11-1-2914 US producer questionnaire

OMB No. 3117-0016/USITC No. 11-1-2914; Expiration Date: 6/30/2011
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
PURIFIED CARBOXYMETHYLCELLULOSE FROM FINLAND,
MEXICO, NETHERLANDS, AND SWEDEN

This questionnaire must be received by the Commission by no later than December 3, 2010
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 review of the antidumping duty orders concerning purified carboxymethylcellulose (“purified CMC”)
from Finland, Mexico, Netherlands, and Sweden (Invs. Nos. 731-TA-1084-1087 (Review)). 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 purified carboxymethylcellulose (as defined in the instruction booklet) at any time since
January 1, 2005?

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 reviews in any other import-injury proceedings or reviews
conducted by the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout these reviews 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 reviews or related proceedings for which this information is submitted, or in internal audits and
proceedings 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 (

)

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

Page 2

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.

OMB statistics.--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.

OMB feedback.--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.

Establishments covered.--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.

I-3.

Support for continuation of order.--Do you support or oppose continuation of the antidumping
and/or countervailing duty order currently in place for purified CMC from the following
countries?
Finland

Support

Oppose

Take no position

Mexico

Support

Oppose

Take no position

Netherlands

Support

Oppose

Take no position

Sweden

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

Page 3

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

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

Yes--List the following information.

Firm name

I-5.

I-6.

Address

Extent of ownership

Related SUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, which are engaged in importing purified CMC from Finland, Mexico,
Netherlands, or Sweden into the United States or which are engaged in exporting purified CMC
from Finland, Mexico, Netherlands, or Sweden to the United States?
No

Yes--List the following information.

Firm name

Address

Affiliation

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, which are engaged in importing purified CMC from countries other than
Finland, Mexico, Netherlands, or Sweden into the United States or which are engaged in
exporting purified CMC from countries other than Finland, Mexico, Netherlands, or Sweden to
the United States?
No

Yes--List the following information.

Firm name and country

Address

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART I.--GENERAL INFORMATION--Continued
I-7.

I-8.

Related producers.--Does your firm have any related firms, either domestic or foreign, which
are engaged in the production of purified CMC?
No

Yes--List the following information.

Firm name

Address

Affiliation

Business plan.--In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for purified CMC?
No

Yes--Please provide the requested documents. If you are not providing the
requested documents, please explain why not.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

Page 5

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Cynthia Trainor (202-2053354, cynthia.trainor@usitc.gov). Supply all data requested on a calendar-year basis.
II-1.

Please identify the individual to be contacted regarding the confidential information requested in
part II?
Name and title:
Please indicate the manner by which Commission staff may contact the individual responsible for
part II with questions regarding the submitted confidential information
E-mail:
Fax: (

II-2.

Telephone: (

)

)

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of purified CMC since January 1, 2005.
(check as many as appropriate)
plant openings ..........................

plant closings ............................

relocations ................................

expansions ................................

acquisitions ...............................

consolidations ...........................

prolonged shutdowns or
production curtailments .................
revised labor agreements ..........

other (e.g., technology) ............

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
your operations or organization (as noted above) relating to the production of purified CMC in
the future?
No

Yes--Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in your response a specific projection of your firm’s
capacity to produce purified CMC (in 1,000 pounds) for 2011 and
2012.

For question II-4, if your response differs for particular orders, please indicate and explain the
particular effect of revocation of specific orders.
II-4.

Anticipated changes in operations in the event the order is revoked.--Would your firm
anticipate any changes in the character of your operations or organization (as noted above)
relating to the production of purified CMC in the future if the antidumping duty orders on
purified CMC from Finland, Mexico, Netherlands, or Sweden were to be revoked?
No

Yes--Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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

Same equipment, machinery, and workers.--Has your firm since 2005 produced, or does your
firm anticipate producing in the future, other products on the same equipment and machinery
used in the production of purified CMC and/or using the same production and related workers
employed to produce purified CMC?
No

Yes--List the following information and report your firm’s combined
production capacity and production of these products and purified
CMC in the periods indicated.

Product

Period

Basis for allocation of capacity and
employment data (indicate if different)

Purified CMC

(Quantity in 1,000 pounds)
Item

2005

2006

2007

2008

2009

Overall Production Capacity
Production of:
Purified CMC
Other product 1
Other product 2

II-6.

Constraints on production.--Please describe the constraint(s) that set the limit(s) on your
production capacity.

II-7.

Production shifting.--Is your firm able to switch production between purified CMC and other
products in response to a relative change in the price of purified CMC vis-a-vis the price of other
products, using the same equipment and labor?
No

Yes--Please identify the other products, the approximate time and cost
involved in switching, and the minimum relative price change required
for your firm to switch production to or from purified CMC.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-8.

Trade data.--Report your firm’s production capacity, production, shipments, inventories, and
employment related to the production of purified CMC in your U.S. establishment(s) during the
specified periods. (See definitions in the instruction booklet.)
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar year
Item

2005

2006

2007

January-September
2008

2009

2009

2010

Average production capacity1 (quantity) (A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
quantity (D)
value (E)
Internal consumption:2
quantity (F)
value (G)
Transfers to related firms:2
quantity (H)
value (I)
Export shipments:3
quantity (J)
value (K)
End-of-period inventories
(quantity) (L)
Channels of distribution:
U.S. shipments to distributors
(quantity) (M)
U.S. shipments to end users
(quantity) (N)
Employment data:
Average number of PRWs
(number) (O)
Hours worked by PRWs
(1,000 hours) (P)
Wages paid to PRWs
(value) (Q)
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 should 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:

.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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

Reconciliation of trade data.--

(a)

Please note that the quantities reported in question II-10 should reconcile as follows in
each period (i.e., in each column):
Reconciliation
B+C–D–F–H–J=L
D+F+H=M+N

(b)

Yes

No--Please

Yes

No--Please

Please note that the quantities reported for end of period inventories should equal the
beginning of period inventories reported in the subsequent calendar year (i.e., line L of
year 2005 should equal line B of year 2006). Do these data reconcile for each adjacent
calendar year?
Yes.

II-10.

Do these data reconcile?
explain
Do these data reconcile?
explain

No--Please explain.

Transfers to related firms.--If you reported transfers to related firms in question II-8, 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.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

Page 10

PART II.--TRADE AND RELATED INFORMATION--Continued
II-11.

U.S. shipments by end use.—Report your firm’s U.S. shipments (commercial shipments and
internal consumption and transfers of purified CMC), by major end use.

Item
FOOD:1
Quantity

2005

(Quantity in 1,000 pounds, value in $1,000)
Calendar years
2006
2007
2008
2009

January-September
2009
2010

Value

PERSONAL CARE, COSMETICS & PHARMACEUTICALS:1
Quantity

Value

PAPER & BOARD:1
Quantity

Value

OIL FIELD:1
Quantity

Value

ALL OTHER:2
Quantity

Value

TOTAL U.S. SHIPMENTS:3
Quantity

Value
1

Please indicate the ranges of key product characteristics for reported U.S. shipments during 2009 as follows:
Purity
(percent)
Food . . . . . . . . . . . . . . . . . . . _____________
Personal care, cosmetics, . .
& pharmaceuticals

_____________

Oilfield . . . . . . . . . . . . . . . . .

______________

Other . . . . . . . . . . . . . . . . . . ______________
2

3

Please describe: ___________________________________________________________________________

U.S. shipment data (commercial shipments + internal consumption + transfers) should reconcile with data
reported in section II-8.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-12. Purchases.--Other than direct imports, has your firm otherwise purchased purified CMC since
January 1, 2005? (See definitions in the instruction booklet.)
No

Yes-- Please indicate the reasons for your purchases (if your reasons differ by
source, please elaborate) and report the quantity and value of such
purchases below for the specified periods

Reasons:
(Quantity in 1,000 pounds, value in $1,000)

Item

2005

2006

2007

2008

2009

JanuarySeptember
2010

PURCHASES FROM U.S.
1
IMPORTERS OF PURIFIED CMC
FROM.—
FINLAND:
quantity
value
MEXICO:
quantity
value
NETHERLANDS:
quantity
value
SWEDEN:
quantity
value
All other countries:
quantity
value
PURCHASES FROM DOMESTIC
PRODUCERS:2
quantity
value
PURCHASES FROM OTHER
SOURCES:
quantity
Value
1

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

Please list the name of the domestic producer(s) from which you purchased this product.

II-13.

Toll production.--Since January 1, 2005, has your firm been involved in a toll agreement (see
definition in the instruction booklet) regarding the production of purified CMC?
No

Yes--Name firm(s):

.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART II.--TRADE AND RELATED INFORMATION--Continued
II-14.

FTZ.--Does your firm produce purified CMC in a foreign trade zone (FTZ)?
No

II-15.

Yes--Identify FTZ(s):

.

Direct imports.--Since January 1, 2005, has your firm imported purified CMC?
No

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

For questions II-16 and II-17, if your response differs for particular orders, please indicate and
explain the particular effect of imposition and/or revocation of specific orders.
II-16.

Effect of order.--Describe the significance of the existing antidumping duty orders covering
imports of purified CMC from Finland, Mexico, Netherlands, and Sweden in terms of their effect
on your firm’s production capacity, production, U.S. shipments, inventories, purchases,
employment, revenues, costs, profits, cash flow, capital expenditures, research and development
expenditures, and asset values. You may wish to compare your firm’s operations before and after
the imposition of the order.

II-17.

Likely effect of revocation of order.--Would your firm anticipate any changes in its production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, or asset values
relating to the production of purified CMC in the future if the antidumping duty orders on
purified CMC from Finland, Mexico, Netherlands, and Sweden were to be revoked?
No

Yes--Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation for any trends or
projections you may provide.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, mary.klir@usitc.gov).
III-1.

Please identify the individual to be contacted regarding the confidential information requested in
part III?
Name and title:
Please indicate the manner by which Commission staff may contact the individual responsible for
part III with questions regarding the submitted confidential information.
E-mail:
Fax: (

III-2.

Telephone: (

)

)

Accounting system.--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,
10Qs,
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
purified CMC, as well as those statements and worksheets used to compile data for your firm’s
questionnaire response.

III-3.

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

III-4.

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

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

Page 14

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

Other products.--Please list any other products you produced in the facilities in which you
produced purified CMC, and provide the share of net sales accounted for by these other products
in your most recent fiscal year:
Products

Share of sales

Purified CMC

III-6.

Raw materials from related firms.--Does your company receive inputs (raw materials, labor,
energy, or any other services) used in the production of purified CMC from any related parties?
Yes--Continue to question III-7 below

III-7.

Inputs from related firms.--In the space provided below, identify the inputs used in the
production of purified CMC that your firm receives from related parties.
Input

III-8.

No--Continue to question III-9 below

Related party

Related firms financials.--With respect to the related parties 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.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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

Inputs from related firms at cost.--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

III-10. Nonrecurring charges.--For each annual and interim period for which financial results are
reported in question III-11, 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 purified CMC operations.
Fiscal years ended-Item

January-September
2009

2010

Non-recurring charges: (In the far left column please provide a brief description of each nonrecurring charge and
indicate the particular expense/cost line items where the associated charges are included in question III-10.)
1.
2.
3.
4.
5.
6.
7.

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART III.--FINANCIAL INFORMATION--Continued
III-11. Operations on purified CMC.--Report the revenue and related cost information requested below
on the purified CMC 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
six most recently completed fiscal years in chronological order from left to right, and for the
specified interim periods (see next page). If your firm was involved in tolling operations (either
as the toller or as the tollee) please contact Mary Klir at (202) 205-3247 before completing this
section of the questionnaire.
Quantity (in 1,000 pounds) and value (in $1,000)
Item
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
Continued Dumping and Subsidy Offset Act
5
funds received

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 indicate the amount of profits or (losses) on inputs from related firms that were eliminated pursuant question III-8:
Year 2
Year 3
Year 4
Year 5
.
Year 1
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.
5
Please report funds received under this act in the period(s) in which they were received. Do not report these funds as an offset to
operating expenses.
2

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART III.--FINANCIAL INFORMATION--Continued
III-11. Operations on purified CMC.--Continued
Quantity (in 1,000 pounds) and value (in $1,000)
Item

January-September 2009

January-September 2010

3

Net sales quantities:
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
Continued Dumping and Subsidy Offset Act funds
5
received

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 indicate the amount of profits or (losses) on inputs from related firms that were eliminated pursuant question III-8:
January-September 2009
January-September 2010
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.
5
Please report funds received under this act in the period(s) in which they were received. Do not report these funds as an offset to
operating expenses.
2

Business Proprietary
U.S. Producers’ Questionnaire—Purified CMC (731-TA-1084-1087 (Review))

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PART III.--FINANCIAL INFORMATION--Continued
III-12. Asset values.--Report the total assets associated with the production, warehousing, and sale of
purified CMC. 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 six most recently completed fiscal years in chronological order
from left to right.
Value (in $1,000)

January-September

Item
ASSETS associated with the
production, warehousing, and sale of
product:
1. Current assets:
A. Cash and equivalents
B. Accounts receivable, net
C. Inventories
D. Other (describe:

)

E. Total current assets (lines
1.A. through 1.D.)
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. Other (describe:

)

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

III-13. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on purified CMC. Provide data for your six
most recently completed fiscal years in chronological order from left to right, and for the
specified interim periods.
Value (in $1,000)
Calendar year
Item
Capital expenditures
Research and
development expenses

January-September
2009

2010

Business Proprietary
U.S. Producers’ Questionnaire –Purified CMC (731-TA-1084-1087 (Review))

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

IV-1.

Please identify the individual to be contacted regarding the confidential information requested in
part IV.
Name and title:
Please indicate the manner by which Commission staff may contact the individual responsible for
part IV with questions regarding the submitted confidential information.
E-mail:
Fax: (

Telephone: (

)

)

PRICE DATA
This section requests quarterly selling quantity and value data during January 2005-September 2010 for
your firm’s U.S. commercial shipments of the following purified CMC products that it produced
domestically and shipped to U.S. end users unrelated to your firm by ownership.
Product 1.–High viscosity (approximately 1,000 to 3,000 Mpas in 1 percent solution), degree of
substitution approximately 0.65 to 0.90 (i.e., 6.5 to 9.0 carboxymethyl groups per 10 anhydroglucose units), used for regulated (food or personal care) applications, excluding pharmaceutical.
The trade names of the suppliers for this product are: Aqualon–7HF; CP Kelco–Cekol 30,000;
Akzo–Akucel AF278; Amtex–PE 31FG.
Product 2.–Very high viscosity (approximately 2,500 to 9,000 Mpas in 1 percent solution),
degree of substitution approximately 0.65 to 0.90 (i.e., 6.5 to 9.0 carboxymethyl groups per 10
anhydroglucose units), used for regulated (food or personal care) applications, excluding
pharmaceutical. The trade names of the suppliers for this product are: Aqualon–7H4F and 9H4F;
CP Kelco–Cekol 50,000; Akzo–Akucell 280X and 298X; Amtex–F1-4000 and F1-6000 (both
formerly included in PE 32 FG).
Product 3.–Medium viscosity (approximately 400 to 800 Mpas in 2 percent solution), degree of
substitution approximately 0.65 to 0.90 (i.e., 6.5 to 9.0 carboxymethyl groups per 10 anhydroglucose units), used for regulated (food or personal care) applications, excluding pharmaceutical.
The trade names of the suppliers for this product are: Aqualon–7MF; CP Kelco–Cekol 700;
Akzo–Akucel AF150 and AF 170; Amtex–F2 750.
Product 4.–Medium viscosity (approximately 400 to 800 Mpas in 2 percent solution), degree of
substitution approximately 0.65 to 0.90 (i.e., 6.5 to 9.0 carboxymethyl groups per 10 anhydroglucose units), non-regulated applications (i.e., standard grade). The trade names of the suppliers
for this product are: Aqualon–7MT; CP Kelco–Finnfix 700; Akzo–None; Amtex–P 2 750.

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PART IV.--PRICING AND MARKET FACTORS--Continued
PRICE DATA--Continued
Product 5.–Low viscosity (approximately 20 to 1,000 Mpas in 4 percent solution, 5 to 100 Mpas
in 2 percent solution), degree of substitution approximately 0.65 to 0.90 (i.e., 6.5 to 9.0
carboxymethyl groups per 10 anhydroglucose units), non-regulated applications (i.e., standard
grade). The trade names of the suppliers for this product are: Aqualon (98 percent CMC
minimum)–7L1, 7L2, and 7L; CP Kelco (98 percent CMC minimum)–Finnfix 5, Finnfix 10, and
Finnfix 30; Akzo–None; Amtex (92 percent CMC minimum)–P2-10, P2-30, and P2-75.
Product 6.–High viscosity (minimum 1,500 Mpas in 1 percent solution), degree of substitution
0.8 to 1.5 (i.e., 8 to 15 carboxymethyl groups per 10 anhydroglucose units), to oilfield customers.
This product is often sold to customers bearing the particular customer’s trade name for its oil
drilling product, such as Drispac, Milpac, and Polypac. Less frequently, the product bears a
proprietary name of the manufacturer, such as Aqualon’s Aquapac or Akzo’s Staflo. In all cases,
the specifications and not the label on the bag should be the controlling factor in reporting.
Please note that quarterly dollar selling values should be on a f.o.b. U.S. point(s)-of-shipment basis
(including those shipped directly from your U.S. plant(s) and from your U.S. warehouse(s)) and should
not include U.S.-inland transportation costs to your end-user customers. For any sales that were on a
delivered basis, deduct from the delivered price all such U.S.-inland freight to your end-user customers
and report the resulting effective f.o.b. U.S. sales values (do not report transactions where you cannot
report values, either actual or adjusted, on a f.o.b. basis). Report the U.S. f.o.b. sales value and quantity
data NET of returns, discounts, allowances, and rebates; also deduct any U.S. freight costs to your
customers’ receiving points that were absorbed by your firm (i.e., not charged to your customers). See
instruction booklet.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.--Report below the quarterly price data1 for the pricing products2 produced and sold
by your firm to end users.

Period of
shipment

(Quantity in pounds, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value

Product 3
Quantity
Value

2005:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2006:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2007:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2008
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2009:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2010:
Jan-Mar
Apr-June
July-Sept
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(s) of shipment; the latter actual or adjusted.
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:

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-2.

Pricing data.--Continued

Period of
shipment

(Quantity in pounds, value in dollars)
Product 4
Product 5
Quantity
Value
Quantity
Value

Product 6
Quantity
Value

2005:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2006:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2007:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2008
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2009:
Jan-Mar
Apr-June
July-Sept
Oct.-Dec
2010:
Jan-Mar
Apr-June
July-Sept
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(s) of shipment; the latter actual or adjusted.
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 4:
Product 5:
Product 6:

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-3.

Pricing products.-U.S. selling and import price comparability.— Is the U.S. producer’s reported selling prices of
the domestic purified CMC at a comparable level of the market as the reported import price data
for the products from the subject countries reported by importing end users (i.e., is it appropriate
to compare the selling prices of the domestic products with the import prices of the subject
imported products reported by importing end users)?
No

Yes

If no, please explain the reason(s) why, including any costs of importing purified CMC that were
not reflected in the reported import price data.

IV-4.

Price comparisons among countries.--Please compare market prices of purified CMC in the
United States vis-a-vis market prices of purified CMC in each of the subject countries, and, if
known, in individual third-country markets during January 2005-September 2010. Provide the
bases for any price comparisons (f.o.b., delivered, etc.), and note the specific information as to
price level, products, time period, and countries for each such price comparison.

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PART IV.--PRICING AND MARKET FACTORS--Continued
Unless otherwise instructed, please answer questions in the rest of Part IV based on your firm’s
total U.S. sales of its U.S.-produced purified CMC to all U.S. customers during January 2005September 2010. If your responses differ by sales to different types of U.S. customers (distributors,
end users, or types of distributors/end users), by product specifications of the purified CMC that
you produce domestically, or for any other reasons, please note such differences.
IV-5.

Length of sales period.--Please estimate below the share of your firm’s total U.S. commercial
shipment quantity during 2009 of its U.S.-produced purified CMC that was on a (1) long-term
basis (multiple deliveries for more than 12 months after the sales agreement), (2) short-term basis
(multiple deliveries up to and including 12 months), and (3) spot sales basis (usually one-time
delivery, within 30 days of the sales agreement). The three different sales bases include both oral
agreements and written contracts.
Share of 2009 U.S.
commercial shipment
quantity (percent)

Type of sale
Long-term
Short-term
Spot
TOTAL
IV-6.

100 percent

Long-term sales provisions.--Please answer the following questions with respect to your firm’s
sales of its U.S.-produced purified CMC on a typical long-term basis during January 2005September 2010.
(a) What was is the average duration of an agreement/contract?
(b) Could prices be renegotiated during the agreement/contract period?
(c) Did the agreement/contract fix quantity, price, or both?

Quantity

(d) Did the agreement/contract have a meet-or-release provision?
IV-7.

Yes
Price
Yes

No
Both
No

Short-term sales provisions.--Please answer the following questions with respect to your firm’s
sales of its U.S.-produced purified CMC on a typical short-term basis during January 2005September 2010.
(a) What was is the average duration of an agreement/contract?
(b) Could prices be renegotiated during the agreement/contract period?
(c) Did the agreement/contract fix quantity, price, or both?

Quantity

(d) Did the agreement/contract have a meet-or-release provision?

Yes
Price
Yes

No
Both
No

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-8.

Price setting.-- How did your firm determine the prices that it charged for U.S. sales during
January 2005-September 2010 of its U.S.-produced purified CMC (check all that apply)?
Transaction-by-transaction

Contracts

Set price lists (if checked, include a copy of a recent price list)
Reverse internet auction sales
Other--Please describe:

IV-9.

Discount policy/practice.-- Please indicate and describe your firm’s discount policies/ practices
(check all that apply) involving domestic sales during January 2005-September 2010 of its U.S.produced purified CMC; include in your discussion any discounts applied to purified CMC
bundled with other products your firm sells (explain below). Please include discounts that your
firm offered even though it may not have a stated discount policy. The one exception--do NOT
include any payment discounts covered in IV-10a.
Quantity discounts

Annual total volume discounts

No discounts

Other--Please describe:

IV-10. Pricing terms.--Report below for your firm’s U.S. commercial shipments during January 2005September 2010 of its U.S.-produced purified CMC.
(a) What were your firm’s typical sales terms (e.g., 2/10 net 30 days)?
(b) On what basis were your prices usually quoted? (Check one)
F.o.b.--Please specify shipping point:

.

Delivered

IV-11. Shipping information.-- Report below for your firm’s U.S. commercial shipments during
January 2005-September 2010 of its U.S.-produced purified CMC.
(a) What was the approximate percentage of the total delivered price that was accounted for by
percent.
U.S. inland transportation costs?
(b) Who generally arranged the transportation to your customers’ locations? (Check one)
Your firm
Purchaser.
(c) What proportion of your sales was delivered within 100 miles of your production facility?
percent. Within 101 to 1,000 miles?
percent. Over 1,000 miles?
percent.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-12. Lead times.--What was your firm’s share of its 2009 U.S. commercial shipments of its
domestically produced purified CMC from inventory and produced to order and what was the
average lead time between customers’ orders and the date of delivery?
Share of U.S.
commercial shipments
in 2009 (Percent)

Source

Lead time (days)

From inventory
Produced to order
Total

100 %

IV-13. Geographical shipments.-- What was the geographic market area in the United States served by
your firm’s U.S. shipments during January 2005-September 2010 of its U.S.-produced purified
CMC? (Check all that apply)
Geographic area

√ if applicable

Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed, including AK, HI,
PR, VI, among others.

IV-14. Product/marketing changes.--Have there been any significant changes in the product range,
product mix, or marketing (including sales over the internet) of purified CMC in the United States
during January 2005-September 2010?
No

Yes

If yes, please describe and quantify if possible. Discuss the time periods when any such changes
occurred, and the impact of any such changes on your firm’s U.S. sales prices and quantities of its
U.S.-produced purified CMC.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-15. Anticipated product/marketing changes.—Do you anticipate any changes in the product range,
product mix, or marketing (including sales over the internet) of purified CMC in the United States
in the future? Provide any underlying assumptions, along with relevant portions of business plans
or other supporting documentation that address this issue
No

Yes—Please identify, including the time period.

IV-16. End uses.--Based on your firm’s U.S. sales during January 2005-September 2010 of its U.S.produced purified CMC, identify the principal direct downstream products associated with such
sales and, to the extent possible, report the approximate percentage share of the total cost to
produce each downstream product that was accounted for by the purified CMC.
Downstream product

Share of total cost (percent)

IV-17. Changes in end uses.--Have there been any changes in the U.S. end uses or mix of end uses of
purified CMC during January 2005-September 2010?
No

Yes--Please describe.

IV-18. Price effects among end-use sectors.—Did a change in prices of purified CMC in one end-use
sector affect prices of purified CMC in another end-use sector in the U.S. market during January
2005-September 2010?
No

Yes.

If yes, please discuss and identify the purified CMC products and their associated end-use sectors,
and the time period of any such effect.

IV-19. Technical support/service provisions.--

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PART IV.--PRICING AND MARKET FACTORS--Continued
a) What technical support/service provisions were important for your firm=s customers in your
sales of its U.S.-produced purified CMC during January 2005-September 2010?

b) Were the technical support and service provisions priced separately for your firm’s sales of its
U.S.-produced purified CMC during January 2005-September 2010?
No

Yes--Please explain.

IV-20. Cellulose preferences/requirements.—
a) Do cotton linters versus wood pulp, or some other form of cellulose, used as an input in the
production of purified CMC, result in better quality and/or performance of the purified CMC?
No

Yes--Please explain.

b) Did your customers ever specify/require the type(s) of cellulose to be used in the purified CMC
that your firm produced for them during January 2005-September 2010?
No

Yes

If yes, please explain below whether your firm, your customer, or both jointly determined the
type(s) of cellulose used and why one form of cellulose was chosen over another form.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-21. Raw materials.—
a) Please describe any trends in the prices of the principal raw materials used by your firm to
produce purified CMC during January 2005-September 2010 and the impact of such trends on
your firm’s selling prices and/or quantities of its purified CMC.

b) Does your firm expect the trends in these import prices to continue in the future?
No

Yes

If yes, please explain below and identify the future time period of any changes.

IV-22. Changes in other factors affecting supply.—
a) Have any changes occurred in any other factors affecting supply (e.g., changes in availability
or prices of energy or labor; transportation conditions; production capacity and/or methods of
production; technology; export markets; or alternative production opportunities) of your U.S.produced purified CMC in the U.S. market since 2005?
No

Yes--Please note the time period(s) of any such changes, the factors(s)
involved, and the impact such changes had on your shipment volumes and prices.

b) Do you anticipate any changes in the future in other factors affecting supply of your U.S.produced purified CMC in the U.S. market?
No

Yes--Please note the time period(s) and factors of any such changes.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-23 Export constraints.—Please describe how easily your firm could shift its sales of purified CMC
between the U.S. market and export markets during January 2005-September 2010. In your
discussion, explain if your firm’s U.S.-produced purified CMC produced for export during
January 2005-September 2010 was not useable/acceptable in the U.S. market, subject to longterm contracts and/or other supply provisions, or other commercial reasons that would have
inhibited or prevented shifting some or all of these products to the U.S. market within a 12-month
period during this period. Provide any underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this issue.

IV-24. Barriers to trade.—Were your firm’s exports of purified CMC subject to any tariff or non-tariff
barriers to trade in other countries during January 2005-September 2010?
No

Yes--Please list the countries and describe for each country any such barriers
and any significant changes in such barriers that occurred during this period, or
that are expected to occur in the future.

IV-25. U.S. inventories.--Please explain if your firm’s U.S. inventories of its U.S.-produced purified
CMC during January 2005-September 2010 were committed to customers by supply agreements,
or other commercial reasons that would have prevented your firm from using some or all of this
inventory to increase shipments to the U.S. market within a 12-month period during this period.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-26. Availability of supply (U.S.-produced).-(a) Has the availability of U.S.-produced purified CMC in the U.S. market changed since 2005?
No

Yes--Please explain the circumstances and identify the time period of any
such changes.

(b) Do you anticipate any changes in the availability of U.S.-produced purified CMC in the U.S.
market in the future?
Increase

No change

Decrease

If you anticipate changes in supply, please identify the changes, including the time period and the
impact of such changes on shipment volumes and prices. Provide any underlying assumptions,
along with relevant portions of business plans or other supporting documentation that address this
issue.

IV-27. Availability of supply (nonsubject).—
(a) Has the availability of purified CMC imported from nonsubject countries in the United States
changed since 2005?
No

Yes--Please explain.

(b) Do you anticipate any changes in terms of the availability of purified CMC imported from
nonsubject countries in the U.S. market in the future?
Increase

No change

Decrease

If you anticipate changes in supply, please identify the changes, including the country(ies) of
origin, the time period, and the impact of such changes on shipment volumes and prices. Provide
any underlying assumptions, along with relevant portions of business plans or other supporting
documentation that address this issue.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-28. Cyclical/seasonal U.S. demand.—Was total U.S. demand for purified CMC subject to any
cyclical/seasonal fluctuations, product cycles, or other U.S. conditions of competition distinctive
to purified CMC during January 2005-September 2010?
No—Skip to the next question

Yes

If yes—
(a) Please check below the type(s) of demand fluctuations and then discuss the nature and timing
of these fluctuations during January 2005-September 2010. In addition indicate whether any
business cycles result from changes in the overall economy and/or specific downstream sectors.
Cyclical (longer than one year for complete cycle)
Seasonal (within one year for complete cycle)
Product cycle (completed

within one year, or

longer than one year—Check one)

Other competitive condition(s) (specify

)

Discussion: --In addition, identify, if applicable, peak and lowest demand months in a year.

(b) Have there been any changes in the business cycles or conditions of competition in specific
U.S. sectors using purified CMC or for total purified CMC in the U.S. market since January
2005?
No

Yes-- Please describe.

(c) Explain how any U.S. cyclical/seasonal/other demand fluctuations affected your firm’s selling
prices and shipment quantities of its U.S.-produced purified CMC to the U.S. market at any
time(s) during January 2005-September 2010.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-29. Demand trends.-(a) How did total demand WITHIN the United States for purified CMC change during January
2005-September 2010? What principal factors affected changes in demand?
Increased

No Change

Decreased

Fluctuated

(b) How did demand OUTSIDE the United States (if known) for purified CMC change during
January 2005-September 2010? What principal factors affected changes in demand? If
applicable, identify specific foreign countries.
Increased

No Change

Decreased

Fluctuated

IV-30. Anticipated demand trends.-(a) Do you anticipate any future changes in total demand for purified CMC WITHIN the United
States?
No

Yes—Please describe and identify the time period. Provide any
underlying assumptions, along with relevant portions of business plans or
other supporting documentation that address this issue.

(b) Do you anticipate any future changes in demand for purified CMC OUTSIDE the United
States? If applicable, identify specific foreign countries that you refer to.
No

Yes—Please describe and identify the time period. Provide any
underlying assumptions, along with relevant portions of business plans or
other supporting documentation that address this issue.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-31. Substitutes in demand in the U.S. market for the subject purified CMC.—
Substitution in demand refers to products that can, based on market price considerations and householdconsumer/industrial-user preferences or technical requirements, reasonably be expected to substitute for
each other when the price of one product changes vis-a vis the price of the other product—some
consumers/industrial users may require greater price changes than others before they switch among the
alternative products.
a) Do substitutes (e.g., crude/unrefined CMC, CMC Fluidized Polymer Suspensions, cross-linked
purified CMC, other hydrocolloids, etc.) for purified CMC exist in the U.S. market?
No

Yes

If yes, please list in descending order of importance any products, other than the subject purified
CMC, that may be substituted for purified CMC in the U.S. market during January 2005September 2010. For each possible substitute product, please give examples of applications and
end uses involving the substitute and indicate whether changes in the price of the substitute affect
the price and/or quantity of purified CMC (also estimate the length of any time lag of such an
effect).

Substitute product

Have changes in the prices of this
substitute affected the price and/or
Description of applications quantity of purified CMC during January
and end uses
2005-September 2010?

1.

No

Yes—Please explain.

2.

No

Yes—Please explain.

3.

No

Yes—Please explain.

4.

No

Yes—Please explain.

5.

No

Yes—Please explain.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-31. Substitutes in demand in the U.S. market for the purified CMC.—Continued
b) Have there been any changes in the number or types of products that can be substituted for
purified CMC or changes in the relative importance/mix of existing substitutes during January
2005-September 2010?
No

Yes--Please explain.

c) Do you anticipate any changes in the number or types of products that can be substituted for
purified CMC or changes in the relative importance/mix of existing substitutes in the future?
No

Yes--Please describe. Provide any underlying assumptions, along with
relevant portions of business plans or other supporting documentation that
address this issue.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-32. Substitutes in demand in the U.S. market among types/grades of purified CMC.-a) Do various types/grades of purified CMC substitute for each other in the U.S. market?
No

Yes

If yes, please discuss below the extent to which purified CMC products could substitute for each
other during January 2005-SeptemberJune 2010 and identify the end uses in which this
substitution could occur. For each possible substitution discussed, please indicate the extent to
which any such substitution actually occurred during January 2005-September 2010.

b) Do you anticipate any changes in the number or types of purified CMC products that can be
substituted for each other or changes in the relative importance/mix of existing substitutes in the
future?
No

Yes--Please describe. Provide any underlying assumptions, along with
relevant portions of business plans or other supporting documentation that
address this issue.

IV-33. Market studies.—Please provide as a separate attachment to this request any studies, surveys,
etc., that you are aware of that quantify and/or otherwise discuss purified CMC demand and
supply (the latter including production capacity and capacity utilization) in (1) the United States,
(2) each of the other major producing/consuming countries, including Finland, Mexico,
Netherlands, and Sweden, and (3) the world as a whole. Of particular interest is such data since
January 2005 and forecasts for the future.

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-34. Interchangeability.—Was purified CMC produced in the United States and in other countries
interchangeable (i.e., could they physically be used in the same applications) in the U.S. market
during January 2005-September 2010? 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

Country-pair

Finland

Mexico

Netherlands

Sweden

Other
2
countries

United States
Finland
Mexico
Netherlands
Sweden
1
For each country-pair where purified CMC was sometimes or never interchangeable during
January 2005-September 2010, please explain the factors that limit or preclude interchangeable use
and identify the associated country pair(s):
2
Identify any “other countries.”

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PART IV.--PRICING AND MARKET FACTORS--Continued
IV-35. Factors other than price.--Were differences other than price (i.e., quality, availability,
transportation network, product range, technical support, etc.) between purified CMC produced in
the United States and imported purified CMC a significant factor in your firm’s U.S. sales of its
U.S.-produced purified CMC during January 2005-September 2010? 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

Country-pair

Finland

Mexico

Netherlands

Sweden

Other
2
countries

United States
Finland
Mexico
Netherlands
Sweden
1
For each country-pair for which factors other than price always or frequently were a significant
factor in your firm’s U.S. sales of its U.S.-produced purified CMC during January 2005-September
2010, please identify the advantages or disadvantages imparted by such factors and identify the
associated country pair(s):
2
Identify any “other countries.”