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pdfOMB No. 3117‐0016/USITC No. 15‐1‐3357; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
BOLTLESS STEEL SHELVING UNITS PREPACKAGED FOR SALE FROM CHINA
This questionnaire must be received by the Commission by June 17, 2015
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning boltless steel shelving units
prepackaged for sale (“boltless steel shelving”) from China (Inv. Nos. 701‐TA‐523 and 731‐TA‐1259 (Final)). The
information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This
report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of
records or information in your firm’s possession (19 U.S.C. § 1333(a)).
Name of firm
Address
City
State
Zip Code
Website
Has your firm produced boltless steel shelving (as defined on next page) at any time since January 1, 2012?
NO
(Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES
(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: SHLV)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission.
By means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import‐injury proceedings conducted by
the Commission on the same or similar merchandise.
I acknowledge that information submitted in this questionnaire response and throughout this proceeding 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 this proceeding 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
Date
Phone:
Signature
Fax:
Email address
Business Proprietary
U.S. Producers’ Questionnaire – Boltless steel shelving
Page 2
PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to petitions filed on August 26, 2014, by Edsal
Manufacturing Co., Inc., Chicago, Illinois. Countervailing and/or 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 subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available at
http://www.usitc.gov/investigations/701731/2015/boltless_steel_shelving_units_prepackaged_sale/fin
al.htm
Boltless steel shelving units prepackaged for sale. The scope of these investigations covers boltless
steel shelving units prepackaged for sale, with or without decks (“boltless steel shelving”). The term
“prepackaged for sale” means that, at a minimum, the steel vertical supports (i.e., uprights and posts)
and steel horizontal supports (i.e., beams, braces) necessary to assemble a completed shelving unit
(with or without decks) are packaged together for ultimate purchase by the end‐user. The scope also
includes add‐on kits. Add‐on kits include, but are not limited to, kits that allow the end‐user to add an
extension shelving unit onto an existing boltless steel shelving unit such that the extension and the
original unit will share common frame elements (e.g., two posts). The term “boltless” refers to steel
shelving in which the vertical and horizontal supports forming the frame are assembled primarily
without the use of nuts and bolts or screws. The vertical and horizontal support members for boltless
steel shelving are assembled by methods such as, but not limited to, fitting a rivet, punched or cut tab or
other similar connector on one support into a hole, slot or similar receptacle on another support. The
supports lock together to form the frame for the shelving unit, and provide the structural integrity of the
shelving unit separate from the inclusion of any decking. The incidental use of nuts and bolts or screws
to add accessories, wall anchors, tie‐bars or shelf supports does not remove the product from scope.
Boltless steel shelving units may also come packaged as partially assembled, such as when two upright
supports are welded together with front‐to‐back supports, or are otherwise connected, to form an end
unit for the frame. The boltless steel shelving covered by these investigations may be commonly
described as rivet shelving, welded frame shelving, slot and tab shelving, and punched rivet (quasi‐rivet)
shelving as well as by other trade names. The term “deck” refers to the shelf that sits on or fits into the
horizontal supports (beams or braces) to provide the horizontal storage surface of the shelving unit.
The scope includes all boltless steel shelving meeting the description above, regardless of (1) vertical
support or post type (including but not limited to open post, closed post and tubing); (2) horizontal
support or beam/brace profile (including but not limited to Z‐beam, C‐beam, L‐beam, step beam and
cargo rack); (3) number of supports; (4) surface coating (including but not limited to paint, epoxy,
powder coating, zinc and other metallic coating); (5) number of levels; (6) weight capacity; (7) shape
(including but not limited to rectangular, square, and corner units); (8) decking material (including but
not limited to wire decking, particle board, laminated board or no deck at all); or (9) the boltless method
by which vertical and horizontal supports connect (including but not limited to keyhole and rivet, slot
and tab, welded frame, punched rivet and clip).
Specifically excluded from the scope are:
(1) Wall‐mounted shelving, defined as shelving that is hung on the wall and does not stand on, or
transfer load to, the floor (the addition of a wall bracket or other device to attach otherwise
freestanding subject merchandise to a wall does not meet the terms of this exclusion); (2) Wire shelving
units, which consist of shelves made from wire that incorporates both a wire deck and wire horizontal
supports (taking the place of the horizontal beams and braces) into a single piece with tubular collars
that slide over the posts and onto plastic sleeves snapped on the posts to create the finished shelving
Business Proprietary
U.S. Producers’ Questionnaire – Boltless steel shelving
Page 3
unit; (3) Bulk‐packed parts or components of boltless steel shelving units; and (4) Made‐to‐order
shelving systems.
Subject boltless steel shelving enters the United States through Harmonized Tariff Schedule of the
United States (“HTSUS”) statistical subheadings 9403.20.0018 and 9403.20.0020, but may also enter
through HTSUS 9403.10.0040. While HTSUS subheadings are provided for convenience and Customs
purposes, the written description of the scope of this investigation is dispositive.
Reporting of information.‐‐ If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.‐‐The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import‐injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
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U.S. Producers’ Questionnaire – Boltless steel shelving
I‐1a.
Page 4
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I‐1b. TAA information release.‐‐In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
No
Yes
I‐2.
Establishments covered.‐‐Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”‐‐Each facility of a firm involved in the production of boltless steel shelving,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
City, State
Zip (5 digit)
Description
covered1
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
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U.S. Producers’ Questionnaire – Boltless steel shelving
I‐3.
Petition support.‐‐Does your firm support or oppose the petition?
Country
China
I‐4.
I‐5.
Page 5
Support
Oppose
Take no position
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing boltless steel shelving from China into the United States
or that are engaged in exporting boltless steel shelving from China to the United States?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
I‐6.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of boltless steel shelving?
No
Yes‐‐List the following information.
Firm name
Address
Affiliation
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Keysha Martinez (202‐205‐
2136, Keysha.Martinez@usitc.gov). Supply all data requested on a calendar‐year basis.
II‐1. Contact information.‐‐ Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax
II‐2. Changes in operations.‐‐Please indicate whether your firm has experienced any of the following
changes in relation to the production of boltless steel shelving since January 1, 2012.
(check as many as appropriate)
(please describe)
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 7
II‐3a. Production using same machinery.‐‐ Please report your firm’s production of products made on
the same equipment and machinery used to produce boltless steel shelving, and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
(Quantity in units)
Calendar years
Item
Overall production capacity
2012
Other products
2014
2015
0
0
0
0
0
0
0
0
0
0
Total
7.
2014
Production of:
Boltless steel shelving1
2
2013
January‐March
1
Data entered for production of boltless steel shelving will populate here once reported in question II‐
2
Please identify these products:
II‐3b. Operating parameters.‐‐The production capacity reported in II‐3a is based on operating hours
per week, weeks per year.
II‐3c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐3a, and explain any changes in reported capacity.
II‐3d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 8
II‐3e. Product shifting.—
(i)
Is your firm able to switch production (capacity) between boltless steel shelving and other
products using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
(ii)
Please describe the factors that affect your firm’s ability to shift production capacity
between boltless steel shelving and other products (e.g., time, cost, relative price change,
etc.), and the degree to which these factors enhance or constrain such shifts.
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U.S. Producers’ Questionnaire – Boltless steel shelving
II‐4.
Page 9
Tolling.‐‐Since January 1, 2012, has your firm been involved in a toll agreement regarding the
production of boltless steel shelving?
“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.
No
Yes‐‐Please describe the toll arrangement(s) and name the firm(s) involved
II‐5.
Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce boltless steel shelving in and/or admit
boltless steel shelving into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign Trade Zones Act.
No
Yes‐‐Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import boltless steel shelving into a foreign trade zone (FTZ) for use in distribution of
boltless steel shelving and/or the production of downstream articles?
No/Don’t know
Yes‐‐Identify the firms and the FTZs.
II‐6.
Importer.‐‐Since January 1, 2012, has your firm imported boltless steel shelving?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No
Yes‐‐COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE
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U.S. Producers’ Questionnaire – Boltless steel shelving
II‐7.
Page 10
Production, shipment and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of boltless steel shelving in its U.S.
establishment(s) during the specified periods.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions are
valued at fair market value.
“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
Such transactions are valued at fair market value.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire – Boltless steel shelving
II‐7.
Page 11
Production, shipment and inventory data.‐‐
Quantity (in units) and value (in $1,000)
Calendar years
Item
2012
2013
January‐March
2014
1
Average production capacity (quantity) (A)
2014
Beginning‐of‐period inventories (quantity)
(B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
2015
3
Export shipments:
Quantity (J)
Value (K)
4
End‐of‐period inventories (quantity) (L)
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 your firm
uses 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 firm’s principal export markets:
.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the end‐of‐
period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B), plus
production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not
due to data entry errors in completing this form, but rather actually reflect your firm’s records; and also provide
any likely explanations for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
2012
2013
0
January‐March
2014
0
2014
0
2015
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate.
Business Proprietary
U.S. Producers’ Questionnaire – Boltless steel shelving
II‐8.
Page 12
Channels of distribution.‐‐Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in units)
Calendar years
Item
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
2012
2013
January‐March
2014
2014
2015
To end users (quantity) (N)
To retailers (quantity) (O)
Calendar years
Reconciliation
M + N + O – D = zero ("0"), if not
revise.
2012
2013
0
January‐March
2014
0
2014
0
0
2015
0
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U.S. Producers’ Questionnaire – Boltless steel shelving
II‐9.
Page 13
Employment data.‐‐Report your firm’s employment‐related data related to the production of
boltless steel shelving and provide any explanation for any trends in these data.
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to March periods, calculate similarly and divide by 3.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old‐age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item
2012
2013
January‐March
2014
2014
2015
Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:
II‐10. Related firms.‐‐If your firm reported transfers to related firms in question II‐7, 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.
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 14
II‐11a. Purchases.‐‐Other than direct imports, has your firm otherwise purchased boltless steel shelving
since January 1, 2012?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign producer or exporter where your firm is
the importer of record or consignee.
No
Yes‐‐Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in units)
Calendar years
Item
2012
Purchases from U.S.
importers1 of boltless steel
shelving from—
China
2013
January‐March
2014
2014
2015
Purchases from domestic
producers2
Purchases from other
sources2
All other import sources
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier.
.
2
Please list the name of the producer(s) or other U.S. distributor(s) from which your firm purchased this
product.
.
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 15
II‐11b. Facilitated transactions.‐‐Other than your firm’s own direct imports and purchases, has your
firm or any affiliated firm identified in questions I‐4 to I‐6 facilitated or arranged for a third party
the sale, export, import, and/or purchase of boltless steel shelving made in China for the U.S.
market since January 1, 2012? For example, without acting as the importer of record, your firm
facilitated a third‐party U.S. retailer’s purchase of boltless steel shelving made in China for the
U.S. market.
No
Yes‐‐Report such facilitated transactions below and explain the reasons for
your firms' role:
(Quantity in units)
Calendar years
Item
Facilitated transactions
involving boltless steel
shelving made in China1 2
2012
2013
January‐March
2014
2014
2015
1
Please list the names of the firm or firms that served as the importer of record for these transactions.
.
2
Please list the names of the firm or firms for which these imports were facilitated (e.g., the purchasers).
.
II‐12. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 16
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Justin Jee (202‐205‐3186, Justin.Jee@usitc.gov).
III‐1. Contact information.‐‐ Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part III.
Name
Title
Email
Telephone
Fax
III‐2. Accounting system.‐‐Briefly describe your firm’s financial accounting system.
A.
When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data‐collection period, explain:
B.1. Describe the lowest level of operations (e.g., plant, division, company‐wide) for
which financial statements are prepared that include boltless steel shelving:
2. Does your firm prepare profit/loss statements for boltless steel shelving:
Yes
No
3. 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
4. Accounting basis: GAAP, cash, tax, or other comprehensive
basis of accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes boltless steel shelving,
as well as specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
III‐4.
Allocation basis.‐‐Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.
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U.S. Producers’ Questionnaire – Boltless steel shelving
III‐5.
Other products.‐‐Please list the products your firm produced in the facilities in which your firm
produced boltless steel shelving, and provide the share of net sales accounted for by these other
products in your firm’s most recent fiscal year.
Products
III‐6.
Page 17
Share of sales
Boltless steel shelving
%
%
%
%
%
Does your firm purchase inputs (raw materials, labor, energy, or any other services) used in the
production of boltless steel shelving from any related parties?
Yes‐‐Continue to question III‐7.
III‐7.
No‐‐Continue to question III‐9a.
Inputs from related parties.‐‐Please identify the inputs used in the production of boltless steel
shelving that your firm purchases from related parties and that are reflected in table III‐9a. For
“Share of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “Input valuation” please describe the basis, as recorded in
your company’s own accounting system, of the purchase cost from the related party; e.g., the
related party’s actual cost, cost plus, negotiated transfer price to approximate fair market value.
Input
Related party
Share of total COGS
Input valuation as recorded in the firm’s accounting books and records
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U.S. Producers’ Questionnaire – Boltless steel shelving
III‐8.
Page 18
Inputs purchased from related parties.‐‐Please confirm that the inputs purchased from related
parties, as identified in III‐7, are being reported in III‐9a below (financial results on boltless steel
shelving) in a manner consistent with your firm’s accounting books and records.
Yes
No‐‐In the space below, please report the valuation basis of inputs purchased from related
parties as reported in table III‐9a.
Business Proprietary
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III‐9a. Operations on boltless steel shelving.‐‐Report the revenue and related cost information
requested below on the boltless steel shelving operations of your firm’s U.S. establishment(s).1
Do not report resales of products. Note that internal consumption and transfers to related firms
must be valued at fair market value. Input purchases from related parties should be consistent
with and based on information in the firm’s accounting books and records. Provide data for
your firm’s three most recently completed fiscal years, and for the specified interim periods. If
your firm was involved in tolling operations (either as the toller or as the tollee), please contact
Justin Jee at (202) 205‐3186 before completing this section of the questionnaire.
Quantity (in units) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2012
2013
January‐March
2014
2014
2015
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
0
0
Internal consumption
Transfers to related firms
0
0
0
0
0
Direct labor
Other factory costs
Total COGS
0
0
0
0
0
Gross profit or (loss)
0
0
0
0
0
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
Cost of goods sold (COGS):3
Raw materials
Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
0
0
0
0
0
0
0
0
0
0
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
0
0
0
0
0
1 Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding
shipment quantities and values reported in Part II of this questionnaire.
3 COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
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III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual and interim period for which financial results are reported in question III‐9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III‐9a line item where the nonrecurring items are included, a brief description
of the relevant nonrecurring items, and the associated values (in $1,000), as reflected in table
III‐9a; i.e., if an aggregate nonrecurring item has been allocated to table III‐9a, only the allocated
value amount included in table III‐9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in table III‐9a.
Fiscal years ended‐‐
2012
Nonrecurring item: In this column please provide a
brief description of each nonrecurring item and indicate
the specific line item in table III‐9a where the
nonrecurring item is classified.
2013
January‐March
2014
2014
Nonrecurring item: In these columns please report the amount of the
relevant nonrecurring item reported in table III‐9a.
Value ($1,000)
1. , classified
2. , classified
3. , classified
4. , classified
5. , classified
6. , classified
7. , classified
2015
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III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in table III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., III‐10 information designates where these items are reported in
table III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of boltless steel shelving. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for boltless steel
shelving in the normal course of business, please estimate this information based upon a
method (such as production, sales, or costs) that is consistent with your firm’s cost allocations in
the previous question. Provide data as of the end of your firm’s three most recently completed
fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
1
Total assets (net)
1
2012
2013
2014
Describe
III‐13a. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses on boltless steel shelving. Provide data
for your firm’s three most recently completed fiscal years, and for the specified interim
periods.
Value (in $1,000)
Fiscal years ended‐‐
Item
2012
2013
January‐March
2014
2014
Capital expenditures
Research and development expenses
III‐13b. Capital expenditures.‐‐Please indicate the nature, focus, and significance of your firm’s capital
expenditures on the subject product.
2015
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III‐14. Data consistency and reconciliation.‐‐Please indicate whether your firm’s financial data for
questions III‐9a, 12, and 13a are based on a calendar year or on your firm’s fiscal year:
Calendar year
Fiscal year Specify fiscal year
Please note the quantities and values reported in question III‐9a should reconcile with the data
reported in question II‐7 (including export shipments) as long as they are reported on the same
calendar year basis.
Do these data in question III‐9a reconcile with data in question II‐7?
Yes
No
If no, please explain.
III‐15. Effects of imports.‐‐Since January 1, 2012, 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 boltless steel
shelving from China?
No
Yes‐‐My firm has experienced actual negative effects as follows:
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):
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III‐16. Anticipated effects of imports.‐‐Does your firm anticipate any negative effects due to imports of
boltless steel shelving from China?
No
Yes
If yes, my firm anticipates negative effects as follows:
III‐17. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.
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PART IV.‐‐PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Tana Farrington (202‐205‐
2389, Tana.Farrington@usitc.gov).
IV‐1. Contact information.‐‐Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax
PRICE DATA
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2012 of the following products produced by your
firm.
Product 1.‐‐77” Width x 24” Depth x 72” to 78” Height, 4‐level rack with steel wire decking,
with load capacity of 1,000 pounds to 2,500 pounds per level
Product 2.‐‐77” Width x 24” Depth x 72” Height, 3‐level rack with steel wire decking, with load
capacity of 1,000 pounds to 2,500 pounds per level
Product 3.‐‐36” Width x 18” Depth x 72” Height, 5‐level boltless/rivet steel shelving with
particle board deck, with load capacity of 250 pounds to 1,000 pounds per level
Product 4.‐‐48” Width x 18‐24” Depth x 72‐84” Height, 5‐ or 6‐level boltless/rivet steel shelving
with particle board or laminate deck, with load capacity of 250 pounds to 1,000
pounds per level
Product 5.‐‐34” to 36” Width x between 15” and 18” Depth x 60” Height, 4‐level boltless/rivet
steel shelving with particle board deck, with load capacity of 250 pounds to 1,000
pounds per level
During January 2012‐March 2015, did your firm produce and sell to unrelated U.S. customers
any of the above listed products (or any products that were competitive with these products)?
Yes.‐‐Please complete the following pricing data tables as appropriate.
No.‐‐Skip to question IV‐3.
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Page 25
IV‐2a. Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm to unrelated customers.
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.‐
inland transportation costs. Values should reflect the final net amount paid to your firm (i.e.,
should be net of all deductions for discounts or rebates).
Report data in actual units and actual dollars (not 1,000s of dollars). Please also specify the
maximum load capacity(ies) of your associated product(s) which fall within the specified load
capacity ranges in the product descriptions above.
(Quantity in units, value in dollars)
Product 1
Product 2
Load Capacity(ies):
Load Capacity(ies):
Quantity
Value
Quantity
Value
Product 3
Load Capacity(ies):
Quantity
Value
Period of shipment
2012:
January‐March
April‐June
July‐September
October‐December
2013:
January‐March
April‐June
July‐September
October‐December
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐ If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
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IV‐2a. Price data (continued).‐‐Report below the quarterly price data1 for pricing products2 produced
and sold by your firm to unrelated customers.
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.‐
inland transportation costs. Values should reflect the final net amount paid to your firm (i.e.,
should be net of all deductions for discounts or rebates).
Report data in actual units and actual dollars (not 1,000s of dollars). Please also specify the
maximum load capacity(ies) of your associated product(s) which fall within the specified load
capacity ranges in the product descriptions above.
(Quantity in units, value in dollars)
Product 4
Load Capacity(ies):
Quantity
Value
Product 5
Load Capacity(ies):
Quantity
Value
Period of shipment
2012:
January‐March
April‐June
July‐September
October‐December
2013:
January‐March
April‐June
July‐September
October‐December
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.‐‐ If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 4:
Product 5:
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IV‐2b. Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.
IV‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales of boltless steel
shelving (check all that apply)? If your firm issues price lists, please submit sample pages of a
recent list.
Transaction
by
transaction
Contracts
IV‐4.
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced boltless steel shelving?
Net 30
days
(b)
IV‐6.
If other, describe
Annual Promotional
No
discounts
total
(i.e. Black discount
volume
policy
Friday)
discounts
Other
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
IV‐5.
Set
price
lists
Net 60
days
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic boltless steel shelving usually quoted
(check one)?
Delivered
F.o.b.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of its U.S.‐produced
boltless steel shelving in 2014 was on a (1) long‐term contract basis, (2) annual contract basis,
(3) short‐term contract basis, and (4) spot sales basis?
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Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2014
sales
IV‐7.
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
0.0
%
Contract provisions. ‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced boltless steel shelving (or check “not applicable” if your firm does not sell on a
long term, short term and/or annual contract basis).
Typical sales
contract provisions
Item
Short‐term contracts
(multiple deliveries
for less than 12
months)
Average contract
duration
# of days
365
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
Lead times.‐‐What is your firm’s share of sales both from inventory and produced to order and
what is the typical lead time between a customer’s order and the date of delivery for your firm’s
sales of its U.S.‐produced boltless steel shelving?
Share of 2014 Lead time (average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
Long‐term contracts
(multiple deliveries for
more than 12 months)
Yes
Price renegotiation
(during contract
period)
IV‐8.
Annual contracts
(multiple
deliveries for 12
months)
0.0 %
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U.S. Producers’ Questionnaire – Boltless steel shelving
IV‐9.
Page 29
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced
boltless steel shelving that is accounted for by U.S. inland transportation costs?
percent
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of boltless steel shelving that
are delivered the following distances from its production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced boltless steel shelving since January 1, 2012 (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, and VI, among others.
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IV‐11. End uses.‐‐List the end uses (e.g., home improvement projects, storage organization, etc.) of the
boltless steel shelving that your firm produces.
IV‐12. Substitutes.‐‐Can other products be substituted for boltless steel shelving?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for boltless steel shelving?
No Yes
Explanation
1.
2.
3.
IV‐13. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for boltless steel shelving has changed since January 1, 2012. Explain any
trends and describe the principal factors that have affected these changes in demand.
Market
Overall
No
Overall
increase change decrease
Fluctuate
with no
clear trend
Explanation and factors
Within
the United
States
Outside
the United
States
IV‐14. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of boltless steel shelving since January 1, 2012?
No
Yes
If yes, please describe and quantify if possible.
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IV‐15. Conditions of competition.‐‐
(a) Is the boltless steel shelving market subject to business cycles (other than general
economy‐wide conditions) and/or other conditions of competition distinctive to boltless
steel shelving? If yes, describe.
Check all that apply.
Please describe.
No
Skip to question IV‐16.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
boltless steel shelving since January 1, 2012?
No
Yes
If yes, describe.
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IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply boltless steel
shelving since January 1, 2012 (examples include placing customers on allocation or “controlled
order entry,” declining to accept new customers or renew existing customers, delivering less
than the quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐17. Raw materials.‐‐How have boltless steel shelving raw materials prices changed since January 1,
2012?
Fluctuate
with no Explain, noting how raw material price changes
clear have affected your firm’s selling prices for boltless
Overall
No
Overall
trend steel shelving.
increase change decrease
IV‐18. Interchangeability.‐‐Is boltless steel shelving produced in the United States and in other
countries interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing boltless steel shelving that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that limit or preclude
interchangeable use:
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IV‐19. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between boltless steel shelving
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of boltless steel shelving, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
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IV‐20. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for boltless steel shelving since January 1, 2012. Indicate the share of the quantity of
your firm’s total shipments of boltless steel shelving that each of these customers accounted for
in 2014.
Customer’s name
City
State
Share of 2014
sales (%)
1
2
3
4
5
6
7
8
9
10
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IV‐21. Competition from imports.‐‐
(a)
Lost revenue.‐‐Since January 1, 2012: To avoid losing sales to competitors selling
boltless steel shelving from China, did your firm:
No
Yes
Reduce prices
Roll back announced price increases
(b)
Lost sales.‐‐Since January 1, 2012: Did your firm lose sales of boltless steel shelving to
imports of this product from China?
No
Yes
(c)
The submission of lost sales/lost revenue allegations is to be completed only by NON‐
PETITIONERS. (Note: petitioners may provide allegations involving quotes made
AFTER the filing of the petitions.) Please do not resubmit allegations provided
previously.
If your firm indicated “yes” to any of the above, your firm can provide the Commission
with additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: SHLV)
IV‐22. Other explanations‐‐If your firm would like to further explain a response to a question in Part IV
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Producers’ Questionnaire – Boltless steel shelving
Page 36
HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
http://www.usitc.gov/investigations/701731/2015/boltless_steel_shelving_units_prepa
ckaged_sale/final.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods
noted below. If your firm is unable to complete the MS Word questionnaire or
cannot use one of the electronic methods of submission, please contact the
Commission for further instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy
of the signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/ Pin: SHLV
• E‐mail.—E‐mail the MS Word questionnaire to Keysha.Martinez@usitc.gov; include a scanned
copy of the signed certification page (page 1). 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.
If your firm does not produce this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a
copy of the completed questionnaire on parties to the proceeding that are subject to
administrative protective order (see 19 CFR §207.7). A list of such parties may be obtained from
the Commission’s Secretary (202‐205‐1803). A certificate of service must accompany the
completed questionnaire you submit (see 19 CFR §207.7). Service of the questionnaire must be
made in paper form.
| File Type | application/pdf |
| File Title | Boltless Steel Shelving Units Prepackaged for Sale from China--U.S. Producer Questionnaire |
| Subject | boltless steel shelving, china, antidumping, countervailing duty, 701, 731, final, final-phase, producer, questionnaire |
| Author | Keysha Martinez |
| File Modified | 2015-05-20 |
| File Created | 2015-05-20 |