18-3-3966 US purchasers' questionnaire

OMB No. 3117-0016/USITC No. 18-3-3966; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

LOST SALES AND LOST REVENUE SURVEY
Refillable Stainless Steel Kegs from China, Germany, and Mexico
This survey must be received by the Commission by October 4, 2018
See last page for filing instructions.
The information called for in this survey is for use by the United States International Trade Commission in connection
with its countervailing duty and antidumping investigations concerning refillable stainless steel kegs from China,
Germany, and Mexico (inv. Nos. 701-TA-610 and 731-TA-1425-1427 (Preliminary)). The information requested in the
survey 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 possession
(19 U.S.C. § 1333(a)). Further information on this survey can be obtained from Jon Ruder (202-205-3435,
jonathan.ruder@usitc.gov).
Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased refillable stainless steel kegs (as defined on next page) at any time since January 1,
2015?

NO

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

YES

(Complete all parts of the survey, and return the entire survey 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: KEGS)
CERTIFICATION
I certify that the information herein supplied in this survey 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 submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
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
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Signature

Phone

Email address

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs (Preliminary)

Page 2

GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on September 19, 2018, by
American Keg Company, LLC, Pottstown, Pennsylvania. 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/dumping. U.S. producers
of refillable stainless steel kegs have provided the USITC with allegations about sales or revenue that
they have lost due to competition from imports of refillable stainless steel kegs from China, Germany,
and Mexico. Questionnaires and other information pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/stainless_steel_kegs_china_germany_and_mexico/
preliminary.htm
Refillable stainless steel kegs covered by these investigations are cylindrical kegs, vessels, or containers
capable of being pressurized made from stainless steel (i.e., steel containing at least 10.5 percent
chromium by weight and less than 1.2 percent carbon by weight, with or without other elements)
("refillable stainless steel kegs") with a nominal liquid volume capacity of 10 liters or more, regardless of
the type of finish, gauge, thickness, or grade of stainless steel, regardless of finish, and whether or not
covered by or encased in other materials. Refillable stainless steel kegs may be imported assembled or
unassembled, with or without all components (including spears, couplers or taps, necks, collars, and
valves), and filled or unfilled. Assembled refillable stainless steel kegs must be capable of being
pressurized to 60 pounds per square inch ("PSI") and must be tested to 90 PSI.
"Unassembled" or "unfinished" refillable stainless steel kegs include drawn stainless steel cylinders that
have been welded to form the body of the keg and welded to an upper (top) chime and/or lower
(bottom) chime. Unassembled refillable stainless steel kegs may or may not be welded to a neck, may or
may not have a valve assembly attached, and may be otherwise complete except for testing,
certification and/or marking.
Subject merchandise also includes refillable stainless steel kegs that have been further processed in a
third country, including but not limited to, attachment of necks, collars, spears or valves, heat
treatment, pickling, passivation, painting, testing, certification or any other processing that would not
otherwise remove the merchandise from the scope of the investigation if performed in the country of
manufacture of the in-scope refillable stainless steel keg.
Specifically excluded are the following:
(1)
vessels or containers that are not cylindrical in nature;
(2)
stainless steel kegs, vessels, or containers that have either a "ball lock" valve system or a "pin
lock" valve system (commonly known as a "Cornelius," ''corny" or "ball lock" kegs);
(3)
any fully assembled or finished stainless steel keg, vessel, or container that is incompatible with
a "D Sankey" extractor (commonly known as a "D Coupler" or "Sankey"); and
(4)
necks, spears, couplers or taps, collars, and valves that are not imported with the subject
merchandise.
(5)
stainless steel kegs that are filled with beer, wine, or other liquid and that are designated by the
Commissioner of Customs as Instruments of International Traffic within the meaning of section 332(a) of
the Tariff Act of 1930, as amended.

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs

Page 3

The merchandise covered by these investigations is currently classified in the Harmonized Tariff
Schedule of the United States ("HTSUS") under subheading 7310.10.0010, 7310.10.0050, 7310.29.0025,
and 7310.29.0050.
These HTSUS subheadings are provided for convenience and customs purposes; the written description
of the scope of this investigation is dispositive. The HTSUS provisions are for convenience and customs
purposes; the written description of the scope is dispositive.
Reporting of information.-- If information is not readily available from your records, provide carefully
prepared estimates.
Confidentiality.--The data furnished in response to this survey 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.
Release of information.--The information provided by your firm in response to this survey, 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. Please also retain a copy of the final document that you submit.
Contact information.--Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs

Page 4

PURCHASE INFORMATION
Purchases and imports.--Report separately your firm’s domestic purchases and imports of
refillable stainless steel kegs.

1.

“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S.
firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2015

2016

Item

January-June January-June
2017
2018

2017

Quantity (in units)

Purchases of refillable
stainless steel kegs produced
in—
United States
China
Germany
Mexico
All other countries1
Sources unknown
Total purchases

0

0

0

0

0

0

0

0

0

0

Imports of refillable stainless
steel kegs from—
China
2

Germany
Mexico
All other countries1
Total imports

Please identify these countries:
If your firm imported refillable stainless steel kegs any time since January 1, 2015, please also complete and
return a U.S. importers' questionnaire in this proceeding.
1
2

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs

Page 5

Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of
refillable stainless steel kegs from different sources have changed since January 1, 2015.

2.

Source of
purchases

Did not
purchase

Decreased Increased

Constant

Fluctuated

Explanation for trend

United States

China

Germany

Mexico

All other
countries
Sources
unknown

3. Major purchasing factors.--Please list, in order of their importance and one item per line, the main
factors your firm considers in deciding from whom to purchase refillable stainless steel kegs.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs

Page 6

4. Purchasing subject imports rather than domestic products.—
(a)

Since January 2015, did your firm purchase imports of refillable stainless steel kegs from
China, Germany, and Mexico instead of available U.S.-produced refillable stainless steel
kegs? Respond for each subject country.

Source

Yes
(also respond to parts (b) and (c))

No
(If “No” for all countries, skip parts (b)
and (c))

China
Germany
Mexico
(b)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source

Yes

No

China
Germany
Mexico
(c)

If you responded “Yes” to part (a), was price a primary reason for purchasing subject
imports rather than domestic product?

Source

China
Germany
Mexico

Yes

If Yes, estimate the quantity
of imports purchased instead
of domestic product since
January 2015
(in units)

No

If No, please indicate the
reason your firm purchased
imports instead of domestic
product

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs
5.

Page 7

U.S. producers and import competition.—
(a)

Since January 1, 2015, in connection with a sale or offer to sell refillable stainless steel
kegs to your firm, did U.S. producers reduce their prices of domestically produced
stainless steel kegs in order to compete with lower-priced imports of refillable stainless
steel kegs from the subject countries? Respond for each subject country.
Source

Yes (also respond to
question part (b))

No (If “No” for all countries,
skip part (b))

Don’t know

China
Germany
Mexico
(b)

If your firm responded “yes” to any of the above countries, please provide an estimate
of the reduction in U.S. producers’ prices, and any additional explanations, such as
timing (e.g., months/years), frequency of price reductions, or other market/competitive
factors.

Source

Estimated
reduction in U.S.
prices
(percent)

China

%

Germany

%

Mexico

%

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

6. Method of purchase--Please provide a general description of your firm’s method(s) of purchase
(e.g., individual purchase, contract, bids, Internet purchases, etc.) for refillable stainless steel kegs.

7. Other explanations--Please provide any additional comments in this box.

Business Proprietary
Lost Sales and Lost Revenue Survey- Refillable Stainless Steel Kegs

Page 8

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

Dollars

The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.

HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey along with a scanned copy of the signed
certification page (page 1) through the Commission’s secure upload facility:
o
o
o

Web address: https://dropbox.usitc.gov/oinv/
Enter Investigation: Select “stainless steel kegs from China, Germany, and Mexico” in the drop
down menu
Pin: KEGS

• E-mail.—E-mail the MS Word survey to jonathan.ruder@usitc.gov; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.