20-2-4330 U.S. importers' questionnaire

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

Importers--Alum foil (P)

Aluminum foil from Armenia, Brazil, Oman, Russia, and Turkey (Inv. nos. 701-TA-658-659 and 731-TA-1538-1542) Prelim

OMB: 3117-0016

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 3117-0016 can be found here:

2023-04-18 - Extension without change of a currently approved collection

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Download: pdf | pdf

OMB No. 3117-0016/USITC No. 20-2-4330; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ 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 imported aluminum foil (as defined on next page) from any country at any time since January 1,
2017?

(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. Importers’ 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.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing aluminum foil (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
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. Importers’ 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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Celia
Feldpausch (202-205-2387, [email protected]).
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. Importers’ Questionnaire – Aluminum Foil (Preliminary)
I-1.

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
40 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-2a.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm involved in the importation of aluminum foil, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 5

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.

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

Firm name

I-4.

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

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing 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

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
I-5.

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

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations of
aluminum foil. More than one answer may be applicable.
Importer of record

I-7.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Consignee.--If your firm is an importer of record of aluminum foil but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).

Firm name

Address

Contact person
and phone
number

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
I-8.

Page 7

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters aluminum foil into,
or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports aluminum foil under the TIB (temporary importation under bond)
program.
“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, as
well as other savings. A foreign trade zone must be designated as such pursuant to the rules
and procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond
I-9.

Other trade actions.--To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No

Yes

If yes, Yes–Please specify.

Business Proprietary
U.S. Importers’ 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 (202-2382387, [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 importation of aluminum foil since January 1, 2017.
(check as many as appropriate)

Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation 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. Importers’ 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, importation, employment, and sales relating to
aluminum foil?

II-3a.

Page 9

Yes

If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) importation and sales impact, and (c)
employment impact of the COVID-19 pandemic.

Arranged imports.--Has your firm imported or arranged for the importation of aluminum foil for
delivery after June 30, 2020?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes

If yes, fill out the table below.

Period
Source

Jul-Sept 2020

Oct-Dec 2020

Jan-Mar 2021

Quantity (in short tons)
Armenia
Brazil
Oman
Russia
Turkey
All other sources

Apr-June 2021

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-3b.

Page 10

Imports in the 12-month period preceding the petition.--Has your firm imported aluminum foil
from any source between September 1, 2019 and August 31, 2020? (i.e., the last four months in
2019 and first eight months in 2020 combined)
No

Yes

If yes, report the quantity of such import below by source.

Quantity (in short tons)
Source

September 2019 through August 2020

Armenia
Brazil
Oman
Russia
Turkey
All other sources
II-4.

Reasons for importing if producer.--If your firm also produces aluminum foil in the United
States, please indicate the reasons for importing this product. If your firm’s reasons differ by
source, please elaborate.

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 11

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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.
“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.
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. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-5a.

Page 12

U.S. imports from Armenia.–Report your firm’s imports and your firm’s shipments and
inventories of aluminum foil imported from Armenia by your firm during the specified periods.

Armenia
Quantity (in short tons), value (in $1,000)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
Imports:1
Quantity (B)
Value (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)
Please identify the foreign producers, if known:
.
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
2

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-5a.

Page 13

U.S. imports from Armenia.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-June
2019

2019
0

2020
0

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

II-5b.

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

Armenia
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

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 14

II-5c. U.S. shipments by thickness: Armenia .--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Armenia 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.

Armenia
Quantity (in short tons); value ($1,000)
Calendar year
Item
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)

2019

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 15

II-5c.U.S. shipments by thickness: Armenia.—Continued
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-5a 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")

Value: R + T + V + X + Z – E – G – I =
should equal zero ("0")

II-5d.

Aluminum foil by product type: Armenia.--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-5a.

Armenia
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-6a.

Page 16

U.S. imports from Brazil.–Report your firm’s imports and your firm’s shipments and inventories
of aluminum foil imported from Brazil by your firm during the specified periods.

Brazil
Quantity (in short tons), value (in $1,000)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-6a.

Page 17

U.S. imports from Brazil.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-June
2019

2019
0

2020
0

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

II-6b.

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

Brazil
Calendar years
Item

2017

2018

January-June
2019

2019

2020

2017

2018
0

January-June
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 18

II-6c. U.S. shipments by thickness: Brazil .--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Brazil 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.

Brazil
Quantity (in short tons); value ($1,000)
Calendar year
Item
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)

2019

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 19

II-6c. U.S. shipments by thickness: Brazil .—Continued
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-6a 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")

Value: R + T + V + X + Z – E – G – I =
should equal zero ("0")

II-6d.

Aluminum foil by product type: Brazil.-- 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-6a.

Brazil
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-7a.

Page 20

U.S. imports from Oman.–Report your firm’s imports and your firm’s shipments and inventories
of aluminum foil imported from Oman by your firm during the specified periods.

Oman
Quantity (in short tons), value (in $1,000)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-7a.

Page 21

U.S. imports from Oman.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-June
2019

2019
0

2020
0

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

II-7b.

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

Oman
Calendar years
Item

2017

2018

January-June
2019

2019

2020

2017

2018
0

January-June
2019

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 22

II-7c. U.S. shipments by thickness: Oman .--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Oman 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.

Oman
Quantity (in short tons); value ($1,000)
Calendar year
Item
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)

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 23

II-7c.U.S. shipments by thickness: Oman.—Continued
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-7a 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")

Value: R + T + V + X + Z – E – G – I =
should equal zero ("0")

II-7d.

Aluminum foil by product type: Oman.-- 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-7a.

Oman
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-8a.

Page 24

U.S. imports from Russia.–Report your firm’s imports and your firm’s shipments and inventories
of aluminum foil imported from Russia by your firm during the specified periods.

Russia
Quantity (in short tons), value (in $1,000)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-8a.

Page 25

U.S. imports from Russia.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-June
2019

2019
0

2020
0

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

II-8b.

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

Russia
Calendar years
Item

2017

2018

January-June
2019

2019

2020

2017

2018
0

January-June
2019

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 26

II-8c. U.S. shipments by thickness: Russia .--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Russia 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.

Russia
Quantity (in short tons); value ($1,000)
Calendar year
Item
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)

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 27

II-8c.U.S. shipments by thickness: Russia.—Continued
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-8a 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")

Value: R + T + V + X + Z – E – G – I =
should equal zero ("0")

II-8d.

Aluminum foil by product type: Russia.--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-8a.

Russia
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-9a.

Page 28

U.S. imports from Turkey.–Report your firm’s imports and your firm’s shipments and
inventories of aluminum foil imported from Turkey by your firm during the specified periods.

Turkey
Quantity (in short tons), value (in $1,000)
Calendar years
Item

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-9a.

Page 29

U.S. imports from Turkey.–Continued

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-June
2019

2019
0

2020
0

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

II-9b.

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

Turkey
Calendar years
Item

2017

2018

January-June
2019

2019

2020

2017

2018
0

January-June
2019

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 30

II-9c. U.S. shipments by thickness: Turkey .--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from Turkey 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.

Turkey
Quantity (in short tons); value ($1,000)
Calendar year
Item
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)

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 31

II-9c.U.S. shipments by thickness: Turkey.—Continued
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-9a 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")

Value: R + T + V + X + Z – E – G – I =
should equal zero ("0")

II-9d.

Aluminum foil by product type: Turkey.-- 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-9a.

Turkey
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 32

II-10a. Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of aluminum foil imported from all other sources by your firm during the specified
periods.

(list sources:

All other sources
)
Quantity (in short tons), value (in $1,000)
Calendar years

Item

2017

2018

January-June
2019

2019

2020

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 33

II-10a. Imports from all other sources.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation

2017

2018

A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1

January-June
2019

2019
0

2020
0

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

II-10b. Channels of distribution: All other sources.-- Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution during the specified periods.

All other sources
Calendar years
Item

2017

2018

January-June
2019

2019

2020

2017

2018
0

January-June
2019

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 34

II-10c. U.S. shipments by thickness: All other sources .--Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
imports from all other sources 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.

All other sources
Quantity (in short tons); value ($1,000)
Calendar year
Item
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)

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 35

II-10c. U.S. shipments by thickness: All other sources.--Report your firm’s U.S. shipments (i.e., inclusive
of commercial U.S. shipments, internal consumption, and transfers to related firms) of imports from all
other sources for 2019.
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-10a 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")

Value: R + T + V + X + Z – E – G – I =
should equal zero ("0")

II-10d. Aluminum foil by product type: All other sources.-- 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-10a.

All other sources
Quantity (in short tons) and value (in $1,000)
Calendar year
Item
U.S. shipments:
In-scope fin stock aluminum foil:
Quantity
Value

2019

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
II-11.

Page 36

Changes in U.S. shipments by thickness.--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

Fin stock
II-12.

Transfers to related firms.--If your firm reported transfers to related firms in any of the data
tables in part II, 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) and whether the
transfers were priced at market value or by a non-market formula.

II-13.

Other explanations.--If your firm would like to further explain a response to a question in Part II
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. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 37

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from James Horne (202-205-2722,
[email protected]).
III-1.

PRICE DATA
III-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 your firm imported
from Armenia, Brazil, Oman, Russia, or Turkey:
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).
During January 2017-June 2020, did your firm import from Armenia, Brazil, Oman, Russia, or
Turkey and sell to unrelated U.S. customers any of the above listed products (or any products
that were competitive with these products)?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-3.

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 38

III-2a. Price data.--Report below the quarterly price data1 for pricing products2 imported from Armenia
and sold by your firm.

Armenia

Report data in pounds 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, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
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 III.
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:
Product 3:
Product 4:

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 39

III-2b. Price data.--Report below the quarterly price data1 for pricing products2 imported from Brazil
and sold by your firm.

Brazil

Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

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 III.

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
III-2c.

Page 40

Price data.--Report below the quarterly price data1 for pricing products2 imported from Oman
and sold by your firm.

Oman

Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 41

III-2d. Price data.--Report below the quarterly price data1 for pricing products2 imported from Russia
and sold by your firm.

Russia

Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 42

III-2e. Price data.--Report below the quarterly price data1 for pricing products2 imported from Turkey
and sold by your firm.

Turkey

Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
III-2f.

Page 43

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

√ if Yes

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 section II in each year?
Explanation(s) for any boxes not checked:

III-2g. 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.

PURCHASE COST DATA
III-3.

This question requests quarterly quantity and landed duty-paid value data for your firm’s
imports of the products defined in question III‐2 above (at the beginning of question III‐2)
for internal consumption and/or use for sales in your firm’s retail locations from Armenia,
Brazil, Russia, and/or Turkey since January 1, 2017.
During January 2017‐June 2020, did your firm import any of the products listed on at the
beginning of question III‐2 from Armenia, Brazil, Russia, and/or Turkey for internal
consumption or for use for sales in your firm’s retail locations?
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-4.

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 44

III‐3a. Imports for internal use or retail sale.—Report below the import data1 for pricing products2
imported from Armenia and used by your own firm or sold at retail.
Please note that values should be landed, duty‐paid (LDP) and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid by your firm (i.e., should
be net of all returns, discounts, allowances, and rebates).

Armenia
Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 45

III‐3b. Imports for internal use or retail sale.—Report below the import data1 for pricing products2
imported from Brazil and used by your own firm or sold at retail.
Please note that values should be landed, duty‐paid (LDP) and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid by your firm (i.e., should
be net of all returns, discounts, allowances, and rebates).

Brazil
Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
III‐3c.

Page 46

Imports for internal use or retail sale.—Report below the import data1 for pricing products2
imported from Russia and used by your own firm or sold at retail.
Please note that values should be landed, duty‐paid (LDP) and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid by your firm (i.e., should
be net of all returns, discounts, allowances, and rebates).

Russia
Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 47

III‐3d. Imports for internal use or retail sale.—Report below the import data1 for pricing products2
imported from Turkey and used by your own firm or sold at retail.
Please note that values should be landed, duty‐paid (LDP) and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid by your firm (i.e., should
be net of all returns, discounts, allowances, and rebates).

Turkey
Report data in pounds and actual dollars (not 1,000s).

(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value

Product 4
Quantity Value

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

Page 48

III-3e. Purchase cost data checklist.--Please check that the pricing data in question III-2(a) has been
correctly reported.
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 section II in each year?
Explanation(s) for any boxes not checked:

III-3f.

Purchase cost data methodology.--Please describe the method and the kinds of
documents/records that were used to compile your price data.

√ if Yes

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Complete these questions only if your firm reported data on the previous page, otherwise skip to
question III-4.
The following questions ask about the costs/benefits (not included in the LDP values reported above)
that factor into your firm’s decision to import aluminum foil rather than purchase from a U.S.
producer or importer of aluminum foil.
III-3g. Additional costs for your firm’s imports of aluminum foil for your firm’s {internal use,
repackaging, or retail sale}.—
i.

Did your firm incur any additional costs by importing aluminum foil rather than
purchasing from a U.S. producer or importer (e.g., logistical or supply chain
management costs, warehousing/inventory carrying costs, insurance or other risk
management fees, demurrage fees, indirect and overseas costs)?
No

Yes—Please answer parts ii, iii, and iv.

ii.

Please provide an estimate of the total additional cost incurred (as a percentage
compared to LDP value) when importing aluminum foil rather than purchasing from a
U.S. producer or importer. (Report only the portion that is related to your firm’s
importing activities, either directly or indirectly, and not already included in the LDP
value. Do NOT include any costs that also would be incurred if your firm purchased the
product from a U.S. producer or importer.)
percent compared to LDP value.

iii.

Please identify and explain the specific additional costs incurred by your firm and
estimate each cost (in percent) compared to the cost of importing. (Only report costs
and the portion of each cost that was related to your firm’s importing activities for
aluminum foil, either directly or indirectly, and that are not already included in the LDP
value. Do NOT report costs that your firm would incur when purchasing aluminum foil
from a U.S. producer or importer.)

Costs

iv.

Estimated
percentage
compared to LDP
value (percent)
%
%
%
%

Explanation

Briefly describe how your firm’s additional costs (beyond the purchase price) by
importing aluminum foil directly compare with the additional costs your firm incurs
when purchasing from a U.S. producer or U.S. importer.

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III-3h. Decision basis.—To which source(s) does your firm compare costs in determining whether or
not to import aluminum foil? Check all that apply.

U.S. importers

III-3i.

U.S. producers

Neither U.S. importers
nor U.S. producers

Benefits of importing aluminum foil.
i.

Briefly identify the benefits of importing aluminum foil instead of purchasing aluminum
foil from a U.S. importer or from a U.S. producer.

ii.

Is it your firm’s experience that the aluminum foil your firm imported from Armenia,
Brazil, Russia, and/or Turkey are priced lower than they would be if your firm purchased
from a U.S. importer or U.S. producer?
Imports are priced lower when

Yes (If yes to either, please
answer parts iii and iv.)

Not including the additional costs above
Including the additional costs above
iii.

Please estimate your firm’s savings by importing aluminum foil instead of purchasing
from a U.S. producer or U.S. importer since January 1, 2017 (as a percent of the
purchase price from the U.S. importer or U.S. producer). For your estimate, compare
the price of purchasing from a U.S. importer or U.S. producer to the cost of direct
imports (including the additional costs described above in III-3b).

Factors

iv.

Estimated savings
(percent of purchase price from
U.S. importer/producer)

U.S. producer

U.S. importer

What methods or experience did you base the estimates in III-3diii (i.e. based on
previous transactions with U.S. producers and/or U.S. importers, market research, etc.)
Check all that apply.
Reported estimates in III-3diii based on
Previous company transactions
Market research
Other – Please explain

√ if Yes

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Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of these data, as Commission staff may contact your firm regarding questions. 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.
III-4.

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

III-5.

Other

If other, describe

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

Quantity
discounts

III-6.

Contracts

Set
price
lists

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported aluminum foil from Armenia,
Brazil, Oman, Russia, and/or Turkey usually quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
III-7.

Contract versus spot.--Approximately what share of your firm’s sales of aluminum foil imported
from Armenia, Brazil, Oman, Russia, and/or Turkey 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
III-8.

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

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
aluminum foil imported from Armenia, Brazil, Oman, Russia, and/or Turkey (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)

Quantity
Price
Both
Yes
No

Not applicable
Please identify the indexes used:

Annual contracts
(multiple
deliveries for 12
months)
365

Indexed to raw
material costs1

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

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)
III-9.

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Lead times.--What is your firm’s share of sales of aluminum foil imported from Armenia, Brazil,
Oman, Russia, and/or Turkey 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 aluminum foil?

Source

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

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

III-10. Shipping information.—
(a)

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

(b)

When your firm sells aluminum foil imported from Armenia, Brazil, Oman, Russia, or
Turkey, from where is it shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of aluminum foil imported
from Armenia, Brazil, Oman, Russia, and/or Turkey that are delivered the following
distances from your firm’s U.S. point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

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III-11. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold aluminum
foil imported from subject countries since January 1, 2017 (check all that apply)?
Geographic area

Armenia

Brazil

Oman

Russia

Turkey

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.
III-12. Inland transportation costs.—What is the approximate percentage of the cost of aluminum foil
imported from Armenia, Brazil, Oman, Russia, and/or Turkey that is accounted for by U.S. inland
transportation costs?
percent.
III-13. End uses.--List the end uses of the aluminum foil that your firm imports. 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

Other inputs

Total
(should sum to
100.0% across)

0.0 %

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

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III-14. 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.
III-15. 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

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

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III-16. 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

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
III-17. 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.

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

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III-18. Conditions of competition.—
(a) Is the aluminum foil market subject to business cycles and/or other conditions of
competition distinctive to aluminum foil?
Check all that apply.

Please describe.

Skip to question III-19.

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.

III-19. 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.

III-20. 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.

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III-21. 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:

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

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III-22. 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:

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

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III-23. 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

Contact person

Telephone

City

State

Share
of
2019
sales
(%)

1
2
3
4
5
6
7
8
9
10
III-24. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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PART IV.—PRODUCT COMPARABILITY
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, [email protected]).
IV-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. Importers’ Questionnaire – Aluminum Foil (Preliminary)
IV-1.

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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. Importers’ Questionnaire – Aluminum Foil (Preliminary)
IV-1.

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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
IV-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. Importers’ Questionnaire – Aluminum Foil (Preliminary)

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Correcting valid number error messages.--If you are completing a Commission questionnaire

in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would appear as
$1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than 999 in
numeric form fields. This issues stem from your computer number formatting setting (e.g., not the MS
Word document itself, but the computer from which you are opening up the document). In the United
States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one. Many EU
countries use the reverse where multiples of 1000 are delineated with periods (.) and fractions less than
one are delineated with commas (,). The U.S. International Trade Commission’s questionnaires are setup in the United States with the U.S. number formatting. When this formatting interacts with a
computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.

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U.S. Importers’ Questionnaire – Aluminum Foil (Preliminary)

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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 did not import 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 importer questionnaire
Subject	Title 7 investigations
Author	Feldpausch, Celia
File Modified	2020-10-01
File Created	2020-10-01