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pdfOMB No. 3117‐0016/USITC No. 20‐1‐4393; Expiration Date: : 6/30/2023
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U.S. PRODUCERS’ QUESTIONNAIRE
CHASSIS AND SUBASSEMBLIES FROM CHINA
This questionnaire must be received by the Commission by DATE
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 certain chassis and subassemblies
thereof (“chassis”) from China (Inv. Nos. 701‐TA‐657 and 731‐TA‐1537 (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 chassis or in‐scope subassemblies (as defined on next page) at any time since January 1,
2018?
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: CHAS)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on July 30, 2020, by the
Coalition of American Chassis Manufacturers, consisting of Cheetah Chassis Corporation, Fairless Hills,
Pennsylvania, Hercules Enterprises, LLC, Hillsborough, New Jersey, Pitts Enterprises, Inc., Pittsview,
Alabama, Pratt Industries, Inc., Bridgman, Michigan, and Stoughton Trailers, LLC, Stoughton, Wisconsin.
Countervailing and/or antidumping duties may be assessed on the subject imports as a result of these
proceedings if the Commission makes an affirmative determination of injury, threat, or material
retardation, and if the U.S. Department of Commerce (“Commerce”) makes an affirmative
determination of subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available at LINK.
Chassis covered by these investigations are chassis and subassemblies thereof, whether finished or
unfinished, whether assembled or unassembled, whether coated or uncoated, regardless of the number
of axles, for carriage of containers, or other payloads (including self‐supporting payloads) for road,
marine roll‐on/roll‐off (RORO) and/or rail transport. Chassis are typically, but are not limited to,
rectangular framed trailers with a suspension and axle system, wheels and tires, brakes, a lighting and
electrical system, a coupling for towing behind a truck tractor, and a locking system or systems to secure
the shipping container or containers to the chassis using twistlocks, slide pins or similar attachment
devices to engage the corner fittings on the container or other payload.
Subject merchandise includes, but is not limited to, the following subassemblies:
Chassis frames, or sections of chassis frames, including kingpins or kingpin assemblies, bolsters
consisting of transverse beams with locking or support mechanisms, goosenecks, drop
assemblies, extension mechanisms and/or rear impact guards;
Running gear assemblies or axle assemblies for connection to the chassis frame, whether fixed
in nature or capable of sliding fore and aft or lifting up and lowering down, which may or may
not include suspension(s) (mechanical or pneumatic), wheel end components, slack adjusters,
axles, brake chambers, locking pins, and tires and wheels;
Landing gear (legs) or landing gear assemblies, for connection to the chassis frame, capable of
supporting the chassis when it is not engaged to a tractor; and
Assemblies and/or components that connect to the chassis frame or a section of the chassis
frame, such as, but not limited to, pintle hooks or B‐trains (which include a fifth wheel), which
are capable of connecting a chassis to a converter dolly or another chassis.
Importation of any of these subassemblies, whether assembled or unassembled, constitutes an
unfinished chassis for purposes of this investigation.
Subject merchandise also includes chassis, whether finished or unfinished, entered with or for further
assembly with components such as, but not limited to: Hub and drum assemblies, brake assemblies
(either drum or disc), axles, brake chambers, suspensions and suspension components, wheel end
components, landing gear legs, spoke or disc wheels, tires, brake control systems, electrical harnesses
and lighting systems.
Processing of finished and unfinished chassis and components such as trimming, cutting, grinding,
notching, punching, drilling, painting, coating, staining, finishing, assembly, or any other processing
either in the country of manufacture of the in‐scope product or in a third country does not remove the
product from the scope. Inclusion of other components not identified as comprising the finished or
unfinished chassis does not remove the product from the scope.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 3
This scope excludes dry van trailers, refrigerated van trailers and flatbed trailers. Dry van trailers are
trailers with a wholly enclosed cargo space comprised of fixed sides, nose, floor and roof, with
articulated panels (doors) across the rear and occasionally at selected places on the sides, with the cargo
space being permanently incorporated in the trailer itself. Refrigerated van trailers are trailers with a
wholly enclosed cargo space comprised of fixed sides, nose, floor and roof, with articulated panels
(doors) across the rear and occasionally at selected places on the sides, with the cargo space being
permanently incorporated in the trailer and being insulated, possessing specific thermal properties
intended for use with self‐contained refrigeration systems. Flatbed (or platform) trailers consist of load‐
carrying main frames and a solid, flat or stepped loading deck or floor permanently incorporated with
and supported by frame rails and cross members.
The finished and unfinished chassis subject to this investigation are typically classified in the Harmonized
Tariff Schedule of the United States (HTSUS) at subheadings 8716.39.00 or 8716.90.50 (statistical
reporting numbers 8716.39.0090 or 8716.90.5060). Imports of finished and unfinished chassis may also
be reported under HTSUS statistical reporting number 8716.90.5010. While the HTSUS subheadings are
provided for convenience and customs purposes, the written description of the merchandise under
investigation is dispositive.
Reporting of information.‐‐If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 4
D‐GRIDS tool.‐‐The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self‐contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell‐by‐cell data entry that would be required to complete this form. This tool is a macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
I‐1a. OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b.
TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, contact person’s
title, telephone number, email address) appearing on the front page of this questionnaire to the
Departments of Commerce, Labor, and Agriculture, as applicable, so that your firm and its
workers can be made eligible for benefits under the Trade Adjustment Assistance program?
Yes
No
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (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 chassis, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
I‐2b.
I‐2c.
1
2
3
4
5
6
Additional discussion on establishments consolidated in this questionnaire: .
Stock symbol information.‐‐ If your firm or parent firm is publicly traded, please specify the
stock exchange and trading symbol: .
External counsel.‐‐ If your firm or parent firm is represented by external counsel in relation to
this proceeding, please specify the name of the law firm and the lead attorney(s).
I‐3.
Law firm:
Lead attorney(s):
Petitioner status.‐‐Is your firm a petitioner in this proceeding or a member firm of the
petitioning entity?
No
Yes
I‐4.
Petition support.‐‐Does your firm support or oppose the petition?
Country
Investigation type
Support
Oppose
Take no position
China
Antidumping duty
China
Countervailing duty
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
I‐5.
I‐6.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information, relating to the ultimate parent/owner.
Extent of
ownership
(percent)
Firm name
Country
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing chassis from China into the United States or that are
engaged in exporting chassis from China to the United States?
No
Yes‐‐List the following information.
Page 6
Firm name
Country
Affiliation
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
I‐7.
I‐8.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of chassis?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
In‐scope subassemblies.‐‐Does your firm produce and ship ONLY in‐scope subassemblies?
No
Yes
If yes, please explain whether these subassemblies can be used for the
production of out‐of‐scope products, and identify the out‐of‐scope
products for which these subassemblies can be used.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 8
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Ahdia Bavari (202‐205‐3191,
[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 chassis since January 1, 2018.
(check as many as appropriate)
(If checked, please describe the nature, date(s), and
significance of any such reported changes as well as the
business reasons for them; leave completely blank if not
applicable)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g updating.,
technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 9
II‐2b. COVID‐19 pandemic.—Since January 1, 2020, has the COVID‐19 pandemic or have any
government actions taken to contain the spread of the COVID‐19 virus resulted in changes in
relation to your firm’s supply chain arrangements, production, sales, and employment relating
to chassis?
No
Yes
If yes, describe these changes including a separate discussion of the (a)
supply chain impact, (b) production and sales impact, and (c) the
employment impact of the COVID‐19 pandemic.
II‐3a. Production using same machinery.‐‐Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce chassis, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Theoretical production capacity”‐‐ The maximum level of production that your
establishment(s) could have attained during the specified periods without additional investment
in machinery and staff. Theoretical capacity is also known as nameplate capacity, rated
capacity, maximum achievable capacity, or nominal capacity, and does not take into account
normal operating levels and downtime.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.‐‐If your firm does not produce any out‐of‐scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II‐7. If, however, your firm does produce out‐of‐scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II‐7 should exclude the portion of "overall production capacity" that was
used to produce this out‐of‐scope merchandise.
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“Unit” – For purposes of this questionnaire, a unit can be either a complete chassis (whether or
not the subassemblies thereof were produced by your firm) or a subassembly (see page 2)
produced for individual use or sale.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 10
II‐3a. Production using same machinery.—Continued
Quantity (in units)
Calendar year
Item
2018
Theoretical production capacity
1
Overall production capacity
Production of:
Chassis2
Out‐of‐scope production.‐‐
Specifically excluded trailers3
4
Other products
Subtotal, out‐of‐scope
production
Total production using
same machinery or workers
2019
2020
0
0
0
0
0
0
0
0
0
1
Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of chassis will populate here once reported in question II‐7.
3
Specifically excluded trailers includes dry van trailers, refrigerated trailers and flatbed trailers.
4
Please identify these products: .
2
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on the following
operating paramaters:
Hours per week
Weeks per year
Implied number of shifts
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. Theoretical vs overall capacity.‐‐Please describe the differences between your firm’s theoretical
capacity and the Commission’s standard “overall production capacity” as reported in II‐3a.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 11
II‐3e. Underutilization.‐‐Has your firm reported an “Overall production capacity” number that is at
least double the reported production achieved (i.e., demonstrating a 50 percent or lower
utilization rate)?
No
Yes
If yes‐‐Please explain why this utilization rate is so low in light of the
definition for “overall production capacity” to be based normal operating
conditions.
II‐3e. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity. In particular, describe any potential bottlenecks in your production process
which limit capacity.
II‐3f.
Product shifting.—
(i)
Is your firm able to switch production (capacity) between chassis and other products using
the same equipment and/or labor?
No
Yes
If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.
(ii)
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.
(iii)
Please describe the factors that affect your firm’s ability to shift production capacity
between in‐scope chassis of different container types (i.e., marine/international or domestic
containers, etc.), and the degree to which these factors enhance or constrain such shifts.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
II‐3g.
Page 12
Production on all machinery.—Has your firm produced any other products on equipment other
than that described in question II‐3a since January 1, 2018?
No
Yes
If yes—Please describe: a) other products produced on such equipment
and b) notable trends in production and/or capacity of this equipment
since January 1, 2018.
II‐4a. Detailed explanation of firm's domestic activities. ‐‐Please describe in detail your firms’
domestic operations since January 1, 2018 with respect to domestic manufacturing of chassis
reported in this U.S. producers’ questionnaire submission. Please discuss specifically: a) the
nature of your firm’s production activities regarding manufacture of subassemblies and/or
complete chassis; b) notable changes in operations; and c) dates when such changes occurred.
II‐4b. Assembly‐only operations.‐‐ Please describe the nature and extent of the following items in
relation to your firm's assembly‐only operations (i.e., assembly of in‐scope subassemblies not
manufactured by your firm into complete chassis) in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Costs and activities
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
II‐4c.
Page 13
Assembly‐only operations' complexity and importance.‐‐On a scale of 1 to 5, please provide
your firm's subjective opinion as to the complexity, intensity, and importance of chassis
assembly activities (i.e., assembly of in‐scope subassemblies not manufactured by your firm into
complete chassis). 1 is considered minimally complex, intense or important, while 5 is
considered extremely complex, intense, and important.
1:
Minimally complex,
intense, and
important
2
3
4
5:
Extremely complex,
intense, and
important
Please describe the reason for your rating.
II‐4d. Assembly‐only machinery investment costs.‐‐Please describe and quantify the amount of
capital investments (from a greenfield investment stand point) needed to assemble complete
chassis from in‐scope subassemblies (i.e., covering only the production steps related to
connection of the in‐scope subassemblies not manufactured by your firm into a complete
chassis).
Value (in dollars)
Description
II‐4e. Full subassembly and final assembly investment costs.‐‐Please describe and quantify the
amount of capital investments (from a greenfield investment stand point) needed to produce
complete chassis in the United States, including subassembly production.
Value (in dollars)
Description
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
II‐5.
Page 14
Tolling.‐‐Since January 1, 2018, has your firm been involved in a toll agreement regarding the
production of chassis?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
II‐6.
No
Yes
If yes‐‐Please describe the toll arrangement(s) and name the firm(s)
involved.
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce chassis in and/or admit chassis into a
foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designated as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes
If yes‐‐Describe the nature of your firm’s operations in FTZs and identify
the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import chassis into a foreign trade zone (FTZ) for use in distribution of chassis and/or
the production of downstream articles?
No
Yes
If yes‐‐Identify the firms and the FTZs.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
II‐7.
Page 15
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of chassis in its U.S. establishment(s)
during the specified periods.
“Unit” – For purposes of this questionnaire, a unit can be either a complete chassis (whether or
not the subassemblies thereof were produced by your firm) or a subassembly (see page 2)
produced for individual use or sale.
“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 ‐ Chassis (Final)
II‐7.
Page 16
Production, shipment, and inventory data.‐‐Continued
Quantity (in units) and value (in $1,000)
Calendar year
Item
2018
2019
2020
1
Average production capacity (quantity)
(A)
Beginning‐of‐period inventories
(quantity) (B)
Production (quantity) (C)
2
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
3
2
Value (G)
Transfers to related firms:
Quantity (H)
3
2
Value (I)
Export shipments:
Quantity (J)
4
Value (K)
End‐of‐period inventories (quantity) (L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity .
2
Identify what share of your firm’s U.S. shipments are remack shipments: percent.
3
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
4
Identify your firm’s principal export markets: .
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
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1
2018
2019
0
2020
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate: .
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
II‐8.
Page 17
Channels of distribution.‐‐Report your firm’s U.S. shipments (i.e. inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution in
the specified periods.
Quantity (in units)
Calendar year
Item
2018
U.S. shipments:
To trucking companies and
other end users (including
leasing companies) (M)
To distributors and dealers (N)
2019
2020
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution (i.e.,
lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F, H) in each time
period. If the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised
prior to submission to the Commission.
Calendar year
Reconciliation
M + N – D – F – H = zero ("0"), if not
revise.
2018
2019
0
2020
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
II‐9.
Page 18
U.S. shipments by product type.‐‐Report your firm’s U.S. shipments (i.e. inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) by product type during the
specified periods.
“Finished chassis” – A complete, fully assembled chassis.
“Subassembly” – An in‐scope component of a chassis. Please see page 2 for a complete
description of the specified subassemblies below.
Calendar year
2018
Item
U.S. shipments:
Finished chassis:
Quantity in units (O)
2019
2020
Quantity in pounds (P)
Value in $1,000 (Q)
Quantity in pounds (S)
Value in $1,000 (T)
Quantity in pounds (V)
Value in $1,000 (W)
Connection subassemblies:
Quantity in units (AA)
Quantity in pounds (AB)
Value in $1,000 (AC)
All other subassemblies:
Quantity in units (AD)
Quantity in pounds (AE)
Value in $1,000 (AF)
Subassemblies:
Chassis frames:
Quantity in units (R)
Running gear/ axle subassemblies:
Quantity in units (U)
Landing gear subassemblies:
Quantity in units (X)
Quantity in pounds (Y)
Value in $1,000 (Z)
1
2
1
Connection subassemblies include assemblies and/or components capable of connecting a chassis to a converter dolly or another
chassis, such a pintle hooks or B‐trains (fifth wheels).
2
Please describe these other subassemblies: .
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II‐9. U.S. shipments by product type.‐‐Continued
RECONCILIATION OF SHIPMENTS.—Please ensure that the quantities (in units) and values reported for
U.S. shipments in this question (i.e., lines O through AC) in each time period equal the quantity and
values reported for U.S. shipments in previous question II‐7 (i.e., lines D through I) in each time period. If
the calculated fields below return values other than zero (i.e., “0”), the data reported must be revised
prior to submission to the Commission.
Calendar year
Reconciliation
2018
2019
2020
Quantity: D + F + H – O – R – U – X – AA –
AD = zero (“0”), if not revise
0
0
0
Value: E + G + I – Q – T – W – Z – AC – AF
= zero, (“0”), if not revise.
0
0
0
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II‐10. U.S. production capacity, production, and shipments of chassis by container type.‐‐ Report
your firm’s U.S. production capacity, production, and U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of chassis for
use with the below container types in 2020.
Quantity (units)
Calendar year
Mode of transport
2018
2019
2020
1
U.S. production capacity:
Marine/international containers (AG)
Domestic containers (AH)
2
Other types of containers (AI)
Total U.S. production capacity:
U.S. production:
Marine/international containers (AJ)
Domestic containers (AK)
0
0
0
2
Total U.S. production:
0
0
0
Other types of containers (AL)
U.S. shipments:
Marine/international containers (AM)
Domestic containers (AN)
2
Total U.S. shipments:
0
0
0
Other types of containers (AO)
1
Please describe the methodology used to calculate capacity by container type: .
2
Please Identify these other types of containers: .
RECONCILIATION OF CAPACITY, PRODUCTION, AND SHIPMENTS.—Please ensure that the quantities
reported for U.S. production capacity, production, and shipments in this question (i.e., lines AG through
AO) equal the quantity and values reported for U.S. capacity, production, and U.S. shipments in previous
question II‐7 (i.e., lines A,C, D, F, and H) in 2020. 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
2020
Capacity: AG + AH + AI – A = zero (“0”), if not revise
0
Production: AJ + AK + AL – C = zero, (“0”), if not revise.
0
Shipments: AM + AN + AO – D – F – H = zero, (“0”), if not revise.
0
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II‐11a. Employment data.‐‐Report your firm’s employment‐related data related to the production of
chassis 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.
“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
2018
2019
2020
Average number of PRWs (number)
Hours worked by PRWs (1,000
hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐11b. Operating shifts.—Please report the number of operating shifts actually worked by PRWs in the
periods indicated in II‐11a. Please describe any changes in shifts utilized over the period(s) indicated,
including the period(s) in which the changes occurred and the business reasons for them.
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Page 22
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.
II‐13a. Purchases (complete chassis).‐‐Has your firm purchased complete chassis produced in the
United States or in other countries since January 1, 2018? (Do not include imports for which
your firm was the importer of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in units)
Calendar year
Item
2018
2019
2020
1
Purchases from U.S. importers of
chassis from—
China
All other sources
Purchases from domestic producers
3
Purchases from other sources
1
2
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: .
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II‐13a. Purchases (subassemblies).‐‐Has your firm purchased subassemblies produced in the United
States or in other countries since January 1, 2018? (Do not include imports for which your firm
was the importer of record. These should be reported in an importer questionnaire.)
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No
Yes
If yes‐‐Report such purchases in the table below and explain the reasons
for your firms' purchases.
Note: If your firm served as the importer of record for any purchases from foreign suppliers,
either for your own account or as a service for another entity, those purchases are to be
considered "imports" not "purchases" and should not be included in the table below
(Quantity in units)
Calendar year
Item
2018
2019
2020
1
Purchases from U.S. importers of
chassis from—
China
All other sources
Purchases from domestic producers2
3
Purchases from other sources
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: .
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II‐13c. Suppliers of in‐scope merchandise.‐‐Does you firm purchase or import any in‐scope
subassemblies (as defined on page 2) from any company, whether a U.S. producer, U.S.
importer, or other entity operating in the United States?
No
Yes
If yes—please complete the table below.
Firm type
Firm name
Contact person
Contact email
II‐14. Imports.‐‐Since January 1, 2018, has your firm imported chassis?
No
Yes
U.S.
U.S.
producer importer Other
If yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
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II‐15. Semi‐finished product analysis.‐‐Please answer the following questions regarding the
differences and similarities in unfinished product(s) and finished product(s) in this proceeding as
defined below:
“Finished product(s)” ‐ Complete chassis that are ready for use on road/rail/water.
“Unfinished product(s)” ‐ In‐scope subassemblies of chassis that need to be further attached to
form a complete chassis and become road/rail/water ready.
(a) Are there uses for the unfinished product(s) other than for the production of the finished
product(s)
No
Yes
If yes‐‐Please describe these uses.
(b) Is the market for unfinished product(s) separate and distinct from the market for finished
product(s)?
No
Yes
If yes‐‐Please describe how they are
separate and distinct.
(c) Are there differences in the physical characteristics and functions of the unfinished
product(s) and finished products(s)?
No
Yes
If yes‐‐Please describe these differences.
(d) Is there a significant difference in the cost or value between unfinished product(s) and
finished product(s)?
No
Yes
If yes‐‐Please describe these differences.
(e) Would you describe the processes used to transform the unfinished product(s) into the
finished product(s) as significant and particularly labor or capital intensive?
No
Yes
If yes‐‐Please describe the labor or capital
intensively of the conversion process.
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Page 26
II‐16. 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 ‐ Chassis (Final)
Page 27
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to AUDITOR (202‐xxx‐xxxx, [email protected]).
III‐1. Contact information.‐‐Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in Part III.
Name
Title
Email
Telephone
III‐2. Accounting system.—Please provide the following information on your firm’s financial
accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain
below:
Note.‐‐Please note that we are requesting that firms report their financial
data 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 chassis:
Does your firm prepare profit/loss statements for chassis:
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 chassis, as well as
specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
III‐4.
Page 28
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
III‐5.
Product listing.‐‐Please list the products your firm produced in the facilities in which your firm
produced chassis and provide the share of net sales accounted for by these products in 2020.
Share of 2020
Products
sales
Chassis
%
%
%
%
%
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
III‐6.
Page 29
Inputs from related suppliers.‐‐Does your firm purchase inputs (raw materials, labor, energy, or
any services) used in the production of chassis from any related suppliers (e.g., inclusive of
transactions between related firms, divisions and/or other components within the same
company)?
Yes‐‐Continue to question III‐7
III‐7.
No—Skip to question III‐9a.
Inputs from related suppliers detailed.‐‐Please identify the inputs used in the production of
chassis that your firm purchases from related suppliers and that are reflected in question III‐9a.
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.
Share of total 2020
COGS
%
%
%
%
Input
Related supplier
Input valuation as recorded in the firm’s accounting books and records:
III‐8. Inputs purchased from related suppliers.‐‐Please confirm that the inputs purchased from
related suppliers, as identified in III‐7, are reported in III‐9a (financial results on chassis) in a
manner consistent with your firm’s accounting books and records.
Yes
No
If no‐‐In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III‐9a.
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 30
III‐9a. Operations on chassis.‐‐Report the revenue and related cost information requested below on
the chassis operations of your firm’s U.S. establishment(s).1 Do not report resales of products.
Note that internal consumption and transfers to related firms must be valued at fair market
value. Input purchases from related suppliers should be consistent with and based on
information in the firm’s accounting books and records. Provide data for the specified calendar
years.
Quantity (in units) and value (in $1,000)
Calendar year
Item
2018
2019
2020
2
Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Internal consumption
Transfers to related firms
Total net sales values
0
0
0
Direct labor
Other factory costs
0
0
0
0
0
0
0
0
0
All other expense items
All other income items
0
0
0
Total net sales quantities
2
Net sales values:
Commercial sales
3
Cost of goods sold (COGS):
Raw materials
Total COGS
Gross profit or (loss)
Selling, general, and administrative (SG&A)
expenses
Operating income (loss)
Other expenses and income:
Interest expense
Net income or (loss) before income taxes
Depreciation/amortization included above
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2 Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), and net income (or loss)) have been
calculated from the data submitted in the other line items. Do the calculated fields return the
correct data according to your firm's financial records ignoring non‐material differences that
may arise due to rounding?
Yes
No
If no‐‐If the calculated fields do not show the correct data, please double
check the feeder data for data entry errors and revise. Also, check signs
accorded to the post operating income line items; the two expense line
items should report positive numbers (i.e., expenses are positive and
incomes or reversals are negative‐‐instances of the latter should be rare in
those lines) while the income line item also in most instances should have
its value be a positive number (i.e., income is positive, expenses or reversals
are negative). If after reviewing and potentially revising the feeder data
your firm has provided, the differences between your records and the
calculated fields persist please identify and discuss the differences in the
space below.
III‐9c. Raw materials.‐‐Please report the share of total raw material costs in 2020 (reported in III‐9a)
for the following raw material inputs:
Procurement method
Share of total raw
material costs
(percent)
Input
Steel for fabrication
1
Fabricated steel components
Primarily
purchased by
your firm
Primarily
produced by
your firm
1
1
Electrical components
Other material inputs2
Running gear components
Landing gear components
1
Total (should sum to 100 percent)
1
0.0
“Fabricated steel components,” “Running gear components,” “Landing gear components,” “Electrical
components,” refer to parts that may require further conversion. If the relevant item is purchased in
completed form ready for installation with minimal to no additional conversion necessary, “Primarily
purchased by your firm” would generally be the appropriate classification.
2
Please indicate any other notable "other" raw materials not expressly identified above and provide
the share of the total raw material costs that they account for: .
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 32
III‐10. Nonrecurring items (charges and gains) included in chassis 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 $1,000), as reflected in question III‐9a; i.e., if
an aggregate nonrecurring item has been allocated to question III‐9a, only the allocated value
amount included in question III‐9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in question III‐9a.
Calendar year
Item
2018
2019
2020
Value ($1,000)
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported
above and indicate the specific line item in table III‐9a where the nonrecurring item is classified.
Description of the
Income statement classification of the
nonrecurring item
nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
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III‐12a. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of chassis. If your firm does not maintain some or all of
the specific asset information necessary to calculate total assets for chassis 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 the specified calendar 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 $1,000)
Item
Calendar year
2018
Total assets (net)
2019
2020
III‐12b. Description of reported assets.‐‐Please 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‐13a. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for chassis. Provide data for the
specified calendar years.
Value (in $1,000)
Calendar year
Item
Capital expenditures
2018
Research and development
expenses
2019
2020
III‐13b. Description of reported capital expenditures.‐‐ Please describe the nature, focus, and
significance of your firm’s reported capital expenditures in the above response. In your
response, please specify the extent to which reported capital expenditures reflect capitalized
maintenance, as well capital expenditures to increase capacity and foster growth in operations.
Please quantify amounts (i.e., capitalized maintenance versus capital expenditures to increase
capacity and foster growth in operations) if this information can be provided meaningfully. If no
capital expenditure data were reported, please explain the reason.
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Page 34
III‐13c. Description of reported R&D expenses.‐‐ Please describe the nature, focus, and significance of
your firm’s reported R&D expenses in the above response. If no R&D expenses were reported,
please explain the reason.
III‐14. Data consistency and reconciliation.‐‐ Please confirm that your firm’s financial data for
questions III‐9a, 12a, and 13a are reported on a calendar year basis:
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments).
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in Part II equal the quantities and values reported for total net sales in Part III of this
questionnaire in each time period. If the calculated fields below return values other than zero (i.e., “0”)
and both are being reported on a calendar basis, please explain the discrepancy below.
Calendar year
Reconciliation
2018
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").
2019
0
Value: Trade data from question II‐7
(lines E, G, I, and K) less financial
total net sales value data from
question III‐9a, = zero ("0").
0
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
2020
0
0
0
0
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
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III‐15. Effects of imports on investment.‐‐Since January 1, 2020, 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 chassis from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Cancellation,
postponement, or
rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
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III‐16. Effects of imports on growth and development.‐‐Since January 1, 2020, 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 chassis from China?
No
Yes
If yes, my firm has experienced actual negative effects as follows.
(check as many as appropriate)
(please describe)
Rejection of bank loans
Lowering of credit rating
Problem related to the
issue of stocks or bonds
Ability to service debt
Other
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Page 37
III‐17. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
chassis from China?
No
Yes
If yes, my firm anticipates negative effects as follows.
III‐18. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 38
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Benedetto (202‐205‐
3270; [email protected]).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in Part IV.
Name
Title
Email
Telephone
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2018 of the following products produced by your
firm.
Product 1.‐‐tandem axle gooseneck chassis for carriage of 53’ domestic containers, without PSI
tire inflation system, with steel wheels, and with mechanic suspension
Product 2.‐‐tandem axle gooseneck chassis for carriage of 40’ ISO containers, without PSI tire
inflation system, with steel wheels, and with mechanic suspension
Product 3.‐‐extendable tandem axle chassis for carriage of 20’ ISO containers, without PSI tire
inflation system, with steel wheels, and with mechanic suspension
Product 4.‐‐ triaxle chassis capable of extension for carriage of heavy 20’ up to 40’ containers,
without PSI tire inflation system, with steel wheels, and with mechanic suspension
Product 5.‐‐ specialty chassis for carriage of 20’ storage tanks, without PSI tire inflation system,
with steel wheels, and with mechanic suspension
Product 6.‐‐tandem axle gooseneck chassis for carriage of 40’ ISO containers, with PSI tire
inflation system, with steel wheels, and with mechanic suspension
Product 7.‐‐ tandem axle gooseneck chassis for carriage of 53’ domestic containers, with PSI tire
inflation system, with steel wheels, and with mechanic suspension
Product 8.‐‐ triaxle chassis capable of extension for carriage of heavy 20’ up to 40’ containers,
with PSI tire inflation system, with steel wheels, and with mechanic suspension
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 also be net of (i.e., excluding) Federal Excise Tax. 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 2018‐December 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)?
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Yes.‐‐Please complete the following pricing data table as appropriate.
No.‐‐Skip to question IV‐3.
Page 39
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 40
IV‐2b. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 1
Product 2
Product 3
Product 4
Period of shipment Quantity
Value
Quantity
Value
Quantity
Value
Quantity
Value
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
October‐
December
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. Values should also
be net of (i.e., excluding) Federal Excise Tax.
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 ‐ Chassis (Final)
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IV‐2b. Price data (Continued).
Report data in units and actual dollars (not 1,000s).
(Quantity in units, value in dollars)
Product 5
Product 6
Product 7
Product 8
Period of shipment Quantity
Value
Quantity
Value
Quantity
Value
Quantity
Value
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
October‐
December
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. Values should also
be net of (i.e., excluding) Federal Excise Tax.
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 5:
Product 6:
Product 7:
Product 8:
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 42
IV‐2c. Price data checklist.‐‐Please check that the pricing data in question IV‐2(b) has been correctly
reported.
Are the price data reported above:
√ if Yes
In actual dollars (not $1,000) and units?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates, and Federal excise tax?
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. Remack sales.‐‐Please estimate the share of your firm’s sales of each pricing product for which
your customers provided components (“remack” sales) in 2020.
Share of 2020 sales for
Describe
which your customers
Pricing product
provided components
Pricing product 1
%
Pricing product 2
%
Pricing product 3
%
Pricing product 4
%
Pricing product 5
%
Pricing product 6
%
Pricing product 7
%
Pricing product 8
%
IV‐2e. 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 ‐ Chassis (Final)
IV‐3.
Page 43
Price setting.‐‐How does your firm determine the prices that it charges for sales of
chassis (check all that apply)? If your firm issues price lists, please submit sample pages
of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of domestic chassis usually quoted (check
one)?
Delivered
F.o.b.
IV‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced
chassis in 2020 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 2020
sales
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
IV‐7.
Page 44
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced chassis (or check “not applicable” if your firm does not sell on a short‐term,
annual and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used: .
IV‐8.
Lead times.‐‐What share of your firm’s sales is from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.‐produced chassis?
Lead time (Average
Source
Share of 2020 sales number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
IV‐9.
Page 45
Shipping information.‐‐
(a)
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of chassis that are delivered
the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 500 miles
%
501 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 chassis since January 1, 2018 (check all that apply)?
Geographic area
2018
2019
2020
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
chassis that is accounted for by U.S. inland transportation costs? percent
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 46
IV‐12. End uses.‐‐List the end uses of the chassis that your firm manufactures. For each end‐use
product or service, what percentage of the total cost is accounted for by chassis and other
inputs?
Share of total cost of end use product or
service accounted for by
Total
(should sum to
End‐use product or
100.0% across)
service
Chassis
Other inputs
%
%
0.0 %
%
%
0.0 %
%
%
IV‐13. Substitutes.‐‐Can other products be substituted for chassis?
No
Yes‐‐Please fill out the table.
0.0 %
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for chassis?
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 chassis has changed since January 1, 2018. Explain any trends and describe
the principal factors that have affected these changes in demand.
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Market
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 chassis since January 1, 2018?
No
Yes
If yes, please describe and quantify if possible.
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 47
IV‐16. Conditions of competition.‐‐
(a) Is the chassis market subject to business cycles and/or other conditions of competition
distinctive to chassis? 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
chassis since January 1, 2018?
No
Yes
If yes, describe.
IV‐17. Supply constraints and order size.—
(a) Has your firm refused, declined, or been unable to supply chassis since January 1, 2018
(examples include placing customers on allocation or “controlled order entry,” declining to
accept new customers or renew existing customers, delivering less than the quantity
promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
(b) Is your firm unable or unwilling to supply some purchasers due to the size of their orders?
No
Yes
If yes, please describe.
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 48
IV‐18. Raw materials.—
(a) How have chassis raw material costs changed since January 1, 2018?
Factor
Overall
increase
Cost of raw materials
No
change
Explain, noting how raw
Fluctuate material price changes have
Overall with no clear affected your firm’s selling
prices for chassis.
trend
decrease
(b) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact raw material costs for chassis?
Factor
Overall increase
Cost of raw materials after
section 232 tariffs imposed
No change
Fluctuate with
Overall decrease no clear trend
(c) How did the imposition of tariffs under section 232 on imported steel/aluminum products
impact your firm’s sales price for chassis?
Factor
Prices for chassis
Fluctuate
Overall
Overall
with no
Increase No change Decrease clear trend
Explanation
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 49
IV‐19. Interchangeability.‐‐Are chassis produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing chassis that is sometimes or never interchangeable, identify the
country‐pair and explain the factors that limit or preclude interchangeable use:
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 50
IV‐20. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between chassis produced in the
United States and in other countries a significant factor in your firm’s sales of the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant factor
in your firm’s sales of chassis, identify the country‐pair and report the advantages or disadvantages
imparted by such factors:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 51
IV‐21. Impact of section 301 tariffs.‐‐ Did the imposition of tariffs on Chinese‐origin products under
section 301 have an impact on the chassis market in the United States?
Yes— Please indicate the
impact in the table below,
indicating in particular the
impact in 2018, if different
from other years.
No
Don’t know
Factor
Explain, noting how the imposition
Fluctuate of tariffs under section 301 affected
with no each factor of the chassis market in
the United States (or for the last
clear
Overall
No
Overall
row, your firm’s production).
trend
increase change decrease
Supply of U.S.‐
produced chassis
Supply of chassis
imported from China
Supply of chassis
imported from other
countries
Prices for chassis
Overall U.S. demand
for chassis
Raw material costs for
chassis
Your firm’s production
of chassis
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 52
IV‐22. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for chassis since January 1, 2018. Indicate the share of the quantity of your firm’s
total shipments of chassis that each of these customers accounted for in 2020.
Customer’s name
City
State
Share of 2020 sales
(%)
1
2
3
4
5
6
7
8
9
10
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 53
IV‐23. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2018: To avoid losing sales to competitors selling
chassis from China did your firm:
Item
No
Yes
(b)
Reduce prices
Roll back announced price increases
Lost sales.‐‐Since January 1, 2018: Did your firm lose sales of chassis 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.
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U.S. Producers’ Questionnaire ‐ Chassis (Final)
Page 54
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at: LINK
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: CHAS
• E‐mail.—E‐mail the MS Word questionnaire to Ahdia Bavari ([email protected]); include a
scanned copy of the signed certification page (page 1). Submitters are strongly encouraged to encrypt
nonpublic documents that are electronically transmitted to the Commission to protect your sensitive
information from unauthorized disclosure. The USITC secure drop‐box system and the Electronic
Document Information System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2
cryptographic algorithms to encrypt data in transit. Submitting your nonpublic documents by a means
that does not use these encryption algorithms (such as by email) may subject your firm’s nonpublic
information to unauthorized disclosure during transmission. If you choose a non‐encrypted method of
electronic transmission, the Commission warns you that the risk of such possible unauthorized disclosure
is assumed by you and not by the Commission.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - US producers--Chassis (F) |
| Author | ahdia.bavari |
| File Modified | 2020-12-29 |
| File Created | 2020-12-29 |