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pdfOMB No. 3117-0016/USITC No. 20-1-4353; Expiration Date: 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
SMALL VERTICAL SHAFT ENGINES FROM CHINA
This questionnaire must be received by the Commission by December 14, 2020
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping duty investigations concerning small vertical shaft engines from
China (Inv. Nos. 701-TA-643 and 731-TA-1493 (Final)). 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 small vertical shaft engines (as defined on next page) at any time since January 1, 2017?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: SMENG)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official
Signature
Title of Authorized Official
Phone
Date
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.—These proceedings were instituted in response to petitions filed on March 18, 2020, by
Briggs & Stratton Corporation, Wauwatosa, Wisconsin. Countervailing and/or antidumping duties may
be assessed on the subject imports as a result of these proceedings if the Commission makes an
affirmative determination of injury, threat, or material retardation, and if the U.S. Department of
Commerce (“Commerce”) makes an affirmative determination of subsidization and/or dumping.
Questionnaires and other information pertinent to this proceeding are available at:
https://www.usitc.gov/investigations/701731/2020/small_vertical_shaft_engines_china/final.htm.
Small vertical shaft engines covered by these investigations consist of spark-ignited, non-road, vertical
shaft engines, whether finished or unfinished, whether assembled or unassembled, whether mounted
or unmounted, primarily for walk-behind lawn mowers. Engines meeting this physical description may
also be for other non-hand-held outdoor power equipment, including but not limited to, pressure
washers. The subject engines are spark ignition, single-cylinder, air cooled, internal combustion engines
with vertical power take off shafts with a minimum displacement of 99 cubic centimeters (cc) and a
maximum displacement of up to, but not including, 225cc. Typically, engines with displacements of this
size generate gross power of between 1.95 kilowatts (kw) to 4.75 kw.
Engines covered by this scope normally must comply with and be certified under Environmental
Protection Agency (EPA) air pollution controls title 40, chapter I, subchapter U, part 1054 of the Code of
Federal Regulations standards for small non-road spark-ignition engines and equipment. Engines that
otherwise meet the physical description of the scope but are not certified under 40 CFR part 1054 and
are not certified under other parts of subchapter U of the EPA air pollution controls are not excluded
from the scope of this proceeding. Engines that may be certified under both 40 CFR part 1054 as well as
other parts of subchapter U remain subject to the scope of this proceeding.
Certain small vertical shaft engines, whether or not mounted on non-hand-held outdoor power
equipment, including but not limited to walk-behind lawn mowers and pressure washers, are included in
the scope. However, if a subject engine is imported mounted on such equipment, only the engine is
covered by the scope. Subject merchandise includes certain small vertical shaft engines produced in the
subject country whether mounted on outdoor power equipment in the subject country or in a third
country. Subject engines are covered whether or not they are accompanied by other parts.
For purposes of these investigations, an unfinished engine covers at a minimum a sub-assembly
comprised of, but not limited to, the following components: Crankcase, crankshaft, camshaft, piston(s),
and connecting rod(s). Importation of these components together, whether assembled or unassembled,
and whether or not accompanied by additional components such as a sump, carburetor spacer, cylinder
head(s), valve train, or valve cover(s), constitutes an unfinished engine for purposes of these
investigations. The inclusion of other products such as spark plugs fitted into the cylinder head or
electrical devices (e.g., ignition coils) for synchronizing with the engine to supply tension current does
not remove the product from the scope. The inclusion of any other components not identified as
comprising the unfinished engine subassembly in a third country does not remove the engine from the
scope.
Specifically excluded from the scope of the investigations are “Commercial” or “Heavy Commercial”
engines under 40 CFR 1054.107 and 1054.135 that have (1) a displacement of 160 cc or greater, (2) a
cast iron cylinder liner, (3) an automatic compression release, and (4) a muffler with at least three
chambers and volume greater than 400 cc.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 3
The engines subject to these investigations are predominantly classified in the Harmonized Tariff
Schedule of the United States (HTSUS) at statistical reporting number 8407.90.1010. The engine
subassemblies that are subject to these investigations enter under HTSUS 8409.91.9990. The mounted
engines that are subject to these investigations enter under HTSUS 8433.11.0050, 8433.11.0060, and
8424.30.9000. Engines subject to these investigations may also enter under HTSUS 8407.90.1020,
8407.90.9040, and 8407.90.9060. The HTSUS statistical reporting numbers are provided for convenience
and customs purposes only, and the written description of the merchandise under investigation is
dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
I-1a.
Page 4
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.
TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
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 small vertical shaft
engines, 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.
Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
Yes
Petition support.--Does your firm support or oppose the petition?
Country
China
Investigation type
AD
China
CVD
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
I-5.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-6.
Page 6
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 small vertical shaft engines from China into the United
States or that are engaged in exporting small vertical shaft engines from China to the United
States?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
I-7.
Page 7
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of small vertical shaft engines?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 8
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Charles Cummings (202-7081666, [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 small vertical shaft engines since January 1, 2017.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
(If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable)
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-2b.
COVID-19 pandemic.--Since January 1, 2020, has the COVID-19 pandemic or have any
government actions taken to contain the spread of the COVID-19 virus resulted in changes in
relation to your firm’s supply chain arrangements, production, sales, and employment relating
to small vertical shaft engines?
No
II-3a.
Page 9
Yes
If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) production and sales impact, and (c)
employment impact of the COVID-19 pandemic.
Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce small vertical shaft engines, and
the combined production capacity on this shared equipment, machinery, or employees in the
periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-7. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-7 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-3a.
Page 10
Production using same machinery.--Continued
Quantity (in units)
Calendar years
Item
Overall production capacity
2017
2019
2019
2020
1
Production of:
Small vertical shaft engines2
Other products
2018
January-September
0
0
0
0
0
0
0
0
0
0
3
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 small vertical shaft engines will populate here once reported in question II-7.
3
Please identify these 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 – Small vertical shaft engines from China (Final)
II-4.
Product shifting.—
(a)
Is your firm able to switch production (capacity) between small vertical shaft engines and
other products using the same equipment and/or labor?
No
(b)
II-5.
Page 11
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of small vertical shaft engines?
“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 – Small vertical shaft engines from China (Final)
II-6.
Page 12
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce small vertical shaft engines in and/or
admit small vertical shaft engines into a foreign trade zone (FTZ)?
(a)
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
Yes
If yes--Describe the nature of your firm’s operations in FTZs and identify
the specific FTZ site(s).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import small vertical shaft engines into a foreign trade zone (FTZ) for use in distribution
of small vertical shaft engines and/or the production of downstream articles?
(b)
No
Yes
If yes--Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-7.
Page 13
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of small vertical shaft engines in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-7.
Page 14
Production, shipment, and inventory data.--Continued
Quantity (in units) and value (in $1,000)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Average production capacity (quantity)
(A)
1
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide
explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar year
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2017
2018
0
January-September
2019
0
2019
0
2020
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1
0
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-8.
Page 15
Channels of distribution.--Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.
Quantity (in units)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
U.S. shipments:
to Distributors or dealers (M)
to OEMs (N)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each time
period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised
prior to submission to the Commission.
Calendar year
Reconciliation
M + N – 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 – Small vertical shaft engines from China (Final)
II-9.
Page 16
U.S. shipments by engine branding.--Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by engine
branding during the specified periods.
Quantity (in units)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
U.S. Shipments:
Branded1:
Quantity (S)
Value (T)
Private label2:
Quantity (U)
Value (V)
Small vertical shaft engines that are assembled and sold with the name or brand of the engine manufacturer.
Small vertical shaft engines that are assembled and sold with the name or brand of a firm other than the engine
manufacturer (e.g., the lawn mower OEM's name or brand).
1
2
RECONCILIATION OF U.S. SHIPMENTS BY BRANDING. Please ensure that the quantities and values reported
for U.S. shipments in this question (i.e., lines S through V) in each time period equal the quantities and
values reported for U.S. shipments reported in question II-7 (i.e., lines D through I) 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
2017
2018
January-September
2019
2019
2020
Quantity: S + U – D – F – H =
zero ("0"), if not revise.
0
0
0
0
0
Value: T + V – E – G – I = zero
("0"), if not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-10.
Page 17
U.S. shipments by nominal useful life rating.–Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by nominal
useful life category (residential, extended life residential, and commercial) of the engines during
the specified periods.
Quantity (in units) and value (in $1,000s)
Calendar year
Item
2017
January-September
2018
2019
2019
2020
U.S. shipments:
Residential engines:1
Quantity (W)
Value (X)
Extended life residential or
general purpose engines:2
Quantity (Y)
Value (Z)
Commercial engines:3
Quantity (AA)
Value (AB)
EPA-certified nominal useful life rating of no more than 125 hours
EPA-certified nominal useful life rating of more than 125 hours but less than 250 hours.
3.
EPA-certified nominal useful life rating of more than 250 hours. Note: Specifically excluded from the scope of
the investigations are “Commercial” or “Heavy Commercial” engines under 40 CFR 1054.107 and 1054.135 that have
(1) a displacement of 160 cc or greater, (2) a cast iron cylinder liner, (3) an automatic compression release, and (4) a
muffler with at least three chambers and volume greater than 400 cc. Please do not include shipments that are
excluded from the scope.
1.
2.
RECONCILIATION OF NOMINAL USEFUL LIFE.–Please ensure that the quantities and values reported for
nominal useful life rating (i.e., lines W through AB) in each time period equal the quantities and values
reported for U.S. shipments (i.e., line D through I) 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.
Reconciliation
Quantity: W + Y + AA – D – F – H =
zero ("0"), if not revise.
Value: X + Z + AB – E – G – I = zero
("0"), if not revise.
Calendar year
2018
2017
January-September
2019
2020
2019
0
0
0
0
0
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-11.
Page 18
Employment data.--Report your firm’s employment-related data related to the production of
small vertical shaft engines 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
2017
2018
January-September
2019
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II-12.
Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
II-13.
Page 19
Purchases.--Has your firm purchased small vertical shaft engines produced in the United States
or in other countries since January 1, 2017? (Do not include imports for which your firm was the
importer of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
(a)
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.
(b)
(Quantity in units)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Purchases from U.S. importers of
small vertical shaft engines from-China
1
All other sources
Purchases from domestic producers2
Purchases from other sources3
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier:
.
2
Please list the name of the U.S. producer(s) from which your firm purchased this product:
.
3
Please list the name of the firm(s) from which your firm purchased this product:
.
1
II-14.
Imports.--Since January 1, 2017, has your firm imported small vertical shaft engines?
No
Yes
If yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II-15.
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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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 20
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-205-3188,
[email protected]).
III-1.
Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part III.
Name
Title
Email
Telephone
III-2.
Accounting system.--Please provide the following information on your firm’s financial
accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:
Note.—Financial data in this section are being collected 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 small vertical shaft
engines:
Does your firm prepare profit/loss statements for small vertical shaft engines:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
U.S. GAAP,
IFRS,
cash,
tax, or
other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes small vertical shaft
engines, as well as specific statements and worksheets) used to compile these data.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 21
III-3.
Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
III-4.
Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III-5.
Product listing.--Please list the products your firm produced in the facilities in which your firm
produced small vertical shaft engines and provide the share of net sales accounted for by these
products in 2019.
Products
Small vertical shaft engines
Share of sales
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
III-6.
Inputs from related suppliers.--Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of small vertical shaft engines from any related suppliers
(e.g., inclusive of transactions between related firms, divisions and/or other components within
the same company)?
Yes--Continue to question III-7
III-7.
Page 22
No—Skip to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
small vertical shaft engines 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 for 2019. For “Input valuation” please describe the basis, as recorded in your company’s
own accounting system, of the purchase cost from the related supplier; e.g., the related
supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market value.
Input
Related supplier
Share of total COGS
in 2019 (percent)
Input valuation as recorded in the firm’s accounting books and records
III-8.
Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, are reported in III-9a (financial results on small vertical
shaft engines) in a manner consistent with your firm’s accounting books and records.
Yes
No
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 23
III-9a. Operations on small vertical shaft engines.--Report the revenue and related cost information
on the small vertical shaft engine 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. Provide data for the specified calendar years and interim periods. If
your firm was involved in tolling operations (either as the toller or as the tollee), please contact
Jennifer Brinckhaus at (202) 205-3188 before completing this section of the questionnaire.
Quantity (in units) and value (in $1,000)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Net sales quantities:
Commercial sales (“CS”)
2
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Net sales values:
Commercial sales
2
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Cost of metal components
3
Cost of other raw material inputs
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense and income items, net4
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment
quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
4 If the total reported amount is net other expenses, report as a positive number. If the total reported amount is net other income,
report as a negative number. Please check the calculated “Net income or (loss) before income taxes” to ensure proper reporting of these
items.
1
2
Note --The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 24
III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, raw materials, total COGS, gross profit (or loss), operating income (or loss)
and net income (or loss)) have been calculated from the data submitted in the other line
items. Do the calculated fields return the correct data according to your firm's financial records
ignoring non-material differences that may arise due to rounding?
Yes
III-9c.
No
If no--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise. Also, check signs of the line item “All other
expense and income items, net.” If the net value of the all other items reported here is
an expense/loss, it should be reported as a positive number. If the net value is an
income/gain it should be reported as a negative value. If after reviewing and
potentially revising the feeder data your firm has provided, the differences between
your records and the calculated fields persist please identify and discuss the
differences in the space below.
Raw material procurement.—Approximately what share of your firm’s 2019 raw material costs
for small vertical shaft engines (as reported in question III-9a) were purchased/acquired on a (1)
short-term contract basis, (2) annual contract basis, (3) long-term contract basis, and (4) spot
purchase basis?
Type of purchase
Share of 2019 raw
material purchases
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)
%
Spot purchases (for a single delivery)
%
Total (should sum to 100.0%)
0.0
%
Please indicate whether the type of purchase (short-term contract, annual contract, spot sale,
etc.) varies significantly by raw material input or whether the 2019 shares indicated in the table
above had changed significantly from January 1, 2017.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 25
III-9d. Impact of tariffs on raw material costs.--Did your firm experience an increase in the 2019 raw
material costs for small vertical shaft engines (as reported in table III-9a) compared to 2017?
No
Yes
If yes, please complete the table below by reporting the approximate
share of the increase in raw material costs attributable to (1.) Section 232
tariffs, (2.) Section 301 tariffs, or (3.) Other factors.
Item
Share
Section 232 tariffs
%
Section 301 tariffs
%
Other factors1
%
Total (should sum to 100.0%)
0.0
%
Please describe the other factors contributing to your firms’ increase in raw
material costs comparing 2019 to 2017:
1
III-9e. COVID-19 pandemic.—Since January 1, 2020, has the COVID-19 pandemic (including any
government actions taken to contain the spread of the virus) had an impact on your firm’s
financial performance as reported in question III-9a?
No
III-9f.
Yes
If yes–please describe the impact on your firm’s reported financial results in
question III-9a.
Warranty expense.--Please report the amount of warranty expense recorded for small vertical
shaft engines in the specified periods.
Item
Warranty expense ($1,000)
2017
Calendar year
2018
2019
January-September
2019
2020
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 26
III-9g. Warranty accounting.--Please describe how your firm accounts for warranty expenses and
where this expense is recorded within the financial performance data in question III-9a. Include
a description of how the amount of warranty expense is calculated each period.
III-9h. Warranty accounting changes.--Has you firm changed its estimated warranty expense liability
for small vertical shaft engines at any time since January 1, 2017?
No
Yes
If yes–please describe the changes, including their magnitude and timing, as well
as the reasons for those changes.
III-9i. Warranty claims and cash outlays.--Regardless of your firm’s accrual accounting of warranty
expenses over the period, please report actual cash outlays your firm made in the specified
periods relating to warranty claims for small vertical shaft engines and the associated number of
claims those outlays satisfied.
Item
Cash outlays for warranty claims
($1,000)
Number of claims (count)
2017
Calendar year
2018
2019
January-September
2019
2020
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 27
III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9a line item where the nonrecurring items are included, a brief
description of the relevant nonrecurring items, and the associated values (in $1,000), as
reflected in 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
Item
2017
2018
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 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Income statement classification of the
nonrecurring item
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 28
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.
III-12a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of small vertical shaft engines. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for
small vertical shaft engines 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.
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 asset values.-- Please describe the main asset categories (both current and longterm assets) in the above response. Provide a brief explanation if there are any substantial
changes in total asset value during the period; e.g., due to asset write-offs, revaluation, and
major purchases.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 29
III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for small vertical shaft engines.
Value (in $1,000)
Calendar year
Item
2017
2018
January-September
2019
2019
Capital expenditures
Research and development
expenses
III-13b. Description of reported capital expenditures.-- Please describe the nature, focus, and
significance of your firm’s reported capital expenditures. 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. If no R&D expenses were reported, please explain the
reason.
2020
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 30
III-14. Data consistency and reconciliation.--Please confirm that your firm’s financial data for
questions III-9a, 12, and 13 are based on a calendar year.
Yes
No
If not, please explain below:
Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments).
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. If the calculated fields below return values other than zero (i.e., “0”),
please explain the discrepancy below.
Calendar years
Reconciliation
2017
2018
January-September
2019
2019
2020
Quantity: Trade data from question
II-7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").
0
0
0
0
0
Value: Trade data from question II-7
(lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").
0
0
0
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 31
III-15. Effects of imports on investment.--Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of small vertical shaft engines from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 32
III-16. Effects of imports on growth and development.--Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of small vertical shaft engines from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows:
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
small vertical shaft engines from China?
No
Yes
If yes, my firm anticipates negative effects as follows.
III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 33
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
IV-1.
Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in Part IV.
Name
Title
Email
Telephone
PRICE DATA
IV-2.
This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. OEM customers since January 1, 2017 of the following products produced by
your firm.
Product 1: Vertical Shaft Engine, Residential (EPA-certified nominal useful life rating of no more
than 125 hours), Air-Cooled, Single Cylinder, Carbureted, 125-140cc Displacement,
Unmounted
Product 2: Vertical Shaft Engine, Residential (EPA-certified nominal useful life rating of no more
than 125 hours), Air-Cooled, Single Cylinder, Carbureted, 141-155cc Displacement,
Unmounted
Product 3: Vertical Shaft Engine, Residential (EPA-certified nominal useful life rating of no more
than 125 hours), Air-Cooled, Single Cylinder, Carbureted, 156-175cc Displacement,
Unmounted
Product 4: Vertical Shaft Engine, Residential (EPA-certified nominal useful life rating of no more
than 125 hours), Air-Cooled, Single Cylinder, Carbureted, 186-205cc Displacement,
Unmounted
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 including those provided to your OEM customers (direct
rebates) and any rebates your firm provided to retailers (indirect rebates)).
IV-2a. During January 2017-September 2020, did your firm produce and sell to unrelated U.S. OEM
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. Report sales
only to OEMs. Do not report sales of replacement engines.
No.--Skip to question IV-3.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
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IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold to
OEMs by your firm.
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 1
Period of shipment
Quantity
Value
Product 2
Quantity
Value
Product 3
Quantity
Value
Product 4
Quantity
Value
2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
April-June
July-September
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.
1
Note.-- Please list the specifications (including displacement ranges) of the engines for which data were reported. 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 – Small vertical shaft engines from China (Final)
Page 35
IV-2c. Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
√ if Yes
Are the price data reported above:
In actual dollars (not $1,000s)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all direct discounts and rebates to your customers?
Net of all indirect discounts and rebates to your customers’ customers (e.g.
lawn mower retailers)?
Have discounts, rebates, and returns been credited to the quarter in which
the sale occurred?
Include only sales to OEMs (i.e., excluding aftermarket and retail sales)?
Exclude all sales of mounted engines?
Less than reported commercial shipments in question II-7 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.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 36
IV-2e. Rebates.—
(a) Does your firm give direct or indirect rebates to retailers for its sales of small vertical shaft
engines?
No
Yes—Please answer parts b and c.
(b) Please describe how such rebates were excluded from your reported pricing data and
indicate the average unit values of rebates excluded from pricing product values for 2019.
Describe how rebates to retailers were
excluded from the pricing data.
Average rebates excluded from pricing data, 2019
(dollars per unit)
Product 1
Product 2
Product 3
Product 4
(c) Provide the names of the retailers to which your firm provided rebates for small vertical
shaft engines since January 1, 2017, and report the terms of these rebates for each of your
five largest retail customers.
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.
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 37
IV-3. Price setting.— How does your firm determine prices for sales of small vertical shaft engines?
Briefly describe the price negotiation process and timeline, and when during the process prices
are finalized. If your firm issues price lists, please submit sample pages of a recent list.
IV-4.
Discount policy.--Please indicate and describe your firm’s discount policies for small vertical
shaft engines (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV-5.
No
discount
policy
Other
Describe
Pricing terms.--On what basis are your firm’s prices of domestic small vertical shaft engines
usually quoted (check one)?
Delivered
IV-6.
Rebates
to
retailers
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 small
vertical shaft engines in 2019 was on a (1) short-term contract basis, (2) annual contract basis,
(3) long-term contract basis, and (4) spot sales basis?
Item
Share of 2019
sales
Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
Short-term
contracts
(multiple
deliveries for
less than 12
months)
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
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U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
IV-7.
Page 38
Contract provisions.—
(a) Please fill out the table regarding your firm’s typical sales contracts for U.S.-produced small
vertical shaft engines (or check “not applicable” if your firm does not sell on a short-term,
annual and/or long-term contract basis).
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
Fixed quantity
and/or price
Short-term contracts
(multiple deliveries
for less than 12
months)
Annual contracts
(multiple
deliveries for 12
months)
Long-term contracts
(multiple deliveries
for more than 12
months)
365
No
Quantity
Indexed to raw
material costs1
Price
Both
Yes
No
Not applicable
1
Please identify the indexes used:
.
(b) Briefly describe your firm’s contracts for small vertical shaft engines.
(c) Since January 1, 2017, has your firm raised its prices for small vertical shaft engines to any
customers during the contract period?
No
Yes If yes, please describe including when such increases took place.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
IV-8.
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
of its U.S.-produced small vertical shaft engines?
Lead time (Average
Source
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
IV-9.
Page 39
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 small vertical shaft engines
that are delivered the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0
%
IV-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold its U.S.produced small vertical shaft engines since January 1, 2017 (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
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 40
IV-11. Warranties. --Does your firm provide product warranties for small vertical shaft engines? If yes,
please briefly summarize the warranties provided and indicate the percentage of the price of an
engine that is accounted for by warranty costs.
No
If yes, describe the warranties and indicate the percentage of the price of an
Yes engine that is accounted for by warranty costs.
IV-12. Inland transportation costs.—What is the approximate percentage of the cost of U.S.-produced
small vertical shaft engines that is accounted for by U.S. inland transportation costs?
percent
IV-13. End uses.--List the end uses of the small vertical shaft engines that your firm manufactures. For
each end-use product, what percentage of the total cost is accounted for by small vertical shaft
engines and other inputs?
Share of total cost of end use product
accounted for by
End-use product
Small vertical shaft
engines
Total
(should sum to
100.0% across)
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-14. Substitutes.--Can other products be substituted for small vertical shaft engines?
No
Substitute
1.
2.
3.
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for small vertical shaft
engines?
No Yes
Explanation
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 41
IV-15. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for small vertical shaft engines has changed since January 1, 2017. Explain any
trends and describe the principal factors that have affected these changes in demand (e.g., new
home construction, weather, overall economy, emissions regulations/environmental policies,
commercial lawn services, electric mowers, and COVID-19).
Overall
increase
Market
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
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 small vertical shaft engines since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
IV-17. Conditions of competition.-(a) Is the small vertical shaft engines market subject to business cycles (other than general
economy-wide conditions) and/or other conditions of competition distinctive to small
vertical shaft engines? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV-18.
Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
small vertical shaft engines since January 1, 2017?
No
Yes
If yes, describe.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 42
IV-18. Supply constraints.--Has your firm refused, declined, or been unable to supply small vertical
shaft engines since January 1, 2017 (examples include placing customers on allocation or
“controlled order entry,” declining to accept new customers or renew existing customers,
delivering less than the quantity promised, being unable to meet timely shipment commitments,
etc.)?
No
Yes
If yes, please describe, including the time period(s) when your
firm experienced supply constraints.
IV-19. Raw materials.-(a) How have small vertical shaft engines raw material prices changed since January 1, 2017?
Factor
Explain, noting how raw material
Fluctuate price changes have affected your
with no
firm’s selling prices for small
Overall
No
Overall
increase change decrease clear trend
vertical shaft engines.
Cost of raw materials
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for small vertical shaft engines?
Factor
No change
Overall
Increase
Fluctuate
Overall
with no
Decrease clear trend
Explanation
Cost of raw materials
after section 232 tariffs
imposed
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for small vertical shaft engines?
Factor
Prices for small vertical
shaft engines
No change
Overall
Increase
Fluctuate
Overall
with no
Decrease clear trend
Explanation
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 43
IV-19. Raw materials.--Continued
(d) Did your firm raise its prices, or attempt to raise prices, at any time since January 1, 2017 in
order to cover increases in production costs?
YesYes- tried to
raised
raise If yes, please describe, noting the time periods in which such increases
No prices prices or attempted increases occurred.
IV-20. Interchangeability.--Are small vertical shaft engines 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
Other countries
United States
China
For any country-pair producing small vertical shaft engines that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 44
IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between small vertical shaft
engines 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
Other countries
United States
China
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of small vertical shaft engines, identify the country-pair and report the
advantages or disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 45
IV-22. Impact of section 301 tariffs.-(a) Did the imposition of tariffs on Chinese-origin products under section 301 have an impact on
the small vertical shaft engines market in the United States?
Yes— Please indicate the
impact in the table below.
No
Don’t know
(b) If yes, fill out the following table.
Factor
Supply of U.S.produced small
vertical shaft engines
Supply of small
vertical shaft engines
imported from China
Supply of small
vertical shaft engines
imported from other
countries
Prices for small
vertical shaft engines
Overall U.S. demand
for small vertical shaft
engines
Raw material costs for
small vertical shaft
engines
Overall
No
Overall
increase change decrease
Explain, noting how the imposition
Fluctuate of tariffs under section 301 affected
with no
each factor of the small vertical
clear
shaft engines market in the United
trend
States.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 46
IV-23. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for small vertical shaft engines since January 1, 2017. Indicate the share of the
quantity of your firm’s total shipments of small vertical shaft engines that each of these
customers accounted for in 2019.
Customer’s name
1
2
3
4
5
6
7
8
9
10
City
State
Share of 2019 sales (%)
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 47
IV-24. Competition from imports.-(a)
Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling small
vertical shaft engines from China, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2017: Did your firm lose sales of small vertical shaft engines
to imports of this product from China?
No
Yes
IV-25. Other explanations.--If your firm would like to further explain a response to a question in Part
IV for which a narrative response box was not provided, please note the question number and
the explanation in the space provided below. Please also use this space to highlight any issues
your firm had in providing the data in this section, including but not limited to technical issues
with the MS Word questionnaire.
Business Proprietary
U.S. Producers’ Questionnaire – Small vertical shaft engines from China (Final)
Page 48
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2020/small_vertical_shaft_engines_china
/final.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: SMENG
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy
of the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | US producer questionnaire |
| Subject | Title 7 investigations |
| Author | Cummings, Charles |
| File Modified | 2020-11-10 |
| File Created | 2020-11-10 |