20-2-4354 U.S. importers' questionnaire

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

US importer -- SVSEs (F)

Small vertical shaft engines (VSEs) from China (Inv. nos. 701-TA-643 and 731-TA-1493) Final

OMB: 3117-0016

⚠️ Notice: This form may be outdated.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

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

Document [pdf]

Download: pdf | pdf

OMB No. 3117-0016/USITC No. 20-2-4354; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

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

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: 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

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

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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.

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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.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing small vertical shaft engines (as defined above) into the United States from a foreign
manufacturer or through its selling agent.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Charles
Cummings (202-708-1666, [email protected]).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

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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.
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
40 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2a.

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

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I-2b.

Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.

I-2c.

External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):

I-3.

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

Firm name

I-4.

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

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing 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. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
I-5.

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

Yes--List the following information.

Firm name

I-6.

Country

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations of small
vertical shaft engines. More than one answer may be applicable.
Importer of record

I-7.

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Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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

Firm name

Address

Contact person
and phone
number

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
I-8.

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

Yes

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

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

Yes

If yes, Yes–Please specify.

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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 importation of small vertical shaft engines since January 1, 2017.
(check as many as appropriate)

Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable)

Business Proprietary
U.S. Importers’ Questionnaire – 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, importation, sales, and employment relating
to small vertical shaft engines?

II-3a.

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Yes

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

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

Yes

If yes, fill out the table below.

Period
Source

Oct-Dec 2020

Jan-Mar 2021

Apr-Jun 2021

Jul-Sep 2021

Quantity (in units)
China

All other sources
1 Data from China should relate to engines mounted using Chinese-origin engines regardless of the
country of engine mounting or country of exportation. In other words, the line for China should exclude
engines mounted with non-Chinese-origin engines, even if the final product was mounted in China or
exported from China.

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
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Imports in the 12 month period preceding the petition.--Has your firm imported small vertical
shaft engines from any source between March 1, 2019 and February 29, 2020? (i.e., the last ten
months in 2019 and first two months in 2020 combined)
No

Yes

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

March 2019 through February 2020
All small
vertical shaft
engines1
Source

Unfinished,
unmounted
engines

Mounted and Mounted and
Finished,
reported
reported
unmounted under primary other HTS
engines
HTS numbers2 numbers3
Quantity (units)

China

All other sources

Data entered for all imports of small vertical shaft engines will populate here once data is reported in the
subsequent columns.
2 Imports of engines mounted on lawn mowers or other machinery and reported for Customs purposes under
statistical reporting numbers 8433.11.0050, 8433.11.0060, and 8424.30.9000.
3 Imports of engines mounted on lawn mowers or other machinery and reported for Customs purposes under
statistical reporting numbers other than those listed in the previous footnote. Please describe the machinery that
include mounted engines and list the statistical reporting numbers used for these imports:
1

II-4.

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

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“Commercial U.S. shipments”— Shipments made within the United States as a result of an
arm’s length commercial transaction in the ordinary course of business. Report net values (i.e.,
gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption/ including for own retail sale”--Product consumed internally by your
firm, which includes merchandise that your firm transferred to your own firm’s retail
establishments. Such transactions are to be valued at fair market value and not the total value
of final downstream processed merchandise in the case of internal consumption, nor the retail
sale value in the case of your firm owning and operating its own retail establishments.
“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.
“Unfinished” – 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.
“Branded” – Small vertical shaft engines that are assembled and sold with the name or brand of
the engine manufacturer.
“Private label” – Small vertical shaft engines that are assembled and sold with the name or
brand of a firm other than the engine manufacturer.
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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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
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U.S. imports from China: Unmounted.—Report your firm’s imports and your firm’s shipments
and inventories of unmounted small vertical shaft engines imported from China by your firm
during the specified periods.

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

2017

2018

January-September
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
U.S. imports:1
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption /
including retail for sale:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1
2

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U.S. imports from China: Unmounted.--Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar year
Reconciliation

2017

2018

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

January-September
2019

2019
0

2020
0

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

II-5b.

Channels of distribution: China: Unmounted.—Report your firm’s U.S. shipments (i.e. inclusive
of commercial U.S. shipments, internal consumption, and transfers to related firms) of
unmounted small vertical shaft engine imports from China by channel of distribution during the
specified periods.

China: Unmounted
Calendar year
Item

2017

2018

January-September
2019

2019

2020

Quantity (in units)
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., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation item
M + N – D – F – H = zero ("0"), if not
revise.

2017

2018
0

January-September
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
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U.S. shipments of imports by nominal useful life rating: China: Unmounted.—Report your
firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and
transfers to related firms) of imports of unmounted small vertical shaft engines from China by
nominal useful life category (residential, extended life residential, and commercial) during the
specified periods.

China: Unmounted

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

2017

January-September

2018

2019

2020

U.S. shipments:
Residential engines:1
Quantity (O)
Value (P)
Extended life residential or
general purpose engines:2
Quantity (Q)
Value (R)
Commercial engines:3
Quantity (S)
Value (T)
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.

RECONCILIATION OF CHANNELS.–Please ensure that the quantities and values reported for nominal
useful life rating (i.e., lines O through T) in each time period equal the quantities and values reported for
U.S. shipments (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.

Reconciliation
Quantity: O + Q + S – D – F – H = zero
("0"), if not revise.
Value: P + R + T – E – G – I = zero
("0"), if not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
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U.S. shipments of imports by engine branding: China: Unmounted.—Report your firm’s U.S.
shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to
related firms) of imports of unmounted small vertical shaft engines from China by engine
branding during the specified periods.

China: Unmounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

U.S. shipments:
Branded:1
Quantity (U)
Value (V)
Private label:2
Quantity (W)
Value (X)
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.
1.

RECONCILIATION OF CHANNELS.–Please ensure that the quantities and values reported for engine
branding (i.e., lines U through X) in each time period equal the quantities and values reported for U.S.
shipments (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.

Reconciliation
Quantity: U + W – D – F – H = zero
("0"), if not revise.
Value: V + X – E – G – I = zero ("0"), if
not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-6a.

Page 16

U.S. imports from China: Mounted.—Report your firm’s imports and your firm’s shipments and
inventories of mounted small vertical shaft engines imported from China by your firm during the
specified periods. Data from China should relate to engines mounted using Chinese-origin
engines regardless of the country of engine mounting or country of exportation. In other words,
these data should exclude engines mounted with non-Chinese-origin engines, even if the final
product was mounted in China or exported from China.

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

2017

2018

January-September
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
U.S. imports:1 2
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption /
including retail for sale:3
Quantity (F)
Value2 (G)
Transfers to related firms: 3
Quantity (H)
Value2 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
What share of your firm’s imports of engines from China are built into downstream products imported from China?
percent.
3
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.
4
Identify your firm’s principal export markets:
.
1
2

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-6a.

Page 17

U.S. imports from China: Mounted.—Continued

2017

2018

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

January-September
2019

2019
0

2020
0

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

II-6b.

Channels of distribution: China: Mounted.—Report your firm’s U.S. shipments (i.e. inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of mounted
small vertical shaft engine imports from China by channel of distribution during the specified
periods.

China: Mounted
Calendar year
Item

2017

2018

January-September
2019

2019

2020

Quantity (in units)
Channels of distribution:
U.S. shipments:
To distributors (M)
To end users (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., lines D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
Reconciliation item
M + N – D – F – H = zero ("0"), if not
revise.

2017

2018
0

January-September
2019

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-6c.

Page 18

U.S. shipments of imports by nominal useful life rating: China: Mounted.—Report your firm’s
U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers
to related firms) of mounted small vertical shaft engine imports from China by nominal useful
life category (residential, extended life residential, and commercial) during the specified periods.

China: Mounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

Reconciliation
Quantity: O + Q + S – D – F – H = zero
("0"), if not revise.
Value: P + R + T – E – G – I = zero
("0"), if not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-6d.

Page 19

U.S. shipments of imports by engine branding: China: Mounted.--Report your firm’s U.S.
shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and transfers to
related firms) of mounted small vertical shaft engine imports from China by engine branding
during the specified periods.

China: Mounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

Reconciliation
Quantity: U + W – D – F – H = zero
("0"), if not revise.
Value: V + X – E – G – I = zero ("0"), if
not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-7a.

Page 20

Imports from all other sources: Unmounted.--Report your firm’s imports and your firm’s
shipments and inventories of unmounted small vertical shaft engines imported from all other
sources by your firm during the specified periods.

All other sources: Unmounted
(list sources:

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

Item

2017

2018

January-September
2019

2019

2020

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-7a.

Page 21

Imports from all other sources: Unmounted.—Continued

2017

2018

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

January-September
2019

2019
0

2020
0

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

II-7b.

Channels of distribution: All other sources: Unmounted.—Report your firm’s U.S. shipments
(i.e. inclusive of commercial U.S. shipments, internal consumption, and transfers to related
firms) of unmounted small vertical shaft engine imports from all other sources by channel of
distribution during the specified periods.

All other sources: Unmounted
Calendar year
Item

2017

2018

January-September
2019

2019

2020

2017

2018
0

January-September
2019

2019
0

2020
0

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-7c.

Page 22

U.S. shipments of imports by nominal useful life rating: All other sources: Unmounted.—
Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal
consumption, and transfers to related firms) of imports of unmounted small vertical shaft
engines from all other sources by nominal useful life category (residential, extended life
residential, and commercial) during the specified periods.

All other sources: unmounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

Reconciliation
Quantity: O + Q + S – D – F – H = zero
("0"), if not revise.
Value: P + R + T – E – G – I = zero
("0"), if not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-7d.

Page 23

U.S. shipments of imports by engine branding: All other sources: Unmounted.—Report your
firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and
transfers to related firms) of imports of unmounted small vertical shaft engines from all other
sources by engine branding during the specified periods.

All other sources: Unmounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

Reconciliation
Quantity: U + W – D – F – H = zero
("0"), if not revise.
Value: V + X – E – G – I = zero ("0"), if
not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-8a.

Page 24

Imports from all other sources: Mounted.--Report your firm’s imports and your firm’s
shipments and inventories of mounted small vertical shaft engines imported from all other
sources by your firm during the specified periods. Report data for imports of non-Chinese-origin
and non-U.S.-origin engines mounted on equipment, regardless of the country of engine
mounting or country of exportation. Include all engines mounted with non-Chinese-origin and
non-U.S. engines, including those engines mounted in China.

All other sources: Mounted
(list sources:

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

Item

2017

2018

January-September
2019

2019

2020

Beginning-of-period inventories
(quantity) (A)
U.S. imports:1 2
Unfinished engines:
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption /
including retail for sale:3
Quantity (F)
Value2 (G)
Transfers to related firms: 3
Quantity (H)
Value2 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
What share of your firm’s imports of engines from all other sources are built into downstream products imported from
all other sources?
percent.
3
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.
4
Identify your firm’s principal export markets:
.
1

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-8a.

Page 25

Imports from all other sources: Mounted.—Continued

2017

2018

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

January-September
2019

2019
0

2020
0

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

II-8b.

Channels of distribution: All other sources: Mounted.—Report your firm’s U.S. shipments (i.e.
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
small vertical shaft engine imports from all other sources by channel of distribution during the
specified periods.

All other sources: Mounted
Calendar year
Item

2017

2018

January-September
2019

2019

2020

2017

2018
0

January-September
2019

2019
0

2020
0

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-8c.

Page 26

U.S. shipments of imports by nominal useful life rating: All other sources: Mounted.—Report
your firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption,
and transfers to related firms) of mounted small vertical shaft engine imports from all other
sources by nominal useful life category (residential, extended life residential, and commercial)
during the specified periods.

All other sources: Mounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

Reconciliation
Quantity: O + Q + S – D – F – H = zero
("0"), if not revise.
Value: P + R + T – E – G – I = zero
("0"), if not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
II-8d.

Page 27

U.S. shipments of imports by engine branding: All other sources: Mounted.--Report your
firm’s U.S. shipments (i.e., inclusive of commercial U.S. shipments, internal consumption, and
transfers to related firms) of unmounted small vertical shaft engine imports from all other
sources by engine branding during the specified periods.

All other sources: Mounted
Quantity (in units) and value (in $1,000s)
Calendar year
Item

2017

January-September

2018

2019

2020

Reconciliation
Quantity: U + W – D – F – H = zero
("0"), if not revise.
Value: V + X – E – G – I = zero ("0"), if
not revise.

Calendar year
2018

2017

January-September
2019
2020

2019

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 28

II-9.

Transfers to related firms.--If your firm reported transfers to related firms in any of the data
tables in part II, please identify the firm(s) and indicate the nature of the relationship between
your firm and the related firms (e.g., joint venture, wholly owned subsidiary) and whether the
transfers were priced at market value or by a non-market formula.

II-10.

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

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 29

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Cindy Cohen (202-205-3230,
[email protected]).
III-1.

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. OEM customers since January 1, 2017 of the following products your firm
imported from China:
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)).
During January 2017-September 2020, did your firm import from China 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 III-3.

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 30

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

China

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 III.
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:

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of these data, as Commission staff may contact your firm regarding questions. The
Commission may also request that your company submit copies of the supporting documents/records
(such as sales journal, invoices, etc.) used to compile these data.

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 31

III-2b. Price data checklist.--Please check that the pricing data in question III-2(a) 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 part II in each year?
Explanation(s) for any boxes not checked:
III-2c.

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

III-2d. 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.

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 32

PURCHASE COST DATA
III-3.

Imports by OEMs for internal use.—This question requests quarterly quantity and landed-duty
paid value data for your firm’s imports of the products defined above (on the first page of part
III) for internal consumption from China since January 1, 2017. These are imports of small
vertical shaft engines that your firm used to produce lawn mowers or other machinery.
During January 2017-June 2020, did your firm import any of the products listed on the first page
of part III from China for internal consumption to produce lawn mowers or other machinery?
Yes.--Please complete the following table(s) as appropriate. Do NOT include any
imports of engines already mounted on lawn mowers or other machinery at the time
of importation.
No.--Skip to question III-4.

III-3a. Imports by OEMs for internal use.--Report below the import data1 for pricing products2 imported
from China and used by your own firm to produce mowers or other machinery. These are imports
that your firm does not resell as small vertical shaft engines. Do NOT include any imports of
engines already mounted on lawn mowers or other machinery at the time of importation.
Please note that values should be landed, duty-paid (LDP) and should not include U.S.-inland transportation
costs. Values should reflect the final net amount paid by your firm (i.e., should be net of all returns, discounts,
allowances, and rebates).

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 33

III-3a. Imports by OEMs for internal use.--Continued

China
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Period of
importation

Product 1
Quantity

LDP value

Product 2
Quantity

LDP value

Product 3
Quantity

LDP value

Product 4
Quantity

LDP value

2017:
January-March
April-June
July-September
October-December
2018:
January-March
April-June
July-September
October-December
2019:
January-March
April-June
July-September
October-December
2020:
January-March
April-June
July-September
1 LDP value (i.e., landed duty-paid values): Values reported should be landed, duty-paid values at the U.S. port of entry, including ocean
freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland freight in the United States). See “Import values”
definition in Part II (Trade and Related Information – Definitions).
2 Pricing product definitions are provided on the first page of Part III.

Note.--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 data.
Product 1:
Product 2:
Product 3:
Product 4:

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 34

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

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

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

ii.

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

iii.

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

Costs

iv.

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

Explanation

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

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
III-3c.

Page 35

Decision basis.—To which source(s) does your firm compare costs in determining whether or
not to import small vertical shaft engines? Check all that apply.
U.S. importers

U.S. producers

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

III-3d. Benefits of importing small vertical shaft engines.
i.

Briefly identify the benefits of importing small vertical shaft engines instead of
purchasing small vertical shaft engines from a U.S. importer or from a U.S. producer.

ii.

Is it your firm’s experience that the small vertical shaft engines your firm imported from
China are priced lower than they would be if your firm purchased from a U.S. importer
or U.S. producer?
Imports are priced lower when

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

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

Please estimate your firm’s savings by importing small vertical shaft engines instead of
purchasing from a U.S. producer or U.S. importer since January 1, 2016 (as a percent of
the purchase price from the U.S. importer or U.S. producer). For your estimate,
compare the price of purchasing from a U.S. importer or U.S. producer to the cost of
direct imports (including the additional costs described above in III-3.b).

Factors

iv.

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

U.S. producer

U.S. importer

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

√ if Yes

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

Page 36

If your firm imports small vertical shaft engines for internal use only, please skip questions III-4
through III-10, as well as III-13.
III-4.

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.

III-5.

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

Quantity
discounts

III-6.

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.--On what basis are your firm’s prices of imported small vertical shaft engines
from China usually quoted (check one)?
Delivered

III-7.

Rebates
to
retailers

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of small vertical shaft
engines imported from China 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

Business Proprietary
U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
III-8.

Page 37

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. Importers’ Questionnaire – Small vertical shaft engines from China (Final)
III-9.

Page 38

Lead times.--What is your firm’s share of sales of small vertical shaft engines imported from
China 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 small vertical shaft engines?

Source

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

From your firm’s U.S. inventory

From foreign manufacturers’ inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

III-10. Shipping information.—
(a)

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

(b)

When your firm sells small vertical shaft engines imported from China, from where is it
shipped?
Point of importation
Storage facility (check one)

(c)

Indicate the approximate percentage of your firm’s sales of small vertical shaft engines
imported from China that are delivered the following distances from your firm’s U.S.
point of shipment.
Distance from your firm’s U.S. point of shipment

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)

0.0

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III-11. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold or
internally consumed small vertical shaft engines imported from China since January 1, 2017
(check all that apply)?
Geographic area

China

Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.
III-12. Warranties.
(a) 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.

If yes, describe the warranties and indicate the percentage of the price of an
Yes engine that is accounted for by warranty costs.

(b) Do the foreign producers from which your firm imports provide product warranties for small
vertical shaft engines? If yes, please briefly summarize the warranties provided and indicate
the percentage of the LDP value of an engine that is accounted for by warranty costs.

If yes, describe the warranties and indicate the percentage of the LDP value of
Yes an engine that is accounted for by warranty costs.

III-13. Inland transportation costs.--What is the approximate percentage of the cost of small vertical
shaft engines imported from China that is accounted for by U.S. inland transportation
costs?
percent.

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III-14. End uses.--List the end uses of the small vertical shaft engines that your firm imports. 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
Small vertical shaft
engines

End-use product

Total
(should sum to
100.0% across)

Other inputs

0.0 %

III-15. Substitutes.--Can other products be substituted for small vertical shaft engines?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for small vertical shaft
engines?
No Yes

Explanation

1.
2.
3.
III-16. 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).

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

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III-17. 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.

III-18. 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?
Check all that apply.

Please describe.

Skip to question III-19.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
small vertical shaft engines since January 1, 2017?
No

Yes

If yes, describe.

III-19. 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.)?

Yes

If yes, please describe, including the time period(s) when your
firm experienced supply constraints.

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III-20. 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

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III-21. 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:

III-22. 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:

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III-23. 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.

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.

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III-24. 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

City

State

Share of 2019 sales
(%)

1
2
3
4
5
6
7
8
9
10

III-25. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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

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

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

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U.S. Importers’ Questionnaire – Small vertical shaft engines from China (Final)

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the Commission’s website at:
https://www.usitc.gov/investigations/701731/2020/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 did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	US importer questionnaire
Subject	Title 7 investigations
Author	Cummings, Charles
File Modified	2020-11-10
File Created	2020-11-10