Form 18-1-3940 US producers' questionnaire

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

US producers--Cast iron soil pipe (F)

Cast iron soil pipe from China (Inv. Nos. 701-TA-597 and 731-TA-1407 (Final))

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 18-1-3940; Expiration Date: 6/30/2020
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U.S. PRODUCERS’ QUESTIONNAIRE
CAST IRON SOIL PIPE FROM CHINA
This questionnaire must be received by the Commission by October 18, 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 investigations concerning cast iron soil pipe from China (Inv.
Nos. 701-TA-597 and 731-TA-1407 (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 cast iron soil pipe (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: CISP)
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 – Cast Iron Soil Pipe

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on January 26, 2018, by Cast
Iron Soil Pipe Institute (“CISPI”), Mundelein, IL. Countervailing and antidumping duties may be assessed
on the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce
(“Commerce”) makes an affirmative determination of subsidization and/or dumping. Questionnaires
and other information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2018/cast_iron_soil_pipe_china/final.htm.
Cast iron soil pipe covered by these investigations is cast iron soil pipe, whether finished or unfinished,
regardless of industry or proprietary specifications, and regardless of wall thickness, length, diameter,
surface finish, end finish, or stenciling. Both hubless and hub and spigot cast iron soil pipe are included
in the scope of this investigation. Cast iron soil pipe is nonmalleable iron pipe of various designs and
sizes. Cast iron soil pipe is generally distinguished from other types of nonmalleable cast iron pipe by the
manner in which it is connected to cast iron soil pipe fittings.
Cast iron soil pipe is classified into two major types – hubless and hub and spigot. Hubless cast iron soil
pipe is manufactured without a hub, generally in compliance with Cast Iron Soil Pipe Institute (“CISPI”)
specification 301 and/or American Society for Testing and Materials (“ASTM”) specification A888. Hub
and spigot pipe has one or more hubs into which the spigot (plain end) of a fitting is inserted. All pipe
meeting the physical description set forth above is covered by the scope of this investigation, whether
or not produced according to a particular standard.
The subject imports are currently classified in statistical reporting number 7303.00.0030 of the
Harmonized Tariff Schedule of the United States (HTSUS): Cast iron soil pipe. The HTSUS subheading and
specifications are provided for convenience and customs purposes only; the written description of the
scope of these investigations 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,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.--The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.
Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
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

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 3

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.
I-1a.

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

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
I-2.

Page 4

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of cast iron soil pipe,
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

I-3.

Additional discussion on establishments consolidated in this questionnaire:

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

China AD
China CVD

Support

Oppose

Take no position

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
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 cast iron soil pipe from China into the United States or
that are engaged in exporting cast iron soil pipe from China to the United States?
No
Firm name

I-6.

Page 5

Yes--List the following information.
Country

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of cast iron soil pipe?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Junie Joseph (202-205-3363,
junie.joseph@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 cast iron soil pipe 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)

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
II-3a.

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Production using same machinery.--Please report your firm’s production of all products made
using the same machinery, equipment or workers as cast iron soil pipe, and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise using the same
machinery, equipment, or employees as scope merchandise then the "overall
production capacity" numbers reported in this question should be exactly equal to the
"average production capacity" numbers reported in question II-7. If, however, your firm
does produce out-of-scope merchandise using the same machinery, equipment or
employees as scope mercandhise, then the "average production capacity" reported in
question II-7 should exclude the portion of "overall production capacity" that was used
to produce this out-of-scope merchandise.

“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-June
2017

2017

2018

Overall production capacity
Production of:
Cast iron soil pipe1
Other products
Total
1
2

Data entered for production of cast iron soil pipe will populate here once reported in question II-7.
Please identify these products:
.

II-3b.

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

Weeks per year

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

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II-3c.

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

II-3d.

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

II-3e.

Product shifting.—
(i)

Is your firm able to switch production (capacity) between cast iron soil pipe and other
products using the same equipment and/or labor?

(ii)

Yes

If 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 – Cast Iron Soil Pipe
II-4.

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Tolling.--Since January 1, 2015, has your firm been involved in a toll agreement regarding the
production of cast iron soil pipe?
“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.

II-5.

Yes

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

Foreign trade zones.-Firm's FTZ operations.--Does your firm produce cast iron soil pipe in and/or admit cast
iron soil pipe 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.

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

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

(b)

II-6.

Yes

If yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2015, has your firm imported cast iron soil pipe?
“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

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
II-7.

Page 10

Production, shipment, and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of cast iron soil pipe in its U.S.
establishment(s) during the specified periods.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. Assume
normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
“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 – Cast Iron Soil Pipe
II-7.

Page 11

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

2015

2016

January-June
2017

2017

2018

Average production capacity (quantity) (A)
1

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)
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. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.):
. However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets:
.
1

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) should be equal to the beginning-of-period inventories (i.e., line B), plus production
(i.e., line C), less total shipments (i.e., lines D, F, H, and J). Please ensure that any differences are not due to data
entry errors in completing this form, but rather reflect your firm’s actual records; and, also provide explanations
for any differences (e.g., theft, loss, damage, record systems issues, etc.) if they exist.
Calendar years

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

2015

2016

January-June
2017

2017

2018

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

0
.

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

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Channels of distribution.--Report your firm’s U.S. shipments (i.e., inclusive of commercial U.S.
shipments, internal consumption, and transfers to related firms) by channel of distribution.

II-8.

Quantity (in short tons)
Calendar years
Item

2015

2016

January-June
2017

2017

2018

Channels of distribution:
U.S. shipments:
To distributors (M)
To plumbers / contractors (N)
To other end users (O)
RECONCILIATION OF CHANNELS.--Please ensure that the quantities reported for channels of distribution (i.e.,
lines M, N, and O) in each time period equal the quantity reported for U.S. shipments (i.e., lines D, F, and H) 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

2015

M + N + O – D – F – H = zero ("0"), if
not revise.
II-9a.

2016

January-June
2017

2017

2018

U.S. shipments by product type and region in 2017.--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 region for calendar year 2017.
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.

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
II-9a.

Page 13

U.S. shipments by product type and region in 2017.—Continued
Calendar year 2017
Region

Hubless

Hub and spigot

Quantity (in short tons) and value (in $1,000)
Northeast.-Quantity (P)
Value (Q)
Midwest.-Quantity (R)
Value (S)
Southeast.-Quantity (T)
Value (U)
Central Southwest.-Quantity (V)
Value (W)
Mountains.-Quantity (X)
Value (Y)
Pacific Coast.-Quantity (Z)
Value (AA)
Other.-Quantity (AB)
Value (AC)
Entire United States.-Quantity
Value

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--The data reported for the quantity and value of
U.S. shipments in this question (i.e., lines P through AC) across all columns should equal to the quantity and value of
U.S. shipments (i.e., lines D through I) 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

Calendar year 2017

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

Value: Q + S + U + W + Y + AA + AC – E - G – I = zero ("0"), if not revise.

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
II-9b.

Page 14

U.S. shipments by product type in 2017.--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 for calendar year 2017.
Quantity (in short tons) and value (in $1,000)
Calendar year 2017
Item

Epoxy coated

Not epoxy coated

All coating types

U.S. shipments:
Quantity (AD)

Value (AE)

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--The data reported for the quantity and value of
U.S. shipments in this question (i.e., lines AD through AE) across all columns should equal to the quantity and value
of U.S. shipments (i.e., lines D through I) for calendar year 2017 in the main trade grid, question II-5a. If the
calculated fields below do not equal to zero, please revise these data prior to submission to the Commission.

Reconciliation

Calendar year 2017

Quantity: AD – D – F – H = zero ("0"), if not revise.

Value: AE – E – G – I = zero ("0"), if not revise.

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
II-10.

Page 15

Employment data.--Report your firm’s employment-related data related to the production of
cast iron soil pipe 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 June periods, calculate similarly and divide by 6.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.
Calendar years
Item

2015

2016

January-June
2017

2017

2018

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

II-11.

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.

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
II-12.

Page 16

Purchases.--Other than your own firm's imports, has your firm otherwise purchased cast iron
soil pipe 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 imported the product.
“Import” –A transaction to buy from a foreign supplier where your firm is the importer of
record.
No

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

(Quantity in short tons)
Calendar years
Item

2015

2016

January-June
2017

2017

2018

Purchases from U.S.
importers1 of cast iron soil
pipe from—
China
All other sources
Purchases from domestic
producers2
Purchases from other
sources2
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:
.
1

II-13.

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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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 17

PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Charles Yost (202-205-3432,
Charles.Yost@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 cast iron soil pipe:

Does your firm prepare profit/loss statements for cast iron soil pipe:
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,
10 Qs,
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 cast iron soil pipe, as
well as specific statements and worksheets) used to compile these data.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 18

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 cast iron soil pipe, and provide the share of net sales accounted for by these products
in your firm’s most recent fiscal year.
Products

Share of sales

Cast iron soil pipe

Cast iron soil pipe fittings

%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any services) used in the
production of cast iron soil pipe 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 cast iron soil
pipe 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

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
III-8.

Page 19

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 cast iron soil
pipe) in a manner consistent with your firm’s accounting books and records.

Yes

If yes-- In the space below, please report the valuation basis of inputs
purchased from related suppliers as reported in question III-9a.:

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 20

III-9a. Operations on cast iron soil pipe.--Report the revenue and related cost information requested
below on the cast iron soil pipe 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. If your
firm was involved in tolling operations (either as the toller or as the tollee), please contact
Charles Yost at (202)205-3432 before completing this section of the questionnaire.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2015

2016

January-June

2017

2018

Net sales quantities:2
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms (“Transfers”)
Total net sales quantities

Total COGS

Gross profit or (loss)

values:2

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

(COGS):3

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
Legal fees and expenses4
All other expense items
All other income items
Net income or (loss) before income taxes
Depreciation/amortization included above
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.
4 Related to lawsuit alleging anticompetitive behavior when it was settled in 2016. Explain how legal fees and expenses were
allocated between cast iron soil pipe, cast iron soil pipe fittings (a product subject to related import injury proceeding), and other
product lines:
.
1

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 21

III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?

Yes

III-9c.

If 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.

Raw materials for cast iron soil pipe.--Please indicate the share of total raw material costs in
2017 (reported in III-9a) for the following raw material inputs:

Products
Metal costs
Coating costs
Other1
Total (should sum to 100 percent)

Share of 2017 total
raw material costs
(percent)
%
%
%
0.0 %

Please indicate any other notable "other" raw materials not expressly identified above
and provide the share of the 2017 total raw material costs that they account for:
1

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 22

III-10. 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.
Fiscal years ended-Item

2015

2016

January-June

2017

2018

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

Income statement classification 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

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.

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 23

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of cast iron soil pipe. If your firm does not maintain some
or all of the specific asset information necessary to calculate total assets for cast iron soil pipe in
the normal course of business, please estimate this information based upon a method (such as
production, sales, or costs) that is consistent with relevant cost allocations in question III-9a.
Provide data as of the end of your firm’s three most recently completed fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

III-13.

2015

2016

2017

Describe

Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses for cast iron soil pipe. Provide data for
your firm’s three most recently completed fiscal years, and for the specified interim periods.
Value (in $1,000)
Fiscal years ended-Item
Capital expenditures

2015

2016

January-June
2017

2017

2018

Research and development
expenses2
Please describe the nature, focus, and significance of your firm’s capital expenditures on the
subject product.
2
Please describe the nature, focus, and significance of your firm’s R&D expenses related to subject
product.
1

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 24

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

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (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.
Fiscal years ended-Reconciliation

2015

2016

January-June
2017

2017

2018

Quantity: Trade data from question II-6
(lines D, F, H, and J) less financial total
net sales quantity data from question III9a, = zero ("0").

Value: Trade data from question II-6
(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.

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 25

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 cast iron soil pipe from China?
No

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

(please describe)

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

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 cast iron soil pipe from China?
No

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

Lowering of credit rating

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

Other

(please describe)

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 26

III-17. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
cast iron soil pipe from China?
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.

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 27

PART IV.--PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Andrew Knipe (202-2052390, andrew.knipe@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.--2” x 10’ no hub cast iron soil pipe, other than epoxy coated
Product 2.--4” x 10’ no hub cast iron soil pipe, other than epoxy coated
Product 3.--3” x 10’ no hub cast iron soil pipe, other than epoxy coated
Product 4.--6” x 10’ no hub cast iron soil pipe, other than epoxy coated

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, direct and indirect rebates, truckload rebates, promotional assistance,
etc.).
IV-2a. During January 2015-June 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 table as appropriate.
No.--Skip to question IV-3.

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 28

IV-2b. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report data in pounds and actual dollars (not 1,000s).

VALUE SHOULD BE THE FINAL AMOUNT RECEIVED, NET OF ALL REBATES AND INCENTIVES.
(Quantity in pounds, value in dollars)
Product 1
Product 2
Product 3
Quantity
Value
Quantity
Value
Quantity
Value
(pounds)
(dollars)
(pounds)
(dollars)
(pounds)
(dollars)

Product 4
Quantity
Value
(pounds)
(dollars)

Period of shipment
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
April-June
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:

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
IV-2c.

Page 29

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

In pounds (not short tons)?
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates, including rebates based on sales of cast iron
soil pipe sold in conjunction with other products?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II-7 in each year?
IV-2d.

Rebate allocation.--Please explain your method for allocating rebates, discounts, et cetera
between cast iron soil pipe and cast iron soil pipe fittings.

IV-2e.

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 – Cast Iron Soil Pipe
IV-3.

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

IV-4.

Contracts

Set
price
lists

Other

If other, describe

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

Quantity
discounts

IV-5.

Page 30

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Rebates.—
(a)

List the names, amounts, and types of rebates offered to purchasers of cast iron soil
pipe in 2017?

Rebate description (including payment frequency and
requirement(s) for payment)

Rebate
amount
(percent)

Type of rebate1
Direct

Indirect

%
%
%
%
%
%
%
%
A direct rebate is based solely on the purchases of cast iron soil pipe. An indirect rebate is based on the
joint purchase of cast iron soil pipe and other products.
1

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
IV-5.

Rebates.—Continued
(b)

For each indirect rebate listed in part (a), what proportion of the total rebate paid in
2017 was attributable to sale of cast iron soil pipe vs. other products that helped to
trigger the payment of that rebate? The two proportions will sum to 100%.

Type of rebate

IV-6.

Page 31

Cast iron soil pipe Other products

Total
(should
sum to
100.0%)

0.0

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced cast iron soil pipe?
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 cast iron soil pipe usually quoted (check
one)?
Delivered

F.o.b.

If f.o.b., specify point

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe
IV-7.

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced cast
iron soil pipe 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
IV-8.

Page 32

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

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

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

Contract provisions.--Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced cast iron soil pipe (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

Indexed to raw
material costs1

Not applicable
1

Please identify the index(es) used:

IV-9.

Lead times.--What is your firm’s share of sales from inventory vs. 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 cast iron soil pipe?
Source

Share of 2017 sales

From inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

Lead time (Average
number of days)

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 33

IV-10. Shipping information.-(a)

What is the approximate percentage of the cost of U.S.-produced cast iron soil pipe 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 cast iron soil pipe 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-11. End uses.--List the end uses of the cast iron soil pipe that your firm manufactures. For each enduse product, what percentage of the total cost is accounted for by cast iron soil pipe and other
inputs?
Share of total cost of end use
product accounted for by
End use product

Cast iron soil
pipe

Other
inputs

Total
(should sum to
100.0% across)

Building wastewater plumbing system

0.0 %

Building/structure (estimated low end of
cost share of cast iron soil pipe)

0.0 %

Building/structure (estimated high end of
cost share of cast iron soil pipe)

0.0 %

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 34

IV-12. Substitutes.--Can other products be substituted for cast iron soil pipe?
No

Yes--Please fill out the table.

End use in which this
substitute is used

Substitute

Have changes in the price of this substitute
affected the price for cast iron soil pipe?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for cast iron soil pipe has changed since January 1, 2015. Explain any trends
and describe the principal factors that have affected these changes in demand.

Market

Overall
increase

No
Overall
Change decrease

Fluctuate
with no
clear trend

Explanation and factors

Within the United
States
Outside the United
States
IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of cast iron soil pipe since January 1, 2015?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Product types.--Does your firm manufacture sizes/types/grades/coatings of cast iron soil pipe
that it does not sell in the United States?

Yes

If yes, please describe these products, where they are sold, why your firm
does not sell them in the U.S. market, and quantify if possible.

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 35

IV-16. Conditions of competition.-(a) Is the cast iron soil pipe market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to cast iron soil pipe?
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
cast iron soil pipe since January 1, 2015?
No

Yes

If yes, describe.

IV-17. Regional requirements.--In which regions/cities/areas are cast iron soil pipe required/used?

IV-18. Building requirements--In what types of building projects are cast iron soil pipe required?

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 36

IV-19. Sales bundles.—
(a)

Do your firm’s sales of cast iron soil pipe also usually involve the sale of products other
than cast iron soil pipe such as cast iron soil pipe fittings, couplings, gaskets, plastic pipe
and fittings, etc.?
No (skip to
IV-20)

(b)

If yes, list the types of products involved in these sales.

Are cast iron soil pipe sales invoiced separately or as part of the bundle with products
other than cast iron soil pipe?
No

(c)

Yes

If yes, list the types of products also listed on these invoices.

Does your firm sell cast iron soil pipe at different price list multipliers than products
other than cast iron soil pipe such as cast iron soil pipe fittings, couplings, gaskets,
plastic pipe and fittings, etc.?

Yes

If yes, list examples of recent sales that have different multipliers
including the approximate dates of those purchases.

IV-20. CISPI Trademark.—
(a)

What share of the cast iron soil pipe that your firm sells carry the CISPI trademark?
0-1%

2-10%

11-50%

51-90%

91-98%

Continue to part (b)
(b)

99-100%

Skip to III-21

What share of the cast iron soil pipe that your firm sells can be used if building plans call
for CISPI trademark materials?
0-1%

2-10%

11-50%

51-90%

91-98%

99-100%

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 37

IV-21. Anti-competitive allegations.--Have the following issues affected your firm and the market for
cast iron soil pipe in general since January 1, 2015?
(a)

The Federal Trade Commission’s inquiry and 2013 consent order regarding Charlotte
Pipe’s 2010 acquisition of Star Pipe (see https://www.ftc.gov/news-events/pressreleases/2013/04/charlotte-pipe-and-foundry-settles-charges-its-2010-purchase-star)
No

Yes

If yes, describe the effect(s)

Effect on your firm
Effect on the market
Effect on prices
(b)

The Federal Trade Commission’s 2012 inquiry and 2014 finding regarding McWane, Star
Pipe, and Sigma Corporation’s price setting for ductile iron pipe fittings
(see https://www.ftc.gov/enforcement/cases-proceedings/101-0080b/mcwane-inc-starpipe-products-ltd-matter)
No

Yes

If yes, describe the effect(s)

Effect on your firm
Effect on the market
Effect on prices
(c)

The U.S. District Court litigation against Charlotte Pipe and McWane regarding alleged
anti-competitive behavior, filed in 2014 and settled in 2017
(see https://www.cohenmilstein.com/case-study/cast-iron-soil-pipe-and-fittingsantitrust-litigation)
No

Effect on your firm
Effect on the market
Effect on prices

Yes

If yes, describe the effect(s)

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U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 38

IV-22. Supply constraints.--Has your firm refused, declined, or been unable to supply cast iron soil pipe
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-23. Raw materials.--How have cast iron soil pipe 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 cast
iron soil pipe.

IV-24. Interchangeability.--Is cast iron soil pipe 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

Other countries

United States
China
For any country-pair producing cast iron soil pipe that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 39

IV-25. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between cast iron soil pipe
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

Other countries

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

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 40

IV-26. Customer identification.--List the names and contact information for your firm’s 10 largest U.S.
customers for U.S.-produced cast iron soil pipe since January 1, 2015. Indicate the share of the
quantity of your firm’s total shipments of U.S.-produced cast iron soil pipe that each of these
customers accounted for in 2017.
Customer’s name
1
2
3
4
5
6
7
8
9
10

City

State

Share of 2017
sales (%)

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 41

IV-27. Competition from imports
(a)

Lost revenue.--Since January 1, 2015: To avoid losing sales to competitors selling cast
iron soil pipe from China, 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 cast iron soil pipe to
imports of this product from China?
No

Yes

IV-28. 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.

Business Proprietary
U.S. Producers’ Questionnaire – Cast Iron Soil Pipe

Page 42

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://usitc.gov/investigations/701731/2018/cast_iron_soil_pipe_china/final.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: CISP

• E-mail.—E-mail the MS Word questionnaire to junie.joseph@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	US producer questionnaire
Subject	Title 7 investigations
Author	Duncan, Russell
File Modified	2018-09-06
File Created	2018-09-06