20-2-4386 U.S. importers' questionnaire

OMB No. 3117-0016/USITC No. 20-2-4386; Expiration Date: 6/30/2023
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
TWIST TIES FROM CHINA
This questionnaire must be received by the Commission by January 23, 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 imported twist ties (as defined on next page) from any country 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. Importers’ 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 consists of 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.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing twist ties (as defined above) into the United States from a foreign manufacturer or through its
selling agent.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)

Page 3

Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Chris
Robinson (202-205-2542, [email protected]).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
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. Importers’ Questionnaire - Twist Ties (Final)
I-1.

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

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

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):

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
I-3.

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

Firm name

I-4.

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

Country

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing 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-5.

Page 5

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. Importers’ Questionnaire - Twist Ties (Final)
I-6.

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

I-7.

Relevant Questionnaire
U.S. importers' questionnaire
U.S. producers' 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
No, not
Yes, sent
applicable

Foreign producers' /exporters'
questionnaire
Foreign producers' /exporters'
questionnaire

Importing operations.--Please indicate the nature of your firm’s importing operations of twist
ties. More than one answer may be applicable.
Importer of record

I-8.

Page 6

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

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

Firm name

Address

Contact person
and phone
number

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
I-9.

Page 7

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

No

Yes

Foreign trade zones
Bonded warehouses
Temporary importation under bond
I-10.

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

Yes

If yes–Please specify.

Business Proprietary
U.S. Importers’ 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 importation of twist ties since January 1, 2017.
(check as many as appropriate)

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

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

Business Proprietary
U.S. Importers’ Questionnaire - 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, importation, employment, and shipments relating
to twist ties in the United States?

No

II-3a.

Page 9

Yes

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

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

Yes

If yes, fill out the table below.

Period
Source

Oct-Dec 2020

Jan-Mar 2021

Apr-Jun 2021

Jul-Sep 2021

Quantity (in 1,000s twist ties)
China
All other sources
II-3b.

Imports in the 12 month period preceding the petition.--Has your firm imported twist ties from
any source between June 1, 2019 and May 30, 2020? (i.e., the last seven months in 2019 and
first five months in 2020 combined)
No

Yes

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

Quantity (in 1,000s twist ties)
Source
China
All other sources

June 2019 through May 2020

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-4.

Page 10

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

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)

Page 11

Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“Commercial U.S. shipments”— Shipments made within the United States as a result of an
arm’s length commercial transaction in the ordinary course of business. Report net values (i.e.,
gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of
returned goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” –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. Importers’ Questionnaire - Twist Ties (Final)
II-5a.

Page 12

U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of twist ties imported from China by your firm during the specified periods.

China
Quantity (in 1,000s twist ties), value (in dollars)
Calendar year
Item

2017

2018

January-September
2019

2019

2020

Beginning-of-period
inventories (quantity) (A)
Imports:1 2
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value3 (G)
Transfers to related
firms:3
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
Please identify the HTSUS codes used by your firm to import these products:
.
3
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
4
Identify your firm’s principal export markets:
.
1
2

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-5a.

Page 13

U.S. imports from China.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar year
Reconciliation
A+B–D–F–H–J–L=
should equal zero ("0") or
provide an explanation.1

2017

January-September

2018

0

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-5b.

U.S. imports from China (additional detail).—Report additional detail relating to your firm’s
imports of twist ties from China during the specified periods.

Calendar Year
Item
Imports
Quantity (in 1,000 twist ties)1

2017

2018

January-September
2019

2019

2020

0

0

0

0

0

0

0

0

0

0

Quantity (pounds)
Value (in dollars)
1

Data for Quantity (in 1,000s twist ties) and Value (in dollars) will automatically populate from question II-5a.

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-5c.

Page 14

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

China
Calendar year
Item

2017

2018

January-September
2019

2019

2020

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)
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. Importers’ Questionnaire - Twist Ties (Final)
II-5d.

Page 15

Product mix: China.--Does your firm import from China 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

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-6a.

Page 16

Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of twist ties imported from all other sources by your firm during the specified
periods.

All other sources

(list sources:

)
Quantity (in 1,000s twist ties), value (in dollars)
Calendar year

Item

2017

2018

January-September
2019

2019

2020

Beginning-of-period
inventories (quantity) (A)
Imports:1 2
Quantity (B)
Value (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:3
Quantity (F)
Value3 (G)
Transfers to related firms:3
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Please identify the foreign producers, if known:
.
Please identify the HTSUS codes used by your firm to import these products:
.
3
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a
different basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However, the data provided above in this table should be based on fair market value.
4
Identify your firm’s principal export markets:
.
1
2

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-6a.

Page 17

Imports from all other sources.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., line B), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar year
Reconciliation
A+B–D–F–H–J–L=
should equal zero ("0") or
provide an explanation.1

2017

January-September

2018

0

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-6b.

U.S. imports from all other sources (additional detail).—Report additional detail relating to
your firm’s imports of twist ties from all other sources during the specified periods.

Calendar Year
Item
Imports
Quantity (in 1,000 twist ties)1

2017

2018

January-September
2019

2019

2020

0

0

0

0

0

0

0

0

0

0

Quantity (pounds)
Value (in dollars)
1

Data for Quantity (in 1,000s twist ties) and Value (in dollars) will automatically populate from question II-6a.

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-6c.

Page 18

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

All other sources
Calendar year
Item

2017

2018

January-September
2019

2019

2020

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)
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. Importers’ Questionnaire - Twist Ties (Final)
II-6d.

Page 19

Product mix: All other sources.--Does your firm import from sources other than China 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. Importers’ Questionnaire - Twist Ties (Final)

Page 20

II-7.

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

II-8.

Measurements in your firm’s books and records.--Please indicate in what metrics your firm
measures its importation 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 imported 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 imported, 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
importation. You do not have to individually measure and assess each product imported
individually, 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
provided but some
based on
metrics were based
information readily on carefully drawn If your firm had to use estimates to arrive at some
available in our estimates to the best metrics, please briefly described the metrics
books and records
of our ability
estimated and the methodology used to do so:

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
II-9.

Page 21

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

Business Proprietary
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Page 22

PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache
([email protected], 202-205-2049).
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

PRICE DATA
III-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 your firm imported
from China:
Product 1.-- Paper 29 gauge cut tie, ranging from 4” x 5/32” to 4” x 3/16” paper
Product 2.-- Paper 29 gauge cut tie, ranging from 7” x 5/32” to 7” x 3/16” paper
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).
During January 2017-September 2020, did your firm import from China 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 III-3.

Business Proprietary
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Page 23

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

China

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 III.

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:

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
III-2b.

Page 24

Price data checklist.--Please check that the pricing data in question III-2a has been correctly
reported.
√ if Yes

Are the price data reported above:
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:

III-2c.

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.
III-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

III-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
III-5.

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

III-6.

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of twist ties imported from
China in 2019 was on a (1) short-term contract basis, (2) annual contract basis, (3) long-term
contract basis, and (4) spot sales basis?

Item
Share of 2019
sales
III-7.

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

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
twist ties imported from China (or check “not applicable” if your firm does not sell on a shortterm, 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)

Quantity
Price
Both
Yes
No

Not applicable
Please identify the indexes used:

Annual contracts
(multiple
deliveries for 12
months)
365

No

Indexed to raw
material costs1

1

Page 25

.

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

%

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)
III-8.

Page 26

Lead times.--What share of your firm’s sales of twist ties imported from China 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 twist ties?

Source

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

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

Total (should sum to 100.0%)
III-9.

0.0 %

Shipping information.—
(a)

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

(b)

When your firm sells twist ties imported from China, from where are they shipped?
Point of importation
Storage facility (check one)

(c)

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

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

III-10. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold twist ties
imported from China since January 1, 2017 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI.

China

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Page 27

III-11. Inland transportation costs.—What is the approximate percentage of the cost of twist ties
imported from China that is accounted for by U.S. inland transportation costs?
percent.
III-12. End uses.--List the end uses of the twist ties that your firm imports. 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 %

III-13. Substitutes.--Can other products be substituted for twist ties?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for twist ties?
No Yes

Explanation

1.
2.
3.
III-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.

Market
Within the United States
Outside the United States

Overall
increase

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)

Page 28

III-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.

III-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?
Check all that apply.

Please describe.

No

Skip to question III-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.

III-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. Importers’ Questionnaire - Twist Ties (Final)

Page 29

III-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. Importers’ Questionnaire - Twist Ties (Final)

Page 30

III-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.

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)

Page 31

III-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:

III-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. Importers’ Questionnaire - Twist Ties (Final)

Page 32

III-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

City

State

Share of
2019 sales
(%)

1
2
3
4
5
6
7
8
9
10
III-23. Other explanations.--If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

Business Proprietary
U.S. Importers’ Questionnaire - Twist Ties (Final)

Page 33

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

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

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

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Page 34

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 did not import this product, please fill out page 1, print, sign, and submit a scanned copy to
the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.