16-2-3461 U.S. Importers' Questionnaire

OMB No. 3117-0016/USITC No. 16-2-3461; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. IMPORTERS’ QUESTIONNAIRE
1,1,1,2 – TETRAFLUOROETHANE (R-134a) FROM CHINA
This questionnaire must be received by the Commission by March 17, 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 antidumping investigation concerning 1,1,1,2 – Tetrafluoroethane (R-134a) from China (Inv. No. 731TA-1313 (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 imported R-134a (as defined on next page) from any country at any time since January 1, 2013?

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: R134A)
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, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 3, 2016, by the
American HFC Coalition and its individual members (Amtrol, Inc., West Warwick, Rhode Island; Arkema,
Inc., King of Prussia, Pennsylvania; The Chemours Company FC LLC, Wilmington, Delaware; Honeywell
International Inc., Morristown, New Jersey; Hudson Technologies, Pearl River, New York; Mexichem
Fluor Inc., St. Gabriel, Louisiana; and Worthington Industries, Inc., Columbus, Ohio) and District Lodge
154 of the International Association of Machinists and Aerospace Workers. Antidumping duties may be
assessed on the subject imports as a result of this proceeding if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce makes
an affirmative determination of dumping. Questionnaires and other information pertinent to this
proceeding are available at:
https://www.usitc.gov/investigations/701731/2016/1112_tetrafluoroethane_r_134a_china/preliminary.htm.

1,1,1,2-Tetrafluoroethane (“R-134a”).--The product covered by this investigation is 1,1,1,2Tetrafluoroethane, R‐134a, or its chemical equivalent, regardless of form, type, or purity level. The
chemical formula for 1,1,1,2‐Tetrafluoroethane is CF3‐CH2F, and the Chemical Abstracts Service registry
number is CAS 811‐97‐2.1
Importer.--Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing R-134a (as defined above) into the United States from a foreign manufacturer or through its
selling agent.
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
1

1,1,1,2‐Tetrafluoroethane is sold under a number of trade names including Klea 134a and Zephex 134a
(Mexichem Fluor); Genetron 134a (Honeywell); Freon™ 134a, Suva 134a, Dymel 134a, and Dymel P134a
(Chemours); Solkane 134a (Solvay); and Forane 134a (Arkema). Generically, 1,1,1,2‐Tetrafluoroethane has been
sold as Fluorocarbon 134a, R‐134a, HFC‐134a, HF A‐134a, Refrigerant 134a, and UN3159.

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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.
I-1.

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
40 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-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”--Each facility of a firm involved in the importation of R-134a, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.

I-3.

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

Firm name

Yes--List the following information

Address

Extent of
ownership
(percent)

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U.S. Importers’ Questionnaire - R-134a
I-4.

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing R-134a from China into the United States or that are
engaged in exporting R-134a from China to the United States?
No

Yes--List the following information.

Firm name

I-5.

Address

Yes--List the following information.

Firm name

Address

Affiliation

Importing operations.--Please indicate the nature of your firm’s importing operations on R134a. More than one answer may be applicable.
Importer of record

I-6b.

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of R-134a?
No

I-6a.

Page 4

Takes title to the
imported product(s)

Consignee of the
imported products(s)

Customs broker or
freight forwarder

Nature of operations.--Please indicate the nature of your firm’s US operations on R-134a. More
than one answer may be applicable.
Distributor (i.e., imports R-134a and resells typically at wholesale to retailers and
end-users)
Repackager (i.e., imports R-134a and repackages into smaller containers for resale)
Retailer (i.e., imports R-134a and resells to consumers at retail)
Other (please describe):

____________________________________

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U.S. Importers’ Questionnaire - R-134a
I-7.

Consignee.--If your firm is an importer of record of R-134a but is not the consignee, please list
the consignees below (firm name, address, telephone number, and individual to contact).
Firm name

I-8.

Page 5

Contact and phone
number

Address

FTZ, TIB, or bonded warehouses.--Please indicate whether your firm enters R-134a into, or
withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports R-134a under the TIB (temporary importation under bond) program.
“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, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re-export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States(HTS).
No
Foreign trade zones
Bonded warehouses
Temporary importation under bond

Yes

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U.S. Importers’ Questionnaire - R-134a
I-9.

Page 6

Third-country trade activities.--To your knowledge, have the products subject to this
proceeding been the subject of any other import relief proceedings in the United States or in
any other countries?
No

Yes–Please specify.

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amy Sherman (202-2053289, amy.sherman@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 importation of R-134a since January 1, 2013.
(check as many as appropriate)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)

(If checked, please describe; leave blank if not
applicable)

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U.S. Importers’ Questionnaire - R-134a
II-3.

Page 8

Arranged imports.--Has your firm imported or arranged for the importation of R-134a for
delivery on or after December 31, 2015?
“Arranged imports” are imports for which your firm has placed an order with a foreign producer
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No

Yes–Fill out the table below.
Quantity (in short tons)

Period/Source

Jan-Mar 2016

Apr-Jun 2016

Jul-Sept 2016

Oct-Dec 2016

China
Other sources1
1

II-4.

Identify your other sources:

.

Reasons for importing if producer.--If your firm also produces R-134a in the United States,
please indicate the reasons for importing this product. If your firm’s reasons differ by source,
please elaborate.

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Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty-paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“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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IMPORTS FROM CHINA.–Report your firm’s imports and your firm’s shipments and inventories
of R-134a imported from China by your firm during the specified periods.

II-5.

CHINA

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

2013

2014

2015

Beginning-of-period inventories (quantity) (A)
Imports:1
Imports under HTS 2903.39.2020
Quantity (B)
Value (C)
Imports under HTS other than 2903.39.20202
Quantity (D)
Value (E)
U.S. shipments:
Commercial shipments:
Quantity (F)
Value (G)
Internal consumption/ company transfers:
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To retailers (quantity) (N)
To end users (quantity) (O)
1

Please identify the foreign producers, if known:
.
List the HTS statistical reporting numbers:
.
3
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each of the periods noted above:
.
4
Identify your firm’s principal export markets:
.
2

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U.S. Importers’ Questionnaire - R-134a
II-5.

Page 11

IMPORTS FROM CHINA.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., lines B and D), less total shipments (i.e., lines 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

2013

A + B + D – F – H – J – L = should equal zero ("0") or
provide an explanation.1

2014
0

2015
0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for commercial U.S. commercial
shipments (i.e., line F) in each time period. If the calculated fields below return values other than zero
(i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
M + N + O – F = zero ("0"), if not revise.

2013

2014
0

2015
0

0

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U.S. Importers’ Questionnaire - R-134a
II-6.

Page 12

U.S. shipments by segment--China.–Report your firm’s U.S. shipments of imports of R-134a
imported from China (inclusive of commercial shipments, internal consumption, and transfers to
related firms) to each of the segments listed.

CHINA

Calendar years
Item

2013

2014

2015

Quantity (in short tons) and Value (in $1,000)
U.S. shipments of imports from China to
Automotive OEM.-Quantity (P)
Value (Q)
Automotive aftermarket.—
Quantity (R)
Value (S)
Stationary OEM.—
Quantity (T)
Value (U)
Stationary aftermarket.—
Quantity (V)
Value (W)
Foam expansion and propellant.—
Quantity (X)
Value (Y)
Other segments and/or unknown1.—
Quantity (Z)
Value (AA)
1

Identify these "other" segments:

Calendar years
Reconciliation

2013

2014

2015

Quantity reconciliation: P + R + T + V + X + Z –
F – H = zero ("0"), if not revise.

0

0

0

Value reconciliation Q + S + U + W + Y + AA– G
– I = zero ("0"), if not revise

0

0

0

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U.S. Importers’ Questionnaire - R-134a
II-7.

Page 13

IMPORTS FROM ALL OTHER SOURCES.–Report your firm’s imports and your firm’s shipments
and inventories of R-134a imported from all other sources combined by your firm during the
specified periods.

ALL OTHER SOURCES

(list sources:

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

2013

2014

2015

Beginning-of-period inventories (quantity) (A)
Imports:1
Imports under HTS 2903.39.2020
Quantity (B)
Value (C)
Imports under HTS other than 2903.39.20202
Quantity (D)
Value (E)
U.S. shipments:
Commercial shipments:
Quantity (F)
Value (G)
Internal consumption/ company transfers:
Quantity (H)
Value3 (I)
Export shipments:4
Quantity (J)
Value (K)
End-of-period inventories (quantity) (L)
Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To retailers (quantity) (N)
To end users (quantity) (O)
1

Please identify the foreign producers, if known:
.
List the HTS statistical reporting numbers:
.
3
Sales to related firms (including internal consumption) must be valued at fair market value. In the event that your firm
uses a different basis for valuing these sales within your company, please specify that basis (e.g., cost, cost plus, etc.) and
provide value data using that basis for each of the periods noted above:
.
4
Identify your firm’s principal export markets:
.
2

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II-7.

Page 14

IMPORTS FROM ALL OTHER SOURCES.–Continued

RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.--Generally, the data reported for the
end-of-period inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line
A), plus imports (i.e., lines B and D), less total shipments (i.e., lines 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

2013

A + B + D – F – H – J – L = should equal zero ("0") or
provide an explanation.1

2014
0

2015
0

0

1

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
.
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines M, N, and O) in each time period equal the quantity reported for commercial U.S. commercial
shipments (i.e., line F) in each time period. If the calculated fields below return values other than zero
(i.e., “0”), the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation item
M + N + O – F = zero ("0"), if not revise.

2013

2014
0

2015
0

0

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U.S. shipments by segment—all other sources.–Report your firm’s U.S. shipments of imports of
R-134a imported from all other sources (inclusive of commercial shipments, internal
consumption, and transfers to related firms) to each of the segments listed.

II-8.

ALL OTHER SOURCES

Calendar years
Item

2013

2014

2015

Quantity (in short tons) and Value (in $1,000)
U.S. shipments of imports from AOS to
Automotive OEM.-Quantity (P)
Value (Q)
Automotive aftermarket.—
Quantity (R)
Value (S)
Stationary OEM.—
Quantity (T)
Value (U)
Stationary aftermarket.—
Quantity (V)
Value (W)
Foam expansion and propellant.—
Quantity (X)
Value (Y)
Other segments and/or unknown1.—
Quantity (Z)
Value (AA)
1

Identify these "other" segments:

Calendar years
Reconciliation

2013

2014

2015

Quantity reconciliation: P + R + T + V + X + Z –
F – H = zero ("0"), if not revise.

0

0

0

Value reconciliation Q + S + U + W + Y + AA– G
– I = zero ("0"), if not revise

0

0

0

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II-9.

Page 16

Other explanations.--If your firm would like to further explain a response to a question in Part II
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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PART III.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Lauren Gamache
(lauren.gamache@usitc.gov, 202-205-3489)
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

PRICE DATA
III-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2013 of the following products your firm imported
from China and/or Germany:
Product 1.-- R-134a in bulk sold to repackers and distributors
Product 2.-- R-134a in 30-pound containers with an automotive valve sold to distributors
(include both product imported in 30-pound containers and product that your firm repackages
into 30-pound containers)
Product 3.-- R-134a in 30-pound containers with an HVAC valve sold to distributors or
wholesalers (include both product imported in 30-pound containers and product that your firm
repackages into 30-pound containers)
Product 4.-- R-134a in 30-pound containers with an automotive valve sold to retailers (include
both product imported in 30-pound containers and product that your firm repackages into 30pound containers)
Product 5.-- R-134a in 12-ounce containers sold to distributors (include both product imported
in 12-ounce containers and product that your firm repackages into 12-ounce containers)

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 2013-December 2015, did your firm import from China and/or Germany and sell
to unrelated U.S. customers any of the above listed products (or any products that were
competitive with these products)?

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U.S. Importers’ Questionnaire - R-134a
Yes.--Please complete the following pricing data tables as appropriate.
No.--Skip to question III-3.

Page 18

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Page 19

III-2a. Price data.--Report below the quarterly price data1 for pricing products2 imported from China
and sold by your firm.

China

Report data in actual pounds (not short tons) and actual dollars (not 1,000s).
Period of shipment
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December

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

Product 3
Quantity
Value

Product 4
Product 5
Period of shipment
Quantity
Value
Quantity
Value
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
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:
Product 5:

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III-2a. Price data (continued).--Report below the quarterly price data1 for pricing products2 imported
from Germany and sold by your firm.

Germany

Report data in actual pounds (not short tons) and actual dollars (not 1,000s).
Period of shipment
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December

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

Product 3
Quantity
Value

Product 4
Product 5
Period of shipment
Quantity
Value
Quantity
Value
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
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 III.
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:
Product 5:

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U.S. Importers’ Questionnaire - R-134a

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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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U.S. Importers’ Questionnaire - R-134a

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III-3a. Imports for internal use or repackaging.-- Did your firm import bulk R-134a for internal use or
repackaging since January 1, 2013?
Yes.--Please complete the following table as appropriate.
No.--Skip to question III-4.
Please note that values should be landed, duty-paid and should not include U.S.-inland transportation
costs. Values should reflect the final net amount paid by your firm (i.e., should be net of all returns,
discounts, allowances, and rebates).

China

Report data in actual pounds (not short tons) and actual dollars (not 1,000s of dollars).
(Quantity in pounds, value in dollars)
Bulk R-134a
Quantity

Landed, duty-paid
1
Period of shipment
Value
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
2015:
January-March
April-June
July-September
October-December
1
Net values (i.e., landed duty-paid values net all discounts, returns, allowances, rebates, prepaid freight, and the value
of returned goods). Moreover, please note that landed duty-paid values are NOT the sales prices at which your firm sells R134a at retail to consumers.
2
Pricing product definitions are provided on the first page of Part III.
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.

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III-3b. Additional costs for your direct imports of R-134a in bulk for retail sale by your firm.
(i)

If your firm reported direct import costs above (question III-3a), please identify the
factors that add to your cost of importing directly since January 1, 2013, estimate the
share of the cost of the landed duty paid value, and explain the specific costs associated
with each category.

Factors
Logistical or supply chain costs
Warehousing costs
Insurance costs
Currency conversion costs
Other
(ii)

Explanation

To which source does your firm compare costs in determining your additional
transaction costs to directly import?
U.S. Importers

(iii)

Estimated share
of landed duty
paid value

U.S. Producers

Both

Neither

(a) If your firm reported data above (question III-2b), briefly identify the benefits of
directly importing R-134a in bulk instead of purchasing R-134a from a U.S. importer or
from a U.S. producer.

(b) Please provide the estimated margin saved by having directly imported R-134a in
bulk instead of purchasing from a U.S. importer.
percent of landed duty-paid
value.
(c) Explain any variation in the margin saved since January 1, 2013.

(iv)

What is the approximate percentage of the total cost of R-134a you directly imported
from China that is accounted for by U.S. inland transportation or other logistics costs
from the port of importation to your distribution network or retail store?
percent.

Business Proprietary
U.S. Importers’ Questionnaire - R-134a
III-4.

Price setting.-- How does your firm determine the prices that it charges for sales of R-134a
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction

III-5.

Set
price
lists

Contracts

Other

If other, describe

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

Quantity
discounts

III-6.

Page 24

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for R-134a imported from China and/or
Germany?
Net 30
days

(b)

Net 60
days

2/10 net 30
days

Other

Other (specify)

On what basis are your firm’s prices of imported R-134a from China and/or Germany
usually quoted (check one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Importers’ Questionnaire - R-134a
III-7.

Contract versus spot.--Approximately what share of your firm’s sales of R-134a imported from
China and/or Germany in 2015 was on a (1) long-term contract basis, (2) annual contract basis,
(3) short-term contract basis, and (4) spot sales basis?

Share of 2015
sales
III-8.

Page 25

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 R134a from China and/or Germany (or check “not applicable” if your firm does not sell on a longterm, short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

Fixed quantity
and/or price
Meet or release
provision
Not applicable

No
Quantity
Price
Both
Yes
No

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

Annual contracts
(multiple deliveries
for 12 months)
365

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

Business Proprietary
U.S. Importers’ Questionnaire - R-134a
III-9.

Page 26

Lead times.--What is your firm’s share of sales of R-134a imported from China and/or Germany
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 R-134a?

Source

Share of
2015 sales

From your firm’s U.S. inventory

%

From foreign manufacturers’ inventory

%

Produced to order

%

Total (should sum to 100.0%)

Lead time
(average
number of
days)

0.0 %

III-10. Shipping information.—
(a)

What is the approximate percentage of the total delivered cost of R-134a imported from
China and/or Germany 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)

When your firm sells R-134a imported from China and/or Germany, from where is it
shipped?
Point of importation
Storage facility (check one)

(d)

Indicate the approximate percentage of your firm’s sales of R-134a imported from China
and/or Germany that are delivered the following distances from your firm’s U.S. point of
shipment.
Distance from your firm’s U.S. point of shipment

Share

Within 100 miles

%

101 to 1,000 miles

%

Over 1,000 miles

%

Total (should sum to 100.0%)

0.0

%

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U.S. Importers’ Questionnaire - R-134a

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III-11. Geographical shipments.--In which U.S. geographic market area(s) has your firm sold R-134a
imported from China since January 1, 2013 (check all that apply)?
Geographic area

China

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.
III-12. End uses.--List the end uses of the R-134a that your firm imports from China and/or Germany.
For each end-use product, what percentage of the total cost is accounted for by R-134a and
other inputs?
Share of total cost of end-use product
accounted for by
End use product

R-134a

Other inputs

Total
(should sum to
100.0% across)

%

%

0.0 %

%

%

0.0 %

%

%

0.0 %

III-13. Substitutes.-- Can other products be substituted for R-134a?
No

Substitute
1.
2.
3.

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 R-134a?
No Yes

Explanation

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U.S. Importers’ Questionnaire - R-134a

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III-14. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for R-134a has changed since January 1, 2013. Explain any trends and describe
the principal factors that have affected these changes in demand.
Overall
increase

Market

No
Overall Fluctuate with
change decrease no clear trend

Explanation and factors

Within
the United
States
Outside
the United
States

III-15. Product changes.--Have there been any significant changes in the product range, product mix or
marketing of R-134a since January 1, 2013?
No

Yes

If yes, please describe.

III-16. Conditions of competition.—
(a) Is the R-134a market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to R-134a?
Check all that apply.

Please describe.

No

Skip to question III-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
R-134a since January 1, 2013?
No

Yes

If yes, describe.

Business Proprietary
U.S. Importers’ Questionnaire - R-134a

Page 29

III-17. Supply constraints.-(a) Has your firm refused, declined, or been unable to supply R-134a since January 1, 2013
(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.

(b) Has your firm refused, declined, or been unable to supply R-134a in bulk form since January
1, 2013?
No

Yes

If yes, please describe.

(c) Since January 1, 2013, has your firm produced R-134a in 12-ounce containers?
If no, was your firm able to arrange for the supply of 12-ounce containers through
distributors by having them package bulk R-134a into 12-ounce cans for retail
customers?
No

Yes

No

Yes

If yes, please describe.

(d) Has your firm refused, declined, or been unable to supply R-134a in 12-ounce containers
with the customer’s label since January 1, 2013?
No

Yes

If yes, please describe.

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U.S. Importers’ Questionnaire - R-134a

Page 30

III-18. Private labels.--

(a) Since January 1, 2013, was your firm capable of supplying, either directly or through a
repackager, 12-ounce cans of R-134a for retail customers with the customer’s label?
Able to supply
No

Yes - Directly Yes - Repackager Please describe.

(b) Since January 1, 2013, did your firm actually supply, either directly or through a repackager,
12-ounce cans of R-134a for any retail customers with the customer’s label?
Actually supplied
No

Yes - Directly Yes - Repackager Please describe.

III-19. Raw materials.-- How have R-134a raw materials prices changed since January 1, 2013?
Fluctuate
Overall
No
Overall
with no
Explain, noting how raw material price changes
increase change decrease clear trend have affected your firm’s selling prices for R-134a.

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Page 31

III-20. Interchangeability.--Is R-134a 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

China

Germany

Other countries

United States
China
Germany
For any country-pair producing R-134a that is sometimes or never interchangeable, identify
the country-pair and explain the factors that limit or preclude interchangeable use:

III-21. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between R-134a 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

China

Germany

Other countries

United States
China
Germany
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of R-134a, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

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U.S. Importers’ Questionnaire - R-134a

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III-22. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for R-134a since January 1, 2013. Indicate the share of the quantity of your firm’s
total shipments of R-134a that each of these customers accounted for in 2015.

Customer’s name

Contact person

Email

Telephone

City

State

Share
of
2015
sales
(%)

1
2
3
4
5
6
7
8
9
10

III-23. Other explanations.--If your firm would like to further explain a response to a question in Part III
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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Page 33

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2016/1112_tetrafluoroethane_r_134a_china/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: R134A

• E-mail.—E-mail the MS Word questionnaire to amy.sherman@usitc.gov; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm did not import 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.