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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4377; Expiration Date: : 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
NON‐REFILLABLE STEEL CYLINDERS FROM CHINA
This questionnaire must be received by the Commission by January 19, 2021
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 non‐refillable steel cylinders from
China (Inv. Nos. 701‐TA‐644 and 731‐TA‐1494 (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 non‐refillable steel cylinders (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: NRSC)
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 Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on March 27, 2020, by
Worthington Industries, Columbus, Ohio. Countervailing and 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 dumping. Questionnaires and
other information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2020/non_refillable_steel_cylinders_china/final.htm.
Non‐refillable steel cylinders covered by these investigations are certain seamed (welded or brazed),
non‐refillable steel cylinders meeting the requirements of, or produced to meet the requirements of,
U.S. Department of Transportation (USDOT) Specification 39, TransportCanada Specification 39M, or
United Nations pressure receptacle standard ISO 11118 and otherwise meeting the description provided
below (non‐refillable steel cylinders). The subject non‐refillable steel cylinders are portable and range
from 300‐cubic inch (4.9 liter) water capacity to 1,526‐cubic inch (25 liter) water capacity. Subject non‐
refillable steel cylinders may be imported with or without a valve and/or pressure release device and
unfilled at the time of importation.
Specifically excluded are seamless nonrefillable steel cylinders.
Non‐refillable steel cylinders are currently imported under statistical reporting numbers 7311.00.0060
and 7311.00.0090 of the Harmonized Tariff Schedule of the United States (HTSUS). They may also be
imported under HTSUS statistical reporting number 7310.29.0025 and 7310.29.0050. The HTSUS
provisions are for convenience and customs purposes; the written description of the scope is dispositive.
Note.— The scope for these final phase investigations has changed and only includes unfilled
cylinders. It does not include filled cylinders, as it did during the preliminary phase of the investigations.
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
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 3
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 macro‐
enabled 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‐1a. 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 – Non‐Refillable Steel Cylinders (Final)
I‐2a.
Page 4
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 non‐refillable steel
cylinders, including auxiliary facilities operated in conjunction with (whether or not physically
separate from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
I‐2c.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
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).
I‐3.
Law firm:
Lead attorney(s):
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Petition support.‐‐Does your firm support or oppose the petition?
Country
China
Investigation type
Antidumping duty
China
Countervailing duty
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
I‐5.
I‐6.
Page 5
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Extent of
ownership
(percent)
Firm name
Country
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing non‐refillable steel cylinders from China into the United
States or that are engaged in exporting non‐refillable steel cylinders from China to the United
States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
I‐7.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of non‐refillable steel cylinders?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Kristina Lara (202‐205‐3386,
[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 non‐refillable steel cylinders since January 1, 2017.
(check as many as appropriate)
(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)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 7
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 arrangements, production, employment, and sales relating to non‐
refillable steel cylinders?
No
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.
II‐3a. Production using same machinery.‐‐Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce non‐refillable steel cylinders, 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.
Quantity (in units)
Calendar years
Item
2017
1
Overall production capacity
Production of:
Non‐refillable steel cylinders2
3
Other products
Total production using same
machinery or workers
1
2018
January‐September
2019
2019
2020
0
0
0
0
0
0
0
0
0
0
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of non‐refillable steel cylinders will populate here once reported in question
II‐7.
3
Please identify these products: .
2
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 8
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.
II‐4.
Product shifting.—
(a)
Is your firm able to switch production (capacity) between non‐refillable steel cylinders and
other products using the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
(b)
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
II‐5.
Page 9
Tolling.‐‐Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of non‐refillable steel cylinders?
“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.
II‐6.
No
Yes
If yes‐‐Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce non‐refillable steel cylinders in and/or
admit non‐refillable steel cylinders into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐Describe the nature of your firm’s operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import non‐refillable steel cylinders into a foreign trade zone (FTZ) for use in distribution
of non‐refillable steel cylinders and/or the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
II‐7.
Page 10
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of non‐refillable steel cylinders in its U.S.
establishment(s) during the specified periods.
If your firm fills its own U.S.‐produced cylinders with gas or other material prior to sale
to a final customer, report those transactions as internal consumption of the unfilled
cylinder excluding the value of gas and report those data on a fair market basis for the
unfilled cylinder.
“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 – Non‐Refillable Steel Cylinders (Final)
II‐7.
Page 11
Production, shipment, and inventory data.‐‐Continued
Quantity (in units) and value (in dollars)
Calendar years
Item
2017
2018
January‐September
2019
2019
2020
1
Average production capacity (quantity)
(A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
2
3
Value (E)
Internal consumption:
Quantity (F)
4
3 4
Value (G)
Transfers to related firms:
Quantity (H)
4
3 4
Value (I)
Export shipments:
Quantity (J)
5
Value3 (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity .
2
What percentage of your U.S. production consisted of 9.5 inches in diameter cylinders? %
3
Report only the value of the cylinder itself, do not include the value of any contents your firm may have filled it with.
Please confirm that you only reported the value of the cylinder alone: (check=yes), and, if applicable, describe how
your firm reported the value of the cylinder alone (e.g., based on "specific invoice records", or based on firm "estimates of
the cylinder’s share of total value", et cetera): .
4
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.
5
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 12
II‐7. Production, shipment, and inventory data.—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
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 years
January‐September
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2017
0
2018
0
2019
0
2019
2020
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
0
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
II‐8.
Page 13
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 years
Item
U.S. shipments:
To distributors1/retailers (M)
To fillers/end users (N)
2017
2018
January‐September
2019
2019
2020
1
Firms that resell the cylinder in the same format it was purchased (i.e., do not include sales to gas distributors that fill
unfilled cylinders as distributors).
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 quantities 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 years
Reconciliation
M + N – D ‐ F‐ H = zero ("0"), if not,
revise.
2017
0
2018
January‐September
2019
0
2019
0
0
2020
0
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
II‐9.
Page 14
Employment data.‐‐Report your firm’s employment‐related data related to the production of
non‐refillable steel cylinders and provide an explanation for any trends in these data.
Note: Do not report employment‐related data related to the filling of non‐refillable steel
cylinders under this question.
“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 years
Item
2017
2018
January‐September
2019
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:
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U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 15
II‐10. 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.
II‐11. Purchases.‐‐Has your firm purchased non‐refillable steel cylinders 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.
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.
(Quantity in units)
Calendar years
Item
2017
2018
January‐September
2019
2019
2020
1
Purchases from U.S. importers of
non‐refillable steel cylinders from—
China
All other sources
Purchases from domestic producers
3
Purchases from other sources
2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
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: .
II‐12. Imports.‐‐Since January 1, 2017, has your firm imported non‐refillable steel cylinders?
No
Yes
If yes—YOU MUST COMPLETE AND RETURN A U.S. IMPORTERS’
QUESTIONNAIRE (This questionnaire is available for download on the
website linked on the last page of this questionnaire)
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 16
II‐13. Captive production use.‐‐Please report the share of your firm’s U.S. shipments of internal
consumption and/or transfers to related firms for the uses identified below in 2019. These data
should reconcile with the 2019 quantities reported in question II‐7 (lines F and H).
Calendar year 2019
Internal consumption
Transfers to related firms
(Quantity in units)
Products
Sold as is (re‐entry
into merchant
N/A
market)
Filled with helium
Filled with other
gas or material1
1
Please describe what the non‐refillable steel cylinders are filled with: .
RECONCILIATION OF CAPTIVE PRODUCTION USE.— The sum of the data reported above should be equal
to the data reported in question II‐7, lines F and H, in 2019.
Reconciliation
Calendar year 2019
Internal consumption (line F in II‐7) reconciliation
0
Transfers to related firms (line H in II‐7) reconciliation.
0
1 Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate: .
II‐14. Non‐refillable steel cylinders’ share contribution to other downstream products.—Does your
firm or related firm produce downstream products using your firm’s U.S. produced non‐refillable
stainless steel cylinders? If yes, describe these downstream products and report the share that
non‐refillable steel cylinders account for of those products on a value basis.
No
Yes
If yes—Please describe these downstream products and then report the
share that non‐refillable steel cylinders account for of these products.
Material inputs used in products
Non‐refillable steel cylinders
All other material inputs
Total (should sum to 100.0%)
Share of value accounted for of the downstream
product(s) (percent)
0.0
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II‐13. 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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PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Joanna Lo (202‐205‐1888, [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.—Please report all financial data in part III on a calendar year basis.
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include non‐refillable steel
cylinders:
2. Does your firm prepare profit/loss statements for non‐refillable steel cylinders:
Yes
No
3. How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: 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 non‐refillable steel
cylinders, as well as specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.). If your firm uses standard cost, how often does your company review
variances from standard cost (e.g. monthly, yearly)?
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III‐4.
Page 19
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses. Please also describe the method and types of
documents/records used to compile your financial data.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced non‐refillable steel cylinders and provide the share of net sales accounted for by these
products in 2019.
Products
Share of sales in 2019
Non‐refillable steel cylinders
%
%
%
%
%
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U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
III‐6.
Page 20
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of non‐refillable steel cylinders 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.
No—Skip to question III‐9a.
Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of
non‐refillable steel cylinders that your firm purchases from related suppliers and that are
reflected in question III‐9a. For “Share of total COGS” please report this information by relevant
input on the basis of your most recently completed calendar year. For “Input valuation” please
describe the basis, as recorded in 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 2020
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 non‐refillable
steel cylinders) 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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III‐9a. Operations on non‐refillable steel cylinders produced by your firm as unfilled cylinders (total
market).‐‐Report the revenue and related cost information requested below on the total market
non‐refillable steel cylinders operations of your firm’s U.S. establishment(s).1 Do not report
resales. Note that internal consumption and transfers to related firms must be valued at fair
market value of the unfilled cylinder. Input purchases from related suppliers should be
consistent with and based on information in your firm’s accounting books and records.
Provide data for your firm’s three most recently completed calendar years, and for the specified
interim periods.
Note: Only report the revenue and costs of the unfilled cylinder itself and not any revenue and
costs associated with filling the cylinders. If your firm fills its own U.S.‐produced cylinders with
gas or any other material (“fillers”) prior to sale to a final customer, report those transactions as
internal consumption of the unfilled cylinder below (exclude the value of fillers).
Quantity (in units) and value (in dollars)
Calendar years
Item
2017
2018
January‐September
2019
2019
2020
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
Total net sales values
0
0
0
0
0
Direct labor
Other factory costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
Total net sales quantities
2
Net sales values:
Commercial sales
Cost of goods sold (COGS):3
Raw materials
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
0
0
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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.
Note ‐‐The table above contains calculations that will appear when you have entered data in the MS Word form fields.
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III‐9b. Financial data checklist.‐‐Please check that the financial data in question III‐9a have been
correctly reported.
Confirm the following regarding your financial data in question III‐9a:
√ if Yes
In actual dollars (not 1,000 dollars)?
Include only the in‐scope product?
Exclude resales of unfilled cylinders?
Exclude any revenue and costs related to filled cylinders?
IC and transfers to related firms are reported at fair market value?
Net Sales (CS, IC, and Transfers) exclude discounts, returns, allowances,
prepaid freight, and all freight out to customers?
COGS excludes finished goods freight to customers?
SG&A excludes finished goods freight to customers?
All costs exclude finished goods freight to customers?
If you did not √ Yes in any of the boxes above, go back to III‐9a and revise your responses.
III‐9c. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), SG&A, 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
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
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative‐‐instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
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III‐9d. Raw materials.‐‐
Note.‐‐If you procured raw materials from related entities, check “primarily purchased by your
company” below and confirm that that these raw material inputs are reported in question III‐7.
(a)
Please report the share of total raw material costs in 2019 and interim 2020 (reported in
III‐9a) for the following raw material inputs:
Procurement method
Share of total raw material costs
(percent)
Input
January‐
September 2020
2019
Steel
1
Other material inputs
Total (should sum to 100 percent)
Primarily
Primarily
produced by purchased by
your firm
your firm
0.0
0.0
1
Please indicate any other notable "other" raw materials not expressly identified above and provide the share of the
total raw material costs accounted for by these “other” raw materials in 2019 and interim 2020: .
(b)
During January to September 2020, did your firm experience changes in obtaining raw
materials for the production of non‐refillable steel cylinders, or when deliveries were
adversely affected, due to the COVID‐19 Pandemic? If so, please provide details
No
Yes
If yes, please describe and quantify if possible.
III‐9e. Effects on financial performance of COVID‐19.‐‐Please explain how the COVID‐19 pandemic has
affected the financial performance of your firm’s operations on cylinders as reported in III‐9a.
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III‐9f. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual 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 actual dollars), 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 years
January‐September
Item
2017
2018
2019
2019
2020
Value (dollars)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III‐9a where the nonrecurring item is classified.
Description of the
Income statement classification of the
nonrecurring item
nonrecurring item in III‐9a
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
III‐9g. 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‐9f above, 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‐9f identify where these items are
reported in question III‐9a.
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III‐10a. Operations on non‐refillable steel cylinders produced by your firm as unfilled cylinders
(merchant market) .‐‐Report the revenue and related cost information requested below ONLY
on the merchant market non‐refillable steel cylinders operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Input purchases from related suppliers
should be consistent with and based on information in your firm’s accounting books and
records. Provide data for your firm’s three most recently completed calendar years, and for the
specified interim periods.
Note 1: The financial data provided below reflect revenue and cost data for commercial sales
only, and are a subset of the data provided in III‐9a. Data for commercial sales quantities and
values will automatically populate based on the data provided in question III‐9a.
Note 2: Only report the revenue and costs of the cylinder itself and exclude all financial data for
filled non‐refillable steel cylinders.
Quantity (in units) and value (in dollars)
Calendar years
Item
2017
Net sales quantities:2
Commercial sales (“CS”)
2018
January‐September
2019
2019
2020
0
0
0
0
0
0
0
0
0
0
Direct labor
Other factory costs
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
0
0
2
Net sales values:
Commercial sales
3
Cost of goods sold (COGS):
Raw materials
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses:
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 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 only.
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 – Non‐Refillable Steel Cylinders (Final)
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III‐10b. Data consistency between total market and merchant market operations.‐‐Are your firm’s
answers to questions on inputs from related entities (question III‐7), raw material types
(question III‐9d), COVID impact, (question III‐9e), and/or nonrecurring charges (questions III‐9f
and III‐9g) the same for both total and merchant market operations?
Yes
No
If no, please explain.
III‐11a. Asset values on non‐refillable steel cylinders produced by your firm as unfilled cylinders (total
market).‐‐Report the total assets (i.e., both current and long‐term assets) associated with the
production, warehousing, and sale of non‐refillable steel cylinders. If your firm does not
maintain some or all of the specific asset information necessary to calculate total assets for non‐
refillable steel cylinders 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 and III‐10a. Provide data for 2017, 2018, and 2019.
Note 1: 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. Please 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.
Note 2: Do not include assets specific to filled non‐refillable steel cylinders.
Value (in dollars)
Calendar years
Item
Total assets (net)
2017
2018
2019
III‐11b. Description of reported assets.‐‐Describe the main asset categories (both current and long‐term
assets) in the above response. Provide a brief explanation if there are any substantial changes in
total asset value during the period; e.g., due to asset write‐offs, revaluation, and/or major
purchases.
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III‐12a. Capital expenditures and research and development expenses on non‐refillable steel
cylinders produced by your firm as unfilled cylinders (total market).‐‐Report your firm’s
capital expenditures and research and development (“R&D”) expenses for non‐refillable steel
cylinders. Provide data for 2017, 2018, 2019, and for the specified interim periods.
Note: Do not include data specific to filled non‐refillable steel cylinders.
Value (in dollars)
Calendar years
Item
Capital expenditures
R&D expenses
2017
2018
January‐September
2019
2019
2020
III‐12b. Description of reported capital expenditures.‐‐Please describe the nature, focus, and
significance of your firm’s reported capital expenditures in question III‐12a. If no capital
expenditure data were reported, explain.
III‐12c. Description of reported R&D expenses.‐‐Describe the nature, focus, and significance of your
firm’s reported R&D expenses in question III‐12a. If no R&D expenses were reported, explain.
III‐13. Assets, capital expenditures, and R&D checklist.‐‐Please check that the assets, capital
expenditures, and R&D information in questions III‐11a, III‐11b, III‐12a, III‐12b, and III‐12c are
complete.
Confirm the following regarding your responses in questions III‐11a, III‐11b, III‐12b,
and III‐12c:
√ if Yes
Exclude data related to filled containers?
In actual dollars (not 1,000 dollars)?
Top assets are listed in question III‐11b?
Substantial changes in assets are described in question III‐11b, if applicable?
Capital expenses are described in question III‐12b?
R&D are described in question III‐12c?
Provided explanations if your firm did not have capital expenditures or R&D?
If you did not √ Yes in any of the boxes above, go back to question III‐11a, III‐11b, III‐12a, III‐
12b, and/or II‐12c and update your responses.
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III‐13. Data consistency and reconciliation.‐‐Please note that we are requesting your firm’s financial
data for questions III‐9a, III‐10a, III‐11a, and III‐12a on a calendar year basis. Please confirm that
your firm reported these data on a calendar‐year basis:
Yes
No
If no, please explain.
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments).
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in question II‐7 equal the quantities and values reported for total net sales in question
III‐9a 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
January‐September
Reconciliation
2017
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").
2018
0
2019
0
2019
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
Do the data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
2020
0
0
0
0
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III‐14. 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 non‐refillable steel cylinders from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
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
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III‐15. 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 non‐refillable steel cylinders 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
non‐refillable steel cylinders 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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PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202‐205‐
3489, [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. customers since January 1, 2017 of the following products produced by your
firm.
Product 1.‐‐ Non‐refillable steel cylinder, 9.5‐inches in diameter, with 260 PSIG service pressure
rating, unfilled, meeting the requirements of U.S. Department of Transportation
specification 39.
Product 2.‐‐ Non‐refillable steel cylinder, 9.5‐inches in diameter, with 400 PSIG service pressure
rating, unfilled, meeting the requirements of U.S. Department of Transportation
specification 39.
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).
IV‐2a. During January 2017‐September 2020, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data table(s) as appropriate.
No.‐‐Skip to question IV‐3.
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IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 1
Product 2
Period of shipment
Quantity
Value
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
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2 Pricing product definitions are provided on the first page of Part IV.
Note.‐‐If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
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IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000) and units?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in which the
sale occurred?
Less than reported commercial shipments in part II in each year?
Excludes sales of cylinders filled with gas/liquid
Explanation(s) for any boxes not checked:
IV‐2d. Pricing data methodology.‐‐Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.
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IV‐3.
Page 34
Price setting.‐‐How does your firm determine the prices that it charges for sales of non‐refillable
steel cylinders (check all that apply)? If your firm issues price lists, please submit sample pages
of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic non‐refillable steel cylinders
usually quoted (check one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced non‐
refillable steel cylinders 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
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
IV‐7.
Page 35
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced non‐refillable steel cylinders (or check “not applicable” if your firm does not sell
on a short‐term, annual and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
IV‐8.
Lead times.‐‐What share of your firm’s sales is 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 non‐refillable steel cylinders?
Lead time (Average
Source
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
IV‐9.
Page 36
Shipping information.‐‐
(a)
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of non‐refillable steel cylinders
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 non‐refillable steel cylinders since January 1, 2017 (check all that apply)?
Geographic area
√ if applicable
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.
IV‐11. Inland transportation costs.—What is the approximate percentage of the cost of U.S.‐produced
non‐refillable steel cylinders that is accounted for by U.S. inland transportation costs?
percent
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 37
IV‐12. End uses.‐‐List the end uses of the non‐refillable steel cylinders that your firm manufactures. For
each end‐use product, what percentage of the total cost is accounted for by non‐refillable steel
cylinders and other inputs?
Share of total cost of end use product
accounted for by
Total
(should sum to
Non‐refillable steel
100.0% across)
End‐use product
cylinders
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV‐13. Substitutes.‐‐Can other products be substituted for non‐refillable steel cylinders?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for non‐refillable steel
cylinders?
No Yes
Explanation
1.
2.
3.
IV‐14. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for non‐refillable steel cylinders has changed since January 1, 2017. Explain any
trends and describe the principal factors that have affected these changes in demand. Please
also note any changes resulting from the COVID‐19 pandemic.
Market
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explanation and factors
Within the United States
Outside the United States
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 38
IV‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of non‐refillable steel cylinders since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
IV‐16. Conditions of competition.‐‐
(a) Is the non‐refillable steel cylinders market subject to business cycles (other than general
economy‐wide conditions) and/or other conditions of competition distinctive to non‐
refillable steel cylinders? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV‐17.
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
non‐refillable steel cylinders since January 1, 2017?
No
Yes
If yes, describe.
IV‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply non‐refillable
steel cylinders 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,
shortages related to COVID‐19 shutdowns, etc.)
No
Yes
If yes, please describe.
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 39
IV‐18. Complaints and returns.‐‐Since January 1, 2017, has any firm complained about or returned
non‐refillable cylinders from you? If yes, please name the firm, reasons for complaint(s) or
return(s), and provide any relevant documentation.
If yes, please identify these firms, the countries where they are
located, and the reasons for the complaint and/or return.
No
Yes
Complaint
Return
IV‐19. Raw materials.—
(a) How have non‐refillable steel cylinders raw material prices changed since January 1, 2017?
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explain, noting how raw material price changes
have affected your firm’s selling prices for non‐
refillable steel cylinders.
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for non‐refillable steel cylinders?
Factor
Cost of raw materials
after section 232 tariffs
imposed
Overall
increase
No
change
Overall
decrease
Fluctuate with no clear
trend
Explanation
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for non‐refillable steel cylinders?
Factor
Prices for non‐refillable
steel cylinders
Fluctuate
with no
Overall
Overall
Increase No change Decrease clear trend
Explanation
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 40
IV‐20. Impact of section 301 tariffs.‐‐ Did the imposition of tariffs on Chinese‐origin products under
section 301 have an impact on the non‐refillable steel cylinders market in the United States?
Yes— Please indicate the
impact in the table below.
No
Don’t know
Factor
Explain, noting how the imposition
Fluctuate of tariffs under section 301 affected
each factor of the non‐refillable
with no
steel cylinders market in the United
clear
Overall
No
Overall
States.
trend
increase change decrease
Supply of U.S.‐
produced non‐
refillable steel
cylinders
Supply of non‐
refillable steel
cylinders imported
from China
Supply of non‐
refillable steel
cylinders imported
from other countries
Prices for non‐
refillable steel
cylinders
Overall U.S. demand
for non‐refillable steel
cylinders
Raw material costs for
non‐refillable steel
cylinders
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 41
IV‐21. Interchangeability.‐‐Is non‐refillable steel cylinders 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
United States
China
Other countries
China
For any country‐pair producing non‐refillable steel cylinders that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that limit or preclude interchangeable
use:
IV‐22. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between non‐refillable steel
cylinders 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
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of non‐refillable steel cylinders, identify the country‐pair and report the advantages or
disadvantages imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 42
IV‐23. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for non‐refillable steel cylinders since January 1, 2017. Indicate the share of the
quantity of your firm’s total shipments of non‐refillable steel cylinders 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
Business Proprietary
U.S. Producers’ Questionnaire – Non‐Refillable Steel Cylinders (Final)
Page 43
IV‐24. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2017: To avoid losing sales to competitors selling non‐
refillable steel cylinders from China, did your firm reduce prices and/or roll back
announced price increases? If yes, please submit any relevant supporting
documentation.
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2017: Did your firm lose sales of non‐refillable steel
cylinders to imports of this product from China? If yes, please submit any relevant
supporting documentation.
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 – Non‐Refillable Steel Cylinders (Final)
Page 44
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://usitc.gov/investigations/701731/2020/non_refillable_steel_cylinders_china/fina
l.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: NRSC
• 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 (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US producer questionnaire_NRSC(F) |
| Author | kristina.lara |
| File Modified | 2020-12-10 |
| File Created | 2020-12-10 |