09-1-2793 US producer questionnaire

OMB No. 3117-0016/USITC No. 10-1-2793; Expiration Date: 6/30/2011
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN SEAMLESS CARBON AND ALLOY STEEL STANDARD,
LINE, AND PRESSURE PIPE FROM CHINA

This questionnaire must be received by the Commission by no later than SEPTEMBER 30, 2009
See page 4 of the Instruction Booklet 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 seamless carbon and alloy steel
standard, line, and pressure pipe (“seamless SLP pipe”) from China (Inv. Nos. 701-TA-469 and 731-TA-1168
(Preliminary)). 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 possession (19 U.S.C. § 1333(a)).

Name of firm
Address
State

City

Zip Code

World Wide Web address
Has your firm produced seamless SLP pipe (as defined in the instruction booklet) at any time since January 1,
2006?

NO

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

YES

(Read the instruction booklet carefully, complete all parts of the questionnaire, and return the entire
questionnaire to the Commission so as to be received by the date indicated above)

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 these investigations in any other import-injury investigations conducted
by the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout these investigations may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of these investigations or related proceedings for which this information is submitted, or in internal audits
and investigations relating to the programs and operations of the Commission pursuant to 5 U.S.C. Appendix 3. I understand that
all contract personnel will sign non-disclosure agreements.

Name of Authorized Official

Title of Authorized Official
Phone: (

Date

)

Signature

E-mail address
Fax (

)

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U.S. Producers’ Questionnaire - Seamless SLP Pipe (Preliminary)

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PART I.—GENERAL INFORMATION
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, searching existing data sources, gathering the data needed,
and completing and reviewing the questionnaire. Send comments regarding the accuracy of this burden
estimate or any other aspect of this collection of information, including suggestions for reducing the
burden, to the Office of Investigations, U.S. International Trade Commission, 500 E Street, SW,
Washington, DC 20436.
I-1a.

Please report below the actual number of hours required and the cost to your firm of preparing the
reply to this questionnaire and completing the form.
hours

dollars

I-1b.

We are interested in any comments you may have for improving this questionnaire in general or
the clarity of specific questions. Please attach such comments to your response or send them to
the above address.

I-2.

Provide the name and address of establishment(s) covered by this questionnaire (see page 3 of the
instruction booklet for reporting guidelines). If your firm is publicly traded, please specify the
stock exchange and trading symbol.
SMALL DIAMETER:

LARGE DIAMETER:

I-3.

Do you support or oppose the petition?
Support

Oppose

Take no position

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U.S. Producers’ Questionnaire - Seamless SLP Pipe (Preliminary)

Page 3

PART I.--GENERAL INFORMATION--Continued
I-4.

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

Firm name

I-5a.

Firm name

Extent of
ownership

Yes--List the following information
Address

Affiliation

Does your firm have any related firms, either domestic or foreign, which are engaged in
importing seamless SLP pipe of greater than 4.5 inches up to and including 16.0 inches
outside diameter (“large diameter” or “large OD”) from China into the United States or which
are engaged in exporting large diameter seamless SLP pipe from China to the United States?
No
Firm name

I-6.

Address

Does your firm have any related firms, either domestic or foreign, which are engaged in
importing seamless SLP pipe of 4.5 inches or less outside diameter (“small diameter” or “small
OD”) from China into the United States or which are engaged in exporting small diameter
seamless SLP pipe from China to the United States?
No

I-5b.

Yes--List the following information

Yes--List the following information
Address

Affiliation

Does your firm have any related firms, either domestic or foreign, which are engaged in the
production of seamless SLP pipe?
No
Firm name

Yes--List the following information
Address

Affiliation

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U.S. Producers’ Questionnaire - Seamless SLP Pipe (Preliminary)

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PART III.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Joanna Lo (202-205-1888,
joanna.lo@usitc.gov). Supply all data requested on a calendar-year basis.
II-1.

Who should be contacted regarding the requested trade and related information?
Company contact:
Name and title
(
)
Phone number

II-2.

Has your firm experienced any plant openings, relocations, expansions, acquisitions,
consolidations, closures, or prolonged shutdowns because of strikes or equipment failure;
curtailment of production because of shortages of materials; or any other change in the character
of your operations or organization relating to the production of seamless SLP pipe since January
1, 2006?
No

II-3.

E-mail address

Yes--Supply details as to the time, nature, and significance of such changes,
and whether they related to small diameter or large diameter seamless SLP
pipe.

Does your firm produce other products on the same equipment and machinery used in the
production of seamless SLP pipe?
No

Yes--List the following information.

Basis for allocation of capacity data (e.g., production):
Products produced on same equipment and share of total production in 2008 (in percent):
Product
SMALL diameter seamless SLP pipe
LARGE diameter seamless SLP pipe

Percent

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-3.

Continued.-Report all of your seamless pipe (including nonsubject seamless pipe) produced on the same
equipment:
Quantity (in short tons)
Calendar years
Item

2006

2007

January-June
2008

2008

2009

Average production capacity
Small diameter seamless pipe
Large diameter seamless pipe
Over 16 inches seamless pipe
TOTAL seamless SLP pipe
Production of small diameter pipe (4.5 inches or less OD):
Standard, line & pressure pipe
OCTG
Boiler tubing
Mechanical tubing
Other tubing:_______________________
Total
Production of large diameter pipe (over 4.5 inches to 16.0 inches OD):
Standard, line & pressure pipe
OCTG
Boiler tubing
Mechanical tubing
Other tubing:_______________________
Total
Production of all seamless pipe greater than
16 inches in OD:
Total production (all products)
Reconciliation of data.–Please note that the production reported above for standard, line, & pressure pipe should equal data
reported in II-9a, II-9b, and II-9c.

II-4.

Please describe the constraint(s) that set the limit(s) on your production capacity and your ability
to shift production capacity between products.

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-5.

Does your firm produce other products using the same production and related workers employed
to produce seamless SLP pipe?
No

Yes--List the following information.

Basis for allocation of capacity data (e.g., sales):
Products produced using the same workers and share of total production in 2006 (in percent):
Product

Percent

Small diameter seamless SLP pipe
Large diameter seamless SLP pipe

II-6.

Since January 1, 2006, has your firm been involved in a toll agreement (see definition in the
instruction booklet) regarding the production of seamless SLP pipe?
No

II-7.

.

Does your firm produce seamless SLP pipe in a foreign trade zone (FTZ)?
No

II-8.

Yes--Name firm(s):

Yes--Identify FTZ(s):

Since January 1, 2006, has your firm imported seamless SLP pipe?
No

Yes--COMPLETE AND RETURN A U.S. IMPORTERS’
QUESTIONNAIRE

.

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-9a.

Report your firm’s production capacity, production, shipments, inventories, and employment
related to the production of SMALL DIAMETER seamless SLP pipe only in your U.S.
establishment(s) during the specified periods. (See definitions in the instruction booklet.)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2006

2007

January-June
2008

2008

2009

1

Average production capacity (quantity)
Beginning-of-period inventories (quantity)
Production (quantity)
U.S. shipments:
Commercial shipments:
Quantity of commercial shipments
Value of commercial shipments
Internal consumption:
Quantity of internal consumption
Value2 of internal consumption
Transfers to related firms:
Quantity of transfers
Value2 of transfers
Export shipments:3
Quantity of export shipments
Value of export shipments
End-of-period inventories4 (quantity)
Channels of distribution:
U.S. shipments to distributors (quantity)
U.S. shipments to end users (quantity)
Employment data:
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs (value)
1

The production capacity (see definitions in instruction booklet) 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 (use additional pages as necessary).
2

Internal consumption and transfers to related firms must be valued at fair market value. In the event that you use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data
using that basis for each of the periods noted above:
3

Identify your principal export markets:
.
Reconciliation of data.--Please note that the quantities reported above should reconcile as follows: beginning-of-period
inventories, plus production, less total shipments, equals end-of-period inventories. Do the data reported reconcile?
4

Yes

No--Please explain:

.

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-9b.

Report your firm’s production capacity, production, shipments, inventories, and employment
related to the production of LARGE DIAMETER seamless SLP pipe only in your U.S.
establishment(s) during the specified periods. (See definitions in the instruction booklet.)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2006

2007

January-June
2008

2008

2009

1

Average production capacity (quantity)
Beginning-of-period inventories (quantity)
Production (quantity)
U.S. shipments:
Commercial shipments:
Quantity of commercial shipments
Value of commercial shipments
Internal consumption:
Quantity of internal consumption
Value2 of internal consumption
Transfers to related firms:
Quantity of transfers
Value2 of transfers
Export shipments:3
Quantity of export shipments
Value of export shipments
End-of-period inventories4 (quantity)
Channels of distribution:
U.S. shipments to distributors (quantity)
U.S. shipments to end users (quantity)
Employment data:
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs (value)
1

The production capacity (see definitions in instruction booklet) 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 (use additional pages as necessary).
2

Internal consumption and transfers to related firms must be valued at fair market value. In the event that you use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data
using that basis for each of the periods noted above:
3

Identify your principal export markets:
.
Reconciliation of data.--Please note that the quantities reported above should reconcile as follows: beginning-of-period
inventories, plus production, less total shipments, equals end-of-period inventories. Do the data reported reconcile?
4

Yes

No--Please explain:

.

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U.S. Producers’ Questionnaire - Seamless SLP Pipe (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-9c.

Report your firm’s production capacity, production, shipments, inventories, and employment
related to the production of TOTAL seamless SLP pipe (including both small and large
diameter SLP pipe) in your U.S. establishment(s) during the specified periods. (See definitions
in the instruction booklet.) This table should be the sum of II-9a and II-9b.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2006

2007

January-June
2008

2008

2009

1

Average production capacity (quantity)
Beginning-of-period inventories (quantity)
Production (quantity)
U.S. shipments:
Commercial shipments:
Quantity of commercial shipments
Value of commercial shipments
Internal consumption:
Quantity of internal consumption
Value2 of internal consumption
Transfers to related firms:
Quantity of transfers
Value2 of transfers
Export shipments:3
Quantity of export shipments
Value of export shipments
End-of-period inventories4 (quantity)
Channels of distribution:
U.S. shipments to distributors (quantity)
U.S. shipments to end users (quantity)
Employment data:
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs (value)
1

The production capacity (see definitions in instruction booklet) 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 (use additional pages as necessary).
2

Internal consumption and transfers to related firms must be valued at fair market value. In the event that you use a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data
using that basis for each of the periods noted above:
3

Identify your principal export markets:
.
Reconciliation of data.--Please note that the quantities reported above should reconcile as follows: beginning-of-period
inventories, plus production, less total shipments, equals end-of-period inventories. Do the data reported reconcile?
4

Yes

No--Please explain:

.

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Page 10

PART II.--TRADE AND RELATED INFORMATION--Continued
II-10.

If you reported transfers to related firms in question II-9, please 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-11a. Other than direct imports, has your firm otherwise purchased SMALL DIAMETER seamless
SLP pipe since January 1, 2006? (See definitions in the instruction booklet.)
Yes--Report such purchases below for the specified periods.1

No

(Quantity in short tons, value in $1,000)
Calendar years
Item

2006

2007

January-June
2008

2008

2009

PURCHASES FROM U.S. IMPORTERS2 OF SMALL DIAMETER SEAMLESS SLP PIPE FROM-CHINA:
Quantity
Value
ALL OTHER COUNTRIES:
Quantity
Value
PURCHASES FROM DOMESTIC PRODUCERS:2
Quantity
Value
PURCHASES FROM OTHER SOURCES:2
Quantity
Value
1

Please indicate your reasons for purchasing this product. If your reasons differ by source, please elaborate.

2
Please list the name of the firm(s) from which you purchased this product. If your suppliers differ by source,
please identify the source for each listed supplier.

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-11b. Other than direct imports, has your firm otherwise purchased LARGE DIAMETER seamless
SLP pipe since January 1, 2006? (See definitions in the instruction booklet.)
Yes--Report such purchases below for the specified periods.1

No

(Quantity in short tons, value in $1,000)
Calendar years
Item

2006

2007

January-June
2008

2008

2009

2

PURCHASES FROM U.S. IMPORTERS OF LARGE DIAMETER SEAMLESS SLP PIPE FROM-CHINA:
Quantity
Value
ALL OTHER COUNTRIES:
Quantity
Value
PURCHASES FROM DOMESTIC PRODUCERS:2
Quantity
Value
PURCHASES FROM OTHER SOURCES:2
Quantity
Value
1

2

Please indicate your reasons for purchasing this product. If your reasons differ by source, please elaborate.

Please list the name of the firm(s) from which you purchased this product. If your suppliers differ by source,
please identify the source for each listed supplier.

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-12a. Please report the quantity of SMALL DIAMETER seamless SLP pipe that was entered into your
firm’s “order books” at the close of the specified months (i.e., SMALL DIAMETER seamless
SLP pipe that had been purchased or arranged for purchase and which was on your firm’s
production schedule at a specified period of time). Please also report the average lead time for
orders placed at the close of the specified months.
Date
2006:
March 31
June 30
September 30
December 31
2007:
March 31
June 30
September 30
December 31
2008:
March 31
June 30
September 30
December 31
2009:
March 31
June 30

Quantity (in short tons)

Lead time (in days)

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U.S. Producers’ Questionnaire - Seamless SLP Pipe (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-12b. Please report the quantity of LARGE DIAMETER seamless SLP pipe that was entered into your
firm’s “order books” at the close of the specified months (i.e., LARGE DIAMETER seamless
SLP pipe that had been purchased or arranged for purchase and which was on your firm’s
production schedule at a specified period of time). Please also report the average lead time for
orders placed at the close of the specified months.
Date
2006:
March 31
June 30
September 30
December 31
2007:
March 31
June 30
September 30
December 31
2008:
March 31
June 30
September 30
December 31
2009:
March 31
June 30

Quantity (in short tons)

Lead time (in days)

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U.S. Producers’ Questionnaire - Seamless SLP Pipe (Preliminary)

Page 14

PART II.--TRADE AND RELATED INFORMATION--Continued
II-13a. Please report the quantity of SMALL DIAMETER seamless SLP pipe that was entered into your
firm’s “order books” at the close of the specified months (i.e., SMALL DIAMETER seamless
SLP pipe that had been purchased or arranged for purchase and which was on your firm’s
production schedule at a specified period of time).
Date
2008:
January
February
March
April
May
June
July
August
September
October
November
December
2009:
January
February
March
April
May
June
July
August

Quantity (in short tons)

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-13b. Please report the quantity of LARGE DIAMETER seamless SLP pipe that was entered into your
firm’s “order books” at the close of the specified months (i.e., LARGE DIAMETER seamless
SLP pipe that had been purchased or arranged for purchase and which was on your firm’s
production schedule at a specified period of time).
Date
2008:
January
February
March
April
May
June
July
August
September
October
November
December
2009:
January
February
March
April
May
June
July
August

Quantity (in short tons)

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-14. COMPARABILITY OF SMALL DIAMETER AND LARGE DIAMETER SEAMLESS
SLP PIPE.–Since January 1, 2006, has your firm produced both small and large diameter seamless SLP
pipe?
No
Yes--Please describe the differences and similarities between small and large diameter seamless
SLP pipe with respect to the following factors: (a) characteristics and uses--describe the differences
and similarities in the physical characteristics and end uses; (b) interchangeability--discuss the
interchangeability in end use of the two products; (c) manufacturing processes--describe the two
processes and include a discussion of the interchangeability of production inputs, machinery and
equipment, and skilled labor; (d) channels of distribution--describe the specific end use/customer
requirements and channels of distribution/market situation in which the products are sold; (e) customer
and producer perceptions--describe any perceived differences in the two products (e.g., sales/marketing
practices); and (f) price--provide a discussion and specific examples of prices for the two products. Use
additional pages as necessary.
(a) Characteristics and uses:

(b) Interchangeability:

(c) Manufacturing processes:

(d) Channels of distribution:

(e) Customer and producer perceptions:

(f) Price:

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202-205-3432,
charles.yost@usitc.gov).
III-1.

Who should be contacted regarding the requested financial information?
Company contact:
Name and title
(
)
Phone number

III-2.

E-mail address

Briefly describe your financial accounting system.
A.

When does your fiscal year end (month and day)?
If your fiscal year changed during the period examined, explain below:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include subject merchandise:

2.
3.

4.

Does your firm prepare profit/loss statements for the subject merchandise:
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:
GAAP,
cash,
tax, or
other comprehensive
(specify)

Note: The Commission may request that your company submit copies of its financial statements,
including internal profit-and-loss statements for the division or product group that includes
seamless SLP pipe, as well as those statements and worksheets used to compile data for your
firm’s questionnaire response.

III-3.

Briefly describe your cost accounting system (e.g., standard cost, job order cost, etc.).

III-4.

Briefly describe your allocation basis, if any, for COGS, SG&A, and interest expense and other
income and expenses.

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PART III.--FINANCIAL INFORMATION--Continued
III-5.

Please list any products you produced in the facilities in which you produced seamless SLP pipe,
and provide the share of net sales accounted for by these other products in your most recent fiscal
year:
Products

Share of sales

Small diameter seamless SLP pipe
Large diameter seamless SLP pipe

III-6.

Does your firm receive inputs (raw materials, labor, energy, or any other services) used in the
production of seamless SLP pipe from any related firm?
Yes—Continue to question III-7 below.

III-7.

In the space provided below, identify the inputs related to the production of seamless SLP pipe
that your firm receives from related parties whose financial statements are consolidated with the
financial statements of your firm.
Input

III-8.

No--Continue to question III-10 below.

Related party

With respect to the related companies identified in response to question III-7 above, are their
financial statements consolidated with your firm’s financial statements? (In other words, are
profits or losses arising from intercompany transactions eliminated?
Yes—Continue to question III-9 below.

No--Continue to question III-10 below.

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PART III.--FINANCIAL INFORMATION--Continued
III-9.

All intercompany profit on inputs purchased from related parties that is eliminated pursuant to
formal financial statement consolidation should also be eliminated from the costs reported to the
Commission in question III-11 (i.e., costs reported in question III-11, to the extent that they
reflect inputs purchased from related parties, should only reflect the related party’s cost and not
include an associated profit component). Reasonable methods for determining and eliminating
the associated profit on inputs purchased from related parties are acceptable.
Has your firm complied with the Commission’s instructions regarding costs associated with
inputs purchased from related parties?
Yes

No—Please contact Charles Yost (202-205-3432, charles.yost@usitc.gov).

III-10. Nonrecurring charges.--For each annual and interim period for which financial results are
reported in question III-11a, please indicate in the schedule below the specific nonrecurring
charges, the particular expense/cost line items from question III-11 where the associated charges
are included, a brief description of the charges, and the associated values (in $1,000).
Nonrecurring charges would include, but are not limited to, items such as asset write-offs and
accelerated depreciation due to restructuring of the company’s total seamless SLP pipe
operations.
Fiscal years ended-Item
Non-recurring charges: (In this column please
provide a brief description of each nonrecurring
charge and indicate the particular expense/cost line
items where the associated charges are classified in
question III-11a.)
1.
2.
3.
4.
5.
6.
7.

January-June
2008

2009

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PART III.--FINANCIAL INFORMATION--Continued
III-11a. Operations on TOTAL SEAMLESS SLP PIPE.--Report the revenue and related cost
information requested below on the total seamless SLP pipe operations of your 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 and purchases from related firms
must be at cost.2 Provide data for your three most recently completed fiscal years in
chronological order from left to right, and for the specified interim periods. If your firm was
involved in tolling operations (either as the toller or as the tollee) please contact Charles Yost at
(202) 205-3432 before completing this section of the questionnaire. Please provide breakouts for
your firm’s operations on small and large diameter seamless SLP pipe in tables III-11b and III11c, respectively. The sum of the breakouts should reconcile to the total.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

January-June
2008

2009

Net sales quantities:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):4
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other income and expenses:
Interest expense
All other expense items
All other income items
All other income or expenses, net
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.
Please list the expense categories and amounts of any profits on internal inputs or inputs from related firms that are reflected on
your books but which are eliminated from the costs reported below.
3
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.
4
COGS should include costs associated with internal consumption and transfers to related firms.
2

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PART III.--FINANCIAL INFORMATION--Continued
III-11b. Operations on SMALL DIAMETER SEAMLESS PIPE.--Report the revenue and related cost
information requested below on the total seamless SLP pipe operations of your 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 and purchases from related firms
must be at cost.2 Provide data for your three most recently completed fiscal years in
chronological order from left to right, and for the specified interim periods. If your firm was
involved in tolling operations (either as the toller or as the tollee) please contact Charles Yost at
(202) 205-3432 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

January-June
2008

2009

Net sales quantities:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):4
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Please list the expense categories and amounts of any profits on internal inputs or inputs from related firms that are reflected on
your books but which are eliminated from the costs reported below.
3
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.
4
COGS should include costs associated with internal consumption and transfers to related firms.
2

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PART III.--FINANCIAL INFORMATION--Continued
III-11c. Operations on LARGE DIAMETER SEAMLESS SLP PIPE.--Report the revenue and related
cost information requested below on the total seamless SLP pipe operations of your 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 and purchases from related firms
must be at cost.2 Provide data for your three most recently completed fiscal years in
chronological order from left to right, and for the specified interim periods. If your firm was
involved in tolling operations (either as the toller or as the tollee) please contact Charles Yost at
(202) 205-3432 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

January-June
2008

2009

Net sales quantities:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales quantities
Net sales values:3
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):4
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)
Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Please list the expense categories and amounts of any profits on internal inputs or inputs from related firms that are reflected on
your books but which are eliminated from the costs reported below.
3
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.
4
COGS should include costs associated with internal consumption and transfers to related firms.
2

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PART III.--FINANCIAL INFORMATION--Continued
III-12. Variable and fixed costs.—For each category of costs reported in III-11b and III-11c, please
provide a breakdown between variable and fixed costs for 2008 in PERCENT as follows:
In percent (%)
Cost category

Variable costs

Fixed costs

Total

Small diameter seamless SLP pipe:
Raw materials

100.0%

Direct labor

100.0%

Other factory costs

100.0%

SG&A expenses

100.0%

Large diameter seamless SLP pipe:
Raw materials

100.0%

Direct labor

100.0%

Other factory costs

100.0%

SG&A expenses

100.0%

III-13. Asset values.--Report the total assets associated with the production, warehousing, and sale of
total seamless SLP pipe (table III-11a). If your firm does not maintain some or all of the
specific asset data in the normal course of business, please estimate it based upon some rational
method (such as production, sales, or costs) that is consistent with your cost allocations in the
previous question. Your finished goods inventory value should reconcile with the inventory
quantity data reported in Part II. Provide data as of the end of your three most recently completed
fiscal years in chronological order from left to right.
Fiscal years ended-Item
Assets associated with the production,
warehousing, and sale of product:
1. Current assets:
A. Cash and equivalents
B. Accounts receivable, net
C. Inventories (finished goods)
D. Inventories (raw materials and work in
process)
E. All other (describe:

)

F. Total current assets (lines 1.A. through 1.E.)
2. Property, plant, and equipment
A. Original cost of property, plant, and equipment
B. Less: Accumulated depreciation
C. Equals: Book value of property, plant, and
equipment
3. All other (describe:

)

4. Total assets (lines 1.F., 2.C., and 3)

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PART III.--FINANCIAL INFORMATION--Continued
III-14. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on seamless SLP pipe. Provide data for
your three most recently completed fiscal years in chronological order from left to right, and for
the specified interim periods for total seamless SLP pipe, and breakouts for small diameter
seamless SLP pipe and large diameter seamless SLP pipe.
Value (in $1,000)
Fiscal years ended-Item

January-June
2008

Total seamless SLP pipe:
Capital expenditures
Research and development expenses
Small diameter seamless SLP pipe:
Capital expenditures
Research and development expenses
Large diameter seamless SLP pipe:
Capital expenditures
Research and development expenses

Please provide a description of the nature or focus of your firm’s capital expenditures:

Please provide a description of the nature or focus of your firm’s R&D expenses:

2009

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PART III.--FINANCIAL INFORMATION--Continued
III-15. Since January 1, 2006, has your firm experienced any actual negative effects on its return on
investment or its growth, investment, ability to raise capital, existing development and production
efforts (including efforts to develop a derivative or more advanced version of the product), or the
scale of capital investments as a result of imports of seamless SLP pipe from China?
No
Small OD

Yes--My firm has experienced actual negative effects as follows:
Large OD
Cancellation, postponement, or rejection of expansion projects
Denial or rejection of investment proposal
Reduction in the size of capital investments
Rejection of bank loans
Lowering of credit rating
Problem related to the issue of stocks or bonds
Other (specify)

III-16a. Does your firm anticipate any negative impact of imports of small diameter seamless SLP pipe
from China?

III-16b. Does your firm anticipate any negative impact of imports of large diameter seamless SLP pipe
from China?

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Page 26

PART IV.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Clark Workman (202-2053248, clark.workman@usitc.gov)
IV-1.

Who should be contacted regarding the requested pricing and related information?
Company contact:
Name and title
(
)
Phone number

E-mail address

PRICE DATA
This section requests quarterly quantity and value data, f.o.b. your U.S. point of shipment, for your
commercial shipments to unrelated U.S. distributors during January 2006–June 2009 of the following
products produced by your firm.
Product 1.—Seamless pipe quad stenciled to meet ASTM A-106 grade B, ASTM A-53 grade
B, API 5L grade B, and API 5L grade X-42 specifications; 2” nominal size (2 3/8 inch OD x
0.154 wall thickness); plain ends.
Product 2.-- Seamless pipe quad stenciled to meet ASTM A-106 grade B, ASTM A-53 grade
B, API 5L grade B, and API 5L grade X-42 specifications; 4” nominal size (4 1/2 inch OD x
0.237 wall thickness); plain ends.
Product 3.-- Seamless pipe quad stenciled to meet ASTM A-106 grade B, ASTM A-53 grade
B, API 5L grade B, and API 5L grade X-42 specifications; 8” nominal size (8 5/8 inch OD x
0.322 wall thickness); plain ends.
Product 4.-- Seamless pipe quad stenciled to meet ASTM A-106 grade B, ASTM A-53 grade
B, API 5L grade B, and API 5L grade X-42 specifications; 12” nominal size (12 3/4 inch OD
x 0.375 wall thickness); plain ends.
Please note that total dollar values should be f.o.b., U.S. point of shipment and should not include
U.S.-inland transportation costs. Total dollar values should reflect the final net amount paid to you
(i.e., should be net of all deductions for discounts or rebates). See instruction booklet.

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-2a. Report below the quarterly price data1 for pricing products2 produced and sold by your firm.

Period of shipment

(Quantity in short tons, value in dollars)
Product 1
Quantity
Value

2006
January-March
April-June
July-September
October-December
2007
January-March
April-June
July-September
October-December
2008
January-March
April-June
July-September
October-December
2009
January-March
April-June
Period of shipment

Product 2
Quantity

Product 3
Quantity

Value

Product 4
Value

Quantity

Value
2006
January-March
April-June
July-September
October-December
2007
January-March
April-June
July-September
October-December
2008
January-March
April-June
July-September
October-December
2009
January-March
April-June
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 U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your product:
Product 1:
Product 2:
Product 3:
Product 4:

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PART IV.--PRICING AND RELATED INFORMATION--Continued
Note: If your responses in this section differ by pipe diameters, please indicate and
elaborate upon the differences.
IV-3.

Please describe how your firm determines the prices that it charges for sales of seamless SLP pipe
(transaction by transaction negotiation, contracts for multiple shipments, set price lists, etc.). If
your firm issues price lists, please include a copy of a recent price list with your submission. If
your price list is large, please submit sample pages.

IV-4.

Please describe your firm’s discount policy (quantity discounts, annual total volume discounts,
etc.).

IV-5.

What are your firm’s typical sales terms for its U.S.-produced seamless SLP pipe (e.g., 2/10 net
30 days)?
. On what basis are your prices of domestic seamless SLP pipe
usually quoted (e.g., f.o.b. warehouse, or delivered)?
.

IV-6.

Approximately what share of your firm’s sales of its U.S.-produced seamless SLP pipe in 2006
were on a (1) long-term contract basis (multiple deliveries for more than 12 months), (2) shortterm contract basis (multiple deliveries up to 12 months), and (3) spot sales basis (for a single
delivery)?
Type of sale
Long-term contracts
Short-term contracts
Spot sales

Share of sales (percent)

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-7.

IV-8.

IV-9.

If you sell on a long-term contract basis, please answer the following questions with respect to
provisions of a typical long-term contract.
(a)

What is the average duration of a contract?

(b)

Can prices be renegotiated during the contract period?

(c)

Does the contract fix quantity, price, or both?

(d)

Does the contract have a meet or release provision?

If you sell on a short-term contract basis, please answer the following questions with respect to
provisions of a typical short-term contract.
(a)

What is the average duration of a contract?

(b)

Can prices be renegotiated during the contract period?

(c)

Does the contract fix quantity, price, or both?

(d)

Does the contract have a meet or release provision?

What is the average lead time between a customer’s order and the date of delivery for your firm’s
sales of your imported seamless SLP pipe?
Share of sales,
Jan-June 2008

July-Dec 2008

Jan-June 2009

100 %

100 %

100 %

Jan-June 2008

July-Dec 2008

Jan-June 2009

100 %

100 %

100 %

Source
From
inventory
Produced
to order
Total

Lead time,

Source
From
inventory
Produced
to order
Total

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PART IV.--PRICING AND RELATED INFORMATION--Continued

IV-10. (a)

What is the approximate percentage of the total delivered cost of seamless SLP pipe that
is accounted for by U.S. inland transportation costs?
percent.

(b)

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

(c)

What proportion of your sales occur within 100 miles of your storage or production
facility?
percent. Within 101 to 1,000 miles?
percent. Over 1,000 miles?
percent.

IV-11. What is the geographic market area in the United States served by your firm’s seamless SLP
pipe? (check all that apply)
Northeast

Mid-Atlantic

Midwest

Southeast

Southwest

Rocky Mountains

West Coast

Northwest

National

Other (describe:

)

IV-12. Describe the end uses of the small diameter seamless SLP pipe that you manufacture. For each
end-use product, what percentage of the total cost is accounted for by seamless SLP pipe?
End use

Share of total cost (percent)

IV-13. Describe the end uses of the large diameter seamless SLP pipe that you manufacture. For each
end-use product, what percentage of the total cost is accounted for by seamless SLP pipe?
End use

Share of total cost (percent)

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-14. (a)

Can other products be substituted for seamless SLP pipe?
No

Yes--Please list these substitute products in order of importance.
Small diameter

Large diameter

(i)

_________________

_________________

(ii)

_________________

_________________

(iii)

_________________

_________________

(b)

For each possible substitute product, please give examples of applications and end uses
for which they are substitutes.

(c)

Have changes in the prices of these products affected the price for seamless SLP pipe?
No

Yes--To what degree do changes in their prices affect the price for
seamless SLP pipe? Does this effect have a time lag? If so, how long is
the time lag for each substitute product? Does this vary by size or type
of seamless SLP pipe or final end use?

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-15. How has the demand within the United States for seamless SLP pipe changed since January 1,
2006? What principal factors affect changes in demand?
(a)

Within the United States:

Small diameter
Large diameter
(b)

Increased
Increased

No change
No change

Decreased
Decreased

No change
No change

Decreased
Decreased

Outside the United States:

Small diameter
Large diameter
(c)

Increased
Increased

Please describe the ability of your firm to forecast and respond to the changes in demand
described above.

IV-16. Have there been any significant changes in the product range or marketing of seamless SLP pipe
since January 1, 2006?
No

Yes-- Please describe.

IV-17. Has your firm refused, declined, or been unable to supply seamless SLP pipe since January 1,
2006? (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,
unable to meet timely shipment commitments, etc.) With respect to timely shipments, your firm
may wish to refer to your firm’s lead time estimates reported in question IV-9.
No

Yes-- Please note and document the time period(s) (i.e., month and year),
country of origin, and the customer involved; and the amount and type of
product involved.

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-18. Is seamless SLP pipe produced in the United States and in other countries interchangeable (i.e.,
can they physically be used in the same applications)? Please indicate below, using “A” to
indicate that the products from a specified country-pair are always interchangeable, “F” to
indicate that the products are frequently interchangeable, “S” to indicate that the products are
sometimes interchangeable, “N” to indicate that the products are never interchangeable, and “0”
to indicate no familiarity with products from a specified country-pair.1 2
Country-pair

United States

China

Other countries

FOR SMALL DIAMETER-United States

China

Other countries
FOR LARGE DIAMETER-United States

China
Other countries
1

For any country-pair producing small diameter seamless SLP pipe which is sometimes or never
interchangeable, please explain the factors that limit or preclude interchangeable use:

2

For any country-pair producing large diameter seamless SLP pipe which is sometimes or never
interchangeable, please explain the factors that limit or preclude interchangeable use:

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-19. Are differences other than price (i.e., quality, availability, transportation network, product range,
technical support, etc.) between seamless SLP pipe produced in the United States and in other
countries a significant factor in your firm’s sales of the products? Please indicate below, using
“A” to indicate that such differences are always significant, “F” to indicate that such differences
are frequently significant, “S” to indicate that such differences are sometimes significant, “N” to
indicate that such differences are never significant, and “0” to indicate no familiarity with
products from a specified country-pair.1 2
Country-pair

United States

China

Other countries

FOR SMALL DIAMETER-United States

China

Other countries
FOR LARGE DIAMETER-United States

China
Other countries
1

For any country-pair producing small diameter seamless SLP pipe which is sometimes or never
interchangeable, please explain the factors that limit or preclude interchangeable use:

2

For any country-pair producing large diameter seamless SLP pipe which is sometimes or never
interchangeable, please explain the factors that limit or preclude interchangeable use:

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-20. Please identify below the names and addresses of your firm’s 10 largest customers for seamless
SLP pipe since 2006. Please also provide the name and telephone number of a contact person and
the share of the quantity of your firm’s total shipments of seamless SLP pipe that each of these
customers accounted for in 2008.

No.

1

2

3

4

5

6

7

8

9

10

Customer’s name

Street address (not P.O.
box), city, state, and zip
code

Contact person

Area
code and
telephone
number

Share of
2008
sales
(%)

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-20. COMPETITION FROM IMPORTS--LOST REVENUES.--THIS SECTION IS TO BE
COMPLETED ONLY BY NON-PETITIONERS. (Note: petitioners may provide allegations
involving quotes made AFTER the filing of the petition.)
Since January 1, 2006: To avoid losing sales to competitors selling seamless SLP pipe from
China, did your firm:
Reduce prices

No

Yes

Roll back announced price increases

No

Yes

If yes, please furnish as much of the following information as possible for each affected
transaction. Document such allegations of lost revenues whenever possible (documentation could
include copies of invoices, sales reports, or letters from customers). Please note that the
Commission may contact the firms named to verify the allegations reported.
Customer name, contact person, phone and fax numbers
Specific product(s) involved
Date of your initial price quotation
Quantity involved
Your initial rejected price quotation (total delivered value)
Your accepted price quotation (total delivered value)
The country of origin of the competing imported product
The competing price quotation of the imported product (total delivered value)
Customer name,
contact person,
phone and fax
numbers

Product

Date of
quote

Quantity
(short tons)

Initial
rejected U.S.
price (total
value-dollars)

Accepted
U.S. price
(total value-dollars)

Country of
origin

Competing
import price
(total
value—
dollars)

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PART IV.--PRICING AND RELATED INFORMATION--Continued
IV-21. COMPETITION FROM IMPORTS--LOST SALES.--THIS SECTION IS TO BE
COMPLETED ONLY BY NON-PETITIONERS. (Note: petitioners may provide allegations
involving quotes made AFTER the filing of the petition.)
Since January 1, 2006: Did your firm lose sales of seamless SLP pipe to imports of these
products from China?
No

Yes

If yes, please furnish as much of the following information as possible for each affected
transaction. Document such allegations of lost sales whenever possible (documentation could
include copies of invoices, sales reports, or letters from customers). Please note that the
Commission may contact the firms named to verify the allegations reported.
Customer name, contact person, phone and fax numbers
Specific product(s) involved
Date of your price quotation
Quantity involved
Your rejected price quotation (total delivered value)
The country of origin of the competing imported product
The accepted price quotation of the imported product (total delivered value)
Customer name,
contact person,
phone and fax
numbers

Product

Date of
quote

Quantity
(short tons)

Rejected
U.S. price
(total value-dollars)

Country of
origin

Competing
import price
(total
value—
dollars)