Form 15-1-3375 U.S. Producers Questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

U.S. Producer Questionnaire

Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes from Korea, Mexico and Turkey Inv. No. 701-TA-539 and 731-1280-1282 Preliminary

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 15-1-3375; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
HEAVY WALLED RECTANGULAR WELDED CARBON STEEL PIPES AND TUBES
FROM KOREA, MEXICO, AND TURKEY
This questionnaire must be received by the Commission by August 4, 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 heavy walled rectangular welded
carbon steel pipes and tubes (“HWR”) from Korea, Mexico, and Turkey (Inv. Nos. 701-TA-539 and 731-TA-1280-1282
(Preliminary)). The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930,
title VII. This report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the
submission of records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced HWR (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: HWR15)
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

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U.S. Producers’ Questionnaire - HWR

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PART I.--GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on July 21, 2015, by Atlas
Tube, a division of JMC Steel Group (Chicago, Illinois), Bull Moose Tube Company (Chesterfield,
Missouri), EXLTUBE (North Kansas City, Missouri), Hannibal Industries, Inc. (Los Angeles, California),
Independence Tube Corporation (Chicago, Illinois), Maruichi American Corporation (Santa Fe Springs,
California), Searing Industries (Rancho Cucamonga, California), and Southland Tube (Birmingham,
Alabama). Countervailing and/or antidumping duties may be assessed on the subject imports as a result
of these proceedings if the Commission makes an affirmative determination of injury, threat, or material
retardation, and if the U.S. Department of Commerce 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/heavy_walled_rectangular_welded_carbon_steel_pi
pes/preliminary.htm
Heavy Walled Rectangular Welded Carbon Steel Pipes and Tubes.--The products covered by
these investigations include certain welded carbon steel pipes and tubes of rectangular
(including square) cross section, having a wall thickness of not less than 4mm, not threaded and
not otherwise advanced.
Included products are those in which: (1) iron predominates, by weight, over each of the other
contained elements; (2) the carbon content is 2 percent or less, by weight; and (3) none of the
elements listed below exceeds the quantity, by weight, respectively indicated:
•
•
•
•
•
•
•
•
•
•
•
•
•

2.50 percent of manganese, or
3.30 percent of silicon, or
1.50 percent of copper, or
1.50 percent of aluminum, or
1.25 percent of chromium, or
0.30 percent of cobalt, or
0.40 percent of lead, or
2.0 percent of nickel, or
0.30 percent of tungsten, or
0.80 percent of molybdenum, or
0.10 percent of niobium (also called columbium), or
0.30 percent of vanadium, or
0.30 percent of zirconium.

The subject merchandise is currently provided for in item 7306.61.1000 of the Harmonized Tariff
Schedule of the United States (“HTSUS”). While the 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

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Page 3

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. In addition, if your firm is a U.S. producer, the information you
provide on your production and imports of HWR 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.

Business Proprietary
U.S. Producers’ Questionnaire - HWR
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?
Yes

I-2.

No

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 HWR, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

Description

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

.

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U.S. Producers’ Questionnaire - HWR
I-3.

Page 5

Petition support.--Does your firm support or oppose the petition?
Country

Support

Oppose

Take no position

Korea AD
Mexico AD
Turkey AD
Turkey CVD

I-4.

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

Firm name

I-5.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing HWR from Korea, Mexico, or Turkey into the United
States or that are engaged in exporting HWR from Korea, Mexico, or Turkey to the United
States?
No
Firm name

I-6.

Yes--List the following information.

Yes--List the following information.
Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of HWR?
No
Firm name

Yes--List the following information.
Address

Affiliation

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Carolyn Carlson (202-2053002, Carolyn.Carlson@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 HWR since January 1, 2012.
(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)

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II-3a.

Page 7

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce HWR, and the combined production
capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
“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 short tons)
Calendar years
Item

2012

2013

January-June
2014

2014

2015

Overall production capacity (A)
Production of:
Subject merchandise/HWR1 (B)

0

0

0

0

0

0

0

0

0

0

Other rectangular (including square) tubing (C)
Other2 (D)
Total production (E)
1

Data entered for production of HWR will populate here once reported in question II-7.
Please identify these products:
.
3
Generally, total production (line E) will not exceed capacity (line A) in any given time period. If it does, please
explain.
.
2

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on operating
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.

hours

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II-3d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

II-3e.

Product shifting.-(i)

Is your firm able to switch production (capacity) between HWR and other products using the
same equipment and/or labor?
No

(ii)

II-4.

Yes--(i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

Tolling.--Since January 1, 2012, has your firm been involved in a toll agreement regarding the
production of HWR?
“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

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II-5.

Page 9

Foreign trade zones.--

“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.
II-5a

Firm's FTZ operations.--Does your firm produce HWR in and/or admit HWR into a
foreign trade zone (FTZ)?
No

II-5b

Yes--Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import HWR into a foreign trade zone (FTZ) for use in distribution of HWR and/or the
production of downstream articles?
No/Don’t know

II-6.

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2012, has your firm imported HWR?
“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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II-7.

Page 10

Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of HWR in its U.S. establishment(s) during
the specified periods.
“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.
“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.

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Production, shipment and inventory data.--

II-7.

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

2012

2013

January-June
2014

2014

2015

1

Average production capacity (quantity) (A)
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)
Export shipments:
Quantity (J)

3

Value (K)
4

End-of-period inventories (quantity) (L)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity
.
2
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-ofperiod 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
1

2012

2013

0

January-June
2014

0

2014

0

2015

0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

0
.

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U.S. Producers’ Questionnaire - HWR
II-8.

Page 12

Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2012

2013

January-June
2014

2014

2015

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To end users (quantity) (N)
Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.

2012

2013
0

January-June
2014

0

2014
0

2015
0

0

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U.S. Producers’ Questionnaire - HWR
II-9.

Page 13

Employment data.--Report your firm’s employment-related data related to the production of
HWR 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 June periods, calculate similarly and divide by 6.
“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-June
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 nonmarket 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 - HWR
II-11.

Page 14

Purchases.--Other than direct imports, has your firm otherwise purchased HWR 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 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 short tons)
Calendar years
Item

2012

2013

January-June
2014

2014

2015

Purchases from U.S.
importers1 of HWR from-Korea
Mexico
Turkey
All other countries
Purchases from domestic
producers2
Purchases from other
sources2
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 U.S. distributor(s) from which your firm purchased this product:
.

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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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
below:

B.1.

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

2.

Does your firm prepare profit/loss statements for HWR:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10 Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

3.

4.

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 HWR, 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 - HWR
III-5.

Page 16

Other products.--Please list the products your firm produced in the facilities in which your firm
produced HWR, and provide the share of net sales accounted for by these other products in
your firm’s most recent fiscal year.
Products

Share of sales

HWR

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of HWR from any related suppliers (e.g., inclusive of transactions between related
firms, divisions and/or other components within the same company)?
Yes--Continue to question III-7.

III-7.

No--Continue to question III-9a.

Inputs from related suppliers.--Please identify the inputs used in the production of HWR that
your firm purchases from related suppliers 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 supplier; e.g., the
related supplier’s actual cost, cost plus, negotiated transfer price to approximate fair market
value.
Input

Related supplier

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records

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U.S. Producers’ Questionnaire - HWR
III-8.

Page 17

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on HWR) 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
suppliers as reported in table III-9a.

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III-9a. Operations on HWR.--Report the revenue and related cost information requested below on the
HWR operations of your firm’s U.S. establishment(s).1 Do not report resales of products. Note
that internal consumption and transfers to related firms must be valued at fair market value.
Input purchases from related suppliers should be consistent with and based on information in
the firm’s accounting books and records. Provide data for 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 short tons) and value (in $1,000)
Fiscal years ended-Item

2012

2013

January-June
2014

2014

2015

2

Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

0

0

0

0

0

0

0

0

0

0

Total COGS

0

0

0

0

0

Gross profit or (loss)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

0

2

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials

3

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
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
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
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.
2

Note -- The table above contains calculations that will appear when you have entered data in the MS
Word form fields.

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U.S. Producers’ Questionnaire - HWR

Page 19

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

2013

January-June
2014

2014

2015

Nonrecurring item: In this column please provide a brief
Nonrecurring item: In these columns please report the amount of the relevant
description of each nonrecurring item and indicate the
nonrecurring item reported in table III-9a.
specific line item in table III-9a where the nonrecurring item is
classified.
Value ($1,000)
1.

, classified as

2.

, classified as

3.

, classified as

4.

, classified as

5.

, classified as

6.

, classified as

7.

, classified as

Business Proprietary
U.S. Producers’ Questionnaire - HWR

Page 20

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 HWR. If your firm does not maintain some or all of the
specific asset information necessary to calculate total assets for HWR 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
Total assets (net)
1

III-13.

2012

2013

2014

1

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on HWR. 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-June
2014

2014

2015

Capital expenditures
Research and development expenses
1

Please indicate the nature, focus, and significance of your firm’s capital expenditures on the subject product.

Business Proprietary
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Page 21

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-15a. Effects of imports on investment.--Since January 1, 2012, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of HWR from Korea, Mexico, and/or Turkey?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

III-15b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
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Page 22

III-16a. Effects of imports on growth and development.--Since January 1, 2012, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of HWR from Korea, Mexico, and/or Turkey?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Rejection of bank loans

Lowering of credit rating

Problem related to the issue
of stocks or bonds
Ability to service debt

Other

III-16b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

(please describe)

Business Proprietary
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Page 23

III-17a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
HWR from Korea, Mexico, and/or Turkey?
No

Yes

If yes, my firm anticipates negative effects as follows:

III-17b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

III-18. 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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Page 24

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Amelia Preece (202-2053250, Amelia.Preece@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.-- 2 inch square ASTM A-500 Grade B with a wall thickness of 0.250 inch
Product 2.-- 3 inch square ASTM A-500 Grade B with a wall thickness of 0.250 inch
Product 3.-- 4 inch square ASTM A-500 Grade B with a wall thickness of 0.250 inch
Product 4.-- 6 inch square ASTM A-500 Grade B with a wall thickness of 0.250 inch

Please note that values should be delivered to the purchaser and should 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).
During January 2012-June 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 table as appropriate.
No.--Skip to question IV-3.

Business Proprietary
U.S. Producers’ Questionnaire - HWR
IV-2.

Page 25

Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.

Report data in actual feet and actual dollars (NOT 1,000s).
Product 1
Quantity
Value

(Quantity in feet, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

Product 4
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
April-June
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
delivered to the purchaser.
2
Pricing product definitions are provided on the first page of Part IV.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a
description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.

Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in
the preparation of the price data, as Commission staff may contact your firm regarding questions on the
price data. The Commission may also request that your company submit copies of the supporting
documents/records (such as sales journal, invoices, etc.) used to compile these data.

Business Proprietary
U.S. Producers’ Questionnaire - HWR
IV-3.

Price setting.--How does your firm determine the prices that it charges for sales of HWR
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction

IV-4.

Contracts

Other

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced HWR?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic HWR usually quoted (check one)?
Delivered

IV-6.

Set
price
lists

Discount policy.--Please indicate and describe your firm’s discount policies (check all that apply).

Quantity
discounts

IV-5.

Page 26

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 HWR
in 2014 was on a (1) long-term contract basis, (2) annual contract basis, (3) short-term contract
basis, and (4) spot sales basis?

Share of 2014
sales

Long-term
contracts
(multiple
deliveries for
more than 12
months)
%

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

%

Business Proprietary
U.S. Producers’ Questionnaire - HWR
IV-7.

Page 27

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced HWR (or check “not applicable” if your firm does not sell on a long-term, shortterm and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

# of days

Short-term contracts
(multiple deliveries
for less than 12
months)

Annual contracts
(multiple
deliveries for 12
months)

Long-term contracts
(multiple deliveries for
more than 12 months)

365

Yes

Price renegotiation
(during contract
period)

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

No

Not applicable
IV-8.

Lead times.--What is your firm’s share of sales 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 HWR?

Source

Share of 2014 Lead time (average
sales
number of days)

From inventory

%

Produced to order

%

Total (should sum to 100.0%)

0.0 %

Business Proprietary
U.S. Producers’ Questionnaire - HWR
IV-9.

Page 28

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced HWR
that is accounted for by U.S. inland transportation costs? For example, if you sell HWR
for $100 f.o.b., and inland transportation costs $50, the percent would be 50/(100+50) =
33%.
percent

(b)

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

(c)

Indicate the approximate percentage of your firm’s sales of HWR 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 HWR since January 1, 2012 (check all that apply)?
Geographic area
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.

√ if applicable

Business Proprietary
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IV-11. End uses.--List the end uses of the HWR that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by HWR and other inputs?
Share of total cost of end use product
accounted for by
End use product

HWR

Total
(should sum to
100.0% across)

Other inputs
%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

IV-12. Substitutes.--Can other products be substituted for HWR?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the prices of this substitute
affected the price for HWR?
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 HWR has changed since January 1, 2012. Explain any trends and describe
the principal factors that have affected these changes in demand.

Market
Within
the United
States
Outside
the United
States

Overall
increase

Fluctuate
No
Overall
with no
change decrease clear trend

Explanation and factors

Business Proprietary
U.S. Producers’ Questionnaire - HWR

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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of HWR since January 1, 2012?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a) Is the HWR market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to HWR? 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
HWR since January 1, 2012?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply HWR 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, been unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

IV-17. Raw materials.--How have HWR raw materials prices changed since January 1, 2012?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for HWR.

Business Proprietary
U.S. Producers’ Questionnaire - HWR

Page 31

IV-18. Interchangeability.--Is HWR 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

Korea

Mexico

Turkey

Other countries

United States
Korea
Mexico
Turkey
For any country-pair producing HWR that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire - HWR

Page 32

IV-19. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between HWR 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

Korea

Mexico

Turkey

Other countries

United States
Korea
Mexico
Turkey
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of HWR, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

Business Proprietary
U.S. Producers’ Questionnaire - HWR

Page 33

IV-20. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for HWR since January 1, 2012. Indicate the share of the quantity of your firm’s total
shipments of HWR that each of these customers accounted for in 2014.

Customer’s name

1
2
3
4
5
6
7
8
9
10

Contact person

Email

Telephone

City

State

Share
of
2014
sales
(%)

Business Proprietary
U.S. Producers’ Questionnaire - HWR

Page 34

IV-21. Competition from imports.-(a)

Lost revenue.--Since January 1, 2012: To avoid losing sales to competitors selling HWR
from Korea, Mexico, or Turkey, did your firm:
Korea
No

Yes

Mexico
No

Yes

Turkey
No

Yes

Reduce prices?
Roll back announced price increases?
(b)

Lost sales.--Since January 1, 2012: Did your firm lose sales of HWR to imports of this
product from Korea, Mexico, or Turkey
Korea
No

(c)

Mexico
Yes

No

Turkey
Yes

No

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS. (Note: petitioners may provide allegations involving quotes made
AFTER the filing of the petition.) 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: HWR15)

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.

Business Proprietary
U.S. Producers’ Questionnaire - HWR

Page 35

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/heavy_walled_rectangular_welded_
carbon_steel_pipes/preliminary.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: HWR15

• E-mail.--E-mail the MS Word questionnaire to Carolyn.Carlson@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 (202205-1803). 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 Typeapplication/pdf
File TitleUS producer questionnaire
SubjectTitle 7 investigations
AuthorEsko, Carolyn
File Modified2015-07-22
File Created2015-07-22

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