20-4-4344 Foreign producers' / exporters' questionnaire

OMB No. 3117-0016/USITC No. 20-4-4344; Expiration Date : 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ 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.

Name of firm
Address
Website
Has your firm produced or exported 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)

Data reported in this questionnaire relate to (Check one):
China

Japan

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 proceeding 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

Phone:
Signature

Email address

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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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.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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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.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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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
Alejandro Orozco (202-205-3177, [email protected]).
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
30 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-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire.
“Establishment”--Each facility of a firm in China or Japan involved in the production or export of
PVA, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities. Firms operating more than one establishment in the subject
country specified on the certification (i.e., China or Japan) should combine the data for all
establishments in that country into a single report.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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I-3.

Stock symbol information.--If your firm or any of the entities reported in question I-2 are
publicly traded in the United States, please specify the stock exchange and trading symbol
(including American Depository Receipts, if applicable):
.

I-4.

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-5.

U.S. importers.--Please provide the names, contacts, email addresses, and telephone numbers
of the FIVE largest U.S. importers of your firm’s PVA in 2019.

No.

1
2
3
4
5

Importer’s name

Contact person

Email address

Share of
Area code
your firm’s
and
2019 U.S.
telephone
exports
number
(%)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
I-6.

U.S. or other country production.--Does your firm or any related firm produce, have the
capability to produce, or have any plans to produce PVA in the United States or other countries?

No

I-7.

Yes

If yes--Please name the firm(s) and country(ies) below and, if U.S.
producer(s), ensure that they complete the Commission’s producer
questionnaire.

U.S. importation.--Does your firm or any related firm import or have any plans to import PVA
into the United States?

No

I-8.

Page 6

Yes

If yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

Business plan.--In Parts II and III 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 future 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.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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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-2.

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
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-2b.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization relating to the production of PVA in the future?

No

II-3a.

Page 8

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 on
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 for all
products manufactured in that establishment using the same manufacturing equipment.
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-11a. 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-11a should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” --All production in your establishment(s) in China and Japan, including production
consumed internally within your firm.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-3a.

Page 9

Production using same machinery.--Continued
Quantity (in 1,000 pounds)
Calendar years
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-11a.
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
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-3e.

Page 10

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.

II-4.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of PVA?
percent.

II-5.

Firm's estimated share of production in country.--Please estimate the percentage of total
production of PVA in the country specified on the certification page accounted for by your firm’s
production in 2019.
percent.

II-6.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of PVA from the country specified on the certification page accounted for by
your firm’s exports in 2019.
percent.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
II-7.

Page 11

Third country trade actions.--Is the PVA exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?

No

Yes

If yes— List the products(s), countries affected, and the date of such
findings/remedies/proceedings

II-8.

Other export markets.--Identify export markets (other than the United States) that your firm
has developed or where it has increased its sales of PVA since 2014. Please identify and discuss
below.

II-9.

Significance of antidumping duty orders.--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, home market shipments, exports to the United States and
other markets, and inventories. You may wish to compare your firm’s operations before and
after the imposition of the order.

II-10.

Likely impact of revocation.--Would your firm anticipate any changes in 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. Include in your
response a specific projection of your firm’s capacity to
produce PVA (in 1,000 pounds) for 2020 and 2021.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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II-11a. Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of PVA in your establishment(s) in the subject country specified in the
certification page (i.e., China or Japan) during the specified periods. Do not include resales of
PVA that your firm did not produce in this question; those data to the degree they are exported
to the United States should only be reported in question II-12.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
Do not submit data on multiple countries combined. The establishments reported here should
all be located in the country of the firm’s address reported on the certification page.
Multinational companies with production in multiple subject countries should submit separate
foreign producer questionnaire responses for each subject country.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s) in China and Japan, including production
consumed internally within your firm.
“Shipments” -- Shipments of products produced in your establishment(s) in China and Japan.
Quantities reported should be net of returns. 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 in China and Japan.
“Home market commercial shipments” -- Shipments, other than internal consumption and
transfers to related firms, within China and Japan.
“Home market internal consumption/transfers to related firms” -- Shipments made to
related firms in China and Japan, including product consumed internally by your firm.
“Export shipments” -- Shipments to destinations outside China and Japan, 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.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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II-11a. Trade data.--Continued.
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
Calendar year
Item

2017

2018

January-September
2019

2019

2020

1

Average production capacity (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
Quantity (D)
Value (E)
Commercial shipments
Quantity (F)
Value (G)
Export shipments:
to the United States:
Quantity (H)
Value (I)
to the European Union:2
Quantity (J)
Value (K)
to Asia:3
Quantity (L)
Value (M)
to all other markets:4
Quantity (N)
Value (O)
Total exports (Quantity) (P)

0

0

0

0

0

Total shipments (Quantity) (Q)

0

0

0

0

0

End-of-period inventories (R)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity:
.
2
Identify your firm’s principal European Union export markets:
.
3
Identify your firm’s principal Asian export markets:
.
4
Identify your firm’s principal other export markets:
.

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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II-11a. Trade data.--Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line R) 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, L,
and N). 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

2017

Item

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

January-September

2018

0

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-11b. Total shipments by product type and end use.--Report your firm’s total shipments (i.e. inclusive
of home-market shipments and export shipments) 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

Item

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 (S)
Textiles (T)
Paper (U)
Adhesives (V)
Emulsion polymerization (W)
Building materials (X)
Pharmaceuticals (Y)
Other (Z)
1

Specify applications reported for “other”

.

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RECONCILIATION OF US SHIPMENTS.--Please ensure that the quantities reported for total
shipments in this question (i.e., lines S through Z across all columns) equal the quantity reported
for total shipments (i.e., line Q) in 2019 in question II-11a. 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.
Calendar year
2019

Reconciliation item
S + T + U + V + W + X + Y + Z (across all columns) – Q (in 2019 column)= zero
("0"), if not revise.
II-12.

0

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of PVA that was produced in the subject country specified in the certification page
(i.e., China or Japan) but not by your firm during the specified periods. Note these data should
not be included in question II-11a.
Quantity (in 1,000 pounds) and Value (in 1,000 dollars)
Calendar year
Item

2017

2018

January-September
2019

2019

2020

Exports of PVA to the United States not
produced by your firm1.—
Quantity 1
Value
1

List the producer(s).

II-13.

.

Excluded items.--Fifteen forms of PVA are specifically excluded from the scope of these reviews,
as is PVA not hydrolyzed in excess of 80 percent (see page 2). Please report your firm’s exports
to the United States of EXCLUDED forms of PVA (as defined on page 2) that were produced by
your firm in the country specified on the certification page during the specified periods.

Quantity (in 1,000 pounds) and value (in $1,000)
Calendar year
Item
2017
2018
2019
Exports to the United States of excluded
forms of PVA:
PVA (excluded from scope)2
Quantity1
Value
1

January-September
2019
2020

List the producer(s) and/or exporter(s).
.
For a listing of excluded PVA items, see page 2. Please identify the PVA excluded items for which data are
reported:
.
2

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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II-14a. 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-14b. 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-15.

Yes

If yes, please describe these effects.

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

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Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

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PART III.--MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Howie Nguyen (202) 7081441, [email protected]).
III-1.

Contact information.--Please identify the responsible individual and how Commission staff may
contact the individual regarding the confidential information submitted in part III.
Name
Title
Email
Telephone

III-2.

Contract versus spot.--Approximately what share of your firm’s sales of PVA to U.S. customers
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 your
2019 sales

%

%

%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

%

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
III-3.

Page 18

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts to
U.S. customers for 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

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Indexed to raw
material costs1

No

Not applicable
1

Please identify the indexes used:

III-4.

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

Source

Share of 2019 sales

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0

%

Lead time (average
number of days)

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)
III-5.

Page 19

Raw materials.--Indicate how PVA raw materials prices have changed since January 1, 2014, and
how you expect they will change in the future.

Raw
materials
prices

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.

Changes since
January 1,
2014
Anticipated
changes
III-6.

Changes in factors affecting supply.--Have any changes occurred in any other factors affecting
supply (e.g., changes in availability or prices of energy or labor; transportation conditions;
production capacity and/or methods of production; technology; export markets; or alternative
production opportunities) that affected the availability of China and Japan-produced PVA in the
U.S. market since January 1, 2014?
No

III-7.

Yes

If yes, please describe.

Availability of SUBJECT import supply.--Do you anticipate any changes in terms of the
availability of China and Japan-produced PVA in the U.S. market in the future?
If you anticipate changes in supply, please identify the changes,
No
including the time period and the impact of such changes on
Increase change Decrease shipment volumes and prices.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

Page 20

III-8.

Product shifting.--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 (including any third-country trade barriers such as
tariffs, quotas, or other non-tariff barriers) that would prevent or retard your firm from shifting
PVA between the U.S. and alternative country markets within a 12-month period.

III-9.

Product range.--Is the product range, product mix, or marketing of PVA in your firm’s home
market different from that of PVA for export to the United States or to third-country markets?
No

Yes

If yes, please explain.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

Page 21

III-10. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of PVA in your firm’s home market, for export to the United States, or for export to
third-country markets since January 1, 2014? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes

Explain

Changes since
January 1, 2014
Anticipated
changes
III-11. 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
III-12. Interchangeability.--Is the PVA produced by your firm and sold in its home market
interchangeable (i.e., can be used in the same applications) with your firm’s PVA sold to the
United States and/or to third-country markets?
Yes

No

If no, identify the market(s) and any differences in the products.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

Page 22

III-13. End uses.—
(a)

Describe the end uses of the PVA that your firm manufactures and sell to your firm’s
home market. If these end uses differ from those of the PVA your firm sells to the U.S.
market or to third-country markets, explain.

(b)

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

III-14. Demand trends.--Indicate how demand in the following markets 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.

Your firm’s Overall
market
increase

Fluctuate
No
Overall
with no
change decrease clear trend
Demand since January 1, 2014

Home
market
United
States
Other
markets
Anticipated future demand
Home
market
United
States
Other
markets

Explanation and factors

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

Page 23

III-15. Price comparisons.--Please compare market prices of PVA in your firm’s home market, the
United States, and third-country markets.

III-16. Description of home market.--Describe briefly your firm’s home market for PVA, including the
number of, and competition between, producers.

III-17. Import competition.--Does your firm face competition from imports of PVA in your firm’s home
market?
No

Yes

If yes, please identify the country sources of these imports.

III-18. 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.
III-19. 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
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

Page 24

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 set-up 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 USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

Business Proprietary
Foreign Producers’/Exporters’ Questionnaire – Polyvinyl Alcohol (Third Review)

Page 25

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 did not produce or export 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.