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pdfOMB No. 3117-0016/USITC No. 20-1-4329; Expiration Date: 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
ALUMINUM FOIL FROM ARMENIA, BRAZIL, OMAN, RUSSIA, AND TURKEY
This questionnaire must be received by the Commission by October 13, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing and antidumping duty investigations concerning aluminum foil from Armenia, Brazil,
Oman, Russia, and Turkey (Inv. Nos. 701-TA-658-659 and 731-TA-1538-1542 (Preliminary)). 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 aluminum foil (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: FOIL)
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
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on September 29, 2020, by
the Aluminum Association Trade Enforcement Working Group, Arlington, Virginia and its individual
members - Gränges Americas Inc., Franklin, Tennessee; JW Aluminum Company, Daniel Island, South
Carolina; and Novelis Corporation, Atlanta, Georgia. 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/aluminum_foil_armenia_brazil_oman_russia_and/p
reliminary.htm.
Aluminum foil .-- The merchandise covered by these investigations is aluminum foil having a thickness of
0.2 mm or less, in reels exceeding 25 pounds, regardless of width. Aluminum foil is made from an
aluminum alloy that contains more than 92 percent aluminum. Aluminum foil may be made to ASTM
specification ASTM B479, but can also be made to other specifications. Regardless of specification,
however, all aluminum foil meeting the scope description is included in the scope, including aluminum
foil to which lubricant has been applied to one or both sides of the foil.
Excluded from the scope of this investigation is aluminum foil that is backed with paper, paperboard,
plastics, or similar backing materials on one side or both sides of the aluminum foil, as well as etched
capacitor foil and aluminum foil that is cut to shape. Where the nominal and actual measurements vary,
a product is within the scope if application of either the nominal or actual measurement would place it
within the scope based on the definitions set forth above. The products under investigation are
currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS) subheadings
7607.11.3000, 7607.11.6090, 7607.11.9030, 7607.11.9060, 7607.11.9090, and 7607.19.6000.
Further, merchandise that falls within the scope of this proceeding may also be entered into the United
States under HTSUS subheadings 7606.11.3060, 7606.11.6000, 7606.12.3045, 7606.12.3055,
7606.12.3091, 7606.12.3096, 7606.12.6000, 7606.91.3095, 7606.91.6095, 7606.92.3035, and
7606.92.6095. The HTSUS provisions are for convenience and customs purposes; the written description
of the scope is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 3
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of aluminum foil and your responses to the questions in Part I
of the producer questionnaire will be provided to the U.S. Department of Commerce, upon its request,
for use in connection with (and only in connection with) its requirement pursuant to section
702(c)(4)/732(c)(4) of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning
the extent of industry support for the petition requesting this proceeding. Any information provided to
Commerce will be transmitted under the confidentiality and release guidelines set forth above. Your
response to these questions constitutes your consent that such information be provided to Commerce
under the conditions described above.
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.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
I-1a.
Page 4
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.
TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
I-2a.
Page 5
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 aluminum foil, 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:
.
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):
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
I-3.
Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
Yes
Petition support.--Does your firm support or oppose the petition?
Country
Armenia
Investigation type
AD
Brazil
AD
Oman
Russia
Turkey
I-5.
Page 6
Support
Oppose
Take no position
AD
CVD
AD
AD
CVD
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)
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
I-6.
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing aluminum foil from Armenia, Brazil, Oman, Russia, and
Turkey into the United States or that are engaged in exporting aluminum foil from Armenia,
Brazil, Oman, Russia, and Turkey to the United States?
No
Firm name
I-7.
Page 7
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 aluminum foil?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 8
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, [email protected]). Supply all data requested on a calendar-year basis.
II-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part II.
Name
Title
Email
Telephone
II-2a.
Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of aluminum foil 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)
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-2b.
COVID-19 pandemic.-- Since January 1, 2020, has the COVID-19 pandemic or have any
government actions taken to contain the spread of the COVID-19 virus resulted in changes in
relation to your firm's supply arrangements, production, employment, and sales relating to
aluminum foil?
No
II-3a.
Page 9
Yes
If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) production and sales impact, and (c)
employment impact of the COVID-19 pandemic.
Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce aluminum foil, 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.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-3a.
Page 10
Production using same machinery.—Continued
Quantity (in short tons)
Calendar years
Item
Overall production capacity
2017
2018
January-June
2019
2019
2020
1
Production of:
Aluminum foil2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Out-of-scope production.-Aluminum sheet, all alloys and
including can stock
Aluminum plate
Other products3
Subtotal, out-of-scope
production
Total production using
same machinery or workers
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of aluminum foil will populate here once reported in question II-7.
3
Please identify these products:
.
1
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
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-4.
Product shifting.—
(a)
Is your firm able to switch production (capacity) between aluminum foil and other products
using the same equipment and/or labor?
No
(b)
II-5.
Page 11
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 aluminum foil?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes--Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-6.
Page 12
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce aluminum foil in and/or admit
aluminum foil into a foreign trade zone (FTZ)?
(a)
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
Yes
If yes--Describe the nature of your firm’s 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 aluminum foil into a foreign trade zone (FTZ) for use in distribution of aluminum
foil and/or the production of downstream articles?
(b)
No
Yes
If yes--Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-7.
Page 13
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of aluminum foil in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“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.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-7.
Page 14
Production, shipment, and inventory data.--Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item
2017
2018
January-June
2019
2019
2020
Average production capacity (quantity)
(A)
1
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2017
2018
0
January-June
2019
0
2019
0
2020
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-8.
Page 15
Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution in
the specified periods.
“Consumer Packaging /Converter”--Shipments to end users in the business of packaging foods,
cosmetics, pharmaceuticals and to other chemical products; these end users are otherwise
known as converters in the industry.
“Household use/spoolers”-- Shipment to end users for eventual retail sale as aluminum foil used
for short-term wrapping, mostly in households, catering and food and floristry retail businesses
after further processing into small reels (e.g., in the context of internal consumption).
“Industrial applications”-- Shipments to end users in the business of using the foil in thermal
insulation, cables, and electronics, among other industrial end uses.
Calendar years
Item
2017
2018
January-June
2019
2019
2020
Quantity (in short tons)
U.S. shipments:
to Distributors (M)
to Consumer packaging/
converter (N)
to Household use/spoolers (O)
to Industrial applications (P)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through P) 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 item
M + N + O + P – D – F – H = zero ("0"),
if not revise.
2017
2018
0
January-June
2019
0
2019
0
2020
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-9.
Page 16
U.S. shipments by thickness.--Report your firm’s U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) for 2019.
Ultra-thin. -- Aluminum foil less than 0.000315 inch (8 microns) thickness.
Thin. -- Aluminum foil greater than or equal to 0.000315 inch (8 microns) and less than 0.00039
inch (10 microns) thickness.
Standard. -- Aluminum foil greater than or equal to 0.00039 inch (10 microns) and less than or
equal to 0.001 inch (25 microns) thickness.
Heavy. -- Aluminum foil greater than 0.001 inch (25 microns) thickness and less than 0.00177
inch (45 microns) thickness.
Extra heavy. -- Aluminum foil greater than or equal to 0.00177 inch (45 microns) thickness.
Quantity (in short tons); value ($1,000)
Calendar year
Item
2019
U.S. shipments.-Ultra-thin:
Quantity (Q)
Value (R)
Thin:
Quantity (S)
Value (T)
Standard:
Quantity (U)
Value (V)
Heavy:
Quantity (W)
Value (X)
Extra-heavy:
Quantity (Y)
Value (Z)
RECONCILIATION OF U.S. SHIPMENTS BY THICKNESS.— Please ensure that the data reported for
U.S. shipments by thickness (i.e., lines Q through Z) in each time period equal the data reported
for U.S. shipments (i.e., lines D through I) in table II-7 in each time period. If the calculated fields
below return values other than zero (i.e., “0”), the data reported must be revised prior to
submission to the Commission.
Calendar year
Reconciliation
2019
Quantity: Q + S + U + W + Y – D – F – H =
should equal zero ("0")
0
Value: R + T + V + X + Z – E – G – I = should
equal zero ("0")
0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-10.
Page 17
U.S. shipments of in-scope fin stock aluminum foil.--Report your firms' U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
in-scope fin stock aluminum foil for 2019. Data reported in this question should be a subset of
overall U.S. shipments reported in question II-7.
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
2019
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value
II-11.
Changes in U.S. shipments by product type.--Since January 1, 2017, indicate whether your
firm's U.S. shipments of the specified product type increased, decreased, or fluctuated with no
clear trend over the period and the reasons for the specified trend.
Category
Increase
Decrease
No change/
fluctuate with no
clear trend
Explanation
Decrease
No change/
fluctuate with no
clear trend
Explanation
Ultra-thin
Thin
Standard
Heavy
Extra-heavy
Category
Fin stock
Increase
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-12.
Page 18
Employment data.--Report your firm’s employment-related data related to the production of
aluminum foil and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 6.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2017
2018
January-June
2019
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II-13.
Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-14.
Page 19
Purchases.--Has your firm purchased aluminum foil produced in the United States or in other
countries since January 1, 2017? (Do not include imports for which your firm was the importer
of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes--Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in short tons)
Calendar years
Item
2017
2018
January-June
2019
2019
2020
Purchases from U.S. importers of
aluminum foil from—
Armenia
1
Brazil
Oman
Russia
Turkey
All other sources
Purchases from domestic producers2
Purchases from other sources3
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.
1
II-15.
Imports.--Since January 1, 2017, has your firm imported aluminum foil?
No
Yes
If yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-16.
Page 20
Captive production use.—Please report your firm’s internal consumption and/or transfers to
related firms in 2019 by disposition.
Internal consumption
2019
(short tons)
Products
Sold as scope merchandise
Transfers to related firms
2019
(short tons)
N/A
Unusable/not further processed
1
Processed into other products2
Total
0
0
Please describe the eventual disposition of these products:
.
Please identify the top-5 products that the aluminum foil was processed into by your firm, rank ordered
by larger to smaller quantity:
.
1
2
RECONCILIATION OF INTERNAL CONSUMPTION AND TRANSFERS.—The sum of the data reported above
should be equal to the 2019 data reported for internal consumption and transfers in question II-7 for
2019. 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.
Internal consumption
2019
(short tons)
Reconciliation
Data in this question minus data in
question II-7.
II-17.
Transfers to related firms
2019
(short tons)
0
0
Aluminum foil’s share contribution to small reels of aluminum foil.--Does your firm or a related
firm produce small reels of aluminum foil using your firm's U.S.-produced aluminum foil?
No
Yes
If yes-- please report the share that aluminum foil accounts for small reels
of aluminum foil.
Material inputs used in small reels of
aluminum foil production
Aluminum foil
All other material inputs
Total (should sum to 100.0%)
Share of value
Share of the quantity
accounted for in small accounted for in small
reels of aluminum foil reels of aluminum foil
(percent)
(percent)
0.0
0.0
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
II-18.
Aluminum foil's share contribution to other downstream products.--Does your firm or a
related firm produce products other than small reels of aluminum foil out of your firm's
production of aluminum foil? If yes, describe these downstream products and report the share
that aluminum foil accounts for of those products on both a value and quantity basis.
No
Yes
If yes-- Please describe these downstream products and then report the
share that aluminum foil accounts for of these products.
Material inputs used in products other
than small reels of aluminum foil
Aluminum foil
All other material inputs
Total (should sum to 100.0%)
II-19.
Page 21
Share of value
Share of the quantity
accounted for of the
accounted for of the
downstream product(s) downstream product(s)
(percent)
(percent)
0.0
0.0
Other explanations.--If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 22
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:
B.1.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include aluminum foil:
2.
3.
4.
Does your firm prepare profit/loss statements for aluminum foil:
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 aluminum foil, as well
as specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 23
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 aluminum foil and provide the share of net sales accounted for by these products in
your firm’s most recent fiscal year.
Products
Aluminum foil
Share of sales
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
III-6.
Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of aluminum foil 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 24
No—Skip to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
aluminum foil that your firm purchases from related suppliers and that are reflected in question
III-9a. For “Share of total COGS” please report this information by relevant input on the basis of
your most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
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 aluminum foil) 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.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 25
III-9a. Operations on aluminum foil.--Report the revenue and related cost information requested
below on the aluminum foil operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item
2017
2018
January-June
2019
2019
2020
Net sales quantities:
Commercial sales (“CS”)
2
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Net sales values:
Commercial sales
2
Internal consumption
Transfers to related firms
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
Note --The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 26
III-9b. Operations on aluminum foil – U.S. commercial sales and exports only (“open market sales”).Report the revenue and related cost information requested below on the aluminum foil
operations of your firm’s U.S. establishment(s).1 Include both domestic and export commercial
sales of aluminum foil, but do not report resales of purchased aluminum foil. Input purchases
from related suppliers should be consistent with and based on information in the firm’s
accounting books and records. Provide data for your firm’s three most recently completed fiscal
years and for the specified interim periods.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item
quantities:2
2017
2018
January-June
2019
2019
2020
Net sales
Commercial sales quantities from III-9a
0
0
0
0
0
Net sales values:2
Commercial sales values from III-9a
0
0
0
0
0
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Cost of goods sold
Raw materials
(COGS):3
Direct labor
Other factory costs
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 commercial sales only.
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
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
III-9c.
Page 27
Financial data reconciliation.-- The calculable line items from questions III-9a and III-9b (i.e.,
total net sales quantities and values, subtotal raw materials, total COGS, gross profit (or loss),
operating income (or loss), and net income (or loss)) have been calculated from the data
submitted in the other line items. Do the calculated fields return the correct data according to
your firm's financial records ignoring non-material differences that may arise due to rounding?
Yes
No
If no– If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs 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.
III-9d. Raw materials.--Please report the share of total raw material costs in 2019 (reported in III-9a)
for the following raw material inputs:
Procurement method
Input
Share of total raw
material costs
(percent)
Primarily
produced by
your firm
Primarily
purchased by
your firm
Re-roll stock aluminum
Primary aluminum (e.g., wrought)
Secondary aluminum (e.g., scrap)
Other material inputs1
Total (should sum to 100 percent)
0.0
Please identify any other notable "other material inputs" and provide the share of the total raw
material costs for which each account:
.
1
III-9e. Active management of aluminum costs.-- Does your firm actively manage its metal costs (i.e.,
the price of acquiring aluminum to roll) used in the production of aluminum foil?
No
III-9f.
Yes
If yes, please describe.
Effects on financial performance of COVID-19-- Please explain how the COVID-19 pandemic has
affected the financial performance of your firm’s operations on aluminum foil as reported in III9a.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 28
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,
please specify all material (significant) nonrecurring items (charges and gains) in the schedule
below, the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in questions III-9a; i.e., if an aggregate nonrecurring item has been allocated to
question III-9a, only the allocated value amount included in questions III-9a should be reported
in the schedule below. Note: The Commission’s objective here is to gather information only on
material (significant) nonrecurring items which impacted the reported financial results of the
subject product in questions III-9a.
Fiscal years ended-Item
2017
2018
January-June
2019
2019
2020
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in the tables at III-9a where the nonrecurring item is classified.
Description 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
Income statement classification of the
nonrecurring item
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 29
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.
III-12a. Asset values.–Report the total assets (i.e., both current and long-term assets) associated with
aluminum foil. If your firm does not maintain some or all of the specific asset information
necessary to calculate total assets for aluminum foil in the normal course of business, please
estimate this information.
For any assets that are not specific to aluminum foil please allocate the asset(s) based upon a
method (such as production, sales, or costs) that is consistent with relevant cost allocations in
questions III-9a.
Value (in $1,000)
Fiscal year
Item
2017
2018
2019
Total assets (net)
III-12b. Description of asset values.– Please describe the main asset categories (both current and longterm assets) in the above response. Provide a brief explanation if there are any substantial
changes in total asset value during the period; e.g., due to asset write-offs, revaluation, and
major purchases.
III-13a. Capital expenditures and research and development (“R&D”) expenses.–Report your firm’s
capital expenditures and research and development expenses for aluminum foil. Provide data
for the specified fiscal years and interim periods.
Value (in $1,000)
Fiscal year
Item
Capital expenditures
Research and development
expenses
2017
2018
January-June
2019
2019
2020
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 30
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.
III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12a, and 13a are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year
Specify fiscal year
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in question II-7 (including export shipments) equal the quantities and values reported
for total net sales in question III-9a of this questionnaire in each time period unless the financial data
from Part III are reported on a fiscal year basis, in which case only the interim periods must reconcile. If
the calculated fields below return values other than zero (i.e., “0”) and both are being reported on a
calendar basis, please explain the discrepancy below.
Fiscal years ended-Reconciliation
2017
2018
January-June
2019
2019
2020
Quantity: Trade data from question
II-7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").
0
0
0
0
0
Value: Trade data from question II-7
(lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").
0
0
0
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 31
If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of aluminum foil from Armenia, Brazil, Oman, Russia, or Turkey?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 32
III-16. Effects of imports on growth and development.--Since January 1, #bopyear, 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 aluminum foil from Armenia, Brazil, Oman,
Russia, or Turkey?
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
aluminum foil from Armenia, Brazil, Oman, Russia, or Turkey?
No
Yes
If yes, my firm anticipates negative effects as follows.
III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 33
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from James Horne (202-205-2722,
[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.-- Aluminum in the 8XXX series, standard tempers, 0.002‐0.0039 inch thickness, width
6-40”, mill finish.
Product 2.-- Aluminum in the 8XXX series, standard tempers, 0.004‐0.0078 inch thickness, width
6-40”, mill finish.
Product 3.-- Aluminum in the 1XXX or 7XXX series, standard tempers, 0.003‐0.0078 inch
thickness, width 26-48”, mill finish.
Product 4.-- Aluminum in the 3XXX series, standard tempers, 0.0016-0.0032 inch thickness,
width 0.5-15”, mill finish.
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.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 34
IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Period of shipment
Quantity
Value
Product 2
Quantity
Value
Product 3
Quantity
Value
Product 4
Quantity
Value
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
April-June
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment. Please subtract any discounts, rebates, and returns from the quarter in which the sale occurred.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 35
IV-2c. Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
√ if Yes
Are the price data reported above:
In actual dollars (not $1,000) and pounds?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in which the
sale occurred?
Quantities do not exceed commercial shipments in question III-9 in each year?
Explanation(s) for any boxes not checked:
IV-2d. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
IV-2f.
Conversion prices.--Report the average conversion price charged for all in-scope aluminum foil
products since January 1, 2017 and provide an explanation for any trends.
Calendar Years
Item
2017
2018
January - June
2019
2019
2020
Average
conversion price
($/pound)
Explanation of trends:
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of aluminum
foil (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 aluminum foil 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 36
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
aluminum foil in 2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) longterm contract basis, and (4) spot sales basis?
Item
Share of 2019
sales
Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
Short-term
contracts
(multiple
deliveries for
less than 12
months)
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
IV-7.
Page 37
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced aluminum foil (or check “not applicable” if your firm does not sell on a shortterm, 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 aluminum foil ?
Source
Lead time (Average
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0
%
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
IV-9.
Page 38
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 aluminum foil 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 aluminum foil 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
aluminum foil that is accounted for by U.S. inland transportation costs?
percent
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 39
IV-12. End uses.--List the end uses of the aluminum foil that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by aluminum foil and other inputs?
Share of total cost of end use product
accounted for by
End-use product
Aluminum foil
Total
(should sum to
100.0% across)
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-13. Substitutes.--Can other products be substituted for aluminum foil?
No
Substitute
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for aluminum foil?
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 aluminum foil has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand.
Market
Within the United States
Outside the United States
Overall
increase
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 40
IV-15. Impact of the section 232 tariffs.-- Did the imposition of tariffs on imported steel/aluminum
products under section 232 have an impact on the aluminum foil market in the United States?
Yes— Please indicate the
impact in the table below.
Overall
increase
Factor
No
change
No
Don’t know
Overall
decrease
Explain, noting how the
Fluctuate
imposition of tariffs under
with no section 232 affected each factor
clear
of the aluminum foil market in
trend
the United States.
Supply of U.S.-produced
aluminum foil
Supply of imported
aluminum foil
Prices for aluminum foil
Overall U.S. demand for
aluminum foil
Raw material costs for
aluminum foil
IV-16. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of aluminum foil since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 41
IV-17. Conditions of competition.-(a) Is the aluminum foil market subject to business cycles and/or other conditions of
competition distinctive to aluminum foil? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV-18.
Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
aluminum foil since January 1, 2017?
No
Yes
If yes, describe.
IV-18. Supply constraints.--Has your firm refused, declined, or been unable to supply aluminum foil
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-19. Raw materials.--How have aluminum foil 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
aluminum foil.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 42
IV-20. Interchangeability.--Is aluminum foil 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
Armenia
Brazil
Oman
Russia
Turkey
Other
countries
United States
Armenia
Brazil
Oman
Russia
Turkey
For any country-pair producing aluminum foil that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 43
IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between aluminum foil
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
Armenia
Brazil
Oman
Russia
Turkey
Other
countries
United States
Armenia
Brazil
Oman
Russia
Turkey
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of aluminum foil, identify the country-pair and report the advantages
or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 44
IV-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for aluminum foil since January 1, 2017. Indicate the share of the quantity of your
firm’s total shipments of aluminum foil that each of these customers accounted for in 2019.
Customer’s name
1
2
3
4
5
6
7
8
9
10
Contact person
Email
Telephone
City
State
Share
of
2019
sales
(%)
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 45
IV-23. Competition from imports.-(a)
Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling
aluminum foil from Armenia, Brazil, Oman, Russia, and/or Turkey 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 aluminum foil to imports
of this product from Armenia, Brazil, Oman, Russia, and/or Turkey?
No
(c)
Yes
The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: FOIL)
IV-24. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 46
PART V.—PRODUCT COMPARABILITY
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, [email protected]).
V-1.
Comparability of types of Aluminum Foil products.--Please compare domestically produced
ultra-thin and fin stock aluminum foil to all other domestically produced in-scope foil and
indicate whether they are: fully comparable or the same, i.e., have no differentiation between
them; mostly comparable or similar; somewhat comparable or similar; never or not-at-all
comparable or similar; or no familiarity with products.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(a) Physical Characteristics and End Uses.--The differences and similarities in the physical
characteristics and end uses.
Product-pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:
in-scope fin stock aluminum foil
products vs. all other in-scope
aluminum foil products
in-scope ultra-thin gauge
aluminum foil products vs. all
other in-scope aluminum foil
products
(b) Interchangeability.--The ability to substitute the products in the same application.
Product-pair
in-scope fin stock aluminum foil
products vs. all other in-scope
aluminum foil products
in-scope ultra-thin gauge
aluminum foil products vs. all
other in-scope aluminum foil
products
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
V-1.
Page 47
Comparability of types of Aluminum Foil products.—Continued.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(c) Manufacturing facilities, production processes, and production employees.--Whether
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.
Product-pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:
in-scope fin stock aluminum foil
products vs. all other in-scope
aluminum foil products
in-scope ultra-thin gauge aluminum
foil products vs. all other in-scope
aluminum foil products
(d) Channels of distribution.--Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).
Product-pair
in-scope fin stock aluminum foil
products vs. all other in-scope
aluminum foil products
in-scope ultra-thin gauge aluminum
foil products vs. all other in-scope
aluminum foil products
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
V-1.
Page 48
Comparability of types of aluminum foil products.—Continued.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not-at-all comparable or similar; or
0: no familiarity with products.
(e) Customer and producer perceptions.--Perceptions as to the differences and/or
similarities in the market (e.g., sales/marketing practices).
Product-pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:
in-scope fin stock aluminum foil
products vs. all other in-scope
aluminum foil products
in-scope ultra-thin gauge aluminum
foil products vs. all other in-scope
aluminum foil products
(f) Price.--Whether prices are comparable or differ between the products.
Product-pair
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:
in-scope fin stock aluminum foil
products vs. all other in-scope
aluminum foil products
in-scope ultra-thin gauge aluminum
foil products vs. all other in-scope
aluminum foil products
V-2.
Other explanations.-- If your firm would like to further explain a response to a question in Part
V, please use the box below to respond. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Aluminum Foil (Preliminary)
Page 49
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2020/aluminum_foil_armenia_brazil_om
an_russia_and/preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/
Pin: FOIL
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | US producer questionnaire |
| Subject | Title 7 investigations |
| Author | Feldpausch, Celia |
| File Modified | 2020-10-01 |
| File Created | 2020-10-01 |