the crude corrosion inhibitor chemicals. These
questions do not cover processing, refining, or purifying of imported crude corrosion inhibitors;
those are to be reported separately in part V.
Please provide the data requested only for your operations involving the processing, refining,
or purifying of the corrosion inhibitors covered by this investigation. If necessary, you can use
reasonable estimates to provide the data requested for your corrosion inhibitor operations.

PROCESSOR / TOLLEE
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Average production capacity
(quantity) (P)
Beginning-of-period
inventories (quantity) (Q)
Processing, refining, or
purifying of corrosion
inhibitors. -Toll produced for your firm
(quantity) (R)
Purchased domestic
(quantity) (S)
Own production (quantity)
(T)
Total production (quantity)
(U)
U.S. shipments:
Commercial shipments:
Quantity (V)
Value (W)
Internal consumption:
Quantity (X)
Value1 (Y)
Transfers to related firms:
Quantity (Z)
Value1 (AA)

0

0

0

0

0

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Page 22

II-10a. Production, shipment, and inventory data: Processor/tollee.--Continued

PROCESSOR / TOLLEE
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item
Export shipments:
Quantity (AB)

2017

January-June

2018

2019

2019

2020

2

Value (AC)
End-of-period inventories
(quantity) (AD)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line AD) should be equal to the beginning-of-period inventories (i.e., line
Q), plus total production (i.e., lines, R, S, and T), less total shipments (i.e., lines V, X, Z, AB). Please ensure
that any differences are not due to data entry errors in completing this form, but rather reflect your
firm’s actual records; and, also provide explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Calendar years
Reconciliation
R + S + T – V – X – Z – AB – AD = zero
("0"), if not revise.= zero ("0"), if not
revise.
1

2017

2018

0

January-June
2019

0

2019

0

2020

0

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

0

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Page 23

II-10b. Channels of distribution: Processor/tollee.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by channel of
distribution in the specified periods.

PROCESSOR / TOLLEE
Quantity (in pounds dry weight)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

U.S. shipments:
to Distributors (AE)
to Processors (AF)
to End users (AG)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines AE, AF, and AG) in each time period equal the quantity reported for U.S. shipments (i.e., lines V, X, and Z)
in each time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported
must be revised prior to submission to the Commission.
Calendar years
Reconciliation
AE + AF + AG - V – X - Z = zero ("0"),
if not revise.= zero ("0"), if not revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 24

II-10c. U.S. shipments by form and/or type: Processor/tollee.--Report your firm’s U.S. shipments (i.e.
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) by
product type in the specified periods.

PROCESSOR/TOLLEE
Quantity (in pounds dry weight); Gross weight (in pounds); value (in dollars)
Calendar years
Item
U.S. shipments:
Crude TTA:
In solid form:
Quantity (AH)
Value (AI)
In liquid form:
Quantity (AJ)
Gross weight (AK)
Value (AL)
Purified TTA:
In solid form:
Quantity (AM)
Value (AN)
In liquid form:
Quantity (AO)
Gross weight (AP)
Value (AQ)
Crude BTA:
In solid form:
Quantity (AR)
Value (AS)
In liquid form:
Quantity (AT)
Gross weight (AU)
Value (AV)
Purified BTA:
In solid form:
Quantity (AW)
Value (AX)
In liquid form:
Quantity (AY)
Gross weight (AZ)
Value (BA)

2017

2018

January to June
2019

2019

2020

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 25

II-10c. U.S. shipments by type and form.--Continued.
RECONCILIATION OF US SHIPMENTS BY TYPE AND FORM--Please ensure that the quantities and values
reported for U.S. shipments by type (i.e., lines AH through BA) in each time period equal the quantities
and values reported for U.S. shipments (i.e., lines V through AA) in each time period from question II-10a.
If the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised
prior to submission to the Commission.
Calendar years
Reconciliation

2017

2018

January to June
2019

2019

2020

Quantity: AH + AK + AN + AO
+ AR + AT + AW + AY – V– X – Z
= zero ("0"), if not revise.

0

0

0

0

0

Value: AI + AL + AN + AQ + AS
+ AT + AY + BA – Y – Z– AA =
zero ("0"), if not revise.

0

0

0

0

0

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Page 26

II-10d. Employment data.--Report your firm’s employment-related data related to the processing,
refining, or purifying of domestically manufactured crude corrosion inhibitors and provide an
explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Please provide the data requested only for your operations involving the processing of the
corrosion inhibitors covered by this investigation. If necessary, you can use reasonable
estimates to provide the data requested for your corrosion inhibitor operations.

PROCESSOR/TOLLEE
Calendar years
Item
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:

2017

2018

January-June
2019

2019

2020

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 27

II-11.

Related firms.--If your firm reported transfers to related firms in questions II-7 and II-10, 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.

II-12.

Purchases.--Has your firm purchased corrosion inhibitors 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 pounds dry weight and Value in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Purchases from U.S. importers1 of
corrosion inhibitors from—
China.—
Quantity
Value
All other sources.—
Quantity
Value
Purchases from domestic producers2 .—
Quantity
Value
Purchases from other sources3
Quantity
Value
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:
.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
II-13.

Page 28

Imports.--Since January 1, 2017, has your firm imported corrosion inhibitors?
No

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

II-14.

Conversion from liquid TTA/BTA.--Are the quantity data reported in part II properly reported in
pounds of dry weight for TTA/BTA? If you converted the gross weight of liquid TTA or BTA to dry
weight for question II-10c, please provide the specific conversion factor that was used to
convert the gross weight for liquid TTA or BTA to dry weight. Also, please indicate whether the
value that your firm reported for liquid forms is based on gross weight or dry weight?
No.--Please revise your questionnaire to report your firm’s data in the requested measure (dry
pounds TTA/BTA) prior to submission to the Commission.
Yes.--Please indicate how your firm came up with its quantity data in the requested measure
(dry pounds TTA/BTA).
Method
Firm’s records maintained in
pounds of dry weight
TTA/BTA
Firm specific conversion
factor or estimates based on
specific products produced
Other

II-15.

Description of methodology
Not applicable

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.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)

Page 29

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[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:
Note.— We are requesting that your firm report financial data on a calendar
year basis.

B.1.
2.
3.

4.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include corrosion inhibitors:
Does your firm prepare profit/loss statements for corrosion inhibitors:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
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 corrosion inhibitors, as
well as specific statements and worksheets) used to compile these data.

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Page 30

III-3.

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

III-4.

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

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced corrosion inhibitors and provide the share of net sales accounted for by these
products in 2019.
Products
Corrosion inhibitors

Share of sales
%
%
%
%
%

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
III-6.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of corrosion inhibitors 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.

Page 31

No—Skip to question III-9a.

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
corrosion inhibitors 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 for
2019. For “Input valuation” please describe the basis, as recorded in your company’s own
accounting system, of the purchase cost from the related supplier; e.g., the related supplier’s
actual cost, cost plus, negotiated transfer price to approximate fair market value.
Input

Related supplier

Share of total COGS in 2019

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

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 (financial results on corrosion
inhibitors) 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 question III-9a.

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Page 32

III-9a(i). Operations on corrosion inhibitors: Producers/tollers.--Report the revenue and related cost
information related to the crude production of corrosion inhibitors (see corrosion inhibitors
production chart on page 5) in your firm’s U.S. establishment(s) during the specified periods,
whether produced for your own account or for the account of a tollee.1 Do not report data in
this grid for which your firm is the tollee for corrosion inhibitors produced by a toll producer. Do
not report resales of products. Note that internal consumption and transfers to related firms
must be valued at fair market value. The data provided should be specific to your operations
involving corrosion inhibitors covered by this investigation. If necessary, reasonable estimates
and/or allocations are acceptable for costs that are not product-specific.
Quantity (in pounds, dry weight) and value (in dollars)
Calendar year
Item

2017

2018

January-June
2019

2019

2020

2

Net sales quantities:
Commercial sales

Internal consumption
Transfers to related firms
Shipments to tollees
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Shipments to tollees (tolling revenue
received)
Total net sales values
Cost of goods sold (COGS):
Raw materials

3

Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense and (income) items, net4
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 If the total reported amount is net other expenses, report as a positive number. If the total reported amount is net other income,
report as a negative number. Please check the calculated “Net income or (loss) before income taxes” to ensure proper reporting of
these items.
1

2

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Page 33

III-9a(ii).Operations on corrosion inhibitors: Processors/Tollees.--Report your firm’s revenue and cost
information related to the processing of domestically manufactured crude corrosion inhibitors,
whether toll-produced by another firm or purchased from another firm, in your firm’s U.S.
establishment(s) during the specified periods. Do not report data in this grid if your firm
produces the crude corrosion inhibitor chemicals. Do not report resales of products. The data
provided should be specific to your operations involving the processing of corrosion inhibitors
covered by this investigation. If necessary, reasonable estimates and/or allocations are
acceptable for revenue or cost data that are not specific to corrosion inhibitors.
Please note – This question does not cover the processing of imported corrosion inhibitors.
Those data should be reported in part V.
Quantity (in pounds, dry weight) and value (in dollars)
Calendar year
Item

2017

2018

January-June
2019

2019

2020

2

Net sales quantities:
Commercial sales

Internal consumption
Transfers to related firms
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

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

3

Direct labor
Other factory costs
Tolling fees paid
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense and (income) items, net4
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers. If prepaid freight was
removed from reported sales values, please ensure that any corresponding costs are also removed.
4 If the total reported amount is net other expenses, report as a positive number. If the total reported amount is net other income,
report as a negative number. Please check the calculated “Net income or (loss) before income taxes” to ensure proper reporting of
these items.
1

2

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Page 34

III-9b. Financial data reconciliation.--The calculable line items from question III-9a(i) and III-9a(ii) (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

III-9c.

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 of
the line item “All other expense and income items, net.” If the net value of
the all other items reported here is an expense/loss, it should be reported
as a positive number. If the net value is an income/gain it should be
reported as a negative value. 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.

No

Raw materials.--Please report the share of total raw material costs in 2019 (reported in III-9a(i)
or III-9a(ii)) for the following raw material inputs:
Procurement method
Share of total raw
material costs
(percent)

Input

Primarily
produced by
your firm

Primarily
purchased by
your firm

Orthotoluene diamine
Sodium nitrite
Other material inputs1
Total (should sum to 100 percent)

0.0

1

Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that each account for:
.

III-9d. Start-up and/or expansion of production capacity included in reported corrosion inhibitor
results.—If your firm began producing corrosion inhibitors on or after January 1, 2017 or
expanded capacity, production, and sales of corrosion inhibitors during the periods for which
financial results are reported in question III-9a(i) or III-9a(ii), please specify the additional cost
included in question III-9a(i) or III-9a(ii).
Calendar years
Item

2017

2018

January-June
2019

2019

Value (in dollars)
Incremental costs included in
III-9a(i) or III-9a(ii) due to
start-up or increase in capacity
Report where these costs are included within question III-9a(i) or III-9a(ii) (i.e., in which line items):

2020

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Page 35

III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in questions III-9a(i) or
III-9a(ii), please specify all material (significant) nonrecurring items (charges and gains) in the
schedule below, the specific question III-9a(i) or III-9a(ii) line item where the nonrecurring items
are included, a brief description of the relevant nonrecurring items, and the associated values
(in dollars), as reflected in question III-9a(i) or III-9a(ii); i.e., if an aggregate nonrecurring item
has been allocated to question III-9a(i), only the allocated value amount included in question III9a(i) should be reported in the schedule below. Note: The Commission’s objective here is to
gather information only on material (significant) nonrecurring items which impacted the
reported financial results of the subject product in questions III-9a(i) and III-9a(ii).
Calendar years
Item

2017

2018

January-June
2019

2019

2020

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

Income statement classification of the
nonrecurring item

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

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

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III-12a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, processing, warehousing, and sale of corrosion inhibitors. Total assets should
reflect asset values after any accumulated depreciation and allowances are deducted.
For asset categories that are not specific to corrosion inhibitors (e.g., shared equipment, cash,
inventories, etc.), please use an appropriate allocation method (such as production, sales, or
costs) that is consistent with relevant cost allocations in questions III-9a(i) or III-9a(ii). If
necessary, reasonable estimates are acceptable.
Value (in dollars)
Calendar years
Item
Total assets (net)

2017

2018

2019

1

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 corrosion inhibitors.
Value (in dollars)
Calendar years
Item
Capital expenditures

2017

2018

January-June
2019

2019

1

Research and development
expenses2
III-13b. Description of reported capital expenditures.-- Please describe the nature, focus, and
significance of your firm’s reported capital expenditures. If no capital expenditures 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. If no R&D expenses were reported, please explain the
reason.

2020

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Page 37

III-14. Data consistency and reconciliation.--Please confirm that your firm’s financial data for
questions III-9a(i) or III-9a(ii), 12, and 13 are based on a calendar year basis:
Yes

No

If no, please explain.

Please note the quantities and values reported in question III-9a(i) should reconcile with the
data reported in question II-7a (including export shipments), and tolling quantities and values
reported in question III-9a(ii) should reconcile with the data reported in question II-9a.
RECONCILIATION OF TRADE VS FINANCIAL DATA: PRODUCERS/TOLLERS.--Please ensure that the
quantities and values reported for total shipments of producers/tollers in Part II equal the quantities and
values reported for total net sales of producers/tollers in Part III of this questionnaire in each time period.
If the calculated fields below return values other than zero (i.e., “0”), please explain the discrepancy
below.
Calendar years
Reconciliation

2017

2018

January-June
2019

2019

2020

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

0

0

0

0

0

Value: Trade data from question II7a (lines E, G, I, K, and M) less
financial total net sales value data
from question III-9a(i), = zero ("0").

0

0

0

0

0

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

No

If no, please explain.

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RECONCILIATION OF TRADE VS FINANCIAL DATA: PROCESSORS.--Please ensure that the quantities and
values reported for total shipments of processors in Part II equal the quantities and values reported for
total net sales of processors in Part III of this questionnaire in each time period. If the calculated fields
below return values other than zero (i.e., “0”), please explain the discrepancy below.
Note.—If you are processing both domestically-produced and imported corrosion inhibitors (i.e.,
completing questions III-9a(ii) and V-9a), the reconciliation grid will not show zeros. It should instead
show the quantities and values that are reported in question V-9a.
Calendar years
Reconciliation

2017

2018

January-June
2017

2018

2017

Quantity: Trade data from question
II-9a (lines Y, AA, AC, and AE) less
financial total net sales quantity data
from question III-9a(ii), = zero ("0").

0

0

0

0

0

Value: Trade data from question II9a (lines Z, AB, AD, and AF) less
financial total net sales value data
from question III-9a(ii), = zero ("0").

0

0

0

0

0

Do these data in question III-9a(ii) reconcile with data in question II-9a?
Yes

No

If no, please explain.

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Page 39

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 corrosion inhibitors from China?
No

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

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

(please describe)

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III-16. Effects of imports on growth and development.--Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of corrosion inhibitors 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
corrosion inhibitors 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.

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Page 41

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, [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.—Liquid TTA in totes of 2,400 to 2,600 pounds net weight (include only refined liquid
TTA)
Product 2.—Liquid TTA in drums of 450 to 550 pounds net weight (include only refined liquid
TTA)

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-June 2020, did your firm produce and sell to unrelated U.S. customers any of
the above listed products (or any products that were competitive with these products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question IV-3.

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IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds dry weight and actual dollars (not 1,000s).

Period of shipment
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
April-June

(Quantity in pounds dry weight, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity

Value

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.
1

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:

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IV-2c.

Page 43

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)?
Weights converted to dry weight?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in which
the sale occurred?
Less than reported commercial shipments in question II-10a in each year?
Explanation(s) for any boxes not checked:
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.
IV-2e. Conversion factor.-- Please provide the specific conversion factor that was used to convert the
gross weight for liquid TTA to dry weight.

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IV-3.

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

IV-4.

Contracts

Annual
total
volume
discounts

Other

If other, describe

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of domestic corrosion inhibitors usually
quoted (check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 44

F.o.b.

If f.o.b., specify point

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

Item
Share of 2019
sales

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

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

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

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IV-7.

Page 45

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

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

IV-8.

.

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

Source

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

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

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IV-9.

Page 46

Shipping information.-(a)

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

(b)

Indicate the approximate percentage of your firm’s sales of corrosion inhibitors 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 corrosion inhibitors 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
corrosion inhibitors that is accounted for by U.S. inland transportation costs?
percent

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IV-12. End uses.--List the end uses of the corrosion inhibitors that your firm manufactures. For each
end-use product, what percentage of the total cost is accounted for by corrosion inhibitors and
other inputs?
Share of total cost of end use product
accounted for by
End-use product

corrosion inhibitors

Total
(should sum to
100.0% across)

Other inputs

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-13. Substitutes.--Can other products be substituted for corrosion inhibitors?
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 corrosion inhibitors?
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 corrosion inhibitors has changed since January 1, 2017. Explain any trends
and describe the principal factors that have affected these changes in demand.

Overall
increase

Market

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Within the United States
Outside the United States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of corrosion inhibitors since January 1, 2017?
No

Yes

If yes, please describe and quantify if possible.

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IV-16. Conditions of competition.-(a) Is the corrosion inhibitors market subject to business cycles and/or other conditions of
competition distinctive to corrosion inhibitors? If yes, describe.
Check all that apply.

Please describe.

No

Skip to question IV-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
corrosion inhibitors since January 1, 2017?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply corrosion
inhibitors since January 1, 2017 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, being unable to meet timely shipment commitments,
etc.)?
No

Yes

If yes, please describe.

IV-18. Raw materials.--How have corrosion inhibitors 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
corrosion inhibitors.

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Page 49

IV-19. Interchangeability.--Are corrosion inhibitors 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

China

Other countries

United States
China
For any country-pair producing corrosion inhibitors that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

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IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between corrosion inhibitors
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

China

Other countries

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

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IV-21. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for corrosion inhibitors since January 1, 2017. Indicate the share of the quantity of
your firm’s total shipments of corrosion inhibitors that each of these customers accounted for in
2019.

Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2019
sales (%)

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IV-22. Competition from imports.-(a)

Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling
corrosion inhibitors from China, did your firm:
Item

No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2017: Did your firm lose sales of corrosion inhibitors to
imports of this product from China?
No

Yes

IV-23. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.

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Page 53

PART V.— PROCESSING OPERATIONS OF NON-DOMESTICALLY PRODUCED CORROSION INHIBITORS
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, [email protected]).
V-1a.

Detailed explanation of firm's domestic activities. --Please describe in detail your firms
operations with respect to further processing, refining or purifying in the United States imported
corrosion inhibitors into further processed corrosion inhibitors.

V-1b.

Conversion operations.-- Since January 1, 2017, has your firm further processed, refined, or
purified in the United States imported corrosion inhibitors into further processed corrosion
inhibitors?

No

Yes

If yes--Please describe the nature and extent of the following items in
relation to your firm’s processing, refining, and purifying operations
conducted in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type, and
source of parts
Costs and activities

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V-2.

Page 54

Refining, processing or purifying imported corrosion inhibitors domestically in the United
States operations’ complexity and importance.--On a scale of 1 to 5, please provide your firm’s
subjective opinion as to the complexity, intensity, and importance of refining, processing or
purifying imported corrosion inhibitors domestically in the United States only activities, with 1
being minimilly complex, intesnse, or important and 5 being extremely complex, intense, and
important.
1:

2

3

4

Minimally
complex,
intense, and
important

5:
Extremely
complex,
intense, and
important

Please describe the reason for your rating.

V-3a.

Production, shipment, and inventory data: Processor of imports.--Report your firm’s capacity,
production, shipments, and inventories related to the refining, processing or purifying in the
United States of imported corrosion inhibitors during the specified periods.
Do not report data in this grid if your firm produces the corrosion inhibitor chemicals. These
questions do not cover processing of domestically produced crude corrosion inhibitors; those
are to be reported separately in part II. Do not include resales of imports that have been
processed domestically.
Please provide the data requested only for your operations involving the processing of the
corrosion inhibitors covered by this investigation. If necessary, you can use reasonable
estimates to provide the data requested for your corrosion inhibitor operations.

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V-3a.

Page 55

Production, shipment, and inventory data: Processor of imports —Continued

Processor of Imports
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Average production capacity
(quantity) (A)
Beginning-of-period
inventories (quantity) (B)
Refining, processing or
purifying imported corrosion
inhibitors domestically in the
United States. —
Purchased/imported Chinese
origin corrosion inhibitors
(quantity) (C)
Purchased/imported all
other foreign origin corrosion
inhibitors (quantity) (D)
Total production (quantity)
I

0

0

0

0

U.S. shipments:
Commercial shipments:
Quantity (F)
Value (G)
Internal consumption:
Quantity (H)
Value1 (I)
Transfers to related firms:
Quantity (J)
Value1 (K)
Export shipments:2
Quantity (L)
Value (M)
End-of-period inventories
(quantity) (N)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.

0

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V-3a.

Page 56

Production, shipment, and inventory data: Processor of imports —Continued

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

2017

C + D – F – H – J — L = zero (“0”), if
not revise.= zero (“0”), if not revise.

2018
0

January-June
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:
.

V-3b.

Channels of distribution: Processor of imports.—Report your firm’s U.S. shipments (i.e.
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) by
channel of distribution in the specified periods.

Processor of Imports
Quantity (in pounds dry weight)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

U.S. shipments:
to Distributors (O)
to Processors (P)
to End users (Q)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines O, P, and Q) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each
time period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be
revised prior to submission to the Commission.
Calendar years
Reconciliation
O + P + Q – D – F – H = zero ("0"), if
not revise.= zero ("0"), if not revise.

2017

2018
0

January-June
2019

0

2019
0

2020
0

0

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V-3c.

Page 57

U.S. shipments by form and/or type: Processor of imports.--Report your firm’s U.S. shipments
(i.e. inclusive of commercial U.S. shipments, internal consumption, and transfers to related
firms) by product type.

Processor of Imports
Quantity (in pounds dry weight); Gross weight (in pounds); value (in dollars)
Calendar years
Item
U.S. shipments:
Crude TTA:
In solid form:
Quantity (R)
Value (S)
In liquid form:
Quantity (T)
Gross weight (U)
Value (V)
Purified TTA:
In solid form:
Quantity (W)
Value (X)
In liquid form:
Quantity (Y)
Gross weight (Z)
Value (AA)
Crude BTA:
In solid form:
Quantity (AB)
Value (AC)
In liquid form:
Quantity (AD)
Gross weight (AE)
Value (AF)
Purified BTA:
In solid form:
Quantity (AG)
Value (AH)
In liquid form:
Quantity (AI)
Gross weight (AJ)
Value (AK)

2017

2018

January to June
2019

2019

2020

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V-3c.

Page 58

U.S. shipments by type and form: Processor of imports.--Continued.

RECONCILIATION OF US SHIPMENTS BY TYPE AND FORM--Please ensure that the quantities and values
reported for U.S. shipments by type (i.e., lines R through AJ) in each time period equal the quantities and
values reported for U.S. shipments (i.e., lines F through K) in each time period from question VI-3a. If the
calculated fields below return values other than zero (i.e., “0”), the data reported must be revised prior
to submission to the Commission.
Calendar years
Reconciliation

2017

2018

January to June
2019

2019

2020

Quantity: R + T + W + Y + AB +
AD + AG + AI – F – H – J = zero
("0"), if not revise.

0

0

0

0

0

Value: S + V + X + AA + AC +
AF + AH + AK – G– I– K = zero
("0"), if not revise.

0

0

0

0

0

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V-3d.

Page 59

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

Please provide the data requested only for your operations involving the processing of the corrosion
inhibitors covered by this investigation. If necessary, you can use reasonable estimates to provide the
data requested for your corrosion inhibitor operations.

Processor of Imports
Calendar years
Item
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:

2017

2018

January-June
2019

2019

2020

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V-4.

Page 60

Conversion from liquid TTA/BTA.--Are the quantity data reported in part II properly reported in
pounds of dry weight for TTA/BTA? If you converted the gross weight of liquid TTA or BTA to dry
weight for question V-3c, please provide the specific conversion factor that was used to convert
the gross weight for liquid TTA or BTA to dry weight. Also, please indicate whether the value
that your firm reported for liquid forms is based on gross weight or dry weight?
No.--Please revise your questionnaire to report your firm’s data in the requested
measure (dry pounds of TTA/BTA) prior to submission to the Commission.
Yes.--Please indicate how your firm came up with its quantity data in the requested
measure (dry pounds of TTA/BTA).
Method
Firm’s records maintained in
pounds of dry weight
TTA/BTA
Firm specific conversion
factor or estimates based on
specific products produced
Other

Description of methodology
Not applicable

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V-5.

Page 61

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

V-6.

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:
Note.— We are requesting that your firm report financial data on a calendar
year basis.

B.1.
2.
3.

4.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include corrosion inhibitors:
Does your firm prepare profit/loss statements for corrosion inhibitors:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
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 corrosion inhibitors, as
well as specific statements and worksheets) used to compile these data.

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Page 62

V-7a.

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

V-7b.

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

V-7c.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced corrosion inhibitors and provide the share of net sales accounted for by these
products in 2019.
Products
Corrosion inhibitors

Share of sales
%
%
%
%
%

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
V-8a.

Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of corrosion inhibitors 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 V-8b

V-8b.

Page 63

No—Skip to question V-9a

Inputs from related suppliers detailed.--Please identify the inputs used in the production of
corrosion inhibitors 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 for
2019. For “Input valuation” please describe the basis, as recorded in your company’s own
accounting system, of the purchase cost from the related supplier; e.g., the related supplier’s
actual cost, cost plus, negotiated transfer price to approximate fair market value.
Input

Related supplier

Share of total COGS in 2019

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

V-8c.

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, are reported in III-9a (financial results on corrosion
inhibitors) 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 question III-9a.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
V-9a.

Page 64

Operations on corrosion inhibitors: Processor of imports.— Report your firm’s revenue and
cost information related to the processing of imported corrosion inhibitors, in your firm’s U.S.
establishment(s) during the specified periods. Do not report resales of products. The data
provided should be specific to corrosion inhibitors covered by this investigation. If necessary,
reasonable estimates and/or allocations are acceptable for revenue or cost data that are not
specific to corrosion inhibitors.

Processor of Imports
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item
Net sales quantities:
Commercial sales

2017

2018

January-June
2019

2019

2020

1

Internal consumption
Transfers to related firms
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):3
Cost of purchased/imported
Chinese-origin corrosion inhibitors
Cost of purchased/imported all other
foreign-origin corrosion inhibitors
Other raw material costs
Subtotal raw material costs
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)

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V-9a.

Page 65

Operations on corrosion inhibitors: Processor of imports.—Continued
Quantity (in pounds, dry weight) and value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Other expenses and income:
Interest expense
All other expense and (income) items,
net4
Net income or (loss) before income taxes

0

0

0

0

0

Depreciation/amortization included
above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 If the total reported amount is net other expenses, report as a positive number. If the total reported amount is net other
income, report as a negative number. Please check the calculated “Net income or (loss) before income taxes” to ensure proper
reporting of these items.
1

2

V-9b.

Financial data reconciliation.--The calculable line items from question V-9a (i.e., total net sales
quantities and values, subtotal of raw material costs, total COGS, gross profit (or loss), total
SG&A, 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 of
the line item “All other expense and income items, net.” If the net value of
the items reported here is an expense/loss, it should be reported as a
positive number. If the net value is an income/gain it should be reported as
a negative value. If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.

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U.S. Producers’ Questionnaire - Corrosion Inhibitors (Final)
V-9c.

Page 66

Raw materials.--Please report the share of total raw material costs in 2019 (reported in V-9a)
for the following raw material inputs:
Share of total raw material costs
(percent)

Input
Purchased/imported TTA
Purchased/imported BTA
Other material inputs1
Total (should sum to 100 percent)

0.0

1

Please indicate any other notable "other" raw materials not expressly identified
above and provide the share of the total raw material costs that each account for:

V-10.

Blends.— If your firm’s reported net sales in question V-9a include blends, provide the net sales
quantity of the blends sold in each period by (1.) total dry weight and (2.) dry weight of the
corrosion inhibitors contained within the blend.
Calendar years
Item

2017

2018

January-June
2019

2019

Quantity (as specified)
Net sales quantity
Blends (total dry weight)
Blends (dry weight of
corrosion inhibitors
contained)
c

.

2020

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Page 67

V-11a. Asset values: Processor of imports.--Report the total assets (i.e., both current and long-term
assets) associated with the refining, processing or purifying in the United States imported
corrosion inhibitors. Total assets should reflect asset values after any accumulated depreciation
and allowances are deducted.
For asset categories that are not specific to corrosion inhibitors (e.g., shared equipment, cash,
inventories, etc.), please use an appropriate allocation method (such as production, sales, or
costs) that is consistent with relevant cost allocations in question V-9a. If necessary, reasonable
estimates are acceptable.

Processor of Imports
Value (in dollars)
Calendar years
Item

2017

2018

2019

Total assets (net)
V-11b.

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.

V-12a.

Capital expenditures and research and development (“R&D”) expenses.--Report your firm’s
capital expenditures and R&D expenses associated with your firm's refining, processing or
purifying in the United States of imported corrosion inhibitors.

Processor of Imports
Value (in dollars)
Calendar years
Item

2017

2018

January-June
2019

2019

Capital expenditures1
R&D expenses2
V-12b. Description of reported capital expenditures.-- Please describe the nature, focus, and
significance of your firm’s reported capital expenditures. If no capital expenditures were
reported, please explain the reason.

2020

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Page 68

V-12c. Description of reported R&D expenses.—Please describe the nature, focus, and significance of
your firm’s reported R&D expenses. If no R&D expenses were reported, please explain the
reason.

V-13.

Data consistency and reconciliation.--Please confirm that your firm’s financial data for
questions V-9a, V-11a, and V-12a are based on a calendar year basis:
Yes

No

If no, please explain.

RECONCILIATION OF TRADE VS FINANCIAL DATA: REFINING, PROCESSING OR PURIFYING IMPORTED
CORROSION INHIBITORS DOMESTICALLY IN THE UNITED STATES OF IMPORTED CORROSION INHIBITORS.- Please note the quantities and values reported for shipments (including export shipments) in question
V-3a should reconcile with the total net sales quantities and values in question V-9a. If the calculated
fields below return values other than zero (i.e., “0”), please explain the discrepancy below.
Note.—If you are refining, processing or purifying imported corrosion inhibitors domestically in the
United States both domestically-produced and imported corrosion inhibitors (i.e., completing questions
III-9a(ii) and V-9a), the reconciliation grid will not show zeros. It should instead show the quantities and
values that are reported in question III-9a(ii).
Calendar years
Reconciliation

2017

2018

January-June
2017

2018

2017

Quantity: Shipment quantities from
question V-3a (lines F, H, J, and L)
less financial total net sales quantity
data from question V-9a, = zero ("0").

0

0

0

0

0

Value: Shipment values from
question V-3a (lines G, I, K, M) less
financial total net sales value data
from question V-9a, = zero ("0").

0

0

0

0

0

Do the data in question V-9a reconcile with data in question V-3a?
Yes

No

If no, please explain.

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V-14.

Page 69

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 corrosion inhibitors from China?
No

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

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

(please describe)

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V-15.

Page 70

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 corrosion inhibitors 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

V-16.

Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
corrosion inhibitors from China?
No

V-17.

Yes

If yes, my firm anticipates negative effects as follows.

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

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Page 71

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at: LINK
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: CIFC

• 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 Refining, processing or purifying imported corrosion
inhibitors domestically in the United States Standards (FIPS) 140-2 cryptographic algorithms to encrypt
data in transit. Submitting your nonpublic documents by a means that does not use these encryption
algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized disclosure
during transmission. If you choose a non-encrypted method of electronic transmission, the Commission
warns you that the risk of such possible unauthorized disclosure is assumed by you and not by the
Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.