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pdfOMB No. 3117-0016/USITC No. 20-1-4385; Expiration Date: : 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
TWIST TIES FROM CHINA
This questionnaire must be received by the Commission by January 13, 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 twist ties from China (Inv. Nos. 701TA-649 and 731-TA-1523 (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 twist ties (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: TIES)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official
Signature
Title of Authorized Official
Phone
Date
Email address
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 26, 2020, by Bedford
Industries Inc., Worthington, Minnesota. 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/twist_ties_china/final.htm.
Twist ties covered by these investigations are thin, bendable ties for closing containers, such as bags,
bundle items, or identifying objects. A twist tie in most circumstances is comprised of one or more metal
wires encased in a covering material, which allows the tie to retain its shape and bind against itself.
However, it is possible to make a twist tie with plastic and no metal wires. The metal wire that is
generally used in a twist tie is stainless or galvanized steel and typically measures between the gauges of
19 (.0410″ diameter) and 31 (.0132″) (American Standard Wire Gauge). A twist tie usually has a width
between .075″ and 1″ in the cross-machine direction (width of the tie—measurement perpendicular
with the wire); a thickness between .015″ and .045″ over the wire; and a thickness between .002″ and
.020″ in areas without wire. The scope includes an all-plastic twist tie containing a plastic core as well as
a plastic covering (the wing) over the core, just like paper and/or plastic in a metal tie. An all-plastic twist
tie (without metal wire) would be of the same measurements as a twist tie containing one or more
metal wires. Twist ties are commonly available individually in pre-cut lengths (“singles”), wound in large
spools to be cut later by machine or hand, or in perforated sheets of spooled or single twist ties that are
later slit by machine or by hand (“gangs”).
The covering material of a twist tie may be paper (metallic or plain), or plastic, and can be dyed in a
variety of colors with or without printing. A twist tie may have the same covering material on both sides
or one side of paper and one side of plastic. When comprised of two sides of paper, the paper material
is bound together with an adhesive or plastic. A twist tie may also have a tag or label attached to it or a
pre-applied adhesive attached to it.
Excluded from the scope of the order are twist ties packaged with bags for sale together where the
quantity of twist ties does not exceed twice the number of bags in each package. Also excluded are
twists ties that constitute part of the packaging of the imported product, for example, merchandise
anchored/secured to a backing with twist ties in the retail package or a bag of bread that is closed with a
twist tie.
Twist ties are imported into the United States under Harmonized Tariff Schedule of the United States
(HTSUS) subheadings 8309.90.0000 and 5609.00.3000. Subject merchandise may also be imported
under HTSUS subheadings 3920.51.5000, 3923.90.0080, 3926.90.9990, 4811.59.6000, 4821.10.2000,
4821.10.4000, 4821.90.2000, 4821.90.4000, and 4823.90.8600. These HTSUS subheadings are provided
for reference only. The written description of the scope of the investigation is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 3
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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of twist ties and your responses to the questions in Part I of the
producer questionnaire will be provided to the U.S. Department of Commerce, upon its request, for use
in connection with (and only in connection with) its requirement pursuant to section 702(c)(4)/732(c)(4)
of the Act (19 U.S.C. § 1671a(c)(4)/1673a(c)(4)) to make a determination concerning the extent of
industry support for the petition requesting this proceeding. Any information provided to Commerce
will be transmitted under the confidentiality and release guidelines set forth above. Your response to
these questions constitutes your consent that such information be provided to Commerce under the
conditions described above.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
I-1a.
Page 4
OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-1b.
TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
I-2a.
Page 5
Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. Firms operating more than one establishment
should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of twist ties, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
.
I-2b.
Stock symbol information.-- If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol:
.
I-2c.
External counsel.-- If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
Law firm:
Lead attorney(s):
I-3.
Petitioner status.--Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
I-4.
Yes
Petition support.--Does your firm support or oppose the petition?
Country
China
Investigation type
Antidumping duty
China
Countervailing duty
Support
Oppose
Take no position
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
I-5.
Ownership.--Is your firm owned, in whole or in part, by any other firm?
No
Firm name
I-6.
Yes--List the following information, relating to the ultimate parent/owner.
Country
Extent of
ownership
(percent)
Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing twist ties from China into the United States or that are
engaged in exporting twist ties from China to the United States?
No
Firm name
I-7.
Page 6
Yes--List the following information.
Country
Affiliation
Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of twist ties?
No
Firm name
Yes--List the following information.
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
I-8.
Page 7
Related firms sent USITC questionnaires.--Please confirm that you have sent all related U.S.
importers and any related producers located in the United States or China the relevant USITC
questionnaire for the final phase of this proceeding. The questionnaires are available for
download from the USITC’s website link found on page two.
Related firm
Related U.S. importer
Related producer in the United
States
Related producer in China
Related exporter in China
Relevant questionnaire
U.S. importers' questionnaire
U.S. producers' questionnaire
Foreign producers' /exporters'
questionnaire
Foreign producers' /exporters'
questionnaire
Check “yes” to confirm that your firm has
sent to your contacts at the related firm(s)
the relevant USITC questionnaire(s), if
applicable
Yes, sent
No, not applicable
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 8
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Christopher W. Robinson
(202-205-2542, [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 twist ties since January 1, 2017.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
(If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable)
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (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 arrangements, production, employment, and shipments relating to
twist ties?
No
II-3a.
Page 9
Yes
If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) production and shipments impact, and (c)
employment impact of the COVID-19 pandemic.
Production using same machinery.--Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce twist ties, 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).
“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 pounds)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Overall production capacity1
Production of:
Twist ties
Other products2
Total production using same
machinery or workers
1
2
0
0
0
0
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Please identify these products:
.
0
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
II-3b.
Page 10
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 twist ties and other products using
the same equipment and/or labor?
No
(b)
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
II-5.
Page 11
Tolling.--Since January 1, 2017, has your firm been involved in a toll agreement regarding the
production of twist ties?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
II-6.
Yes
If yes--Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce twist ties in and/or admit twist ties into
a foreign trade zone (FTZ)?
(a)
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No
Yes
If yes--Describe the nature of your firm’s operations in FTZs and identify
the specific FTZ site(s).
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
II-6.
Foreign trade zones.—Continued
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import twist ties into a foreign trade zone (FTZ) for use in distribution of twist ties
and/or the production of downstream articles?
(b)
No
II-7.
Page 12
Yes
If yes--Identify the firms and the FTZs.
Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of twist ties in its U.S. establishment(s)
during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“Transfers to related firms” –Shipments made to related firms. Such transactions are valued at
fair market value.
“Related firm” –A firm that your firm solely or jointly owned, managed, or otherwise controlled;
a firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm
that was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or
jointly owned, managed, or otherwise controlled your firm.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the trade data, as Commission staff may contact your firm regarding questions on the
trade data. The Commission may also request that your company submit copies of the supporting
documents/records (such as production and sales schedules, inventory records, etc.) used to compile
these data.
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
II-7.
Page 13
Production, shipment, and inventory data.--Continued
Quantity (in 1,000s twist ties) and value (in dollars)
January-September
Calendar year
Item
2017
2018
2019
2019
2020
Average production capacity1
(quantity) (A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:2
Quantity (F)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories (quantity)
(L)
The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 14
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--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 year
Reconciliation
2018
B+C–D–F–H–J–L=
should equal zero ("0") or
provide an explanation.1
2019
0
January-September
2019
0
2019
0
2020
0
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
1
II-8.
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) in pounds and 1,000s of twist
ties by channel of distribution.
Calendar year
Item
U.S. shipments:
To distributors / wholesalers:
Quantity in 1,000 twist ties (M)
Quantity in pounds (N)
Value in dollars (O)
To retailers:
Quantity in 1,000 twist ties (P)
Quantity in pounds (Q)
Value in dollars (R)
To end users:
Quantity in 1,000 twist ties (S)
Quantity in pounds (T)
Value in dollars (U)
2017
2018
January-September
2019
2019
2020
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 15
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M through U) in each time period equal the quantity 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.
Calendar year
Reconciliation item
2017
2018
January-September
2019
2019
2020
Quantity: M + P + S – D – F – H =
zero ("0"), if not revise.
0
0
0
0
0
Value: O + R + U – E- G- I = zero
(“0”), if not revise.
0
0
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
II-9.
Page 16
Product mix.--Does your firm produce and sell the following products? (check all that apply):
Core type
Single stainless steel wire
Single galvanized steel wire
More than one stainless steel wire
More than one galvanized steel wire
Plastic
Wire gauge sizes
<= Gauge 19
Gauges 20 & 21
Gauges 22 & 23
Gauges 24 & 25
Gauges 26 & 27
Gauges 28 & 29
>= Gauge 30
Coverings
Dry paper
Wet paper
Polyethylene
Other plastic
Paper and plastic combo
Cutting
Pre-cut <= 4" lengths
Pre-cut > 4" and <=6" lengths
Pre-cut > 6" and <=8" lengths
Pre-cut > 8" and <=10" lengths
Pre-cut > 10" lengths
Spool
Gangs
End-use
Bib ties/Flag ties
Other grocery ties (bread bag ties and produce ties)
Dry cleaner ties
Nose wires for face masks
Industrial ties (television cables, computer cords, other appliances and household ties)
Describe any other unique characteristics or applications
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 17
II-10. Measurements in your firm’s books and records.--Please indicate in what metrics your firm
measures its production of twist ties in the normal course of business:
Measurement(s) used in your firm’s books and records to record twist ties (check all that apply):
Value (dollars or other currency)
Individual twist ties/ units / or counts
Aggregate weight measures (kilograms, pounds, et cetera)
Other metric:
In this questionnaire, quantity measures are requested both in terms of (i) units, or “1,000 twist
ties,” and (ii) pounds, depending on the question. Please confirm that your firm has either
reported the data as available in your firm’s books and records, or that your firm has reported
data based on carefully crafted estimates (to the best of your availability), such that your firm
has not left any relevant data point empty or blank due a particular metric not being stored in
the normal course of business. For example, if your firm produced spools of twist ties, but does
not store information on the count of individual twist ties or the weight of those twist ties,
please make an effort to assess the largest volume spools your firm produced, and if those large
volume spools contained approximately 500 twist ties and weighted on average 3 pounds, use
that to estimate the aggregate quantities (in 1,000 of twist ties) and quantities (in pounds) for all
production. You do not have to individually measure and assess each product produced, but use
some systematic method to report in every metric that has been requested (value, units, and
weight). Please do not report only one metric; please always provide each of the metrics
requested.
Yes--All data have
Yes--All data have been provided but
been provided
some metrics were
based on
based on carefully
information readily drawn estimates to If your firm had to use estimates to arrive at some
available in our
the best of our
metrics, please briefly described the metrics
books and records
ability
estimated and the methodology used to do so:
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
II-11.
Page 18
Employment data.--Report your firm’s employment-related data related to the production of
twist ties and provide an explanation for any trends in these data.
“Production and Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to September periods, calculate similarly and multiply by 9.
If your firm had the same number of PRWs in all calendar years and had not experienced
any changes in PRWs in the most recent interim period, you would have the same
number of PRWs for the interim periods, regardless of whether the interim periods are
Jan-Mar (Q1), Jan-June (Q1+Q2), or Jan-Sept (Q1+Q2+Q3).”
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (hours)
Wages paid to PRWs (dollars)
Explanation of trends:
II-12.
Related firms.--If your firm reported transfers to related firms in question II-7, please identify
the firm(s) and indicate the nature of the relationship between your firm and the related firms
(e.g., joint venture, wholly owned subsidiary), whether the transfers were priced at market
value or by a non-market formula, whether your firm retained marketing rights to all transfers,
and whether the related firms also processed inputs from sources other than your firm.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
II-13.
Page 19
Purchases.--Has your firm purchased twist ties 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 1,000s twist ties)
Calendar year
Item
2017
2018
January-September
2019
2019
2020
Purchases from U.S. importers of
twist ties from—
China
1
All other sources
Purchases from domestic producers2
Purchases from other sources3
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-14.
Imports.--Since January 1, 2017, has your firm imported twist ties?
No
Yes
If yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
II-15.
Other explanations.--If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 20
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 company’s financial
accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain
below:
Note.--Please report all financial data in part III on a calendar year basis.
B.1.
2.
3.
4.
Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include twist ties:
Does your firm prepare profit/loss statements for twist ties:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
U.S. GAAP,
IFRS,
cash,
tax, or
other
comprehensive basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit-and-loss statements for the division or product group that includes twist ties, as well as
specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system.--Briefly describe your company’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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U.S. Producers’ Questionnaire - Twist Ties (Final)
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III-4.
Allocation basis.--Briefly describe your company’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 company produced in the facilities in which your
company produced twist ties and provide the share of net sales accounted for by these products
in 2019.
Products
Twist ties
Share of sales in 2019
%
%
%
%
%
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
III-6.
Inputs from related suppliers.--Does your company purchase inputs (raw materials, labor,
energy, or any services) used in the production of twist ties from any related suppliers (e.g.,
inclusive of transactions between related entities, divisions and/or other components within the
same company)?
Yes--Continue to question III-7
III-7.
Page 22
No—Skip to question III-9a.
Inputs from related suppliers detailed.--Please identify the inputs used in the production of
twist ties that your company purchases from related suppliers and that are reflected in question
III-9a. For “Share of total COGS” please report this information by relevant input in 2019. For
“Input valuation” please describe the basis, as recorded in your company’s own accounting
system, of the purchase cost from the related supplier; e.g., the related supplier’s actual cost,
cost plus, negotiated transfer price to approximate fair market value.
Input
Related supplier
Share of total COGS in 2019
Input valuation as recorded in the company’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 twist ties) in a
manner consistent with your company’s accounting books and records.
Yes
No
If no--In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 23
III-9a. Operations on twist ties.--Report the revenue and related cost information requested below on
the twist ties operations of your firm’s U.S. establishment(s).1 Do not report resales of twist
ties. Note that internal consumption and transfers to related firms must be valued at fair market
value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for 2017, 2018, 2019, and
the specified interim periods.
Quantity (in 1,000s twist ties) and value (in dollars)
Calendar year
2017
Item
2018
January-September
2019
2019
2020
Net sales quantities:
Commercial sales (“CS”)
2
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Net sales values:
Commercial sales
2
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials
3
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
1
2
Note --The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
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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?
Do not include any resales of twist ties?
IC and transfers to related firms 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), operating income (or loss), and net
income (or loss)) have been calculated from the data submitted in the other line items. Do the
calculated fields return the correct data according to your firm's financial records ignoring nonmaterial differences that may arise due to rounding?
Yes
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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U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 25
III-9d. Raw materials.--Please report the share of total raw material costs in 2019 (reported in III-9a)
for the following raw material inputs:
Share of total raw material costs
in 2019 (percent)
Input
Wire
Paper
Plastic components
Other material inputs1
Total (should sum to 100 percent)
0.0
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:
.
1
III-9e. Procurement of raw materials.--Please report the procurement method of raw materials in
2019 (reported in III-9a) for the following raw material inputs listed below.
Note.--The term “your company” or “your firm” should include only the facilities listed in
question I-2a allocated to the subject product and reflect the raw materials reported in question
III-9a. If you procured raw materials from related entities, check “primarily purchased by your
company” below and ensure that you included the raw material input from related entities are
reported in question III-7 above.
Procurement method
Input
Primarily produced by
your company
Primarily purchased by
your company1
Wire
Paper
Plastic components
Other material inputs
Purchases include those from related and unrelated entities. For purchases from related entities,
confirm that those raw materials are listed in response to question III-7.
1
III-9f.
Raw materials checklist.--Please check that the raw materials information in questions III-9d
and III-9e have been correctly reported.
Confirm the following regarding your responses in questions III-9e and III-9f:
√ if Yes
Include only raw materials used for twist ties?
Reflect the raw materials reported in question III-9a?
Inputs “produced by your company” are from the facilities listed in question I-2a
and not separate legal entities with common ownership or other affiliation?
Inputs purchased from related entities are purchases listed in question III-7?
“Other” raw materials, if any, are specified and listed in question III-9d, footnote 1?
Total sums to 100 percent in question III-9d?
If you did not √ Yes in any of the boxes above, go back to III-9d or III-9e and revise your responses.
III-9g. Explanation of trends.--Please indicate the primary decisions, events, or factors that impacted
the trends in the following metrics reported in question III-9a from 2017 to 2019 and interim
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U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 26
2020.
Metric
Explanation of trends
Net sales quantity
Net sales values
Raw material costs
Direct labor costs
Other factory costs
SG&A costs
III-9f.
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 twist ties as reported in III-9a.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 27
III-10a. 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 year
Item
2017
2018
January-September
2019
2019
2020
Value (in dollars)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III-9a where the nonrecurring item is classified.
Description of the
nonrecurring item
Income statement classification of the
nonrecurring item in III-9a
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III-10b. 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-10a above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III-10a identify where these items
are reported in question III-9a.
III-11a. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of twist ties. If your firm does not maintain some or all of
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U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 28
the specific asset information necessary to calculate total assets for twist ties in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III-9a. Provide data as
of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted. Total assets should be allocated to the subject products if these assets are also
related to other products.
Value (in dollars)
Calendar year
Item
2017
2018
2019
Total assets (net)
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 major
purchases.
III-12a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development (“R&D”) expenses for twist ties. Provide data for
2017, 2018, 2019, and the specified interim periods.
Value (in dollars)
Calendar year
Item
2017
2018
January-September
2019
2019
Capital expenditures
R&D expenses
III-12b. Description of reported capital expenditures.--Describe the nature, focus, and significance of
your firm’s reported capital expenditures. If no capital expenditure data are reported, explain.
III-12c. Description of reported R&D expenses.--Describe the nature, focus, and significance of your
firm’s reported R&D expenses. If no R&D expenses are reported, explain.
2020
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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
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, III12b, and/or II-12c and update your responses.
III-14. 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 year
Reconciliation
2017
2018
January-September
2019
2019
2020
Quantity: Trade data from question II-7
(lines D, F, H, and J) less financial total net
sales quantity data from question III-9a, =
zero ("0").
0
0
0
0
0
Value: Trade data from question II-7 (lines
E, G, I, and K) less financial total net sales
value data from question III-9a, = zero
("0").
0
0
0
0
0
Do these data in question III-9a reconcile with data in question II-7?
Yes
No
If no, please explain.
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Page 30
III-15. Effects of imports on investment.--Since January 1, 2017, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of twist ties from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
(please describe)
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Page 31
III-16. Effects of imports on growth and development.--Since January 1, 2017, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of twist ties from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
(please describe)
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Page 32
III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
twist ties 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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Page 33
PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Natalia King (natalia.king
@usitc.gov, 202-205-2049).
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.-- Paper/paper 29 gauge cut tie, ranging from 4” x 5/32” to 4” x 3/16”
Product 2.-- Paper/paper 29 gauge cut tie, ranging from 7” x 5/32” to 7” x 3/16”
Product 3.-- Produce tie, wet strength paper/paper 27 gauge, galvanized wire, 8” x 7/16”
Product 4.-- Produce tie, wet strength paper/paper 27 gauge, galvanized wire, 10” x 7/16”
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 as appropriate.
No.--Skip to question IV-3.
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Page 34
IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in 1,000s twist ties and actual dollars (not 1,000s).
(Quantity in 1,000s twist ties, 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
1 Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment. Please subtract any discounts, rebates, and returns from the quarter in which the sale occurred.
2 Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
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U.S. Producers’ Questionnaire - Twist Ties (Final)
IV-2c.
Page 35
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)?
In 1,000 twist ties?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have discounts, rebates, and returns been credited to the quarter in which the
sale occurred?
Quantities do not exceed commercial shipments in question II-7 in each year?
Explanation(s) for any boxes not checked:
IV-2d.
Pricing data methodology.--Please describe the method and the kinds of documents/records
that were used to compile your price data.
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.
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
IV-3.
Price setting.--How does your firm determine the prices that it charges for sales of twist ties
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
IV-4.
Contracts
Annual
total
volume
discounts
Other
If other, describe
No
discount
policy
Other
Describe
Pricing terms.--On what basis are your firm’s prices of domestic twist ties usually quoted (check
one)?
Delivered
IV-6.
Set
price
lists
Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV-5.
Page 36
F.o.b.
If f.o.b., specify point
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced twist
ties in 2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) long-term
contract basis, and (4) spot sales basis?
Item
Share of 2019
sales
Type of sale
Long-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
Short-term
contracts
(multiple
deliveries for
less than 12
months)
%
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
0.0
%
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U.S. Producers’ Questionnaire - Twist Ties (Final)
IV-7.
Page 37
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced twist ties (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:
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 twist ties?
Source
Lead time (Average
Share of 2019 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0
%
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U.S. Producers’ Questionnaire - Twist Ties (Final)
IV-9.
Page 38
Shipping information.-(a)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)
(b)
Indicate the approximate percentage of your firm’s sales of twist ties 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 twist ties 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
twist ties that is accounted for by U.S. inland transportation costs?
percent
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
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IV-12. End uses.--List the end uses of the twist ties that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by twist ties and other inputs?
Share of total cost of end-use product
accounted for by
End-use product
Twist ties
Other inputs
Total
(should sum to
100.0% across)
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
IV-13. Substitutes.--Can other products be substituted for twist ties?
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 twist ties?
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 twist ties has changed since January 1, 2017. Explain any trends and
describe the principal factors that have affected these changes in demand. If demand trends
vary by market segments (e.g., grocery, dry cleaning, face masks), please discuss each
separately. Please also note any changes resulting from the COVID-19 pandemic.
Overall
increase
Market
Fluctuate
No
Overall
with no
change decrease clear trend
Explanation and factors
Within the United States
Outside the United States
IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of twist ties since January 1, 2017?
No
Yes
If yes, please describe and quantify if possible.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
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IV-16. Conditions of competition.-(a) Is the twist ties market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to twist ties? 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
twist ties since January 1, 2017?
No
Yes
If yes, describe.
IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply twist ties 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 - Twist Ties (Final)
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IV-18. Raw materials.—
(a) How have twist ties raw material costs changed since January 1, 2017?
Factor
Overall
increase
No
change
Overall
decrease
Explain, noting how raw
Fluctuate
material price changes have
with no clear affected your firm’s selling
trend
prices for twist ties.
Cost of raw materials
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for twist ties?
Factor
Overall
Increase
No change
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 twist ties?
Factor
Prices for twist ties
Overall
Increase
No change
Fluctuate
Overall
with no
Decrease clear trend
Explanation
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
Page 42
IV-19. Impact of section 301 tariffs.-- Did the imposition of tariffs on Chinese-origin products under
section 301 have an impact on the twist ties market in the United States?
Yes— Please indicate the
impact in the table below.
Factor
Supply of U.S.produced twist ties
Supply of twist ties
imported from China
Supply of twist ties
imported from other
countries
Prices for twist ties
Overall U.S. demand
for twist ties
Raw material costs for
twist ties
No
Overall
No
Overall
increase change decrease
Don’t know
Fluctuate Explain, noting how the imposition
with no of tariffs under section 301 affected
clear
each factor of the twist ties market
trend
in the United States.
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U.S. Producers’ Questionnaire - Twist Ties (Final)
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IV-20. Interchangeability.--Are twist ties 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 twist ties that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:
IV-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between twist ties 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 twist ties, identify the country-pair and report the advantages or disadvantages imparted
by such factors:
Business Proprietary
U.S. Producers’ Questionnaire - Twist Ties (Final)
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IV-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for twist ties since January 1, 2017. Indicate the share of the quantity of your firm’s
total shipments of twist ties that each of these customers accounted for in 2019.
Customer’s name
1
2
3
4
5
6
7
8
9
10
City
State
Share of
2019 sales
(%)
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U.S. Producers’ Questionnaire - Twist Ties (Final)
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IV-23. Competition from imports.-(a)
Lost revenue.--Since January 1, 2017: To avoid losing sales to competitors selling twist
ties from China, did your firm:
Item
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.--Since January 1, 2017: Did your firm lose sales of twist ties to imports of this
product from China?
No
Yes
IV-24. 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 - Twist Ties (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://usitc.gov/investigations/701731/2020/twist_ties_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: TIES
• E-mail.—E-mail the MS Word questionnaire to [email protected]; include a scanned copy of
the signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic
documents that are electronically transmitted to the Commission to protect your sensitive information
from unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
Information System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic
algorithms to encrypt data in transit. Submitting your nonpublic documents by a means that does not
use these encryption algorithms (such as by email) may subject your firm’s nonpublic information to
unauthorized disclosure during transmission. If you choose a non-encrypted method of electronic
transmission, the Commission warns you that the risk of such possible unauthorized disclosure is
assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | US producer questionnaire |
| Subject | Title 7 investigations |
| Author | Andrade, Andres |
| File Modified | 2020-12-17 |
| File Created | 2020-12-17 |