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pdfOMB No. 3117-0016/USITC No. 20-1-4341; Expiration Date : 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
POLYVINYL ALCOHOL FROM CHINA AND JAPAN
This questionnaire must be received by the Commission by November 16, 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 reviews of the antidumping duty orders concerning polyvinyl alcohol (“PVA”) from China and Japan
(Inv. Nos. 731-TA-1014 and 1016 (Third Review)). The information requested in the questionnaire is requested under the
authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as directed can result in a
subpoena or other order to compel the submission of records or information in your firm’s possession (19 U.S.C. §
1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced PVA (whether or not excluded from the scope as defined on the next page) at any time
since January 1, 2014?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/ (PIN: PVA)
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 or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official
Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 2
PART I.—GENERAL INFORMATION
Background.— On July 2, 2003, the Department of Commerce (“Commerce”) issued an antidumping
duty order on imports of polyvinyl alcohol (“PVA”) from Japan (68 FR 39518). On October 1, 2003,
Commerce issued an antidumping duty order on imports of PVA from China (68 FR 56620). Following the
first five-year reviews by Commerce and the Commission, effective April 13, 2009, Commerce issued a
continuation of the antidumping duty orders on imports of PVA from China and Japan (74 FR 16834).
Following the second five-year reviews by Commerce and the Commission, effective May 27, 2015,
Commerce issued a continuation of the antidumping duty orders on imports of PVA from China and
Japan (80 FR 30208). On April 1, 2020, the Commission instituted reviews pursuant to section 751(c) of
the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine whether revocation of the orders
would be likely to lead to continuation or recurrence of material injury to the domestic industry within a
reasonably foreseeable time. If both the Commission and Commerce make affirmative determinations,
the orders will remain in place. If either the Commission or Commerce makes negative determinations,
Commerce will revoke the orders. Questionnaires and other information pertinent to this proceeding
are available at
https://www.usitc.gov/investigations/701731/2020/polyvinyl_alcohol_china_and_japan/third_review_f
ull.htm
Polyvinyl Alcohol (“PVA”) — All PVA hydrolyzed in excess of 80 percent, whether or not mixed or
diluted with commercial levels of defoamer or boric acid, except as noted below. The following products
are specifically excluded from the scope of these reviews:
1) PVA in fiber form.
2) PVA with hydrolysis less than 83 mole percent and certified not for use in the production of
textiles.
3) PVA with hydrolysis greater than 85 percent and viscosity greater than or equal to 90 cps.
4) PVA with a hydrolysis greater than 85 percent, viscosity greater than or equal to 80 cps but less
than 90 cps, certified for use in an ink jet application.
5) PVA for use in the manufacture of an excipient or as an excipient in the manufacture of film
coating systems which are components of a drug or dietary supplement, and accompanied by an
end-use certification.
6) PVA covalently bonded with cationic monomer uniformly present on all polymer chains in a
concentration equal to or greater than one mole percent.
7) PVA covalently bonded with carboxylic acid uniformly present on all polymer chains in a
concentration equal to or greater than two mole percent, certified for use in a paper
application.
8) PVA covalently bonded with thiol uniformly present on all polymer chains, certified for use in
emulsion polymerization of non-vinyl acetic material.
9) PVA covalently bonded with paraffin uniformly present on all polymer chains in a concentration
equal to or greater than one mole percent.
10) PVA covalently bonded with silan uniformly present on all polymer chains certified for use in
paper coating applications.
11) PVA covalently bonded with sulfonic acid uniformly present on all polymer chains in a
concentration level equal to or greater than one mole percent.
12) PVA covalently bonded with acetoacetylate uniformly present on all polymer chains in a
concentration level equal to or greater than one mole percent.
13) PVA covalently bonded with polyethylene oxide uniformly present on all polymer chains in a
concentration level equal to or greater than one mole percent.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 3
14) PVA covalently bonded with quaternary amine uniformly present on all polymer chains in a
concentration level equal to or greater than one mole percent.
15) PVA covalently bonded with diacetoneacrylamide uniformly present on all polymer chains in a
concentration level greater than three mole percent, certified for use in a paper application.
The merchandise subject to these orders is currently classifiable under subheading 3905.30.00 of the
Harmonized Tariff Schedule of the United States (HTSUS). Although the HTSUS subheading is provided
for convenience and customs purposes, the written description of the scope of these orders is
dispositive.
Reporting of information.--If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 4
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.
Note.--Throughout this questionnaire please report only included forms of PVA in data grids that ask for
information on “PVA” unless expressly instructed by the question to report excluded forms of PVA.
I-1.
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
I-2a.
Page 5
Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of PVA, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
Covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I-2b.
Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.
I-2c.
External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):
I-3.
Position regarding continuation of orders.--Does your firm support or oppose continuation of
the following antidumping duty orders currently in place for PVA from the following countries?
Country
China
Order type
Antidumping duty
Japan
Antidumping duty
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
I-4.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-5.
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 PVA into the United States or that are engaged in
exporting PVA to the United States?
No
Firm name
I-6.
Page 6
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 PVA?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
I-7.
Page 7
Business plan.--In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for PVA?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 8
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Alejandro Orozco (202-2053177, [email protected]). Supply all data requested on a calendar-year basis.
II-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
II-2a.
Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of PVA since January 1, 2014.
Check as many as appropriate.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-2b.
Anticipated changes in operations.--Does your firm anticipate any changes in in the character of
its operations or organization relating to the production of PVA in the future?
No
II-3a.
Page 9
Yes
If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions, along with relevant
portions of business plans or other supporting documentations that
address this issue.
Production using same machinery.--Please report your firm’s production of products made
using the same equipment, machinery, or employees as used to produce PVA, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-4a. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-4a should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-3a.
Page 10
Production using same machinery.--Continued
Quantity (in 1,000 pounds)
Calendar year
Item
Overall production capacity
2017
2018
January-September
2019
2019
2020
1
Production of:
PVA (in-scope)2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Out-of-scope production.-PVA (excluded from scope)3
Other products4
Subtotal, out-of-scope
production
Total production using same
machinery or workers
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of PVA will populate here once reported in question II-4a.
3
For a listing of excluded PVA items, see page 2. Please identify the PVA excluded items for which data are reported:
.
4
Please identify these other out-of-scope products:
.
2
II-3b.
Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week
Weeks per year
II-3c.
Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.
II-3d.
Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-3e.
Page 11
Product shifting.-(i)
Is your firm able to switch production (capacity) between PVA and other products using the
same equipment and/or labor?
No
(ii)
Yes
If yes—(i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-4a.
Page 12
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of included forms of PVA in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“U.S. shipments” – Shipments made within the United States.
“Export shipments” – Shipments to destinations outside the United States.
“Commercial shipments” – Shipments made 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.
“Inventories” — Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-4a.
Page 13
Production, shipment, and inventory data.--Continued
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
Calendar year
Item
Average production capacity
(quantity) (A)
2017
2018
January-September
2019
2019
2020
1
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:3
quantity (F)
value (G)
Transfers to related firms:3
quantity (H)
value (I)
Export shipments:2
Commercial shipments:
quantity (J)
value (K)
Transfers to related firms:3
quantity (L)
value (M)
End-of-period inventories (quantity)
(N)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity (use additional pages as
necessary).
.
2 Identify your firm’s principal export markets:
.
3 Internal consumption and transfers to related firms must be valued at fair market value. Does your firm use a different basis
for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.):
(however, provide the data above at fair
market value).
1
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-4a.
Page 14
Production, shipment, and inventory data.--Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line N) should be equal to the beginning-of-period
inventories (i.e., line B), plus production (i.e., line C), less total shipments (i.e., lines D, F, H, J, and
L). Please ensure that any differences are not due to data entry errors in completing this form,
but rather reflect your firm’s actual records; and, also provide explanations for any differences
(e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar year
Item
2017
B+C–D–F–H–J–L–N=
should equal zero ("0") or provide
an explanation.1
2018
0
January-September
2019
0
2019
0
2020
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate:
.
II-4b.
Historical U.S. shipment data. --Report the quantity and value of your firm’s U.S. shipments
(including commercial U.S. shipments, internal consumption, and transfers, but not including
exports) of PVA produced in your U.S. establishment(s) during the specified periods.
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
Calendar year
Item
Historical U.S. shipments:
Quantity
Value
2014
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-5.
Page 15
Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution in
the specified periods.
Quantity (in 1,000 pounds)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
U.S. shipments:
to Distributors (O)
to End users (P)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines O and P) in each time period equal the quantity reported for U.S shipments (i.e., lines D, F, and
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 year
Reconciliation item
O + P – D – F – H = zero ("0"), if
not revise.
2017
2018
0
January-September
2019
0
2019
0
2020
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-6.
Page 16
US shipments by product type and end use.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by the end use
applications and product type (i.e., by the range of hydrolysis levels) in calendar year 2019.
Calendar year 2019
Hydrolysis levels
U.S. shipments
Greater than or
equal to 97
percent
Greater than 85
percent but less
than 97 percent
Greater than 80
percent but less
than or equal to
85 percent
Quantity (in 1,000 pounds)
End use application.-Polyvinyl butyral (Q)
Textiles (R)
Paper (S)
Adhesives (T)
Emulsion polymerization (U)
Building materials (V)
Pharmaceuticals (W)
Other (X)1
1
Specify applications reported for “other”
.
RECONCILIATION OF US SHIPMENTS.--Please ensure that the quantities reported for US
shipments in this question (i.e., lines Q through X across all columns) equal the quantity reported
for U.S shipments (i.e., lines D, F, and H) in 2019 in question II-4a. If the calculated field below
returns a value other than zero (i.e., “0”), the data reported must be revised prior to submission
to the Commission.
Reconciliation item
Q + R + S + T + U + V + W + X (across all columns) – D
– F – H (in 2019 column)= zero ("0"), if not revise.
Calendar year 2019
0
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-7.
Page 17
Employment data.--Report your firm’s employment-related data related to the production of
PVA and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12.
For the January to September periods, calculate similarly and divide by 9. If your firm had the
same number of PRWs in all calendar years and had not experienced any changes in PRWs in the
most recent interim period, you would have the same number of PRWs for the interim periods,
regardless of whether the interim periods are Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept
(Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” – Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
Employment data:
Average number of
PRWs (number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs
($1,000)
Explanation of trends:
2017
2018
January-September
2019
2019
2020
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 18
II-8.
Transfers to related firms.--If your firm reported transfers to related firms in question II-4a,
please identify the firm(s) and indicate the nature of the relationship between your firm and the
related firms (e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at
market value or by a non-market formula, whether your firm retained marketing rights to all
transfers, and whether the related firms also processed inputs from sources other than your
firm.
II-9.
Purchases.--Has your firm purchased included forms of PVA produced in the United States or in
other countries since January 1, 2014? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire).
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” – A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes--Report such purchases in the table below and explain the
reasons for your firms' purchases:
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-9.
Page 19
Purchases.--Continued
Quantity (in 1,000 pounds)
Calendar years
Item
2017
Purchases from U.S. importers
of PVA from—
China
2018
January-September
2019
2019
2020
1
Japan
Germany
Singapore
Taiwan
All other sources2
Purchases from domestic
producers3
Purchases from other sources4
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Identify other sources:
.
3
Please list the name of the U.S. producer(s) from which your firm purchased this product:
.
4
Please list the name of the firm(s) from which your firm purchased this product:
.
II-10.
Imports.--Since January 1, 2014, has your firm imported PVA?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf.
No
Yes
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II-11.
Toll production.--Since January 1, 2014, has your firm been involved in a toll agreement
regarding the production of PVA?
“Toll agreement” – Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes
If yes--Please describe the toll arrangement(s) and name the firm(s)
involved.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-12.
Page 20
Foreign trade zones.-(a)
Firm's FTZ operations.--Does your firm produce PVA in and/or admit PVA into a foreign
trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
(b)
Yes
If yes--Describe the nature of your firm’s operations in FTZs
and identify the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import PVA into a foreign trade zone (FTZ) for use in distribution of PVA and/or the
production of downstream articles?
No
Yes
If yes--Identify the firms and the FTZs.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 21
For questions II-13 and II-14, if your response differs for particular orders, please indicate and explain
the particular effect of imposition and/or revocation of specific orders.
II-13.
Effect of order(s).--Describe the significance of the existing antidumping duty orders covering
imports of PVA from China and Japan in terms of its effect on your firm’s production capacity,
production, U.S. shipments, inventories, purchases, employment, revenues, costs, profits, cash
flow, capital expenditures, research and development expenditures, and asset values. You may
wish to compare your firm’s operations before and after the imposition of the order(s).
II-14.
Likely impact of revocation.--Would your firm anticipate any changes in the character of its
operations or organization, including its production capacity, production, U.S. shipments,
inventories, purchases, employment, revenues, costs, profits, cash flow, capital expenditures,
research and development expenditures, or asset values relating to the production of PVA in the
future if the antidumping duty orders on PVA from China and Japan were to be revoked?
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 22
II-15a. 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, production, shipments, and employment
relating to PVA?
No
Yes
If yes, describe these changes including a separate discussion of the
(a) supply chain impact, (b) production and shipment impact, and (c)
employment impact of the COVID-19 pandemic.
II-15b. Anticipated effects of COVID-19 pandemic on production and shipments.--Does your firm
anticipate any changes in relation to the production and shipments of PVA relating to the
COVID-19 pandemic or any government actions taken to contain the spread of COVID-19 virus in
the future?
No
II-16.
Yes
If yes, please describe these effects.
Other explanations.--If your firm would like to explain further a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 23
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Zahra Bekkal (202-205-2684,
[email protected]).
III-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
III-2.
Accounting system.--Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain below:
Note.—Please report all financial data in part III on a calendar year basis.
B.1.
2.
3.
4.
Describe the lowest level of operations (e.g., plant, division, company-wide) for which
financial statements are prepared that include PVA:
Does your firm prepare profit/loss statements for PVA:
Yes
No
How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
U.S. GAAP,
IFRS,
cash,
tax, or
other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes PVA, as well as specific
statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 24
III-4.
Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III-5.
Product listing.--Please list the products your firm produces in the facilities in which it produces
PVA, and provide the share of net sales accounted for by these products in your firm’s most
recent calendar year.
Products
Share of sales
PVA (as defined)
%
PVA (excluded forms)
%
%
%
%
III-6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of PVA from any related suppliers (e.g., inclusive of transactions between related
firms, divisions and/or other components within the same company)?
Yes--Continue to question III-7a.
No--Continue to question III-9a.
III-7a. Inputs from related suppliers.--Please identify the inputs used in the production of PVA that
your firm purchases from related suppliers and that are reflected in question III-9a. For “Share
of total COGS” please report this information by relevant input on the basis of your most
recently completed calendar year. For “Input valuation” please describe the basis, as recorded
in the company’s own accounting system, of the purchase cost from the related supplier; e.g.,
the related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input
Related supplier
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 25
III-7b. Inputs from related suppliers at cost.--Please confirm that the inputs purchased from related
suppliers, as identified in III-7a, were reported in III-9a (financial results on PVA) in a manner
consistent with the firm’s accounting books and records.
Yes
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:
No
III-8a. By-products.—Does your firm have any by-product revenue associated with its PVA operations?
Yes
If yes--In the space below, please identify the by-product(s) and complete
table III-8b. If no--Continue to question III-9a.
No
III-8b. By-product revenue.--Report your firm’s total by-product revenue associated with the PVA
operations of your U.S. establishment(s). Provide data for the three most recently completed
calendar years, and for the specified interim periods. Note: the data provided below will
appear in question III-9a as a reduction to COGS.
Value (in $1,000)
Calendar year
Item
By-product revenue
1
2017
2018
January-September
2019
2019
2020
1
Please describe how your firm classifies these by-product revenues in the normal course of business
(e.g., included in net sales values, as a reduction to COGS, included in “all other income”).
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 26
III-9a. Operations on PVA.--Report the revenue and related cost information requested below on the
included forms of PVA operations of your firm’s U.S. establishment(s). 1 Do not report resales of
products. Note that internal consumption and transfers to related firms must be valued at fair
market value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for your firm’s three most
recently completed calendar years, and for the specified interim periods.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Less: by-product revenue
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment
quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1
2
Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 27
III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), operating income (or loss), and net
income (or loss)) have been calculated from the data submitted in the other line items. Do the
calculated fields return the correct data according to your firm's financial records ignoring nonmaterial differences that may arise due to rounding?
Yes
III-9c.
If no--If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative--instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
No
Raw materials.--Please report the share of total raw material costs in 2019 (reported in III-9a)
for the following raw material inputs:
Procurement method
Input
Share of total raw
material costs
(percent)
Primarily
produced by
your firm
Primarily
purchased by
your firm
Vinyl Acetate Monomer (VAM) 1
Polyvinyl Acetate1
Other material inputs2 (specify below)
Total (should sum to 100 percent)
1
0.0
Please identify the upstream products your firm purchased to produce this raw material if your firm
did not purchase the specified raw material, but are integrated into its upstream production:
For VAM:
For Polyvinyl Acetate:
2
Please indicate any notable "other" raw materials not expressly identified above and provide the
share of the total raw material costs that they account for:
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
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III-9d. Effects on financial performance of COVID-19.--Since January 1, 2020, has the COVID-19
pandemic or have any government actions taken to contain the spread of the COVID-19 virus
affected the financial performance of your firm’s operations on PVA as reported in III-9a?
No
III-9e.
Yes
If yes, please describe these effects.
Anticipated effects of COVID-19 on financial performance.--Does your firm anticipate any
effects on its financial performance due to the COVID-19 pandemic?
No
Yes
If yes, please describe these effects.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 29
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each period for which financial results are reported in question III-9a, please specify all material
(significant) nonrecurring items (charges and gains) in the schedule below, the specific III-9a line
item where the nonrecurring items are included, a brief description of the relevant nonrecurring
items, and the associated values (in $1,000), as reflected in question III-9a; i.e., if an aggregate
nonrecurring item has been allocated to question III-9a, only the allocated value amount
included in question III-9a should be reported in the schedule below. Note: The Commission’s
objective here is to gather information only on material (significant) nonrecurring items which
impacted the reported financial results of the subject product in question III-9a.
Calendar year
2017
2018
Item
January-September
2019
2019
2020
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Income statement classification of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in question III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10 identify where these items
are reported in question III-9a.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 30
III-12a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of PVA. If your firm does not maintain some or all of the
specific asset information necessary to calculate total assets for PVA in the normal course of
business, please estimate this information based upon a method (such as production, sales, or
costs) that is consistent with relevant cost allocations in question III-9a. Provide data as of the
end of your firm’s three most recently completed calendar years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted. Total assets should be allocated to the subject products if these assets are also
related to other products.
Value (in $1,000)
Calendar year
Item
2017
2018
2019
Total assets (net)
III-12b. Description of reported assets.-- Please describe the main asset categories (both current and
long-term assets) in the above response. Provide a brief explanation if there are any substantial
changes in total asset value during the period; e.g., due to asset write-offs, revaluation, and
major purchases.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 31
III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for PVA. Provide data for the
three requested calendar years, and for the specified interim periods.
Value (in $1,000)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Capital expenditures
R&D expenses
III-13b. Description of reported capital expenditures.-- Please describe the nature, focus, and
significance of your firm’s reported capital expenditures in the above response. If no capital
expenditure data were reported, please explain the reason.
III-13c. Description of reported R&D expenses.-- Please describe the nature, focus, and significance of
your firm’s reported R&D expenses in the response above. If no R&D expenses were reported,
please explain the reason.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 32
III-14. Data consistency and reconciliation.--Please note that we are requesting your firm’s financial
data for questions III-9a, III-12a, and III-13a on a calendar year basis. Please confirm that your
firm reported these data on a calendar-year basis:
Yes
No
If no, please explain.
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-4a (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.--Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported for total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis, in which case only the interim periods must reconcile. If the calculated fields below return values
other than zero (i.e., “0”) and both are being reported on a calendar basis, please explain the discrepancy
below.
Calendar year
Reconciliation
2017
2018
January-September
2019
2019
2020
Quantity: Trade data from
question II-4a (lines D, F, H,
and J) less financial total net
sales quantity data from
question III-9a, = zero ("0").
0
0
0
0
0
Value: Trade data from
question II-4a (lines E, G, I,
and K) less financial total
net sales value data from
question III-9a, = zero ("0").
0
0
0
0
0
Do these data in question III-9a reconcile with data in question II-4a?
Yes
No
If no, please explain.
III-15. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 33
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Howie Nguyen (202) 7081441, [email protected]).
IV-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 IV.
Name
Title
Email
Telephone
PRICE DATA
IV-2.
This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products produced by your firm.
Product 1.-- PVA for use in textile applications with a range of hydrolysis between 89-100
(percent) and a viscosity between 13-35 (centipois), sold in bags
Product 2.-- PVA for use in paper applications with a range of hydrolysis between 87-100
(percent) and a viscosity between 13-55 (centipois), sold in bags
Product 3.-- PVA for use in adhesive applications with a range of hydrolysis between 80-100
(percent) and a viscosity between 0-19 (centipois), sold in bags
Product 4.— PVA for use in adhesive applications with a range of hydrolysis between 80-89
(percent) and a viscosity between 36-55 (centipois), sold in bags
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).
(a) During January 2017 -September 2020, did your firm produce and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with
these products)?
Yes.--Please complete the following pricing data table as appropriate.
No.--Skip to question IV-3.
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 34
IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds and actual dollars (not 1,000s).
(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value Quantity
Value
Product 4
Quantity
Value
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
July-September
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods), f.o.b. your firm’s U.S. point of shipment. Please subtract any discounts, rebates, and returns from
the quarter in which the sale occurred.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified
product, provide a description of the product. Also, please explain any anomalies in your firm’s reported pricing
data.
Product 1:
Product 2:
Product 3:
Product 4:
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 35
IV-2 c. Price data checklist.--Please check that the pricing data in question IV-2(a) has been correctly
reported.
√ if Yes
Are the price data reported above:
Quantity
Value
In actual dollars (not $1,000) and pounds (not 1,000 pounds)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport
costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in
which the sale occurred?
Quantities do not exceed commercial shipments in question II-4 in each
year?
Explanation(s) for any boxes not checked:
IV-2d. Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of PVA (check
all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Set
price
lists
Other
If other, describe
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
No
discount
policy
Other
Describe
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
IV-5.
Pricing terms.--On what basis are your firm’s prices of U.S.-produced PVA usually quoted (check
one)?
Delivered
IV-6.
F.o.b.
If f.o.b., specify point
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced PVA in
2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) long-term contract
basis, and (4) spot sales basis?
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)
Share of 2019
sales
IV-7.
%
%
%
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
U.S.-produced PVA (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
No
Quantity
Indexed to raw
material costs1
Price
Both
Yes
No
Not applicable
1
Page 36
Please identify the indexes used:
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
365
Long-term contracts
(multiple deliveries
for more than 12
months)
%
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
IV-8.
Lead times.--What is the typical lead time between a customer’s order and the date of delivery
for your firm’s sales of its U.S.-produced PVA?
Share of 2019 Lead time (average
sales
number of days)
Source
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV-9.
Page 37
0.0 %
Shipping information.-(a)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(b)
Indicate the approximate percentage of your firm’s sales of U.S.-produced PVA that are
delivered the following distances from your firm’s production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0
%
IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced PVA since January 1, 2014 (check all that apply)?
Geographic area
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.
√ if applicable
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U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
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IV-11. Inland transportation costs.—What is the approximate percentage of the cost of U.S.-produced
PVA that is accounted for by U.S. inland transportation costs?
percent
IV-12. End uses.--Have there been any changes in the end uses of PVA since January 1, 2014? Do you
anticipate any future changes?
Changes in end
uses
No
Yes
Explain
Changes since
January 1, 2014
Anticipated
changes
IV-13. Substitutes.--Have there been any changes in the number or types of products that can be
substituted for PVA since January 1, 2014? Do you anticipate any future changes?
Changes in
substitutes
No Yes
Explain
Changes since
January 1, 2014
Anticipated
changes
IV-14. Availability of supply.--Has the availability of PVA in the U.S. market changed since January 1,
2014? Do you anticipate any future changes?
Please explain, noting the countries and reasons for
Availability in the U.S. market No Yes the changes.
Changes since January 1, 2014:
U.S.-produced product
Imports from China and Japan
Imports from all other
countries
Anticipated changes:
U.S.-produced product
Imports from China and Japan
Imports from all other
countries
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 39
IV-15. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for PVA has changed since January 1, 2014, and how you anticipate demand
will change in the future. Explain any trends and describe the principal factors that have
affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2014
Within the
United States
Outside the
United States
Anticipated future demand
Within the
United States
Outside the
United States
IV-16. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of PVA since January 1, 2014? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2014
Anticipated
changes
Explain
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
IV-17.
Page 40
Conditions of competition.-(a) Is the PVA market subject to business cycles and/or other conditions of competition
distinctive to PVA?
Check all that apply.
Please describe.
No
Skip to question IV-18.
Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
PVA since January 1, 2014?
No
Yes
If yes, describe.
IV-18. Supply constraints.--Has your firm refused, declined, or been unable to supply PVA since
January 1, 2014 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV-19. Raw materials.-- Indicate how PVA raw material prices have changed since January 1, 2014, and
how you expect they will change in the future.
Raw
materials
prices
Changes since
January 1,
2014
Anticipated
changes
Fluctuate
with no
Overall
No
Overall
clear
increase change decrease trend
Explain, noting how raw material
price changes have affected your
firm’s selling prices for PVA.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 41
IV-20. Price comparisons.--Please compare market prices of PVA in U.S. and non-U.S. markets, if
known. Provide specific information as to time periods and regions for any price comparisons.
IV-21. Market studies.--Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss PVA supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China and Japan, and (3) the world as
a whole. Of particular interest is such data from 2014 to the present and forecasts for the
future.
IV-21. Export constraints.--Describe how easily your firm can shift its sales of PVA between the U.S.
market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints that would prevent or retard your firm from
shifting PVA between the U.S. and alternative country markets within a 12-month period.
IV-22. Barriers to trade.--Are your firm’s exports of PVA subject to any tariff or non-tariff barriers to
trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2014, or that are expected to occur in the future.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 42
IV-23. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products under
section 301 have an impact on the PVA market in the United States?
Yes— Please indicate the
impact in the table below.
Factor
Supply of U.S.produced PVA
Supply of PVA
imported from China
Supply of PVA
imported from other
countries
Prices for PVA
Overall U.S. demand
for PVA
Raw material costs for
PVA
No
Overall
No
Overall
increase change decrease
Don’t know
Fluctuate Explain, noting how the imposition
with no of tariffs under section 301 affected
clear
each factor of the PVA market in
trend
the United States.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 43
IV-24. Interchangeability.--Is PVA produced in the United States and in other countries interchangeable
(i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair
China
Japan
Other countries
United States
China
Japan
For any country-pair producing PVA which is sometimes or never interchangeable, please
identify the country-pair and explain the factors that limit or preclude interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 44
IV-25. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between PVA produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair
China
Japan
Other countries
United States
China
Japan
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of PVA, identify the country-pair and report the advantages or
disadvantages imparted by such factors:
IV-26. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Polyvinyl Alcohol (Third Review)
Page 45
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/polyvinyl_alcohol_china_and_japan/third
_review_full.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: PVA
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - PRO--Questionnaire |
| Author | alejandro.orozco |
| File Modified | 2020-10-06 |
| File Created | 2020-10-06 |