20-2-4334 U.S. importers' questionnaire

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

US importers--Wind Tower (P)

Utility scale wind towers from India, Malaysia, and Spain (Inv. nos. 701-TA-660-661 and 731-TA-1543-1545) 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⚠️ Notice: This form may be outdated.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. 20-2-4334; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
UTILITY SCALE WIND TOWERS FROM INDIA, MALAYSIA, AND SPAIN
This questionnaire must be received by the Commission by October 14, 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 duty and antidumping investigations concerning wind towers from India, Malaysia,
and Spain (inv. Nos. 701-TA-660-661 and 731-TA-1543-1545 (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 wind towers (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: WIND)
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 – Wind towers (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to petitions filed on September 30, 2020, by
the Wind Tower Trade Coalition (Arcosa Wind Towers Inc. (Dallas, Texas) and Broadwind Towers, Inc.
(Manitowoc, Wisconsin)). 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://usitc.gov/investigations/701731/2020/utility_scale_wind_towers_india_malaysia_and_spain/pr
eliminary.htm.
Wind towers covered by these investigations is certain wind towers, whether or not tapered, and
sections thereof. Certain wind towers support the nacelle and rotor blades in a wind turbine with a
minimum rated electrical power generation capacity in excess of 100 kilowatts and with a minimum
height of 50 meters measured from the base of the tower to the bottom of the nacelle (i.e., where the
top of the tower and nacelle are joined) when fully assembled.
A wind tower section consists of, at a minimum, multiple steel plates rolled into cylindrical or conical
shapes and welded together (or otherwise attached) to form a steel shell, regardless of coating, endfinish, painting, treatment, or method of manufacture, and with or without flanges, doors, or internal or
external components (e.g., flooring/decking, ladders, lifts, electrical buss boxes, electrical cabling,
conduit, cable harness for nacelle generator, interior lighting, tool and storage lockers) attached to the
wind tower section. Several wind tower sections are normally required to form a completed wind tower.
Wind towers and sections thereof are included within the scope whether or not they are joined with
nonsubject merchandise, such as nacelles or rotor blades, and whether or not they have internal or
external components attached to the subject merchandise.
Specifically excluded from the scope are nacelles and rotor blades, regardless of whether they are
attached to the wind tower. Also excluded are any internal or external components which are not
attached to the wind towers or sections thereof, unless those components are shipped with the tower
sections.
Merchandise covered by these orders is currently classified in the Harmonized Tariff Schedule of the
United States (HTSUS) under subheading 7308.20.0020 or 8502.31.0000. Wind towers of iron or steel
are classified under HTSUS 7308.20.0020 when imported separately as a tower or tower section(s).
Wind towers may be classified under HTSUS 8502.31.0000 when imported as combination goods with a
wind turbine (i.e., accompanying nacelles and/or rotor blades). While the HTSUS subheadings are
provided for convenience and customs purposes, the written description of the scope of these orders is
dispositive.
Unit.—A unit, unless otherwise stated, is a complete wind tower (whether or not comprised of multiple
sections) or wind tower equivalent (e.g., one section of a wind tower comprised of four sections would
be equal to ¼ or 0.25 wind towers).
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing wind towers (as defined above) into the United States from a foreign manufacturer or
through its selling agent.

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)

Page 3

Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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 Calvin
Chang (202-205-3062, [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 – Wind towers (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 wind towers, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

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. Importers’ Questionnaire – Wind towers (Preliminary)
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 wind towers from India, Malaysia, or Spain into the
United States or that are engaged in exporting wind towers from India, Malaysia, or Spain to the
United States?
No
Firm name

I-5.

Page 5

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 wind towers?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
I-6.

Page 6

Importing operations.—
(a) Please indicate the nature of your firm’s importing operations of wind towers. More than
one answer may be applicable.
Importer of record

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

(b) Did your foreign supplier take over the formal importation of products for which your firm
had otherwise served as the importer of record during the period of investigation?

I-7.

Yes

If yes, please indicate the foreign suppliers/importers of record
involved, and describe the timing and reasons for such change in
your firm’s role relating to importation of wind towers.

Consignee.--If your firm is an importer of record of wind towers 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 – Wind towers (Preliminary)
I-8.

Page 7

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters wind towers into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports wind towers 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 – Wind towers (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Calvin Chang (202-205-3062,
[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 wind towers 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 – Wind towers (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 chain arrangements, importation, employment, and sales relating
to wind towers?

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 wind towers 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-Sep 2020

Oct-Dec 2020

Jan-Mar 2021

Quantity (in units)
India
Malaysia
Spain
All other sources

Apr-Jun 2021

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
II-3b.

Page 10

Imports in the 12-month period preceding the petition.--Has your firm imported wind towers
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 units)
Source

September 2019 through August 2020

India
Malaysia
Spain
All other sources
II-4.

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

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U.S. Importers’ Questionnaire – Wind towers (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.
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 – Wind towers (Preliminary)
II-5a.

Page 12

U.S. imports from India.–Report your firm’s imports and your firm’s shipments and inventories
of wind towers imported from India by your firm during the specified periods.

India

Quantity (in units), value (in $1,000)
Calendar year
Item

2017

January-June

2018

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

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

2017

2018
0

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:
.

Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (Preliminary)
II-5b.

Page 13

U.S. shipments of imports by region: India.--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 India to each of the specified regions during the specified period.

India
"Northeast".--CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
"Upper Midwest".--MI, MN, NE, ND, SD, and WI.
"Lower Midwest".--IL, IN, IA, KS, OH, and MO.
"Upper Southeast.--DE, DC, MD, VA, and WV.
"Lower Southeast".--AL, FL, GA, KY, MS, NC, SC, and TN.
"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.
Quantity (in units)
Calendar year
Geographic region

2017

2018

January-June
2019

2019

2020

Northeast (M)
Upper Midwest (N)
Lower Midwest (O)
Upper Southeast (P)
Lower Southeast (Q)
Central Southwest (R)
Mountains (S)
Pacific Coast (T)
Other (U)
RECONCILIATION OF SHIPMENTS BY GEOGRAPHIC REGION.--Please ensure that the quantities reported
for shipments by region (i.e., lines M through U) equal the quantities reported for U.S. shipments (i.e.,
lines D,F, and H). 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
Quantity: M + N + O + P + Q + R +
S + T + U – D – F – H = zero ("0"), if
not revise.
II-5c.

2017

2018

January-June
2019

2019

2020

U.S. shipments of wind towers without internal components: India.— Please report the share
of your firm’s U.S. shipments of wind towers reported in II-5a that were shipped without any
mechanical and/or electrical fittings such as platforms, ladders, lighting, lifts (elevators),
electrical-cable harnesses, storage lockers, and/or other accessories/internal components:
percent.

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

Page 14

U.S. imports from Malaysia.–Report your firm’s imports and your firm’s shipments and
inventories of wind towers imported from Malaysia by your firm during the specified periods.

Malaysia

Quantity (in units), value (in $1,000)
Calendar year
Item

2017

January-June

2018

2019

2020

2017

2018
0

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

Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (Preliminary)
II-6b.

Page 15

U.S. shipments of imports by region: Malaysia.--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 Malaysia to each of the specified regions during the specified period.

Malaysia
"Northeast".--CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
"Upper Midwest".--MI, MN, NE, ND, SD, and WI.
"Lower Midwest".--IL, IN, IA, KS, OH, and MO.
"Upper Southeast.--DE, DC, MD, VA, and WV.
"Lower Southeast".--AL, FL, GA, KY, MS, NC, SC, and TN.
"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.
Quantity (in units)
Calendar year
Geographic region

2017

2018

January-June
2019

2019

2020

2017

2018

January-June
2019

2019

2020

U.S. shipments of wind towers without internal components: Malaysia.— Please report the
share of your firm’s U.S. shipments of wind towers reported in II-6a that were shipped without
any mechanical and/or electrical fittings such as platforms, ladders, lighting, lifts (elevators),
electrical-cable harnesses, storage lockers, and/or other accessories/internal components:
percent.

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

Page 16

U.S. imports from Spain.–Report your firm’s imports and your firm’s shipments and inventories
of wind towers imported from Spain by your firm during the specified periods.

Spain

Quantity (in units), value (in $1,000)
Calendar year
Item

2017

January-June

2018

2019

2020

2017

2018
0

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

Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (Preliminary)
II-7b.

Page 17

U.S. shipments of imports by region: Spain.--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 Spain to each of the specified regions during the specified period.

Spain
"Northeast".--CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
"Upper Midwest".--MI, MN, NE, ND, SD, and WI.
"Lower Midwest".--IL, IN, IA, KS, OH, and MO.
"Upper Southeast.--DE, DC, MD, VA, and WV.
"Lower Southeast".--AL, FL, GA, KY, MS, NC, SC, and TN.
"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.
Quantity (in units)
Calendar year
Geographic region

2017

2018

January-June
2019

2019

2020

2017

2018

January-June
2019

2019

2020

U.S. shipments of wind towers without internal components: Spain.— Please report the share
of your firm’s U.S. shipments of wind towers reported in II-7a that were shipped without any
mechanical and/or electrical fittings such as platforms, ladders, lighting, lifts (elevators),
electrical-cable harnesses, storage lockers, and/or other accessories/internal components:
percent.

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

Page 18

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and inventories
of wind towers imported from all other sources by your firm during the specified periods.

(list sources:

All other sources

)

Quantity (in units), value (in $1,000)
Calendar year
Item

2017

January-June

2018

2019

2020

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--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 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 year
Reconciliation
A + B – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1

2017

2018
0

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:
.

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
II-8b.

Page 19

U.S. shipments of imports by region: 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 to each of the specified regions during the specified period.

All other sources
"Northeast".--CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
"Upper Midwest".--MI, MN, NE, ND, SD, and WI.
"Lower Midwest".--IL, IN, IA, KS, OH, and MO.
"Upper Southeast.--DE, DC, MD, VA, and WV.
"Lower Southeast".--AL, FL, GA, KY, MS, NC, SC, and TN.
"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.
Quantity (in units)
Calendar year
Geographic region

2017

2018

January-June
2019

2019

2020

2017

2018

January-June
2019

2019

2020

U.S. shipments of wind towers without internal components: All other sources.— Please
report the share of your firm’s U.S. shipments of wind towers reported in II-8a that were
shipped without any mechanical and/or electrical fittings such as platforms, ladders, lighting,
lifts (elevators), electrical-cable harnesses, storage lockers, and/or other accessories/internal
components:
percent.

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Page 20

II-9.

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-10.

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.

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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, [email protected]).
III-1.

PURCHASE COST DATA
III-2.

This question requests quarterly quantity and value data for your firm’s imports since January 1,
2017 of the following products your firm imported from India, Malaysia, and Spain:
Product 1.— Wind towers, more than 80 meters but less than or equal to 90 meters in height
Product 2.—Wind towers, more than 90 meters but less than or equal to 100 meters in height
Product 3.—Wind towers, more than 100 meters but less than or equal to 110 meters in height
Product 4.—Wind towers, more than 110 meters but less than or equal to 120 meters in height
Please note that values should be reported on a landed duty paid costs (LDP) basis. Values
should reflect the final net L.D.P. amount your firm paid (i.e., should be net of all deductions
for discounts or rebates).

III-2.

Imports for internal use/installation--This question requests quarterly quantity and landed-duty
paid value data for your firm’s imports of the products defined above for internal consumption
from India, Malaysia, and Spain since January 1, 2017. These are imports that your firm installs
and therefore does not resell as wind towers.
During January 2017-June 2020, did your firm import any of the products listed above from
India, Malaysia, and Spain for installation?
Yes.--Please complete the following table(s) as appropriate.
No.--Skip to question III-3.

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III-2a. Imports for internal use.—Report below the import data1 for pricing products2 imported from
India and installed by your own firm.
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).

India
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity
LDP Value
Quantity
LDP Value
Quantity
LDP Value

Product 4
Quantity
LDP Value

Period of importation
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 LDP value (i.e., landed duty-paid 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). See “Import
values” definition in Part II (Trade and Related Information – Definitions).
2 Pricing product definitions are provided on the first page of Part III.
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 data.
Product 1:
Product 2:
Product 3:
Product 4:

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Page 23

III-2b. Imports for internal use.—Report below the import data1 for pricing products2 imported from
Malaysia and installed by your own firm.
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).

Malaysia

Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity
LDP Value
Quantity
LDP Value
Quantity
LDP Value

Product 4
Period of importation
Quantity
LDP 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 LDP value (i.e., landed duty-paid 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). See “Import
values” definition in Part II (Trade and Related Information – Definitions).
2 Pricing product definitions are provided on the first page of Part III.
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 data.
Product 1:
Product 2:
Product 3:
Product 4:

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)

Page 24

III-2c. Imports for internal use.—Report below the import data1 for pricing products2 imported from
Spain and installed by your own firm.
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).

Spain
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Quantity
LDP Value
Quantity
LDP Value
Quantity
LDP Value

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Complete these questions only if your firm reported data on the previous page, otherwise skip to
question III-3.
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 wind towers rather than purchase from a U.S. producer
or importer of wind towers.
III-2d. Additional costs for your firm’s imports of wind towers for your firm’s internal use.—
i.

Did your firm incur any additional costs by importing wind towers 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 wind towers 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 wind
towers, 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 wind towers 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 wind towers 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-2e. Decision basis.—To which source(s) does your firm compare costs in determining whether or
not to import wind towers? Check all that apply.

U.S. importers

III-2f.

U.S. producers

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

Benefits of importing wind towers.
i.

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

ii.

Is it your firm’s experience that the wind towers your firm imported from India,
Malaysia, and Spain 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 wind towers 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-2b).

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-2diii (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-2iii 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-2g. Purchase cost data checklist.--Please check that the purchase cost data in question III-2(a) has
been correctly reported.
Are the purchase cost data reported above:
In actual dollars (not $1,000) and number of wind towers?
L.D.P. value is value at U.S. port of entry (i.e., does not include U.S. transport
costs)?
Quantities for subject imports do not exceed imports reported for the same
country in part II in each year?
Explanation(s) for any boxes not checked:

√ if Yes

Business Proprietary
U.S. Importers’ Questionnaire – Wind towers (Preliminary)
III-3.

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

III-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 installed wind tower produced in the
United States and imported wind towers from India, Malaysia, and Spain usually quoted (check
one)?
Source

III-6.

Set
price
lists

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

Quantity
discounts

III-5.

Page 28

Delivered

F.o.b.

If f.o.b., specify point

U.S. produced

Subject imports

Contract versus spot.--Approximately what share of your firm’s sales of wind towers purchased
from U.S. producers and imported from India, Malaysia, and Spain in 2019 was on a (1) shortterm contract basis, (2) annual contract basis, (3) long-term contract basis, and (4) spot sales
basis?

Share of 2019
sales
U.S. produced
Subject imports

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

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

Spot sales
(for a
single
delivery)
%
%

Total
(should
sum to
100.0%)
0.0
0.0

%
%

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
III-7.

Page 29

Contract provisions.—Please fill out the table regarding your firm’s typical sales contracts for
wind towers purchased from U.S. producers and imported from India, Malaysia, and Spain (or
check “not applicable” if your firm does not sell on a short-term, annual and/or long-term
contract basis).
Wind towers purchased from U.S. producers
Short-term contracts Annual contracts
(multiple deliveries
(multiple
Item
for less than 12
deliveries for 12
months)
months)

Typical sales
contract provisions
Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

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

365

No
Quantity
Price
Both
Yes

Indexed to raw
material costs1

Not applicable
1

Please identify the indexes used:

Typical sales
contract provisions

Wind towers imported from India, Malaysia, and Spain
Short-term contracts Annual contracts Long-term contracts
(multiple deliveries
(multiple
(multiple deliveries
Item
for less than 12
deliveries for 12
for more than 12
months)
months)
months)

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price

365

No
Quantity

Indexed to raw
material costs1

Price
Both
Yes
No

Not applicable
1

Please identify the indexes used:

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
III-8.

Page 30

Lead times.--What is your firm’s share of sales of wind towers imported from India, Malaysia,
and Spain from inventory and produced to order and what is the typical lead time between a
your or your customer’s order and the date of delivery for your firm’s sales or purchases of wind
towers? (If your firm is an importer and re‐seller of wind towers, please answer for your sales. If
your firm is an importer and installer of wind towers, please answer for the wind towers
installed.)?

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 %

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
III-9.

Page 31

Shipping information.—
(a)

What is the approximate percentage of the cost of installed wind towers produced in
the United States and imported from India, Malaysia, and Spain that is accounted for by
U.S. inland transportation costs?
U.S.
Share of costs of wind towers accounted for by
U.S. transportation costs

(b)

Subject Import
%

Who generally arranges the transportation of subject imports and U.S. produced
product to your firm’s customers’ locations?
Source

Your firm

Purchaser

U.S. product (check one)
Subject imported product (check one)
(c)

When your firm sells wind towers imported from India, Malaysia, and Spain, from where
are they shipped, i.e., where is the initial point of shipment in the United States?
Point of importation
Your U.S. storage facility (check one)
Additional explanation if needed:

(d)

When your firm sells wind towers produced in the United States, from where are they
shipped, i.e., where is the initial point of shipment in the United States?
Producers’ facility
Your U.S. storage facility (check one)
Additional explanation if needed:

(e)

Indicate the approximate percentage of your firm’s sales of wind towers produced in the
United States and imported from India, Malaysia, and Spain 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

Import
Share

Within 100 miles

101 to 500 miles

501 to 1,000 miles

Over 1,000 miles

0.0 %

Totals (should sum to 100.0%)
(f)

U.S. product
Share

0.0

Are your FOB prices that you pay for the same wind tower models consistent across all
shipping distances or do they vary by shipping distances? Please explain and report if
this response differs between U.S. and imported wind towers.

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)
II-10.

Page 32

Geographical shipments.— Describe the importance, if any, of geographic location in your
firm’s sales/installation of wind towers.

III-11. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for wind towers has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within the United States
Outside the United States
III-12. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of wind towers since January 1, 2017?
No

Yes

If yes, please describe.

III-13. Conditions of competition.—
(a) Is the wind towers market subject to business cycles and/or other conditions of competition
distinctive to wind towers?
Check all that apply.

Please describe.

Skip to question III-14.

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
wind towers since January 1, 2017?
No

Yes

If yes, describe.

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III-14. Supply constraints.-(a) Has your firm refused, declined, or been unable to supply wind towers 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.

(b) Has any firm refused, declined, or been unable to supply your firm with wind towers 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-15. Raw materials.—

(a) How have wind towers 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 purchase or import
prices for wind towers.

(b) Has information on raw material prices affected your firm’s negotiations or contracts to
purchase or import wind towers since 2017?

Yes Explain

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III-16. Impact of the PTC expiration and wind-down.—This question concerns the anticipated
expiration of the Federal wind energy production tax credit (PTC).
(a) Has the anticipated expiration of the PTC at the end of 2020 had an impact on the U.S.
market for wind towers?
Yes—Please answer part (b)

Don’t know

(b) Assessment of impact of the anticipated PTC expiration.-- Please indicate the impact of the
anticipated expiration of the Federal wind energy PTC.

Item
Acquisitions of wind
towers by your firm
Financial performance
of your firm
Demand for wind
towers in the U.S.
market
Prices for wind towers
in the U.S. market
Timing of U.S. wind
energy projects in the
development pipeline

Fluctuate
with no
No
clear
Increase change Decrease
trend

Explanation and factors

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III-17. Interchangeability.--Is wind towers 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

India

Malaysia

Spain

Other countries

United States
India
Malaysia
Spain
For any country-pair producing wind towers that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

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III-18. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between wind towers 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

India

Malaysia

Spain

Other countries

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

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U.S. Importers’ Questionnaire – Wind towers (Preliminary)

Page 37

III-19. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for wind towers since January 1, 2017. Indicate the share of the quantity of your
firm’s total shipments of wind towers 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-20. 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.

Business Proprietary
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Page 38

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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Page 39

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://usitc.gov/investigations/701731/2020/utility_scale_wind_towers_india_malaysia_and_spain/pr
eliminary.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: WIND

• 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	USITCQUESTIONNAIRE
Subject	Title 7 investigations
Author	Chang, Calvin
File Modified	2020-10-02
File Created	2020-10-02