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pdfOMB No. 3117‐0016/USITC No. 17‐1‐3637; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE
PAPER CLIPS FROM CHINA
This questionnaire must be received by the Commission by April 20, 2017
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 review of the antidumping duty order concerning paper clips from China (Inv. No. 731‐TA‐663
(Fourth Review)). 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 paper clips (as defined on the next page) at any time since January 1, 2011?
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: PCFC)
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 or reviews
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 proceedings 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
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐On November 25, 1994, the Department of Commerce (“Commerce”) issued an
antidumping duty order on imports of paper clips from China. On June 1, 2016, the Commission
instituted a review pursuant to section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to
determine whether revocation of the order would be likely to lead to continuation or recurrence of
material injury to the domestic industry within a reasonably foreseeable time. If both the Commission
and Commerce make an affirmative determination, the order will remain in place. If either the
Commission or Commerce makes a negative determination, Commerce will revoke the order.
Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2016/paper_clips_china/fourth_review_full.htm.
Paper clips covered by this review is certain paper clips, wholly of wire of base metal, whether or not
galvanized, whether or not plated with nickel or other base metal (e.g., copper), with a wire diameter
between 0.025 inches and 0.075 inches (0.64 to 1.91 millimeters), regardless of physical configuration,
except as specifically excluded. The products subject to the order may have a rectangular or ring‐like
shape and include, but are not limited to, clips commercially referred to as No. 1 clips, No. 3 clips, Jumbo
or Giant clips, Gem clips, Frictioned clips, Perfect Gems, Marcel Gems, Universal clips, Nifty clips,
Peerless clips, Ring clips, and Glide‐On clips. The products subject to the order are currently classifiable
under subheading 8305.90.3010 of the Harmonized Tariff Schedule of the United States (HTSUS).
Specifically excluded from the scope of the order are plastic and vinyl covered paper clips, butterfly
clips, binder clips, or other paper fasteners that are not made wholly of wire of base metal and are
covered under a separate subheading of the HTSUS.
Although the HTSUS subheadings are provided for convenience and customs purposes, the written
description of the scope of the order is dispositive.1
Reporting of information.‐‐ If information is not readily available from your records in exactly the form
requested, furnish carefully prepared estimates. If your firm is completing more than one questionnaire
in connection with this proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you
need not respond to duplicated questions in the questionnaires.
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 of your 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.
1
Certain Paper Clips From the People’s Republic of China: Final Results of Expedited Fourth Sunset Review of
Antidumping Duty Order, 81 FR 69512, October 6, 2016.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 3
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.
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
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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
I‐2.
Page 4
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 paper clips, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Establishments
Covered1
City, State
Zip (5 digit)
Description
1
2
3
4
5
6
1
Additional discussion on establishments consolidated in this questionnaire:
I‐3.
Position regarding continuation of order.‐‐Does your firm support or oppose continuation of
the following antidumping duty order currently in place for paper clips?
Support
Oppose
I‐4.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Firm name
Take no position
Extent of
ownership
(percent)
Address
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
I‐5.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing paper clips into the United States or that are engaged in
exporting paper clips to the United States?
No
Yes‐‐List the following information.
Firm name
I‐6.
Country
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of paper clips?
No
Yes‐‐List the following information.
Firm name
I‐7.
Page 5
Country
Affiliation
Business plan.‐‐In Parts II and IV of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for paper clips?
No
Yes
If yes, please provide the requested documents. If you are not providing the
requested documents, please explain why not.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 6
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Justin Enck (202‐205‐3363,
justin.enck@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 paper clips since January 1, 2011.
Check as many as appropriate.
If checked, please describe; leave blank if not
applicable.
Plant openings
Plant closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
production curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
II‐3.
Page 7
Anticipated changes in operations.‐‐Does your firm anticipate any changes in the character of
operations or organization (as noted above) relating to the production of paper clips in the
future?
No
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 your response a specific projection of your firm’s
capacity to produce paper clips (in million units) for 2017 and 2018.
II‐4.
Anticipated changes in operations in the event the order is revoked.‐‐Would your firm
anticipate any changes in the character of its operations or organization (as noted above)
relating to the production of paper clips in the future if the antidumping duty order on paper
clips from China were to be revoked?
No
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 your response a specific projection of your firm’s
capacity to produce paper clips (in million units) for 2017 and 2018.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 8
II‐5a. Production using same machinery.‐‐ Please report your firm’s production of products made on
the same equipment and machinery used to produce paper clips, 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 million units)
Calendar year
Item
2014
Overall production
capacity
Production of:
Paper clips1
2
Other products
Total
1
2
2015
2016
0
0
0
0
0
0
Data entered for production of paper clips will populate here once reported in question II‐6.
Please identify these products: .
II‐5b. Operating parameters.‐‐The production capacity reported in II‐5a is based on operating hours
per week, weeks per year.
II‐5c. Capacity calculation.‐‐Please describe the methodology used to calculate overall production
capacity reported in II‐5a, and explain any changes in reported capacity.
II‐5d. Production constraints.‐‐Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 9
II‐5e. Product shifting.‐‐Is your firm able to switch production (capacity) between paper clips and other
products using the same equipment and/or labor?
No
Yes‐‐ (i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products: .
II‐5f. Product shifting factors.‐‐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‐6.
Production, shipment, and inventory data.‐‐Report your firm’s production capacity, production,
shipments, and inventories related to the production of paper clips 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, on a delivered basis
“Internal consumption” – Product consumed internally by your firm. Such transactions are
valued at fair market value.
“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.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work‐in‐progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records used in the
preparation of the trade data, as Commission staff may contact your firm regarding questions on the trade data.
The Commission may also request that your company submit copies of the supporting documents/records (such as
production and sales schedules, inventory records, etc.) used to compile these data.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
II‐6.
Page 10
Production, shipment, and inventory data. ‐‐Continued
Quantity (in million units) and value (in $1,000)
Calendar year
Item
2014
2015
2016
Average production
capacity1 (quantity) (A)
Beginning‐of‐period
inventories (quantity)
(B)
Production (quantity)
(C)
U.S. shipments:
Commercial
shipments:
quantity (D)
value (E)
Internal
consumption:2
quantity (F)
value (G)
Transfers to related
firms:2
quantity (H)
value (I)
3
Export shipments:
quantity (J)
value (K)
End‐of‐period
inventories (quantity)
(L)
1
The production capacity reported is based on operating hours per week, weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity (use additional pages as necessary).
.
2
Internal consumption and transfers to related firms should 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: .
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 11
II‐6. Production, shipment, and inventory data.‐‐Continued
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any
differences are not due to data entry errors in completing this form, but rather reflect your firm’s actual
records; and, also provide explanations for any differences (e.g., theft, loss, damage, record systems
issues, etc.) if they exist.
Calendar year
Item
2014
B + C – D – F – H – J – L
= should equal zero
("0") or provide an
explanation.1
2015
0
2016
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
II‐7. Channels of distribution.‐‐ Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in million units)
Calendar year
Item
2014
Channels of distribution:
Commercial U.S. shipments.—
to distributors (quantity) (M)
2015
2016
to end users (quantity) (N)
to retailers (quantity) (O)
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 D) 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 year
Reconciliation item
2014
M + N + O – D = zero ("0"), if not revise.
2015
0
2016
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
II‐8.
Page 12
U.S. shipments by product type.‐‐ Report your firm’s U.S. shipments (inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) in 2016 by product type.
Item
2016
(millions of units; values in $1,000)
U.S. shipments:
No. 1 paper clips
Quantity (P)
Value (Q)
No. 3 paper clips
Quantity (R)
Value (S)
Jumbo paper clips
Quantity (T)
Value (U)
Other wire paper clips
Quantity (V)
Value (W)
RECONCILIATION OF SHIPMENTS.‐‐U.S. shipment quantities (lines P , R, T, and V) reported in this
question should be equal to U.S. shipment quantities in 2016 in the previous question (lines D, F, and H);
likewise, U.S. shipment values (lines Q, S, U, and W) reported in this question should be equal to U.S.
shipment values in 2016 in the previous question (lines E, G, and I). 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.
Item
Quantity reconciliation: P + R + T + V – D –F – H =
zero ("0"), if not revise.
Value reconciliation: Q + S + U + W – E –G – I =
zero ("0"), if not revise.
Calendar year 2016
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
II‐9.
Page 13
Employment data.‐‐Report your firm’s employment‐related data related to the production of
paper clips and provide an explanation for any trends in these data.
“Production and 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.
“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 year
Item
2014
2015
2016
Employment data:
Average number of
PRWs (number)
Hours worked by
PRWs (1,000 hours)
Wages paid to
PRWs ($1,000)
Explanation of trends:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 14
II‐10. Transfers to related firms.‐‐If your firm reported transfers to related firms in question II‐6,
please indicate the nature of the relationship between your firm and the related firms (e.g., joint
venture, wholly owned subsidiary), whether the transfers were priced at market value or by a
non‐market formula, whether your firm retained marketing rights to all transfers, and whether
the related firms also processed inputs from sources other than your firm.
II‐11. Purchases.‐‐Other than direct imports, has your firm otherwise purchased paper clips since
January 1, 2014?
No
Yes‐‐ Please indicate the reasons for your firm’s purchases (if your firms’
reasons differ by source, please elaborate) and report the quantity and
value of such purchases below for the specified periods.
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign supplier where your firm is the importer of
record or consignee.
Reason for purchases:
Quantity (in million units)
Calendar years
Item
2014
2015
2016
Purchases from U.S.
importers1 of paper
clips from‐‐
China
All other sources
Purchases from
domestic producers2
Purchases from other
sources2
1
Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier: .
2
Please list the name of the producer(s) or U.S. distributor(s) from which your firm purchased this product:
.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 15
II‐12. Toll production.‐‐Since January 1, 2011, has your firm been involved in a toll agreement
regarding the production of paper clips?
“Toll agreement”‐‐Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No
Yes‐‐ Please describe the toll arrangement(s) and name the firm(s) involved.
II‐13. Foreign trade zones.‐‐
(a)
Firm's FTZ operations.‐‐Does your firm produce paper clips in and/or admit paper clips
into a foreign trade zone (FTZ)?
“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
No
Yes‐‐Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).
(b)
Other firms' FTZ operations.‐‐To your knowledge, do any firms in the United States
import paper clips into a foreign trade zone (FTZ) for use in distribution of paper clips
and/or the production of downstream articles?
No/Don’t know
Yes‐‐Identify the firms and the FTZs.
II‐14. Direct imports.‐‐Since January 1, 2011, has your firm imported paper clips?
“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
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 16
II‐15. Effect of order.‐‐Describe the significance of the existing antidumping duty order covering
imports of paper clips from China in terms of its effect on your firm’s production capacity, production,
U.S. shipments, inventories, purchases, employment, revenues, costs, profits, cash flow, capital
expenditures, research and development expenditures, and asset values. You may wish to compare
your firm’s operations before and after the imposition of the order.
II‐16. Likely effect of revocation of order.‐‐Would your firm anticipate any changes in its production
capacity, production, U.S. shipments, inventories, purchases, employment, revenues, costs,
profits, cash flow, capital expenditures, research and development expenditures, or asset values
relating to the production of paper clips in the future if the antidumping duty order on paper
clips from China were to be revoked?
No
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 for any trends or
projections you may provide.
II‐17. Other explanations:‐‐If your firm would like to explain further 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
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 17
PART III.‐‐FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202‐205‐3188,
Jennifer.Brinckhaus@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 paper clips:
2. Does your firm prepare profit/loss statements for paper clips:
Yes
No
3. How often did your firm (or parent company) prepare financial statements (including
annual reports, 10Ks)? Please check relevant items below.
Audited, unaudited, annual reports, 10Ks, 10 Qs,
Monthly, quarterly, semi‐annually, annually
4. Accounting basis: GAAP, cash, tax, or other comprehensive basis of
accounting (specify)
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the financial data, as Commission staff may contact your firm
regarding questions on the financial data. The Commission may also request that your company
submit copies of the supporting documents/records (financial statements, including internal
profit‐and‐loss statements for the division or product group that includes paper clips, as well as
specific statements and worksheets) used to compile these data.
III‐3.
Cost accounting system.‐‐Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
III‐4.
Page 18
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.
Product listing.‐‐Please list the products your firm produces in the facilities in which it produces
paper clips, and provide the share of net sales accounted for by these products in your firm’s
most recent fiscal year.
Products
Share of sales
Paper clips
%
%
%
%
%
III‐6.
Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of paper clips 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 paper clips
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
the 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 (percent)
Input valuation methodology as recorded in the firm’s accounting books and records
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
III‐8.
Page 19
Inputs from related suppliers at cost.‐‐Please confirm that the inputs purchased from related
suppliers, as identified in III‐7, were reported in III‐9a (financial results on paper clips) in a
manner consistent with the 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 ‐ Paper Clips
Page 20
III‐9a. Operations on paper clips.‐‐Report the revenue and related cost information requested below
on the paper clips 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 year. If your firm was involved in tolling operations (either as the
toller or as the tollee), please contact Jennifer Brinckhaus at (202) 205‐3188 before completing
this section of the questionnaire.
Quantity (in million units) and value (in $1,000)
Fiscal years ended‐‐
Item
Net sales quantities:2
Commercial sales (“CS”)
2014
2015
2016
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
0
0
0
Internal consumption
Transfers to related firms
0
0
0
Direct labor
Other factory costs
Total COGS
0
0
0
Gross profit or (loss)
0
0
0
0
0
0
0
0
0
Total net sales quantities
Net sales values:2
Commercial sales
Total net sales values
3
Cost of goods sold (COGS):
Raw materials
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
0
0
0
Net income or (loss) before income taxes
Depreciation/amortization included above
1
Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
2
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the corresponding shipment quantities
and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
Note ‐‐ The table above contains calculations that will appear when you have entered data in the MS
Word form fields.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 21
III‐9b. Financial data reconciliation.‐‐The calculable line items from question III‐9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non‐material
differences that may arise due to rounding?
Yes No‐‐If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative‐‐instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.
III‐10. Nonrecurring items (charges and gains) included in the subject product financial results.‐‐For
each annual 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
question 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 question III‐
9a; i.e., if an aggregate nonrecurring item has been allocated to question III‐9a, only the
allocated value amount included in question 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
question III‐9a.
Fiscal years ended‐‐
2014
2015
2016
Nonrecurring item: In this column please provide a brief
description of each nonrecurring item and indicate the specific
line item in table III‐9a where the nonrecurring item is classified.
Nonrecurring item: In these columns please report the amount of the relevant
nonrecurring item reported in table III‐9a.
Value ($1,000)
1. , classified as
2. , classified as
3. , classified as
4. , classified as
5. , classified as
6. , classified as
7. , classified as
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 22
III‐11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.‐‐If non‐recurring items were reported in question III‐10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., just as responses to question III‐10 identify where these items
are reported in question III‐9a.
III‐12. Asset values.‐‐Report the total assets (i.e., both current and long‐term assets) associated with
the production, warehousing, and sale of paper clips. If your firm does not maintain some or all
of the specific asset information necessary to calculate total assets for paper clips in the normal
course of business, please estimate this information based upon a method (such as production,
sales, or costs) that is consistent with relevant cost allocations in question III‐9a. Provide data as
of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write‐offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended‐‐
Item
1
Total assets (net)
1
Describe
2014
2015
2016
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 23
III‐13. Capital expenditures and research and development expenses.‐‐Report your firm’s capital
expenditures and research and development expenses for paper clips. Provide data for your
firm’s three most recently completed fiscal years.
Value (in $1,000)
Item
Capital expenditures
Research and development
expenses
Fiscal years ended‐‐
2015
2014
2016
1
Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject
product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject
product.
III‐14. 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 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‐6 (including export shipments) as long as they are reported on the same
calendar year basis.
RECONCILIATION OF TRADE VS FINANCIAL DATA.‐‐Please ensure that the quantities and values reported
for total shipments in part II equal the quantities and values reported total net sales in part III of this
questionnaire in each time period unless the financial data from part III are reported on a fiscal year
basis. If the calculated fields below return values other than zero (i.e., “0”) and both are being reported
on a calendar basis, please explain the discrepancy below.
Full year data
Reconciliation
2014
2015
2016
Quantity: Trade data from part II
less financial data from part III, =
zero ("0") except as noted above.
0
0
0
Value: Trade data from part II less
financial data from part III, = zero
("0") except as noted above.
0
0
0
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 24
Do these data in question III‐9a reconcile with data in question II‐6?
Yes
No
If no, please explain.
III‐15. 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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 25
PART IV.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Arthur Gailes (202‐205‐3001,
arthur.gailes@usitc.gov).
IV‐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
IV‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers of the following products your firm imported from China:
Product 1. — No. 1 gem style paper clips with smooth finish, packaged in boxes/plastic bags.
Product 2. — Jumbo/giant gem style paper clips with smooth finish, packaged in boxes/plastic
bags.
Product 3. — No. 3 gem style paper clips with smooth finish, packaged in boxes/plastic bags.
Please note that values should be on a delivered basis and should include U.S.‐inland transportation
costs. Values should reflect the final net amount paid to your firm (i.e., should be net of all deductions
for discounts or rebates) but should include transportation to the indicated market.
(a) During January 2014‐December 2016, did your firm produce and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with
these products)?
Yes.‐‐Please complete the following pricing data table as appropriate.
No.‐‐Skip to question IV‐3.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 26
IV‐2(b). Price data.‐‐Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in 1,000 units (NOT millions) and actual dollars (not 1,000s).
(Quantity in 1,000 units, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Period of shipment
Quantity
Value
2014:
January‐March
April‐June
July‐September
October‐December
2015:
January‐March
April‐June
July‐September
October‐December
2016:
January‐March
April‐June
July‐September
October‐December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, and the value of returned goods), on a delivered
basis.
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 27
IV‐2(c). Pricing data methodology.‐‐ Please describe the method and the kinds of documents/records
that were used to compile your price data.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the price data, as Commission staff may contact your firm regarding
questions on the price data. The Commission may also request that your company submit copies
of the supporting documents/records (such as sales journal, invoices, etc.) used to compile these
data.
IV‐3.
Price setting.‐‐ How does your firm determine the prices that it charges for sales of paper clips
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
IV‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐ Please indicate and describe your firm’s discount policies (check all that
apply).
Annual
total
volume
discounts
Quantity
discounts
IV‐5.
Other
Describe
Pricing terms.‐‐
(a)
What are your firm’s typical sales terms for its U.S.‐produced paper clips?
Net 30
days
Net 60
days
No
discount
policy
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of domestic paper clips usually quoted (check one)?
Delivered
F.o.b.
If f.o.b., specify point
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
IV‐6.
Page 28
Contract versus spot.‐‐ Approximately what share of your firm’s sales of its U.S.‐produced paper
clips in 2016 was on a (1) long‐term contract basis, (2) annual contract basis, (3) short‐term
contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of 2016
sales
IV‐7.
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%
%
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
0.0
%
Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced paper clips (or check “not applicable” if your firm does not sell on a long‐term,
short‐term and/or annual contract basis).
Long‐term contracts
(multiple deliveries for
more than 12 months)
365
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
IV‐8.
Lead times.‐‐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 paper clips?
Share of 2016 Lead time (average
Source
sales
number of days)
From inventory
%
Produced to order
%
Total (should sum to 100.0%)
Annual contracts
(multiple
deliveries for 12
months)
Short‐term contracts
(multiple deliveries
for less than 12
months)
0.0 %
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
IV‐9.
Page 29
Shipping information.‐‐
(a)
(b)
(c)
What is the approximate percentage of the total delivered cost of U.S.‐produced paper
clips that is accounted for by U.S. inland transportation costs? %
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
Indicate the approximate percentage of your firm’s sales of paper clips that are
delivered the following distances from your firm’s production facility.
Distance from production facility
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
IV‐10. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold its U.S.‐
produced paper clips since January 1, 2011 (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.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 30
IV‐11. Substitutes.‐‐
(a)
Can other products be substituted for paper clips?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Substitute
Have changes in the price of this substitute
affected the price for paper clips?
No Yes
Explanation
1.
2.
3.
(b)
Have there been any changes in the number or types of products that can be
substituted for paper clips since January 1, 2011? Do you anticipate any future changes?
Changes in
substitutes
No Yes
Explain
Changes since
January 1, 2011
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 31
IV‐12. Availability of supply.‐‐Has the availability of paper clips in the U.S. market changed since
January 1, 2011? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
Changes since January 1, 2011:
U.S.‐produced product
Imports of Chinese
product
Imports of products from
other countries
U.S.‐produced product
Imports of Chinese
product
Imports of products from
other countries
Anticipated changes:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 32
IV‐13. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for paper clips has changed since January 1, 2011, and how you anticipate
demand will change in the future. Explain any trends and describe the principal factors that
have affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2011
Within the
United
States
Outside
the United
States
Anticipated future demand
Within the
United
States
Outside
the United
States
IV‐14. Product changes.‐‐ Have there been any significant changes in the product range, product mix,
or marketing of paper clips since January 1, 2011? Do you anticipate any future changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2011
Anticipated
changes
Explain
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 33
IV‐15. Conditions of competition.‐‐
(a) Is the paper clips market subject to business cycles (other than general economy‐wide
conditions) and/or other conditions of competition distinctive to paper clips?
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
paper clips since January 1, 2011?
No
Yes
If yes, describe.
IV‐16. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply paper clips since
January 1, 2011 (examples include placing customers on allocation or “controlled order entry,”
declining to accept new customers or renew existing customers, delivering less than the
quantity promised, been unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
IV‐17. Raw materials.‐‐ Indicate how paper clips raw material prices have changed since January 1,
2011, and how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no
clear
Overall
No
Overall
trend
increase change decrease
Explain, noting how raw material
price changes have affected your
firm’s selling prices for paper clips.
Changes since
January 1,
2011
Anticipated
changes
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 34
IV‐18. Price comparisons.‐‐Please compare market prices of paper clips in U.S. and non‐U.S. markets, if
known. Provide specific information as to time periods and regions for any price comparisons.
IV‐19. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss paper clips supply (including
production capacity and capacity utilization) and demand in (1) the United States, (2) each of
the other major producing/consuming countries, including China, and (3) the world as a whole.
Of particular interest is such data from 2011 to the present and forecasts for the future.
IV‐20. Export constraints.‐‐Describe how easily your firm can shift its sales of paper clips between the
U.S. market and alternative country markets. In your discussion, please describe any contracts,
other sales arrangements, or other constraints that would prevent or retard your firm from
shifting paper clips between the U.S. and alternative country markets within a 12‐month period.
IV‐21. Barriers to trade.‐‐Are your firm’s exports of paper clips subject to any tariff or non‐tariff
barriers to trade in other countries?
No
Yes
If yes, please list the countries and describe any such barriers and any
significant changes in such barriers that have occurred since January 1,
2011, or that are expected to occur in the future.
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 35
IV‐22. Interchangeability.‐‐Is paper clips produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country‐pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
China
Other countries
For any country‐pair producing paper clips which is sometimes or never interchangeable,
please identify the country‐pair and explain the factors that limit or preclude
interchangeable use:
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 36
IV‐23. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between paper clips produced in
the United States and in other countries a significant factor in your firm’s purchases of the
products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
United States
China
Other countries
China
For any country‐pair for which factors other than price always or frequently are a significant
factor in your firm’s purchases of paper clips, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
IV‐24. 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.
IV‐25 Bundling sales of paper clips with other products.‐‐Does your firm bundle the sales of paper
clips with other office supply products?
Estimated share
of your sales of
paper clips in
2016 that were Describe the other products that are included in typical
No
Yes sold in a bundle bundled sales
Business Proprietary
U.S. Producers’ Questionnaire ‐ Paper Clips
Page 37
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/paper_clips_china/fourth_review_f
ull.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: PCFC
• E‐mail.—E‐mail the MS Word questionnaire to justin.enck@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 does not produce this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202‐
205‐1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.
| File Type | application/pdf |
| File Title | Microsoft Word - PC US Producer Questionnaire |
| Author | fred.ruggles |
| File Modified | 2017-03-07 |
| File Created | 2017-03-07 |