Preliminary Investigations - April

INSTRUCTION BOOKLET
GENERAL INFORMATION, INSTRUCTIONS, AND
DEFINITIONS FOR COMMISSION QUESTIONNAIRES

Certain Stilbenic Optical Brightening Agents (CSOBAs) from
China and Taiwan
Investigations Nos. 731-TA-1186-1187 (Preliminary)

Further information.--If you have any questions concerning the enclosed
questionnaire(s) or other matters related to this proceeding, you may contact
the following members of the Commission=s staff (Fax 202-205-3205):
Cynthia Trainor, investigator (202-205-3354; E-mail cynthia.trainor@USITC.GOV)
regarding general questions and trade and related information;
Charles F. Yost, auditor (202-205-3432; E-mail charles.yost@USITC.GOV)
regarding financial information; and
Gerry Benedick, economist (202-205-3244; E-mail gerald.benedick@USITC.GOV)
regarding pricing, market, and related information.

GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 31, 2011 by
Clariant Corp., Charlotte, NC. Antidumping duties may be assessed on the subject imports as a
result of this proceeding if the Commission makes an affirmative determination of injury, threat,
or material retardation, and if the U.S. Department of Commerce makes an affirmative
determination of dumping.
Questionnaires and other information pertinent to this proceeding are available at
http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2011/stilbenic_optical_brig
htening_agents/prelimphase.htm. Address all correspondence to the United States International
Trade Commission, Washington, DC 20436. Hearing-impaired individuals can obtain
information regarding this proceeding via the Commission=s TDD terminal (202-205-1810).
Due date of questionnaire(s).--Return the completed questionnaire(s) to the United States
International Trade Commission by no later than April 15, 2011. Although the enclosed postpaid
envelope may be used to return the completed questionnaire, use of an overnight mail service may
be necessary to ensure that your response actually reaches the Commission by April 15, 2011. If
you do not use the enclosed envelope, please make sure the completed questionnaire is sent to the
attention of Cynthia Trainor, Room 615. Return only one copy of the completed
questionnaire(s), but please keep a copy for your records so that you can refer to it if the
Commission staff contacts you with any questions during the course of this proceeding.
Service of questionnaire response(s).--In the event that your firm is a party to this proceeding,
you are required to serve a copy of the questionnaire(s), once completed, on parties to the
proceeding that are subject to administrative protective order (see 19 CFR ' 207.7). A list of such
parties is maintained by the Commission=s Secretary and may be obtained by calling
202-205-1803. A certificate of service must accompany the copy of the completed questionnaire(s)
you submit (see 19 CFR ' 207.7).
Confidentiality.--The commercial and financial data furnished in response to the enclosed
questionnaire(s) that reveal the individual operations of your firm will be treated as confidential by
the Commission to the extent that such data are not otherwise available to the public and will not
be disclosed except as may be required by law (see 19 U.S.C. ' 1677f). Such confidential
information will not be published in a manner that will reveal the individual operations of your
firm; however, nonnumerical characterizations of numerical business proprietary information
(such as discussion of trends) will be treated as confidential business information only at the
request of the submitter for good cause shown.
Verification.--The information submitted in the enclosed questionnaire(s) is subject to audit
and verification by the Commission. To facilitate possible verification of data, please keep
all your workpapers and supporting documents used in the preparation of the questionnaire
response(s).

2

GENERAL INFORMATION--Continued
Release of information.--The information provided by your firm in response to the
questionnaire(s), as well as any other business proprietary information submitted by your firm to
the Commission in connection with this proceeding, may become subject to, and released under,
the administrative protective order provisions of the Tariff Act of 1930 (19 U.S.C. ' 1677f) and
section 207.7 of the Commission=s Rules of Practice and Procedure (19 CFR ' 207.7). This means
that certain lawyers and other authorized individuals may temporarily be given access to the
information for use in connection with this proceeding or other import-injury proceedings
conducted by the Commission on the same or similar merchandise; those individuals would be
subject to severe penalties if the information were divulged to unauthorized individuals. In
addition, if your firm is a U.S. producer, the information you provide on your production and
imports of Certain Stilbenic Optical Brightening Agents (CSOBA) and your responses to the
questions in Part I of the producer questionnaire will be provided to the U.S. Department of
Commerce, upon its request, for use in connection with (and only in connection with) its
requirement pursuant to section 702(c)(4)/732(c)(4) of the Act (19 U.S.C. '
1671a(c)(4)/1673a(c)(4)) to make a determination concerning the extent of industry support for
the petition requesting this proceeding. Any information provided to Commerce will be
transmitted under the confidentiality and release guidelines set forth above. Your response to
these questions constitutes your consent that such information be provided to Commerce under the
conditions described above.

INSTRUCTIONS
Answer all questions.--Do not leave any question or section blank unless a questionnaire
expressly directs you to skip over certain questions or sections. If the answer to any question is
Anone,@ write Anone.@ If information is not readily available from your records in exactly the
form requested, furnish carefully prepared estimates--designated as such by the letter
AE@--and explain the basis of your estimates. Answers to questions and any necessary
comments or explanations should be supplied in the space provided or on separate sheets attached
to the appropriate page of the questionnaire(s). If your firm is completing more than one
questionnaire in connection with this proceeding (i.e., a producer, importer, and/or purchaser
questionnaire), you need not respond to duplicated questions in the questionnaires.
Consolidate all U.S. establishments.--Report the requested data for your establishment(s) located
in the United States. Firms operating more than one establishment should combine the data
for all establishments into a single report.
Filing instructions.—Questionnaires may be filed either electronically or in paper form.

3

INSTRUCTIONS--Continued
OPTIONS FOR FILING
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at
http://www.usitc.gov/trade_remedy/731_ad_701_cvd/investigations/2011/stilbeni
c_optical_brightening_agents/prelimphase.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. You may complete the questionnaire and submit it, electronically, or
you may print it out and submit it in paper form, as described below:
• Compact disc (CD).—Copy your questionnaire onto a CD, include a signed certification page
(page 1) (either in paper form or scanned PDF copied onto CD), and mail to the address above. It
is strongly recommended that you use an overnight mail service. U.S. mail sent to government
offices undergoes additional processing which not only results in substantial delays in delivery but
may also damage CDs.
• E-mail.—E-mail your questionnaire to the investigator identified on page 1 of the Instruction
Booklet; include a scanned PDF of the signed certification page (page 1). Type the following in
the e-mail subject line: BPI Questionnaire, INV. NO. 1186. Please note that submitting your
questionnaire by e-mail may subject your firm’s business proprietary information to transmission
over an unsecure environment and to possible disclosure. If you choose this option, the
Commission warns you that any risk involving possible disclosure of such information is assumed
by the submitter and not by the Commission.
• Fax.—Fax to 202.205.3205.
• Overnight mail service.—Mail to the following address:
United States International Trade Commission
Office of Investigations, Room 615
500 E Street SW
Washington, DC 20024
• U.S. mail.—Mail to the address above, but use zip code 20436. This option is not recommended.
U.S. mail sent to government offices undergoes additional processing to screen for hazardous
materials; this additional processing results in substantial delays in delivery.
Note: If you are a party to the proceeding, and service of the questionnaire is required,
such service should be made in paper form.

4

Product.—The certain stilbenic optical brightening agents (CSOBAs) covered by this
investigation are all forms, whether free acid or salt, of compounds known as
triazinylaminostilbenes (i.e., all derivatives of 4’-bis[1,3,5-triazin-2-yl]amino-2,2’stilbenedisulfonic acid), including polymers thereof, except for 4,4’-bis[4-anilino-6-morpholino1,3,5-triazin-2-yl]amino-2,2’-stilbenedisulfonic acid, C40H40N12O8S2 (“Fluorescent Brightener
71”). The certain stilbenic OBAs as covered by this investigation include final OBA products, as
well as intermediate products that are themselves triazinylaminostilbenes produced during the
synthesis of final OBA products. This investigation covers the above-described compounds in any
state (including but not limited to powder, slurry, or solution), of any concentrations, as well as
any compositions (i.e., mixtures or blends, whether of certain stilbenic OBAs with each other, or
of certain stilbenic OBAs with other products), and in any type of packaging. Certain stilbenic
OBAs (CSOBAs) are covered by subheadings 3204.20.80; 2921.59.40; and statistical reporting
number 2921.59.80.90 of the Harmonized Tariff Schedule of the United States (HTS).
The compounds excluded from this investigation are all forms of the following:
4,4’-bis[4-anilino-6-morpholino-1,3,5-triazin-2yl]amino-2,2’-stilbenedisulfonic acid,
C40H40N12O8S2. This is also called “Fluorescent Brightener 71” and is not typically used as an
optical brightener for paper products:
CSOBAs are characterized by (a) DAS as the central moiety in the chemical structure of the
molecule; (b) 1,3,5-triazine moieties bonded to the amino groups at the 4 and 4’ positions of the
DAS moiety; and (c) variable atoms or moieties bonded to the 4 and 6 positions of the
1,3,5-triazine moieties. One of these positions, the 4 or 6, of the 1,3,5-triazine moieties is typically
occupied by an aniline moiety with zero, one, or two sulfonate functional groups. The other
position, the 6 or 4, of the 1,3,5-triazine moieties is typically occupied by an amino moiety. In
triazinylaminostilbenes that are intermediate products produced during the synthesis of final
OBAs, the 4 and/or 6 positions may be occupied by chlorine atoms. CSOBAs may be grouped into
three categories depending on the number of sulfonate groups on the final molecule:
Di-category: a total of two sulfonate groups, which are located at the 2 and 2’ positions
of the DAS moiety; in solution, the Di-category has approximately 20 percent active
ingredient.
Tetra-category: a total of four sulfonate groups, which are located at the 2 and 2’ positions
of the DAS moiety, and at one of the open positions on each of the two aniline moieties
(typically at the 4 position); in solution, the Tetra-category has approximately 23 percent
active ingredient.
Hexa-category: a total of six sulfonate groups, which are located at the 2 and 2’ positions
of the DAS moiety, and at two of the open positions on each of the two aniline moieties
(typically at the 2 and 5 positions); in solution, the Hexa-category has approximately 16
percent active ingredient.

5

DEFINITIONS
Firm.--An individual proprietorship, partnership, joint venture, association, corporation
(including any subsidiary corporation), business trust, cooperative, trustee in bankruptcy, or
receiver under decree of any court.
Related firm.--A firm that your firm solely or jointly owned, managed, or otherwise controlled; a
firm that solely or jointly owned, managed, or otherwise controlled your firm; and/or a firm that
was solely or jointly owned, managed, or otherwise controlled by a firm that also solely or jointly
owned, managed, or otherwise controlled your firm.
Establishment.--Each facility of a firm involved in the production, importation, and/or purchase
of CSOBAs (as defined above), including auxiliary facilities operated in conjunction with
(whether or not physically separate from) such facilities.
United States.--For purposes of this proceeding, the 50 States, Puerto Rico, the U.S. Virgin Islands,
and the District of Columbia.
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary,
in importing CSOBAs (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
Imports.--Those products identified for Customs purposes as imports for consumption for which
your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
Import quantities.—Report quantities in both of two ways: in (1) 1,000 dry pounds
(100 percent active ingredient basis) and (2) 1,000 pounds (in solution). Quantities should be
net of returns. To calculate dry pounds basis 100 percent active ingredient divide 95 by the
percentage of active ingredient for each category of CSOBA: 20 for Di-category; 23 for
Tetra-category; and 16 for Hexa-category. Follow similar methodology for the reporting of other
CSOBAs and Fluorescent Brightener 71.
Import values.--Values reported should be landed, duty-paid values at the U.S. port of
entry, including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
Purchaser.--Any person or firm engaged, either directly or through a parent company or
subsidiary, in purchasing CSOBAs (as defined above) from another firm that produces, imports,
or otherwise distributes CSOBAs.

6

DEFINITIONS--Continued
Purchases.--Purchases from all sources, NOT including direct imports from foreign sources
located outside of the United States (which should be reported in an importer questionnaire).
Purchase quantities.-- Report quantities in both of two ways: in (1) 1,000 dry pounds
(100 percent active ingredient basis) and (2) 1,000 pounds (in solution). Quantities
should be net of returns. To calculate dry pounds basis 100 percent active ingredient
divide 95 by the percentage of active ingredient for each category of CSOBA: 20 for
Di-category; 23 for Tetra-category; and 16 for Hexa-category. Follow similar
methodology for the reporting of other CSOBAs and Fluorescent Brightener 71.
Purchase values.--Values reported should be net values (i.e., gross purchase values less all
discounts, allowances, rebates, and the value of returned goods), delivered to your U.S.
receiving point.
Shipments and exports.--Shipments of products produced in or imported by your establishment(s).
Include shipments to the contracting firm of product produced by your firm under a toll
agreement.
Shipment quantities.-- Report quantities in both of two ways: in (1) 1,000 dry pounds
(100 percent active ingredient basis) and (2) 1,000 pounds (in solution). Quantities
should be net of returns. To calculate dry pounds basis 100 percent active ingredient divide
95 by the percentage of active ingredient for each category of CSOBA: 20 for Di-category;
23 for Tetra-category; and 16 for Hexa-category. Follow similar methodology for the
reporting of other CSOBAs and Fluorescent Brightener 71
Shipment values.--Values reported should be 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. The value of domestic shipments to the contracting firm
under a toll agreement is the conversion fee (including profit).
Types of shipments:
U.S. shipments.--Commercial shipments, internal consumption, and transfers to related
firms within the United States.
Commercial shipments.--Shipments, other than internal consumption and transfers
to related firms, within the United States.
Internal consumption.--Product consumed internally by your firm.
Transfers to related firms.--Shipments made to related domestic firms.
Export shipments.--Shipments to destinations outside the United States, including
shipments to related firms.
7

DEFINITIONS--Continued
Inventories.--Finished goods inventory, not raw materials or work-in-progress.
Average production capacity.--The level of production that your establishment(s) could
reasonably have expected to attain during the specified periods. Assume normal operating
conditions (i.e., using equipment and machinery in place and ready to operate; normal operating
levels (hours per week/weeks per year) and time for downtime, maintenance, repair, and cleanup;
and a typical or representative product mix). Report quantities in both of two ways: in (1)
1,000 dry pounds (100 percent active ingredient basis) and (2) 1,000 pounds (in solution).
Follow the calculation methodology described earlier.
Toll agreement.--Agreement between two firms whereby the first firm furnishes the raw materials
and the second firm uses the raw materials to produce a product that it then returns to the first firm
with a charge for processing costs, overhead, etc.
Production.--All production in your establishment(s), including production consumed internally
within your firm and production for another firm under a toll agreement. Report quantities in
both of two ways: in (1) 1,000 dry pounds (100 percent active ingredient basis) and (2) 1,000
pounds (in solution). Follow the calculation methodology described earlier.
PRWs.--Production and related workers, including working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production for
plant=s own use (e.g., power plant), recordkeeping, and other services closely associated with the
above production operations.
Average number employed.--Add the number of employees, both full-time and part-time, for the
12 pay periods ending closest to the 15th of the month and divide that total by 12.
Hours worked.--Include time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight-time hours.
Wages paid.--Total wages paid before deductions of any kind (e.g., withholding taxes, old-age and
unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid directly
by your firm for overtime, holidays, vacations, and sick leave.
Fiscal year.--The 12-month period between settlement of your firm=s financial accounts.

8