Form US producers' ques US producers' ques 18-1-3896

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

US producers--FSF (F) - Commission

Forged steel fittings from China, Italy, and Taiwan (Inv. nos. 701-TA-589 and 731-TA-1394-1396)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 18-1-3896; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PRODUCERS’ QUESTIONNAIRE
FORGED STEEL FITTINGS FROM CHINA, ITALY, AND TAIWAN
This questionnaire must be received by the Commission by June 28, 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 countervailing duty and antidumping duty investigations concerning forged steel fittings from China,
Italy, and Taiwan (Inv. Nos. 701-TA-589 and 731-TA-1394-1396 (Final)). The information requested in the questionnaire
is requested under the authority of the Tariff Act of 1930, title VII. This report is mandatory and failure to reply as
directed can result in a subpoena or other order to compel the submission of records or information in your firm’s
possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced forged steel fittings (as defined on next page) at any time since January 1, 2015?

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: FSF)
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

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on October 5, 2017, by
Bonney Forge Corporation, Mount Union, PA; and United Steel Workers, Pittsburgh, PA. Countervailing
and/or antidumping duties may be assessed on the subject imports as a result of these proceedings if
the Commission makes an affirmative determination of injury, threat, or material retardation, and if the
U.S. Department of Commerce (“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/701731/2018/forged_steel_fittings_china_italy_and_taiwan/final.
htm
Forged steel fittings covered by these investigations are carbon and alloy forged steel fittings, whether
unfinished (commonly known as blanks or rough forgings) or finished. Such fittings are made in a variety
of shapes including, but not limited to, elbows, tees, crosses, laterals, couplings, reducers, caps, plugs,
bushings, unions and outlets. Forged steel fittings are covered regardless of end finish, whether
threaded, socket-weld or other end connections.
While these fittings are generally manufactured to specifications ASME B16.11, MSS SP-79, and MSS SP83, MSS SP-97, ASTM A105, ASTM A350, and ASTM A182, the scope is not limited to fittings made to
these specifications.
The term forged is an industry term used to describe a class of products included in applicable
standards, and does not reference an exclusive manufacturing process. Forged steel fittings are not
manufactured from casting. Pursuant to the applicable specifications, subject fittings may also be
machined from bar stock or machined from seamless pipe and tube.
All types of fittings are included in the scope regardless of nominal pipe size (which may or may not be
expressed in inches of nominal pipe size), pressure rating (usually, but not necessarily expressed in
pounds of pressure/PSI, e.g., 2,000 or 2M; 3,000 or 3M; 6,000 or 6M; 9,000 or 9M), wall thickness, and
whether or not heat treated.
Excluded from this scope are all fittings entirely made of stainless steel. Also excluded are flanges, butt
weld fittings, butt weld outlets, nipples, and all fittings that have a maximum pressure rating of 300
pounds of pressure/PSI or less.
Further excluded are fittings certified or made to the following standards, so long as the fittings are
not also manufactured to the in-scope specifications of ASME B16.11, MSS SP-79, MSS SP-83, MSS SP-97,
ASTM A105, ASTM A350, and ASTM A182:
• American Petroleum Institute (API) API 5CT, API 5L, or API 11B;
• Society of Automotive Engineering (SAE) SAE J476, SAE J514, SAE J516, SAE J517, SAE J518, SAE J1026,
SAE J1231, SAE J1453, SAE J1926, SAE J2044 or SAE AS 35411;
• Underwriter’s Laboratories (UL) certified electrical conduit fittings;
• ASTM A153, A536, A576, or A865;
• Casing Conductor Connectors 16-42 inches in diameter made to proprietary specifications;
• Military Specification (MIL) MIL-C-4109F and MIL-F-3541; or
• International Organization for Standardization (ISO) ISO6150-B.
To be excluded from the scope, products must have the appropriate standard or pressure markings
and/or accompanied by documentation showing product compliance to the applicable standard or
pressure (e.g., marked as meeting “API 5CT”) and/or a mill certification report.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings

Page 3

Subject carbon and alloy forged steel fittings are currently imported under statistical reporting numbers
7307.99.5045, 7307.99.5060, 7307.99.1000, and 7307.99.3000 of the Harmonized Tariff Schedule of the
United States (HTSUS). They may also be imported under HTSUS statistical reporting numbers
7307.92.3010, 7307.92.3030, 7307.92.9000, or 7326.19.0010. The HTSUS provisions are for convenience
and customs purposes; the written description of the scope is dispositive.
Certain excluded fittings are carbon and alloy (excluding stainless) forged steel fittings that are excluded
from the definition of forged steel fittings above based on being certified to the following standards, and
not also being dual certified to ASME B16.11, MSS SP-79, MSS SP-83, MSS SP-97, ASTM A105, ASTM
A350, or ASTM A182 standards. The excluded fittings are those with the following certifications:
•
•
•
•
•
•
•

American Petroleum Institute (API) API 5CT, API 5L, or API 11B;
Society of Automotive Engineering (SAE) SAE J476, SAE J514, SAE J516, SAE J517, SAE J518, SAE
J1026, SAE J1231, SAE J1453, SAE J1926, J2044 or SAE AS 35411;
Underwriter’s Laboratories (UL) certified electrical conduit fittings;
ASTM A153, A536, A576, or A865;
Casing Conductor Connectors 16-42 inches in diameter made to proprietary specifications;
Military Specification (MIL) MIL-C-4109F and MIL-F-3541; or
International Organization for Standardization (ISO) ISO6150-B.

Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings

Page 4

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.
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
I-1a.

Page 5

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
50 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

I-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes

I-2.

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 forged steel fittings,
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:

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
I-3.

Page 6

Petition support.--Does your firm support or oppose the petition?
Country

Support

Oppose

Take no position

China CVD
China AD
Italy AD
Taiwan AD
I-4.

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

Firm name

I-5.

Yes--List the following information.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing forged steel fittings from China, Italy, and/or Taiwan into
the United States or that are engaged in exporting forged steel fittings from China, Italy, and/or
Taiwan to the United States?
No
Firm name

Yes--List the following information.
Country

Affiliation

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
I-6.

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of forged steel fittings?
No
Firm name

I-7.

Page 7

Yes--List the following information.
Country

Affiliation

Firm type.--Please indicate which type of operation best describes that of your firm and follow
directions to the relevant portions of the questionnaire.
“Integrated operations” Any operations involving the forging of steel fittings that are covered by
the investigations (defined on page 2), regardless of whether they are sold as unfinished steel
fittings or further processed into semi-finished or finished steel fittings by your firm before being
sold.
“Finishing only operations” Any operations involving the purchase of unfinished or semifinished steel fittings that are covered by the investigations (defined on page 2) and further
machined (drilling holes, beveling, sanding, et cetera) or processed to produce a finished steel
fitting still covered by the investigations.
Operations
Integrated
Finishing only

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings

Page 8

PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, celia.feldpausch@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

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of forged steel fittings 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
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-3a.

Page 9

Production using same forging machinery.--Please report your firm’s production of products
made on the same forging equipment and machinery used to produce steel fittings, and the
combined production capacity on this shared equipment and machinery in the periods
indicated.
“Overall 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 short tons)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Overall forging capacity
Production of:
Forged steel fittings1
Certain excluded fittings

Other products3
Total
1

Data entered for production of forged steel fittings will populate here once reported in question II-7.
As defined on page 2. Please identify these excluded fittings:
.
3
Please identify these products:
.
2

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week

Weeks per year

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-3c.

Page 10

Production using same finishing machinery.--Please report your firm’s production of products
made on the same finishing equipment and machinery used to produce forged steel fittings, and
the combined production capacity on this shared equipment and machinery in the periods
indicated.
“Overall 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 short tons)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Overall finishing capacity
Production on finishing equipment
and machinery:
Using your own forgings
Not using your own forgings1
Subtotal, finished steel fittings
Certain excluded fittings

Other products3
Total
1

Data entered for production of finished steel fittings made from purchased unfinished steel fittings will populate here once
reported in question II-10.
2
As defined on page 2. Please identify these excluded fittings:
.
3
Please identify these machine worked products:
.

II-3d.

Operating parameters.--The production capacity reported in II-3c is based on the following
operating paramaters:
Hours per week

Weeks per year

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings

Page 11

II-3e.

Forging capacity calculation.--Please describe the methodology used to calculate overall forging
capacity reported in II-3a, and explain any changes in reported capacity.

II-3f.

Finishing capacity calculation.--Please describe the methodology used to calculate overall finishing
capacity reported in II-3b, and explain any changes in reported capacity.

II-3g.

Production constraints on forging operations.--Please describe the constraint(s) that set the limit(s)
on your firm’s forging capacity.

II-3h.

Production constraints on finishing operations.--Please describe the constraint(s) that set the
limit(s) on your firm’s finishing capacity.

II-3i.

Unfinished and finished steel fittings.—
(i)

Please describe the similarities and differences in the physical characteristics and functions
of unfinished steel fittings (forgings) and finished steel fittings.

(ii)

Please describe the uses and markets for your firm’s unfinished steel fittings (forgings) that
you do not further manufacture into finished steel fittings.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-3j.

Page 12

Finishing only operations.--Since January 1, 2015, has your firm purchased unfinished or semifinished forged steel fittings covered by the investigations (either domestic or imported) and
further processed those purchases into products that still match the scope definition of forged
steel fittings?

Yes

If yes—Please describe the nature and extent of the following items in
relation to your firm's finishing processing operations in the United States.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Costs and activities

II-3k.

Capital investments.-(i)

Forging only machinery investment costs.--Please describe and quantify the amount of
capital investments (from a greenfield investment stand point) needed to forge steel
fittings.
Value (in $1,000)
Description

(ii)

Finishing only machinery investment costs.--Please describe and quantify the amount
of capital investments needed (from a greenfield investment stand point) to finish steel
fittings. Do not include in this analysis any upstream forging machinery, or downstream
end use machinery.
Value (in $1,000)
Description

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-3l.

Page 13

Finishing only processing operations' complexity and importance.--On a scale of 1 to 5, please
provide your firm's subjective opinion as to the complexity, intensity, and importance
of finishing only processing activities. 1 being minimally complex, intense, and important. 5
being extremely complex, intense, and important.

1:
Minimally complex,
intense, and
important

5:
Extremely complex,
intense, and
important

Please describe the reason for your rating.

II-3m. Product shifting.—
(i)

Is your firm able to switch production (capacity) between forged steel fittings 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.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-3n.

Page 14

Machining of bar stock and/or seamless tubular products.—
(i).

Does your firm generate fittings corresponding to the definition of “forged steel fittings”
(see pages 2-3 of this questionnaire) by machining carbon or alloy (other than stainless)
steel bar stock and/or seamless tubular products?
No

(ii).

Yes -- Please describe the nature of your firm’s machining operations.

Please report the quantity of “forged steel fittings” generated by machining carbon or alloy
(other than stainless) steel bar stock and/or seamless tubular products.
Quantity (in short tons)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Production of forged steel
fittings generated by machining

II-4.

Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of forged steel fittings?
“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.

Yes

If yes-- Please describe the toll arrangement(s) and name the firm(s)
involved.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-5.

Page 15

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce forged steel fittings in and/or admit
forged steel fittings into a foreign trade zone (FTZ)?

(a)

“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import forged steel fittings into a foreign trade zone (FTZ) for use in distribution of
forged steel fittings and/or the production of downstream articles?

(b)

II-6.

Yes

If yes-- Describe the nature of your firms operations in FTZs and identify
the specific FTZ site(s).

Yes

If yes--Identify the firms and the FTZs.

Importer.--Has your firm imported forged steel fittings, including unfinished, semi-finished, or
finished fittings, since January 1, 2015?
“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
If yes-- COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
II-7.

Page 16

Production, shipment, and inventory data – integrated production.--Report your firm’s
production capacity, production, shipments, and inventories related to the production of forged
steel fittings in its U.S. establishment(s) during the specified periods. In this question include
only data relating to forged steel fittings (regardless of whether they were sold as finished
forged steel fittings or unfinished forged steel fittings) that your firm itself forged in the United
States. Do not include data relating to forged steel fittings that your firm purchased or imported
as an unfinished or semi-finished steel fitting from outside the United States and finished in the
United States. Do not include data relating to steel fittings that your firm machined from
purchases of bar stock or steel pipes. Also do not include resales.
“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.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. 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 - Forged Steel Fittings
II-7.

Page 17

Production, shipment, and inventory data.--Continued

Forged Steel Fittings (Integrated Operations)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Average production capacity
(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)
Value2 (G)
Transfers to related firms:2
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories
(quantity) (L)
Channels of distribution:
Commercial U.S. shipments:
To distributors (M)
To finishers/converters (N)
To end users (O)
1

The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
.
methodology used to calculate production capacity, and explain any changes in reported capacity
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm uses a
different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value data using
that basis for each of the periods noted above:
.
3
Identify your firm’s principal export markets:
.

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-7.

Page 18

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.

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

Calendar years
2016

2015
0

January-March
2017
2018

2017

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

0
.

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. 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 years
Reconciliation
M + N + O – D = zero ("0"), if not
revise.

2015

2016
0

January-March
2017

2017
0

2018
0

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-8.

Page 19

U.S. shipments by level of processing.--Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by level of
processing during the specified periods.

Forged Steel Fittings (Integrated Operations)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2015

January-March

2016

2017

2018

U.S. shipments:
Unfinished or semi-finished
forged steel fittings:
Quantity (P)
Value (Q)
Finished forged steel fittings:
Quantity (R)
Value (S)
RECONCILIATION OF SHIPMENTS.--Please ensure that the quantities reported for U.S. shipments in this
question (i.e., lines P through S) in each time period equal the quantity reported for U.S. shipments a
previous question (i.e., lines D through I) 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.

Reconciliation
Quantity: P + R – D –F – H = zero
("0"), if not revise.
Value: Q + S – E –G – I = zero ("0"), if
not revise.

Calendar years
2016

2015

January-March
2017
2018

2017

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-9.

Page 20

U.S. shipments by product type and size.--Report your firm's U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) by product
type and size for calendar year 2017. If any fittings have both a threaded and non-threaded
end, classify those fittings as threaded for the purposes of this question. If any fittings have
both less than 4 inch end and a 4 inch or greater end, classify those as 4 inch or greater fittings
for the purposes of this question.

Forged Steel Fittings (Integrated Operations)
Calendar year 2017
Product type

Less than 4 inches

4 inches or greater

All sizes

Quantity (in short tons)
Elbows.-Threaded (T)

Non-threaded (U)

Tees.-Threaded (V)

Non-threaded (W)

Couplings.—
Threaded (X)

Non-threaded (Y)

Unions.—
Threaded (Z)

Non-threaded (AA)

Other fittings. —
Threaded (AB)

Non-threaded (AC)

All in-scope fittings.—
Threaded (AD)

Non-threaded (AE)

Please describe the type of fittings:

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--The data reported for the quantity of
U.S. shipments in this question (i.e., lines T through AC) should equal to the quantity of U.S. shipments
(i.e., lines D, F, and H) for calendar year 2017 in the main trade grid, question II-7. If the calculated fields
below do not equal to zero, please revise these data prior to submission to the Commission.
Reconciliation
Quantity: T + U + V + W + X + Y + Z + AA + AB + AC – D – F
– H = zero ("0"), if not revise.

Calendar year 2017
0

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-10.

Page 21

Employment data – integrated operations.--Report your firm’s employment-related data
related to the production of finished forged steel fittings 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. For the January to March periods, calculate similarly and divide by 3.
“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. If
there are hours that are not specific to either forging or finishing operations, allocate them on
the same basis as the ratio that exists for hours that can be specifically identified (e.g., if your
there are 600 hours for forging activities and 400 for finishing activities, and an additional 100
hours that cannot be tired to either level of processing, report 60 of that 100 under forging and
40 of that 100 under finishing).
“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.

Forged Steel Fittings (Integrated Operations)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
dedicated to forging activities
Hours worked by PRWs (1,000 hours)
dedicated to finishing activities
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-11.

Page 22

Production, shipment, and inventory data – finishing operations only.--Report your firm’s
production capacity, production, shipments, and inventories related to the production of
finished forged steel fittings in its U.S. establishment(s) during the specified periods. In this
question include only data relating to forged steel fittings that your firm finished in the United
States but did not forge, i.e., data relating to purchased unfinished fittings, bar stock, and/or
seamless pipe and tube, that your firm finished prior to sale to a customer. Do not include data
reported in question II-7. Also do not include resales.
“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.
“Commercial U.S. shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm. 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.

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-11.

Page 23

Production, shipment, and inventory data.--Continued

Forged Steel Fittings (Finishing Only Operations)
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Average production capacity
(quantity) (AF)

Beginning-of-period inventories
(quantity) (AG)
Production (quantity) using.-Purchases of U.S.-manufactured
unfinished or semi-finished
steel fittings (AH)
Purchases/imports of unfinished
or semi-finished steel fittings
from subject sources (AI)
Purchases/imports of unfinished
or semi-finished steel fittings
from nonsubject sources (AJ)
Purchases/imports of bar stock
or seamless pipe and tube,
regardless of source (AK)
Total production (AL)

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II-11.

Page 24

Production, shipment, and inventory data.--Continued
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

U.S. shipments:
Commercial shipments:
Quantity (AM)
Value (AN)
Internal consumption:2
Quantity (AO)
Value2 (AP)
Transfers to related firms:2
Quantity (AQ)
Value2 (AR)
Export shipments:3
Quantity (AS)
Value (AT)
End-of-period inventories
(quantity) (AU)
Channels of distribution:
Commercial U.S. shipments:
To distributors (AV)
To end users (AW)
1

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U.S. Producers’ Questionnaire - Forged Steel Fittings
II-11.

Page 25

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 AU) should be equal to the beginning-of-period inventories (i.e., line
AG), plus production (i.e., lines AH through AK), less total shipments (i.e., lines AM, AO, AQ, and AS).
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.

Reconciliation
AG + AH + AI + AJ + AK – AM – AO – AQ – AS
– AU = should equal zero ("0") or provide
an explanation.1
1

Calendar years
2016

2015

January-March
2017
2018

2017

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:

0
.

RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution
(i.e., lines AW and AX) in each time period equal the quantity reported for commercial U.S. shipments
(i.e., line AN) in each time period. If the calculated fields below return values other than zero (i.e., “0”),
the data reported must be revised prior to submission to the Commission.
Calendar years
Reconciliation
AV + AW – AM = zero ("0"), if not
revise.

2015

2016
0

January-March
2017

2017
0

2018
0

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II-12.

Page 26

Forged Steel Fittings (Finishing Only Operations)
Calendar year 2017
Product type

Less than 4 inches

4 inches or greater

All sizes

Quantity (in short tons)
Elbows.-Threaded (AX)

Non-threaded (AY)

Tees.-Threaded (AZ)

Non-threaded (BA)

Couplings.—
Threaded (BB)

Non-threaded (BC)

Unions.—
Threaded (BD)

Non-threaded (BE)

Other fittings. —
Threaded (BF)

Non-threaded (BG)

All in-scope fittings.—
Threaded (BH)
Non-threaded (BI)
1

Please describe the type of fittings:

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--The data reported for the quantity of
U.S. shipments in this question (i.e., lines AX through BI) should equal to the quantity of U.S. shipments
(i.e., lines AM, AO, and AQ) for calendar year 2017 in the main trade grid, question II-10. If the
calculated fields below do not equal to zero, please revise these data prior to submission to the
Commission.
Reconciliation
Quantity: AX + AY + AZ + BA + BB + BC + BD + BE + BF + BG
– AM – AO – AQ = zero ("0"), if not revise.

Calendar year 2017
0

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II-13.

Page 27

Employment data – finishing only operations.--Report your firm’s employment-related data
related to the production of unfinished forged steel fittings 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. For the January to March periods, calculate similarly and divide by 3.
“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.

Forged Steel Fittings (Finishing Only Operations)
Calendar years
Item
Average number of PRWs (number)
Hours worked by PRWs (1,000 hours)
Wages paid to PRWs ($1,000)
Explanation of trends:

2015

2016

January-March
2017

2017

2018

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II-14.

Page 28

Related firms.--If your firm reported transfers to related firms in question II-7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

II-15a. Purchases.--Other than direct imports, has your firm otherwise purchased steel fittings,
including unfinished, semi-finished, or finished fittings, since January 1, 2015?
“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.
No

Yes--Report such purchases below and explain the reasons for your firms'
purchases:

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Page 29

II-15b. Purchases of unfinished or semi-finished forged steel fittings.--Report your firm's purchases of
unfinished or semi-finished steel fittings.
(Quantity in short tons)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Purchases from U.S.
importers1 of unfinished
forged steel fittings from—
China
Italy
Taiwan
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:
.

II-15c. Purchases of finished forged steel fittings.--Report your firm's purchases of finished steel
fittings.
(Quantity in short tons)
Calendar years
Item

2015

2016

January-March
2017

2017

2018

Purchases from U.S.
importers1 of finished forged
steel fittings from—
China
Italy
Taiwan
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
1

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II-16.

Page 30

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

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Page 31

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Jennifer Brinckhaus (202-2053188, jennifer.brinckhaus@usitc.gov).
III-1.

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 forged steel fittings:

Does your firm prepare profit/loss statements for forged steel fittings:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
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 forged steel fittings, 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.).

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Page 32

III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

III-5.

Product listing.--Please list the products your firm produced in the facilities in which your firm
produced forged steel fittings, and provide the share of net sales accounted for by these
products in your firm’s most recent fiscal year.
Products

Share of sales

Forged steel fittings

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of forged steel fittings 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 forged steel
fittings that your firm purchases from related suppliers and that are reflected in question III-9a.
For “Share of total COGS” please report this information by relevant input on the basis of your
most recently completed fiscal year. For “Input valuation” please describe the basis, as
recorded in your company’s own accounting system, of the purchase cost from the related
supplier; e.g., the related supplier’s actual cost, cost plus, negotiated transfer price to
approximate fair market value.
Input

Related supplier

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records (e.g., cost plus, FMV, etc.)

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U.S. Producers’ Questionnaire - Forged Steel Fittings
III-8.

Page 33

Inputs purchased from related suppliers.--Please confirm that the inputs purchased from
related suppliers, as identified in III-7, were reported in III-9a (financial results on forged steel
fittings) in a manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
suppliers as reported in table III-9a.

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Page 34

III-9a. Operations on forged steel fittings –Integrated producers.--Report the revenue and related
cost information requested below on the forged steel fittings operations of your firm’s U.S.
establishment(s).1 Do not report resales of products. Note that internal consumption and
transfers to related firms must be valued at fair market value. Input purchases from related
suppliers should be consistent with and based on information in the firm’s accounting books
and records. Provide data for your firm’s three most recently completed fiscal years, and for
the specified interim periods.

Forged Steel Fittings (Integrated Production)
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2015

2016

January-March

2017

2018

Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

Total COGS

Gross profit or (loss)

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
Cost of goods sold (COGS):
Raw materials

Direct labor
Other factory costs

Selling, general, and administrative (SG&A)
expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
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.
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.
2

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Page 35

III-9b. Alternative COGS based on level of processing –Integrated producers.--Report the cost of
goods sold below on the forged steel fittings operations of your firm’s U.S. establishment(s). If
there are costs that are not specific to either forging or finishing operations, allocate them on
the same basis as the ratio that exists for costs that can be specifically identified (e.g., if there
are $600 costs for forging activities and $400 costs for finishing activities, and there are an
additional $100 costs that are not specific to either level of the process, put $60 of that $100
under forging and $40 of that $100 under finishing). Note that most, if not all, raw materials
would be classified under forging costs.

Forged Steel Fittings (Integrated Production)
Value (in $1,000)
Fiscal years ended-Item

2015

2016

January-March

2017

2018

Cost of goods sold (COGS):
Forging costs
Finishing costs
Total COGS

RECONCILIATION OF CHANNELS.--Please ensure that the total COGS in III-9a equals the total COGS in this
question in each. If the calculated fields below return values other than zero (i.e., “0”), the data reported
must be revised prior to submission to the Commission.
Calendar years
Reconciliation
Should equal = zero ("0"), if not
revise.

2015

2016

January-March
2017

2017

2018

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U.S. Producers’ Questionnaire - Forged Steel Fittings
III-9c.

Page 36

Operations on forged steel fittings –Producers that purchase unfinished forged steel fittings
and further finish them.--Report the revenue and related cost information requested below on
the finished forged steel fittings operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related suppliers should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years, and for the specified interim periods.

Forged Steel Fittings (Firms with Finishing Operations Only)
Quantity (in short tons) and value (in $1,000)
Fiscal years ended--

2015

Item

2016

January-March

2017

2018

Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
3

Cost of goods sold (COGS):
Purchases domestically produced
unfinished or semi-finished forged steel
fittings (Domestic)
Purchased imported unfinished or semifinished forged steel fittings from subject
sources (Subject)
Purchased imported unfinished or semifinished forged steel fittings from
nonsubject sources (Nonsubject)
Total purchased unfinished forged steel
fittings
Purchased bar or pipes
Other raw materials
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)

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U.S. Producers’ Questionnaire - Forged Steel Fittings
III-9c.

Page 37

Operations on forged steel fittings –Continued
Quantity (in short tons) and value (in $1,000)
Fiscal years ended--

2015

Item

2016

January-March

2017

2018

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
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.
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.
2

III-9d. Financial data reconciliation.--The calculable line items from questions III-9a and III-9c (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.

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Page 38

III-10a. Nonrecurring items (charges and gains) included in the subject product financial results.-- For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific 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.

Forged Steel Fittings (Integrated Production)
Fiscal years ended--

2015

2016

Item

January-March

2017

2018

Value ($1,000)

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9a where the nonrecurring item is classified.

Description of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Income statement classification of the
nonrecurring item

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III-10b. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9c, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific question III-9c 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-9c; i.e., if an aggregate nonrecurring item has been allocated to question
III-9c, only the allocated value amount included in question III-9c 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-9c.

Forged Steel Fittings (Firms with Finishing Operations Only)
Fiscal years ended--

2015

2016

Item

January-March

2017

2018

Value ($1,000)

Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Nonrecurring item: In this table please provide a brief description of each nonrecurring item reported above and
indicate the specific line item in table III-9c where the nonrecurring item is classified.

Description of the nonrecurring item
Nonrecurring item 1
Nonrecurring item 2
Nonrecurring item 3
Nonrecurring item 4
Nonrecurring item 5
Nonrecurring item 6
Nonrecurring item 7

Income statement classification of the
nonrecurring item

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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-12a. Asset values – Integrated Producers.--Report the total assets (i.e., both current and long-term
assets) associated with the production, warehousing, and sale of forged steel fittings. If your
firm does not maintain some or all of the specific asset information necessary to calculate total
assets for forged steel fittings 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: Fixed assets should reflect the historical acquisition cost of your firm's fixed assets (such
as property, plant, and equipment), while net fixed assets should be the book value of your
firm's fixed assets taking into account any accumulated depreciation, impairments, or
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.

Forged Steel Fittings (Integrated Production)
Value (in $1,000)
Fiscal years ended-Item

2015

2016

2017

Fixed assets (historical value)
Accumulated depreciation

Net fixed assets (book value)

Non-fixed assets

Total net assets (book value)
1

Indicate the average age of these fixed assets.
.
Include all impairments and write-offs.
3
Describe the composition of the fixed asset pool and the reason for any noticeable changes over
the period.
4
If applicable, report non-fixed assets net of any accumulated depreciation, amortizations, and/or
impairments; and describe the major classes (by dollar value) of non-fixed assets reported
above.
2

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III-12b. Asset values – Finishing Operations Only.--Report the total assets (i.e., both current and longterm assets) associated with the production, warehousing, and sale of forged steel fittings. If
your firm does not maintain some or all of the specific asset information necessary to calculate
total assets for forged steel fittings 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-9c. Provide data as of the end of your firm’s three most
recently completed fiscal years.
Note: Fixed assets should reflect the historical acquisition cost of your firm's fixed assets (such
as property, plant, and equipment), while net fixed assets should be the book value of your
firm's fixed assets taking into account any accumulated depreciation, impairments, or
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.

Forged Steel Fittings (Finishing Operations Only)
Value (in $1,000)
Fiscal years ended-Item

2015

2016

2017

Fixed assets (historical value)
Accumulated depreciation

Net fixed assets (book value)

Non-fixed assets

Total net assets (book value)
1

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III-13a. Capital expenditures and research and development expenses – Integrated producers.-Report your firm’s capital expenditures and research and development expenses for forged
steel fittings. Provide data for your firm’s three most recently completed fiscal years, and for
the specified interim periods.

Forged Steel Fittings (Integrated Production)
Value (in $1,000)
Fiscal years ended--

Item
Capital expenditures

2015

2016

January-March

2017

2018

1
2

Research and development expenses
1
2

Please describe the nature, focus, and significance of your firm’s capital expenditures on the subject product.
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject product.

III-13b. Capital expenditures and research and development expenses – Finisher operations only.-Report your firm’s capital expenditures and research and development expenses for forged
steel fittings. Provide data for your firm’s three most recently completed fiscal years, and for
the specified interim periods.

Forged Steel Fittings (Finishing Operations Only)
Value (in $1,000)
Fiscal years ended--

Item
Capital expenditures

2015

2016

January-March

2017

1
2

Research and development expenses
1
2

2018

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III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9, 12, and 13 are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in questions III-9a and III-9c should reconcile
with the data reported in questions II-7 and II-11 (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 for 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, in which case only the interim periods must reconcile. 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.

Forged Steel Fittings (Integrated Production)
Full year data
Reconciliation

2015

2016

Partial year periods
2017

2017

2018

Quantity: Trade data from question
II-7 (lines D, F, H, and J) less financial
total net sales quantity data from
question III-9a, = zero ("0").

Value: Trade data from question II-7
(lines E, G, I, and K) less financial
total net sales value data from
question III-9a, = zero ("0").

Do these data in question III-9a reconcile with data in question II-7?
Yes

If no, please explain.

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III-14. Data consistency and reconciliation.--Continued

Forged Steel Fittings (Finishing Operations Only)
Full year data
Reconciliation

2015

2016

Partial year periods
2017

2017

2018

Quantity: Trade data from question
II-9 (lines AM, AO, AQ, and AS) less
financial total net sales quantity data
from question III-9c, = zero ("0").

Value: Trade data from question II-9
(lines AN, AP, AR, and AT) less
financial total net sales value data
from question III-9c, = zero ("0").

Do these data in question III-9c reconcile with data in question II-9?
Yes

If no, please explain.

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If your responses to any of the items in questions III-15, III-16, and III-17 differ by country, please
describe these differences and, as applicable, indicate which country or countries your response refers
to in the relevant form fields.
III-15. Effects of imports on investment.--Since January 1, 2015, has your firm experienced any actual
negative effects on its return on investment or the scale of capital investments as a result of
imports of forged steel fittings from China, Italy, and/or Taiwan?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)
Cancellation, postponement,
or rejection of expansion
projects
Denial or rejection of
investment proposal
Reduction in the size of
capital investments
Return on specific
investments negatively
impacted
Other

(please describe)

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III-16. Effects of imports on growth and development.--Since January 1, 2015, has your firm
experienced any actual negative effects on its growth, ability to raise capital, or existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product) as a result of imports of forged steel fittings from China, Italy, and/or
Taiwan?
No

Yes--My firm has experienced actual negative effects as follows:
(check as many as appropriate)

(please describe)

Rejection of bank loans

Lowering of credit rating

Problem related to the issue
of stocks or bonds
Ability to service debt

Other

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
forged steel fittings from China, Italy, and/or Taiwan?
No

Yes

If yes, my firm anticipates negative effects as follows:

III-18. Other explanations.--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, please note the question number and the explanation in
the space provided below. Please also use this space to highlight any issues your firm had in
providing the data in this section, including but not limited to technical issues with the MS Word
questionnaire.

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PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Jeffrey Clark (202-2053318, jeffrey.clark@usitc.gov).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2015 of the following products produced by your
firm.
Product 1.--ASME B16.11, ¼” 3000 Tee (threaded)
Product 2.--ASME B16.11, 1” 2000 90 Elbow (threaded)
Product 3.--ASME B16.11, ¾” 3000 Union (threaded)
Product 4.--ASME B16.11, 2” 3000 Coupling (threaded)

Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
IV-2 (a). During January 2015-March 2018, 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 tables as appropriate.
No.--Skip to question IV-3.

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IV-2(b). Price data.--Report below the quarterly price data1 for pricing products2 produced (i.e., forged
and finished) and sold by your firm

Integrated Production
Report data in pounds (not short tons) and actual dollars (not 1,000s).
Product 1
Quantity
Value

(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

Product 4
Period of shipment
Quantity
Value
2015:
January-March
April-June
July-September
October-December
2016:
January-March
April-June
July-September
October-December
2017:
January-March
April-June
July-September
October-December
2018:
January-March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods), f.o.b. your
firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.
Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product, provide a description
of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:

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IV-2(c). Price data.--Report below the quarterly price data1 for pricing products2 finished in the United
States but initially forged or semi-finished outside the United States and sold by your firm

Finisher Only
Report data in pounds (not short tons) and actual dollars (not 1,000s).
Product 1
Quantity
Value

(Quantity in pounds, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value

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IV-2 (d). Price data checklist.--Please check that the pricing data in question IV-2(b) has been correctly
reported.
Is the price data reported above:

√ if Yes

Value data In actual dollars (not $1,000)?
Quantity data in pounds (not short tons)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-2 (e). 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.

Business Proprietary
U.S. Producers’ Questionnaire - Forged Steel Fittings
IV-3.

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

IV-4.

Contracts

Other

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced forged steel fittings?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic forged steel fittings usually quoted
(check one)?
Delivered

IV-6.

Set
price
lists

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

Quantity
discounts

IV-5.

Page 51

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced forged
steel fittings in 2017 was on a (1) long-term contract basis, (2) annual contract basis, (3) shortterm contract basis, and (4) spot sales basis?

Share of 2017
sales

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

Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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U.S. Producers’ Questionnaire - Forged Steel Fittings
IV-7.

Page 52

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced forged steel fittings (or check “not applicable” if your firm does not sell on a longterm, short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

No. of
days

Price renegotiation
(during contract
period)

Yes

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

Annual contracts
(multiple
deliveries for 12
months)

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

365

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

Not applicable
IV-8.

Lead times.--What is your firm’s share of sales from inventory and produced to order and what
is the typical lead time between a customer’s order and the date of delivery for your firm’s sales
of its U.S.-produced forged steel fittings?

Source

Share of 2017 Lead time (Average
sales
number of days)

From inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

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U.S. Producers’ Questionnaire - Forged Steel Fittings
IV-9.

Page 53

Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced forged steel fittings
that is accounted for by U.S. inland transportation costs?
percent

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(c)

Indicate the approximate percentage of your firm’s sales of forged steel fittings that are
delivered the following distances from its production facility.
Distance from production facility

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 forged steel fittings since January 1, 2015 (check all that apply)?
Geographic area
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.

√ if applicable

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IV-11. End uses.--List the end uses of the forged steel fittings that your firm manufactures. For each
end-use product, what percentage of the total cost is accounted for by forged steel fittings and
other inputs?
Share of total cost of end use product
accounted for by
End use product

Forged steel fittings

Total
(should sum to
100.0% across)

Other inputs

0.0 %

IV-12. Substitutes.--Can other products be substituted for forged steel fittings?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for forged steel fittings?
No Yes

Explanation

1.
2.
3.

IV-13. Unfinished fittings. –
(a) Is there a market for unfinished forged steel fittings?
No – skip to part (c)

Yes – continue to part (b)

(b) Please describe your firm’s efforts to sell unfinished forged steel fittings since

January 1, 2015?

Reason
There is no demand for unfinished forged steel fittings
Your firm does not want to supply competitors with unfinished forged steel fittings
It is not profitable to sell unfinished forged steel fittings
Other:

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IV-14. Demand trends.—Indicate how demand within the United States and outside of the United
States (if known) for forged steel fittings has changed since January 1, 2015. Explain any trends
and describe the principal factors that have affected these changes in demand.
January 1, 2015-December 31, 2016
Overall
increase

Market

No change

Overall
decrease

Since January 1, 2017
Overall
increase

No change

Overall
decrease

Within the United States
for the Oil and Gas
Sector
Within the United States
for all other sectors1
Outside the United States
for the Oil and Gas
Sector
Outside the United States
for all other sectors1
Explanation and factors:
1

Please describe the "other" sectors:

IV-15. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of forged steel fittings since January 1, 2015?
No

Yes

If yes, please describe and quantify if possible.

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IV-16. Conditions of competition.-(a) Is the forged steel fittings market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to forged steel
fittings? If yes, describe.
Check all that apply.

Please describe.

Skip to question IV-17.

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
forged steel fittings since January 1, 2015?
No

Yes

If yes, describe.

IV-17. Supply constraints.--Has your firm refused, declined, or been unable to supply forged steel
fittings since January 1, 2015 (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, being unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

IV-18. Raw materials.--How have forged steel fittings raw material prices changed since January 1,
2015?
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend

Explain, noting how raw material price changes
have affected your firm’s selling prices for forged
steel fittings.

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IV-19. Interchangeability.--Is forged steel fittings produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair
Country-pair

China

Italy

Taiwan

Other countries

United States
China
Italy
Taiwan
For any country-pair producing forged steel fittings that is sometimes or never
interchangeable, identify the country-pair and explain the factors that limit or preclude
interchangeable use:

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IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between forged steel fittings
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair
Country-pair

China

Italy

Taiwan

Other countries

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

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IV-21. Customer identification.--List your firm’s 10 largest U.S. customers for forged steel fittings since
January 1, 2015. Indicate the share of the quantity of your firm’s total shipments of forged steel
fittings that each of these customers accounted for in 2017.

Firm name

1
2
3
4
5
6
7
8
9
10

City and state

Share of 2017
sales (%)

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IV-22. Competition from imports
(a)

Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling forged
steel fittings from China, Italy, and Taiwan, did your firm:
Item

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2015: Did your firm lose sales of forged steel fittings to
imports of this product from China, Italy, and Taiwan?
No

Yes

IV-23. Other explanations.--If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

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Page 61

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/forged_steel_fittings_china_ital
y_and_taiwan/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: FSF

• E-mail.—E-mail the MS Word questionnaire to celia.feldpausch@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 (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.

File Type	application/pdf
File Title	USITCQUESTIONNAIRE
Subject	Title 7 investigations
Author	Boyland, David
File Modified	2018-05-21
File Created	2018-05-21