16-4-3586 Foreign Producers' Questionnaire

OMB No. 3117-0016/USITC No. 16-4-3586; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
STAINLESS STEEL SHEET AND STRIP FROM CHINA
This questionnaire must be received by the Commission by December 6, 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 duty and antidumping investigations concerning stainless steel sheet and strip
from China (Inv. Nos. 701-TA-557 and 731-TA-1312 (Final)). The information requested in the questionnaire is
requested under the authority of the Tariff Act of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported stainless steel sheet and strip (as defined on next page) 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 Commission Drop Box by clicking on the following
link: https://dropbox.usitc.gov/oinv/. (PIN: SSSS)
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
proceeding 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

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip

Page 2

PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on February 12, 2016, by AK
Steel Corp., West Chester, Ohio; Allegheny Ludlum, LLC, Pittsburgh, Pennsylvania; North American
Stainless, Inc., Ghent, Kentucky; and Outokumpu Stainless USA, LLC, Bannockburn, Illinois.
Countervailing and 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 (“Commerce”) makes an affirmative
determination of subsidization and/or dumping. Questionnaires and other information pertinent to this
proceeding are available
at https://www.usitc.gov/investigations/title_7/2016/stainless_steel_sheet_and_strip_china/final.htm.
Stainless Steel Sheet and Strip (“SSSS”) covered by these investigations is stainless steel sheet and strip,
whether in coils or straight lengths. Stainless steel is an alloy steel containing, by weight, 1.2 percent or
less of carbon and 10.5 percent or more of chromium, with or without other elements. The subject
sheet and strip is a flatrolled product with a width that is greater than 9.5 mm and with a thickness of
0.3048 mm and greater but less than 4.75 mm, and that is annealed or otherwise heat treated, and
pickled or otherwise descaled. The subject sheet and strip may also be further processed (e.g., coldrolled, annealed, tempered, polished, aluminized, coated, painted, varnished, trimmed, cut, punched, or
slit, etc.) provided that it maintains the specific dimensions of sheet and strip set forth above following
such processing. The products described include products regardless of shape, and include products of
either rectangular or non-rectangular crosssection where such cross-section is achieved subsequent to
the rolling process, i.e., products which have been ‘‘worked after rolling’’ (e.g., products which have
been beveled or rounded at the edges). For purposes of the width and thickness requirements
referenced above: (1) Where the nominal and actual measurements vary, a product is within the scope
if application of either the nominal or actual measurement would place it within the scope based on the
definitions set forth above; and (2) where the width and thickness vary for a specific product (e.g., the
thickness of certain products with non-rectangular cross-section, the width of certain products with
nonrectangular shape, etc.), the measurement at its greatest width or thickness applies.
All products that meet the written physical description, and in which the chemistry quantities do not
exceed any one of the noted element levels listed above, are within the scope of these investigations
unless specifically excluded.
Subject merchandise includes stainless steel sheet and strip that has been further processed in a third
country, including but not limited to cold-rolling, annealing, tempering, polishing, aluminizing, coating,
painting, varnishing, trimming, cutting, punching, and/or slitting, or any other processing that would not
otherwise remove the merchandise from the scope of the investigation if performed in the country of
manufacture of the stainless steel sheet and strip.
Excluded from the scope of these investigations are the following: (1) Sheet and strip that is not
annealed or otherwise heat treated and not pickled or otherwise descaled; (2) plate (i.e., flat-rolled
stainless steel products of a thickness of 4.75 mm or more); and (3) flat wire (i.e., cold-rolled sections,
with a mill edge, rectangular in shape, of a width of not more than 9.5 mm). The products under
investigation are currently classifiable under Harmonized Tariff Schedule of the United States (HTSUS)
subheadings 7219.13.0031, 7219.13.0051, 7219.13.0071, 7219.13.0081, 7219.14.0030, 7219.14.0065,
7219.14.0090, 7219.23.0030, 7219.23.0060, 7219.24.0030, 7219.24.0060, 7219.32.0005, 7219.32.0020,
7219.32.0025, 7219.32.0035, 7219.32.0036, 7219.32.0038, 7219.32.0042, 7219.32.0044, 7219.32.0045,

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip

Page 3

7219.32.0060, 7219.33.0005, 7219.33.0020, 7219.33.0025, 7219.33.0035, 7219.33.0036, 7219.33.0038,
7219.33.0042, 7219.33.0044, 7219.33.0045, 7219.33.0070, 7219.33.0080, 7219.34.0005, 7219.34.0020,
7219.34.0025, 7219.34.0030, 7219.34.0035, 7219.34.0050, 7219.35.0005, 7219.35.0015, 7219.35.0030,
7219.35.0035, 7219.35.0050, 7219.90.0010, 7219.90.0020, 7219.90.0025, 7219.90.0060, 7219.90.0080,
7220.12.1000, 7220.12.5000, 7220.20.1010, 7220.20.1015, 7220.20.1060, 7220.20.1080, 7220.20.6005,
7220.20.6010, 7220.20.6015, 7220.20.6060, 7220.20.6080, 7220.20.7005, 7220.20.7010, 7220.20.7015,
7220.20.7060, 7220.20.7080, 7220.90.0010, 7220.90.0015, 7220.90.0060, and 7220.90.0080. Although
the HTSUS subheadings are provided for convenience and customs purposes, the written description of
the scope of this proceeding 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,
purchaser and/or foreign producer 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
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
I-1.

Page 4

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
20 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 in China involved in the production or export of SSSS,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities. Firms operating more than one establishment in China should combine the
data for all establishments into a single report.

I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce SSSS in the United States or other countries?
No

Yes--Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire.

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
I-4.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
SSSS into the United States?
No

I-5.

2

3

4

5

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

U.S. importers.--Please provide the names, street addresses (not P.O. boxes), contacts,
telephone numbers, and e-mail addresses of the FIVE largest U.S. importers of your firm’s SSSS
in 2015.

Importer’s name

1

Page 5

Contact
person

Email

Telephone

Street address (not
P.O. box), city, state,
and zip code

Street Address
,
City State Zip Code
Street Address
,
City State Zip Code
Street Address
,
City State Zip Code
Street Address
,
City State Zip Code
Street Address
,
City State Zip Code

Share of
your
firm’s
2015 U.S.
exports
(%)

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip

Page 6

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Michael Szustakowski (202205-3169, mgs@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 SSSS since January 1, 2013.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
(please specify the dates and
volume of capacity that was
made unavailable)
revised labor agreements
other (e.g., technology)

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

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
II-3.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of SSSS in the future?
No

II-4a.

Page 7

Yes–Supply details as to the time, nature, and significance of such changes
and provide underlying assumptions, along with relevant portions of
business plans or other supporting documentation that address this
issue. Include in the response a specific projection of your firm’s
capacity to produce SSSS (in short tons) for 2016 and 2017.

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce SSSS, and the combined production
capacity on this shared equipment and machinery.
“Overall production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s) in China, including production consumed
internally within your firm.
Quantity (in short tons)
Calendar years
Item

2013

2014

January-September
2015

2015

2016

Overall capacity
Production of.-1
In-scope SSSS

0

0

0

0

0

0

0

0

0

0

Thin/ultra-thin gage stainless steel (less
than 0.3048 mm)
2

All other out-of-scope products
Total production
1
2

Data entered for production of stainless steel sheet and strip will populate here once reported in question II-10.
Please identify these products:
.

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip

Page 8

II-4b.

Operating parameters.--The production capacity reported in II-4a is based on operating
per week,
weeks per year.

II-4c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-4a, and explain any changes in reported capacity.

II-4d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Stage of production
Raw stainless steel production
capacity
Annealing and pickling capacity
Cold rolling capacity
Other finishing capacity

II-4e.

2015 capacity (short tons)

hours

Nature of constraint

Product shifting.—
(i).

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

(ii).

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.

II-5.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of SSSS?
percent.

II-6.

Firm's estimated share of production in China.--Please estimate the percentage of total production
of SSSS in the country specified on the certification page accounted for by your firm’s production in
2015.
percent.

II-7.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of SSSS from the country specified on the certification page accounted for by
percent.
your firm’s exports in 2015.

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
II-8.

Page 9

Inventories in the United States.--Has your firm, since 2013, maintained any inventories of SSSS
in the United States (not including inventories held by firms identified in question I-3)?
“Inventories”--Finished goods inventory, not raw materials or work in progress.
No

Yes--Report the quantity of such end-of-period inventories below.
Quantity (in short tons)
Calendar year

Item

2013

2015

January-September
2015

2015

Inventory
II-9.

Third country trade actions.--Is the SSSS exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?
No

Yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

2016

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
II-10.

Page 10

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of SSSS in your establishment(s) in China during the specified periods.
Do not include resales of SSSS that your firm did not produce in this question; those data to the
degree they are exported to the United States should only be reported in question II-11.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
Do not submit data on multiple countries combined. The establishments reported here should
all be located in the country of the firm’s address reported on the certification page.
Multinational companies with production in multiple subject countries should submit separate
foreign producer questionnaire responses for each subject country.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
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 establishment(s) in China, including production consumed
internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”--Shipments to destinations outstide of the country indicacted on page 1
(China), including shipments to related firms.
“Inventories”--Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
II-10.

Page 11

Trade data.--Continued.
Quantity (in short tons)
Projections1

Actual experience
Calendar year
Item

2013

2014

January-September
2015

2015

2016

Calendar year
2016

2017

2

Average production capacity (A)
Beginning-of-period inventories
(B)
Production.-Hot-rolled annealed and pickled
SSSS from firm's own steel
production (quantity) (C)
Cold-rolled SSSS from firm's own
steel production (quantity) (D)
Hot-rolled annealed and pickled
SSSS from purchased steel
(quantity) (E)
Cold-rolled SSSS from purchased
steel (quantity) (F)
Total in-scope production (G)

0

0

0

0

0

0

0

Total exports (L)
(should equal J+K)

0

0

0

0

0

0

0

Total shipments (M)
(should equal H+I+J+K)

0

0

0

0

0

0

0

Home market shipments:
Internal consumption/
transfers (H)
Commercial shipments (I)
Exports to the United States (J)
Exports to all other markets3 (K)

End-of-period inventories (N)
1

Please explain the basis for your firm’s projections.
.
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.
3
Identify principal other export markets.
.
2

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip
II-10.

Page 12

Trade data.—Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line N) should be equal to the beginning-of-period
inventories (i.e., line B), plus production (i.e., line G), less total shipments (i.e., lines H, I, J, and K).
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.
Actual experience

Projections
JanuarySeptember

Calendar year
Item

2013

2014

2015

2015

Calendar year

2016

2016

2017

B + G – H – I – J – K – N=
should equal zero ("0")
or provide an
explanation.1
0
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.
II-11.

0

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of SSSS that was produced in China but not by your firm during the specified
periods. Note these data should not be included in question II-10.
Quantity (in short tons)
Actual experience
Calendar year
Item

2013

2014

Projections

January-September
2015

2015

2016

Calendar year
2016

2017

Exports of SSSS to the United
States not produced by your
firm1
1

List the producer(s).

II-12.

Other explanations.--If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.

.

Business Proprietary
Foreign Producers’ Questionnaire – Stainless Steel Sheet and Strip

Page 13

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/title_7/2016/stainless_steel_sheet_and_strip_
china/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: SSSS

• E-mail.—E-mail your questionnaire to mgs@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 produce or export 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, you are 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.