18-4-3835 Foreign producers' questionnaire

OMB No. 3117-0016/USITC No. 18-4-3835; Expiration Date: : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
RUBBER BANDS FROM CHINA, SRI LANKA, AND THAILAND
This questionnaire must be received by the Commission by February 13, 2018
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 and countervailing duty investigations concerning rubber bands from China, Sri
Lanka, and Thailand (Inv. Nos. 701-TA-598-600 and 731-TA-1408-1410 (Preliminary)). 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 rubber bands (as defined on next page) at any time since January 1, 2015?

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)

Data reported in this questionnaire relate to (Check one):
CHINA

SRI LANKA

THAILAND

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: BAND)
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 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

Email address
Fax:

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)

Page 2

PART I.—GENERAL INFORMATION
Background. --This proceeding was instituted in response to a petition filed on January 30, 2018 by
Alliance Rubber Co., Hot Springs, Arkansas. Antidumping and countervailing 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 dumping and subsidization. Questionnaires and
other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/rubber_bands_china_sri_lanka_and_thailand/preli
minary.htm.
Rubber bands covered by these investigations are defined as bands made of vulcanized rubber, with a
flat length, as measured end-to-end by the band lying flat, no less than 1/2 inch and no greater than 10
inches; with a width, which measures the dimension perpendicular to the length, of at least 3/64 inch
and no greater than 2 inches; and a wall thickness from 0.020 inch to 0.125 inch. Vulcanized rubber has
been chemically processed into a more durable material by the addition of sulfur or other equivalent
curatives or accelerators. Subject products are included regardless of color or inclusion of printed
material. The scope includes vulcanized rubber bands which are contained or otherwise exist in various
fowls and packages, such as, without limitation, vulcanized rubber bands included within a desk
accessory set or other type of set or package, and vulcanized rubber band balls, but excludes Bedford
Elastitags®, and bands that are being used at the time of import to fasten an imported product.
Rubber bands are currently imported under statistical reporting number 4016.99.3510 of the
Harmonized Tariff Schedule of the United States (HTSUS). The HTSUS provisions are for convenience and
customs purposes; the written description of the scope 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.

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)

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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from
Amanda Lawrence (202-205-3185, amanda.lawrece@usitc.gov).
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
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, Sri Lanka, or Thailand involved in the
production or export of rubber bands, including auxiliary facilities operated in conjunction with
(whether or not physically separate from) such facilities. Firms operating more than one
establishment in China, Sri Lanka, and Thailand should combine the data for all establishments
into a single report.

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)
I-3.

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

I-4.

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
rubber bands in 2017.

Importer’s name

1

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.

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

I-5.

Page 4

Contact person

Email

Telephone

Share of your
firm’s 2017 U.S.
exports (%)

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amanda Lawrence (202-2053185, amanda.lawrence@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 rubber bands since January 1, 2015.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)
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 rubber bands in the
future?
No

II-4a.

Page 6

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 rubber bands (in pounds) for 2018 and 2019.

Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce rubber bands, 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, Sri Lanka, and Thailand,
including production consumed internally within your firm.
Quantity (in pounds)
Calendar years
Item

2015

2016

2017

Overall production capacity
Production of:
Rubber bands1

0

0

0

0

0

0

0

0

0

Products not covered:
Excluded vulcanized rubber bands2
Bedford Elastitags®
Non-latex rubber bands
Other products3
Subtotal, products not covered
Total
1

Data entered for production of rubber bands will populate here once reported in question II-7.
Excluded vulcanized rubber bands are bands made of vulcanized rubber with a flat length less than 1/2" or
greater than 10”, a width less than 3/64” or greater than 2”, or a wall thickness less than 0.020” or greater
than 0.125”.
3
Please identify these products:
.
2

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Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)

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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.

II-4e.

Product shifting.—
(i).

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

(ii).

hours

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

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

II-5.

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

II-6.

Firm's estimated share of production in China, Sri Lanka, and Thailand.--Please estimate the
percentage of total production of rubber bands in the country specified on the certification page
accounted for by your firm’s production in 2017.
percent.

II-7.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of rubber bands from the country specified on the certification page
accounted for by your firm’s exports in 2017.
percent.

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)
II-8.

Third country trade actions.--Are the rubber bands 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.

Page 8

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)
II-9.

Page 9

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of rubber bands in your establishment(s) in China, Sri Lanka, and
Thailand during the specified periods. Do not include resales of rubber bands 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-10.
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, Sri Lanka, and Thailand,
including production consumed internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s) in China, Sri Lanka, and
Thailand. Quantities reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within China, Sri Lanka, and Thailand.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in China, Sri Lanka, and Thailand, including product consumed internally by your
firm.
“Export shipments”--Shipments to destinations outstide of the country indicacted on page 1
(China, Sri Lanka, and Thailand), 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 – Rubber Bands (Preliminary)
II-9.

Page 10

Trade data.--Continued.
Quantity (in pounds)

Item

Actual experience

Projections1

Calendar year

Calendar year

2015

2016

2017

2018

2019

2

Average production capacity (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers (D)
Commercial shipments (E)
Exports to the United States (F)
Exports to all other markets3 (G)
Total exports (H)
(should equal F+G)

0

0

0

0

0

Total shipments (I)
(should equal D+E+F+G)

0

0

0

0

0

End-of-period inventories (J)
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

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line J) 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, E, F, and G). 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.

Item

2015

Actual experience

Projections

Calendar year

Calendar year

2016

2017

2018

2019

B + C – D – E – F –G – J = should
equal zero ("0") or provide an
explanation.1
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

0

Business Proprietary
Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)
II-10.

Page 11

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of rubber bands that was produced in China, Sri Lanka, and Thailand but not by
your firm during the specified periods. Note these data should not be included in question II-9.
Quantity (in pounds)

Item

2015

Actual experience

Projections

Calendar year

Calendar year

2016

2017

2018

2019

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

List the producer(s).

II-11.

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

.

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Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)

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Correcting Valid number error messages.--If you are completing a Commission
questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than
one. Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):






START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

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Foreign Producers’ Questionnaire – Rubber Bands (Preliminary)

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2018/rubber_bands_china_sri_lanka_and
_thailand/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: BAND

• E-mail.—E-mail your questionnaire to amanda.lawrence@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.