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pdfOMB No. 3117-0016/USITC No. 15-1-3420; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
CERTAIN POLYETHYLENE TEREPHTHALATE RESIN FROM
CANADA, CHINA, INDIA, AND OMAN
This questionnaire must be received by the Commission by January 5, 2016
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/antidumping duty investigation(s) concerning Polyethylene Terephthalate Resin (PET
resin) from Canada, China, India, and Oman (Inv. Nos. 701-TA-531-533; 731-TA-1270-1273 (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 PET resin (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: PRES)
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 - Certain PET resin
Page 2
PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 10, 2015, by DAK
Americas LLC (Charlotte, NC), M&G Chemicals (Houston, TX), and Nan Ya Plastics Corporation, America
(Lake City, SC). 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/dumping. Questionnaires and other information pertinent to this proceeding are available
at
http://www.usitc.gov/investigations/701731/2015/certain_polyethylene_terephthalate_resin_canada/f
inal.htm.
Certain PET resin covered by these investigations is polyethylene terephthalate (PET) resin having an
intrinsic viscosity of at least 0.70, but not more than 0.88, deciliters per gram. The scope includes blends
of virgin PET resin and recycled PET resin containing predominantly virgin PET resin content, provided
such blends meet the intrinsic viscosity requirements above. The scope includes all PET resin meeting
the above specifications regardless of additives introduced in the manufacturing process. The
merchandise subject to these investigations is properly classified under statistical reporting number
3907.60.00.30 of the Harmonized Tariff Schedule of the United States (HTSUS). Although the HTSUS
subheading is provided for convenience and customs purposes, the written description of the
merchandise under 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.
Business Proprietary
U.S. Producers’ Questionnaire - Certain PET resin
I-1a.
Page 3
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 PET resin, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
covered1
City, State
Zip (5 digit)
Description2
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
.
Please include the date of establishment and a brief description of the current activities of the
establishment.
2
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U.S. Producers’ Questionnaire - Certain PET resin
I-3.
Page 4
Petition support.--Does your firm support or oppose the petition?
Country
Support
Oppose
Take no position
Canada
China
India
Oman
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 PET resin from Canada, China, India, and/or Oman into
the United States or that are engaged in exporting PET resin from Canada, China, India, and/or
Oman to the United States?
No
Firm name
I-6a.
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 PET resin?
No
Firm name
Yes--List the following information.
Address
Affiliation
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U.S. Producers’ Questionnaire - Certain PET resin
I-6b.
Page 5
Related producers.—Do any of these related firms supply PET resin to the subject countries?
No
Yes--Please describe the quantities and list which subject countries.
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U.S. Producers’ Questionnaire - Certain PET resin
Page 6
PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Michael Haberstroh (202205-3390, michael.haberstroh@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 PET resin since January 1, 2012.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
planned expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)
(please describe)
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U.S. Producers’ Questionnaire - Certain PET resin
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 PET resin, 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 1,000 pounds)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Overall production capacity
(A)
Production of:
PET resin.-Hot-Fill PET resin
applications (B)
Cold-Fill PET resin
applications (C)
Subject PET resin (D)
0
0
0
0
0
0
0
0
0
0
1
Other products (E)
Total (F)
1
Please identify these products:
.
RECONCILIATION OF PRODUCTION.—Production of PET resin report in this table (lines B plus C) should be
exactly equal to production reported in question II-7 (line I).
Calendar years
Reconciliation
B + C – I should equal zero,
revise if not.
2012
2013
0
January-September
2014
0
2014
0
2015
0
0
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U.S. Producers’ Questionnaire - Certain PET resin
Page 8
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.
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 PET resin and other products using
the same equipment and/or labor?
No
(ii)
hours
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.
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U.S. Producers’ Questionnaire - Certain PET resin
II-4.
Page 9
Tolling.--Since January 1, 2012, has your firm been involved in a toll agreement regarding the
production of PET resin?
“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
II-5.
Yes--Please describe the toll arrangement(s) and name the firm(s) involved
Foreign trade zones.-Firm's FTZ operations.--Does your firm produce PET resin in and/or admit PET resin into
a foreign trade zone (FTZ)?
(a)
“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).
Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import PET resin into a foreign trade zone (FTZ) for use in distribution of PET resin
and/or the production of downstream articles?
(b)
No/Don’t know
II-6.
Yes--Identify the firms and the FTZs.
Importer.--Since January 1, 2012, has your firm imported PET resin?
“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 - Certain PET resin
II-7.
Page 10
Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of PET resin 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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U.S. Producers’ Questionnaire - Certain PET resin
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Production, shipment and inventory data.--Continued
II-7.
Quantity (in 1,000 pounds) and value (in $1,000)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
1
Average production capacity (quantity) (G)
Beginning-of-period inventories (quantity)
(H)
Production (quantity) (I)
U.S. shipments:
Commercial shipments:
Quantity (J)
Value (K)
Internal consumption:
Quantity (L)
2
Value (M)
Transfers to related firms:
Quantity (N)
2
Value (O)
Export shipments:
Quantity (P)
34
Value (Q)
End-of-period inventories (quantity) (R)
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:
.
4
What share of your firm's exports in 2014 were exports to related parties or used for internal consumption by your
firm abroad?
percent.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line R) should be equal to the beginning-of-period inventories (i.e., line H), plus
production (i.e., line I), less total shipments (i.e., lines J, L, N, and P). 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
H + I – J – L – N – P – R = should equal
zero ("0") or provide an explanation.1
1
2012
2013
0
January-September
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 - Certain PET resin
II-8.
Page 12
Channels of distribution.--Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in 1,000 pounds)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Channels of distribution:
Commercial U.S. shipments:
To distributors (S)
To end users.—
Bottle producers
Soda bottlers (T)
Water bottlers (U)
Hot-fill bottlers (V)
Other bottlers (W)
Carpeting manufacturers (X)
Sheet, packaging, and strapping
manufacturers (Y)
Other end users (Z)1
1
Please describe the other end users:
.
Calendar years
Reconciliation
S + T + U + V + W + X + Y + Z – J = zero
("0"), if not revise.
2012
2013
0
January-September
2014
0
2014
0
2015
0
0
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U.S. Producers’ Questionnaire - Certain PET resin
II-9.
Page 13
Mode of transportation.--Report your firm’s commercial U.S. shipments by modes of
transportation.
Quantity (in 1,000 pounds)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
Mode of transportation:
Commercial U.S. shipments:
Shipped entirely via rail (quantity) (AA)1
Shipped entirely via truck (quantity) (AB)
Shipped by a combination of both truck
and rail (e.g., bimodal) (quantity) (AC)
Shipped via other modes (quantity) (AD)2
1
Please list the largest customers reported here that received shipments of PET resin from your firm via rail delivery directly
into their facilities, indicate the end use(s) of the shipped PET resin, and the geographic location of those customers.
.
2
Describe the "other" modes.
.
Calendar years
Reconciliation
AA + AB + AC + AD – J = zero ("0"), if not
revise.
2012
2013
0
January-September
2014
0
2014
0
2015
0
0
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U.S. Producers’ Questionnaire - Certain PET resin
II-10.
Page 14
Employment data.--Report your firm’s employment-related data related to the production of
PET resin 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 September periods, calculate similarly and divide by 9.
“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-September
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-11.
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 - Certain PET resin
II-12.
Page 15
Purchases.—
“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 (including from
a related party).
“Direct import” –A transaction to buy from a foreign producer where your firm is the importer
of record or consignee.
(a)
Other than direct imports, has your firm otherwise purchased PET resin since January 1,
2012?
No
Yes--Report such purchases below and explain the reasons for your firms'
purchases:
(Quantity in 1,000 pounds)
Calendar years
Item
2012
2013
January-September
2014
2014
2015
1
Purchases from U.S. importers of PET
resin from—
Canada
China
India
Oman
Purchases of subject imports1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Mexico
Korea
Taiwan
All other sources
Purchases of nonsubject imports2
Purchases of imports
Purchases from domestic producers
3
Purchases from other sources3
TOTAL PURCHASES4
1
Please list the name of the subject 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 nonsubject 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:
.
3
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
4
This should represent all your firm's purchases of PET resin except any purchases where your firm served as the importer
of record for U.S. Customs purposes.
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U.S. Producers’ Questionnaire - Certain PET resin
II-12.
Purchases.—Continued
(b)
Do any of the data reported in questions II-7 (production, shipments, and inventories) or
question III-9a (Operations on certain PET resin) include data sourced from the
purchases reported above?
No
II-13.
Page 16
Yes—PLEASE REVISE the data in questions II-7 and III-9a to exclude
data for resales of PET resin not produced by your firm prior
to submission of this questionnaire response to the
Commission.
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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Page 17
PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, mary.klir@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 certain PET resin:
2.
Does your firm prepare profit/loss statements for certain PET resin:
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,
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 certain PET resin, as
well as specific statements and worksheets) used to compile these data.
III-3.
Cost accounting system/Inventories.--Briefly describe your firm’s cost accounting system (e.g.,
standard cost, job order cost) and your firm’s basis for valuing raw material inventories (e.g.,
FIFO, LIFO, weighted average) related to certain PET resin operations, as well as the average
number of weeks of MEG and PTA inventories maintained for normal operations.
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Page 18
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.
III-5.
Other products.--Please list the products your firm produced in the facilities in which your firm
produced certain PET resin, 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
Certain PET resin
%
%
%
%
%
III-6.
Input purchases.--Does your firm purchase inputs (raw materials, labor, energy, or any services)
used in the production of certain PET resin 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 certain PET
resin 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 - Certain PET resin
III-8.
Page 19
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 certain PET
resin) 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.
Business Proprietary
U.S. Producers’ Questionnaire - Certain PET resin
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III-9a. Operations on certain PET resin--Report the revenue and related cost information requested
below on the certain PET resin 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.
Quantity (in 1,000 pounds) and value (in $1,000)
Fiscal years ended-Item
2012
2013
January-September
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
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
Net income or (loss) before income taxes
0
0
0
0
0
Depreciation/amortization included above
0
0
0
0
0
2
Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
3
Cost of goods sold (COGS):
Raw materials: MEG and related costs
Raw materials: PTA and related costs
Raw materials: All other
Total Raw materials
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
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts (including all applicable rebates that affect net sales values), 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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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.
Raw material inputs from related suppliers at cost.—If your firm provided data for question
III-7, please provide an alternative valuation for the reported raw material costs in table III-9a
which eliminates all profit on inputs purchased from related suppliers (i.e., raw material costs
reported below should reflect: (a) the related supplier’s cost with elimination, as necessary, of
an associated profit component for your firm’s raw materials purchased from related suppliers,
and (b) your firm’s costs for all other raw materials purchased from unrelated suppliers).
Reasonable methods for determining and eliminating the associated profit on raw materials
purchased from related suppliers are acceptable. Provide the alternative raw material 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-September
2014
2014
2015
MEG exclusive of related supplier
profit, as applicable
PTA exclusive of related supplier
profit, as applicable
Other raw material costs exclusive of
related supplier profit, as applicable
Total
0
0
0
0
0
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III-11a. Effects of raw material prices on reported profitability .—Does your firm purchase all of the
MEG and PTA used in the production of certain PET resin at prevailing market prices at the time
of purchase?
Yes
No
If no, in the space below please explain: (1) the bases for pricing MEG and PTA; (2) the market
indices utilized in any pricing formulae; (3) the portion of your 2014 MEG and PTA purchases
made using these other price bases.
III-11b. Effects of increasing raw material prices on reported profitability .—Please discuss your firm’s
experience with increasing prices for MEG and PTA and the lag between purchases of these raw
materials and their use in the production of certain PET resin. How has this timing difference
(i.e., between raw materials valued at historical cost and used in the production of certain PET
resin and the subsequent sale of certain PET resin at current market prices) impacted your firm’s
reported profitability in table III-9a? When MEG and PTA prices increase, to what extent do
customers resist price increases on certain PET resin or delay purchases of certain PET resin?
III-11c. Effects of decreasing raw material prices on reported profitability .—Please discuss your firm’s
experience with decreasing prices for MEG and PTA and the lag between purchases of these raw
materials and their use in the production of certain PET resin. How has this timing difference
(i.e., between raw materials valued at historical cost and used in the production of certain PET
resin and the subsequent sale of certain PET resin at current market prices) impacted your firm’s
reported profitability in table III-9a? When MEG and PTA prices decrease, to what extent do
customers immediately push for price decreases on certain PET resin?
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III-12. 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-September
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
III-13. 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-12, please identify
where your company recorded these items in your accounting books and records in the normal
course of business; i.e., III-12 information designates where these items are reported in table III9a.
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III-14. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of certain PET resin. If your firm does not maintain some
or all of the specific asset information necessary to calculate total assets for certain PET resin 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-15.
2012
2013
2014
1
Describe
Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for certain PET resin. Provide data for
your firm’s three most recently completed fiscal years, and for the specified interim periods.
Please include in your response all capital expenditures and/or R&D expenses related to new
facilities (open/completed or not) associated with the production of certain PET resin.
Value (in $1,000)
Fiscal years ended-Item
2012
2013
January-September
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.
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Page 25
III-16. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13 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-17a. 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 certain PET resin from Canada, China, India, and/or Oman?
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-17b. Does your firm’s response differ by country?
No
Yes
If yes, indicate which country and why:
(please describe)
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III-18a. 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 certain PET resin from Canada, China, India,
and/or Oman?
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-18b. Does your firm’s response differ by country?
No
Yes
If yes, indicate which country and why:
(please describe)
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Page 27
III-19a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
certain PET resin from Canada, China, India, and/or Oman?
No
Yes
If yes, my firm anticipates negative effects as follows:
III-19b. Does your firm’s response differ by country?
No
Yes
If yes, indicate which country and why:
III-20. 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 MARKET FACTORS
Further information on this part of the questionnaire can be obtained from John Benedetto (202-2053270, john.benedetto@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.—PET resin, being either a clear homo- or co-polymer, and having an intrinsic
viscosity of 0.72 IV to 0.84 IV, in the solid stated form. This PET resin product is
typically used in water bottle applications.
Product 2.—PET resin, being either a clear homo- or co-polymer, and having an intrinsic
viscosity of 0.72 IV to 0.84 IV, in the solid stated form. This PET resin product is
typically used in sheet and strapping.
Product 3.--PET resin, being either a clear homo- or co-polymer, and having an intrinsic
viscosity of 0.78 IV to 0.86 IV, in the solid stated form. This PET resin product is
typically used in carbonated soft drink applications.
Product 4.—PET resin, being mainly a co-polymer, and having an intrinsic viscosity of 0.75 IV
to 0.86 IV, in the solid stated form. This PET resin product is typically used in heat
set or hot fill applications; food, household, and other products.
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).
During January 2012-September 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(s) as appropriate.
No.--Skip to question IV-3.
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U.S. Producers’ Questionnaire - Certain PET resin
IV-2.
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Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in actual pounds and actual dollars (not 1,000s).
Product 1
Quantity
Value
(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
Period of shipment
Quantity
Value
2012:
January-March
April-June
July-September
OctoberDecember
2013:
January-March
April-June
July-September
OctoberDecember
2014:
January-March
April-June
July-September
OctoberDecember
2015:
January-March
April-June
July-September
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:
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.
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IV-3a. Price setting.-- How does your firm determine the prices that it charges for sales of PET resin
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
IV-3b
Contracts
Yes
If other, describe
If yes, please briefly describe each pricing mechanism
Discount policy.-- Please indicate and describe your firm’s discount policies (check all that
apply).
Quantity
discounts
IV-5.
Other
Do your firm’s contracts set prices based on a comparison to raw material costs or raw material
price indexes?
No
IV-4.
Set
price
lists
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 PET resin?
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 PET resin usually quoted (check one)?
Delivered
F.o.b.
If f.o.b., specify point
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U.S. Producers’ Questionnaire - Certain PET resin
IV-6.
Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced PET
resin 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
IV-7.
Page 31
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
%
Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced PET resin (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
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 PET resin?
Source
Average lead time
Share of 2014 (average number
sales
of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
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IV-9.
Page 33
Shipping information.-(a)
What is the approximate percentage of the total delivered cost of U.S.-produced PET
resin that is accounted for by U.S. inland transportation costs?
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 PET resin 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-10a. Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced PET resin 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.
IV-10b. Geographical shipments.—If your firm’s PET resin is only available in a few geographic market
areas, please describe what limits its availability in other regions.
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IV-10c. Geographical shipments.—Does your firm’s PET resin compete with PET resin from U.S.
producers and other subject countries in all U.S. geographic regions?
No
Yes
Please describe any limitations or lack thereof, and attach any available
documentation to the questionnaire.
IV-11a. End uses.--List the end uses of the PET resin that your firm manufactures. For each end-use
product, what percentage of the total cost is accounted for by PET resin and other inputs?
Share of total cost of end-use product
accounted for by
End use product
PET resin
Other inputs
Total
(should sum to
100.0% across)
Bottled water/soda.-Excluding liquid
contents (e.g., just
the bottle)
%
%
0.0 %
Inclusive of liquid
contents (e.g., final
bottled product)
%
%
0.0 %
Carpet
%
%
0.0 %
Roll of PET sheet
%
%
0.0 %
PET strapping
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
Other:
%
%
0.0 %
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IV-11b. End uses.—Does your firm’s PET resin compete with PET resin from other U.S. producers,
Canada, China, India, and/or Oman across all end uses?
PET resin source
United States
Canada
China
India
Oman
Other
Competes with
your firm’s PET
resin in all end
uses
Does not
compete with
your firm’s PET
resin in all end
uses
List end uses in which other suppliers’ product
does not compete with your firm’s PET resin
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IV-12. Substitutes.-- Can other products be substituted for PET resin?
No
Substitute
Yes--Please fill out the table.
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for PET resin?
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 PET resin 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
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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of PET resin since January 1, 2012?
No
Yes
If yes, please describe and quantify if possible.
IV-15. Conditions of competition.-(a) Is the PET resin market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to PET resin? 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
PET resin since January 1, 2012?
No
Yes
If yes, describe.
IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply PET resin 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.
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IV-17. Raw materials.--How have PET resin raw materials prices changed since January 1, 2012?
Overall
increase
No
change
Fluctuate Explain, noting how raw
Explain, noting how raw
with no
material price increases
material price decreases
clear
have affected your firm’s have affected your firm’s
Overall
decrease trend
selling prices for PET resin. selling prices for PET resin.
IV-18. Interchangeability.--Is PET resin 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
Countrypair
Canada
China
India
Oman
Other countries
United
States
Canada
China
India
Oman
For any country-pair producing PET resin which is sometimes or never interchangeable, please
identify the country-pair and explain the factors that limit or preclude interchangeable use:
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U.S. Producers’ Questionnaire - Certain PET resin
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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 PET resin 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
Countrypair
Canada
China
India
Oman
Other countries
United
States
Canada
China
India
Oman
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of PET resin, 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 PET resin since January 1, 2012. Indicate the share of the quantity of your firm’s
total shipments of PET resin that each of these customers accounted for in 2014.
Customer’s name
1
2
3
4
5
6
7
8
9
10
City
State
Share of 2014 sales (%)
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IV-21. Competition from imports
(a)
Lost revenue.--Since January 1, 2012: To avoid losing sales to competitors selling PET
resin from Canada, China, India, and/or Oman, 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 PET resin to imports of this
product from Canada, China, India, and/or Oman?
No
Yes
IV-22. Average selling price.--Please estimate the average selling price in 2015 for PET resin sold by
different modes of packaging/transport:
Rail car direct
Rail car plus bulk truck
Bulk truck direct
Super sacs
IV-23. 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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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/certain_polyethylene_terephthalate
_resin_canada/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: PRES
• E-mail.—E-mail the MS Word questionnaire to michael.haberstroh@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 Type | application/pdf |
| File Title | USITCQUESTIONNAIRE |
| Subject | Title 7 investigations |
| Author | Benedetto, John |
| File Modified | 2015-12-15 |
| File Created | 2015-12-15 |