19-3-4023 US purchasers' questionnaire

OMB No. 3117-0016/USITC No. 19-3-4023; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

U.S. PURCHASERS’ QUESTIONNAIRE
STEEL RACKS FROM CHINA
This questionnaire must be received by the Commission by May 1, 2019
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 steel racks from China (Inv. Nos. 701TA-608 and 731-TA-1420 (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 possession (19 U.S.C. § 1333(a)). Further information
on this questionnaire can be obtained from Cindy Cohen (202-205-3230, cindy.cohen@usitc.gov).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased steel racks (as defined on next page) from any source (domestic or foreign) at any time
since January 1, 2016?

NO (Sign the certification below and promptly return only this page of the questionnaire to the Commission)
YES (Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: RACKS)
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
submitting 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

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on June 20, 2018, by Bulldog
Rack Company, Weirton, West Virginia; Hannibal Industries, Inc., Los Angeles, California; Husky Rack and
Wire, Denver, North Carolina; Ridg-U-Rak, Inc., North East, Pennsylvania; SpaceRAK, A Division of
Heartland Steel Products, Inc., Marysville, Michigan; Speedrack Products Group, Ltd., Sparta, Michigan;
Steel King Industries, Inc., Stevens Point, Wisconsin; Tri-Boro Shelving & Partition Corp., Farmville,
Virginia; and UNARCO Material Handling, Inc., Springfield, Tennessee. 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/steel_racks_china/final.htm.
Steel racks covered by these investigations are steel racks and parts thereof, assembled, to any extent,
or unassembled, including but not limited to, vertical components (e.g., uprights, posts, or
columns), horizontal or diagonal components (e.g., arms or beams), braces, frames, locking devices (e.g.,
end plates and beam connectors), and accessories (including, but not limited to, rails, skid channels, skid
rails, drum/coil beds, fork clearance bars, pallet supports, row spacers, and wall ties).
Subject steel racks and parts thereof are made of steel, including, but not limited to, cold and/or
hot-formed steel, regardless of the type of steel used to produce the components and may, or may not,
include locking tabs, slots, or bolted, clamped, or welded connections. Subject steel racks have the
following physical characteristics:
(1) Each steel vertical and horizontal load bearing member (e.g., arms, beams, posts, and
columns) is composed of steel that is at least 0.044 inches thick;
(2) Each steel vertical and horizontal load bearing member (e.g., arms, beams, posts, and
columns) is composed of steel that has a yield strength equal to or greater than 36,000 pounds
per square inch;
(3) The width of each steel vertical load bearing member (e.g., posts and columns) exceeds two
inches; and
(4) The overall depth of each steel roll-formed horizontal load bearing member (e.g., beams)
exceeds two inches.
In the case of steel horizontal load bearing members other than roll-formed (e.g., structural beams, Zbeams, or cantilever arms), only the criteria in subparagraphs (1) and (2) apply to these horizontal load
bearing members. The depth limitation in subparagraph (4) does not apply to steel horizontal load
bearing members that are not roll-formed.
Steel rack components can be assembled into structures of various dimensions and configurations by
welding, bolting, clipping, or with the use of devices such as clips, end plates, and beam connectors,
including, but not limited to the following configurations: 1) racks with upright frames perpendicular to
the aisles that are independently adjustable, with positive-locking beams parallel to the aisle spanning
the upright frames with braces; and 2) cantilever racks with vertical components parallel to the aisle and
cantilever beams or arms connected to the vertical components perpendicular to the aisle. Steel racks
may be referred to as pallet racks, storage racks, stacker racks, retail racks, pick modules, selective racks,
or cantilever racks and may incorporate moving components and be referred to as pallet-flow racks,

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

Page 3

carton-flow racks, push-back racks, movable-shelf racks, drive-in racks, and drive-through racks. While
steel racks may be made to ANSI MH16.l or ANSI MH16.3 standards, all steel racks and parts thereof
meeting the description set out herein are covered by the scope of these investigations, whether or not
produced according to a particular standard.
The scope includes all steel racks and parts thereof meeting the description above, regardless of
(1) other dimensions, weight, or load rating;
(2) vertical components or frame type (including structural, roll-form, or other);
(3) horizontal support or beam/brace type (including but not limited to structural, roll-form, slotted,
unslotted, Z-beam, C-beam, L-beam, step beam, and cantilever beam);
(4) number of supports;
(5) number of levels;
(6) surface coating, if any (including but not limited to paint, epoxy, powder coating, zinc, or
other metallic coatings);
(7) rack shape (including but not limited to rectangular, square, corner, and cantilever);
(8) the method by which the vertical and horizontal supports connect (including but not limited
to locking tabs or slots, bolting, clamping, and welding); and
(9) whether or not the steel rack has moving components (including but not limited to rails, wheels,
rollers, tracks, channels, carts, and conveyors).
Subject merchandise includes merchandise matching the above description that has been finished or
packaged in a third country. Finishing includes, but is not limited to, coating, painting, or assembly,
including attaching the merchandise to another product, or any other finishing or assembly operation
that would not remove the merchandise from the scope of these investigations if performed in the
country of manufacture of the steel racks and parts thereof. Packaging includes packaging the
merchandise with or without another product or any other packaging operation that would not remove
the merchandise from the scope of these investigations if performed in the country of manufacture of
the steel racks and parts thereof.
Steel racks and parts thereof are included in the scope of these investigations whether or not imported
attached to, or included with, other parts or accessories such as wire decking, nuts, and bolts. If steel
racks and parts thereof are imported attached to, or included with, such non-subject merchandise, only
the steel racks and parts thereof are included in the scope.
The scope of these investigations does not cover: 1) decks, i.e., shelving that sits on or fits into the
horizontal supports to provide the horizontal storage surface of the steel racks; 2) wire shelving units,
i.e., units made from wire that incorporate both a wire deck and wire horizontal supports (taking the
place of the horizontal beams and braces) into a single piece with tubular collars that slide over the
posts and onto plastic sleeves snapped on the posts to create a finished unit; 3) pins, nuts, bolts,
washers, and clips used as connecting devices; and 4) non-steel components.
Specifically excluded from the scope of these investigations are any products covered by Commerce’s
existing antidumping and countervailing duty orders on boltless steel shelving units prepackaged for sale
from the People’s Republic of China. See Boltless Steel Shelving Units Prepackaged for Sale From the
People’s Republic of China: Antidumping Duty Order, 80 Fed. Reg. 63,741 (October 21, 2017); Boltless
Steel Shelving Units Prepackaged for Sale From the People’s Republic of China: Amended Final
Affirmative Countervailing Duty Determination and Countervailing Duty Order, 80 Fed. Reg. 63,745
(October 21, 2017).

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Also excluded from the scope of these investigations are bulk-packed parts or components of boltless
steel shelving units that were specifically excluded from the scope of the Boltless Steel Shelving Orders
because such bulk-packed parts or components do not contain the steel vertical supports (i.e., uprights
and posts) and steel horizontal supports (i.e., beams, braces) packaged together for assembly into a
completed boltless steel shelving unit.
Such excluded components of boltless steel shelving are defined as:
(1) boltless horizontal supports (beams, braces) that have each of the following characteristics: (a) a
length of 95 inches or less, (b) made from steel that has a thickness of 0.068 inches or less, and (c) a
weight capacity that does not exceed 2500 lbs per pair of beams for beams that are 78” or shorter, a
weight capacity that does not exceed 2200 lbs per pair of beams for beams that are over 78” long but
not longer than 90”, and/or a weight capacity that does not exceed 1800 lbs per pair of beams for
beams that are longer than 90”;
(2) shelf supports that mate with the aforementioned horizontal supports; and
(3) boltless vertical supports (upright welded frames and posts) that have each of the following
characteristics: (a) a length of 95 inches or less, (b) with no face that exceeds 2.90 inches wide, and (c)
made from steel that has a thickness of 0.065 inches or less.
Excluded from the scope of these investigations are: (1) wall-mounted shelving and racks, defined as
shelving and racks that suspend all of the load from the wall, and do not stand on, or transfer load to,
the floor; (2) ceiling-mounted shelving and racks, defined as shelving and racks that suspend all of the
load from the ceiling and do not stand on, or transfer load to, the floor; and (3) wall/ceiling mounted
shelving and racks, defined as shelving and racks that suspend the load from the ceiling and the wall and
do not stand on, or transfer load to, the floor. The addition of a wall or ceiling bracket or other device to
attach otherwise subject merchandise to a wall or ceiling does not meet the terms of this exclusion.
Also excluded from the scope of these investigations is scaffolding that complies with ANSI/ASSE
A10.8 - 2011 – Scaffolding Safety Requirements, CAN/CSA S269.2-M87 (Reaffirmed 2003) – Access
Scaffolding for Construction Purposes, and/or Occupational Safety and Health Administration
regulations at 29 C.F.R. Part 1926 subpart L – Scaffolds.
Also excluded from the scope of these investigations are tubular racks such as garment racks and drying
racks, i.e., racks in which the load bearing vertical and horizontal steel members consist solely of: (1)
round tubes that are no more than two inches in diameter; (2) round rods that are no more than two
inches in diameter; (3) other tubular shapes that have both an overall height of no more than two inches
and an overall width of no more than two inches; and/or (4) wire.
Also excluded from the scope of these investigations are portable tier racks. Portable tier racks must
meet each of the following criteria to qualify for this exclusion:
(1) They are freestanding, portable assemblies with a fully welded base and four freely inserted and
easily removable corner posts;
(2) They are assembled without the use of bolts, braces, anchors, brackets, clips, attachments, or
connectors;
(3) One assembly may be stacked on top of another without applying any additional load to the product
being stored on each assembly, but individual portable tier racks are not securely attached to one
another to provide interaction or interdependence; and
(4) The assemblies have no mechanism (e.g., a welded foot plate with bolt holes) for anchoring the
assembly to the ground.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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Also excluded from the scope of these investigations are accessories that are independently bolted to
the floor and not attached to the rack system itself, i.e., column protectors, corner guards, bollards, and
end row and end of aisle protectors.
Merchandise covered by these investigations is currently classified in the Harmonized Tariff Schedule of
the United States (HTSUS) under the following subheadings: 7326.90.8688, 9403.20.0080, and
9403.90.8041. Subject merchandise may also enter under subheadings 7308.90.3000, 7308.90.6000,
7308.90.9590, and 9403.20.0090. The HTSUS subheadings are provided for convenience and U.S.
Customs purposes only. The written description of the scope is dispositive.
Purchaser.--Any firm engaged, either directly or through a parent company or subsidiary, in purchasing
steel racks from another firm that produces, imports, or otherwise distributes steel racks.
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
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.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)
I-1.

Page 6

Establishments covered.--Provide the name and address of your U.S. establishment(s) covered
by this questionnaire, if different from that listed on the cover page. Firms operating more than
one establishment should combine the data for all establishments into a single response.
“Establishment”--Each facility of a firm involved in the purchase of steel racks, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.

I-2.

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

Firm name

I-3.

Address

Extent of ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, which import steel racks into the United States or which export steel racks to the United
States?
No
Firm name

I-4.

Yes--List the following information.

Yes--List the following information.
Country

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, which
produce steel racks?
No
Firm name

Yes--List the following information.
Country

Affiliation

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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PART II.--PURCHASES
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 questionnaire.
Name
Title
Email
Telephone
II-1.

Purchases and imports.1-- Report separately your firm’s domestic purchases and imports of
steel racks.
“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.
2016

2017

Item

January-March
2019

2018

Quantity (in pounds)

Purchases of steel racks
produced in-United States
China
Mexico
All other countries1
Sources unknown2
Total purchases

0

0

0

0

0

0

0

0

3

Imports of steel racks from-China
Mexico
All other countries1
Total imports3
1

Please identify these countries:
.
2
Please indicate the reason for not knowing the source of the steel racks purchased and indicate the firm(s)
from which you purchased this merchandise:
.
3
If your firm imported steel racks at any time since January 1, 2016, please also complete and return a U.S.
importers' questionnaire in this proceeding.

1

Please complete and return a U.S. importers’ questionnaire if your firm is an importer of record.

Business Proprietary
U.S. Purchasers’ Questionnaire – Steel racks (Final)
II-2.

Page 8

Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of
steel racks from different sources have changed since January 1, 2016.
Source of
purchases

Did not
purchase

Decreased Increased Constant Fluctuated

Explanation for
trend

United States
China
Mexico
All other countries
Sources unknown
II-3.

Country knowledge.--Please indicate the countries of origin with which your firm has
experience or information in the steel racks market.
United
States

II-4.

China

Mexico

Other
countries

Other countries (specify)

Supplier identification.--Please list your firm’s FIVE largest suppliers for steel racks since January
1, 2016. Also, provide the share of the quantity of your firm’s total purchases of steel racks that
each of these suppliers accounted for in 2018.

No.

Supplier’s name

City and state

Share of quantity of
2018 purchases

1

%

2

%

3

%

4

%

5

%

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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PART III.--MARKET CHARACTERISTICS AND PURCHASING PRACTICES
III-1.

Firm type.--Which of the following best describes your firm as a purchaser of steel racks (check
all that apply)?
End user/retailer

Distributor

Other

Describe other

If your firm is a distributor of steel racks, please answer questions III-2 and III-3.
III-2.

Competition for sales.--Does your firm compete for sales to customers with the manufacturers
or importers from which your firm purchases steel racks?
No

III-3.

Yes

If yes, please describe.

Types of customers.--What are the major types of consumers to which your firm sells steel
racks?

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If your firm is an end user of steel racks, please answer questions III-4 and III-5.
III-4a. Cost share by end uses.--List the top 3 products your firm makes using steel racks and estimate
the percent of your total production cost that is accounted for by steel racks and by other inputs
(such as labor, energy, and other raw materials).
Share of total cost in each of the product(s) your
firm produces accounted for by

Final product(s) your firm
produces

Total
(should
sum to
100.0%
across)

Other inputs,
assembly, or
installation costs

Steel racks
% +

%

=

0.0 %

% +

%

=

0.0 %

% +

%

=

0.0 %

III-4b. End use categories.--Please indicate what share of your firm’s purchases of steel racks in 2018
were used for each of the following end user categories.
Share of 2018 purchases
(should sum to 100.0% down)

End use
Used for retail or customer-visible displays
Used for warehousing and storage
Other uses, describe
Total (should sum to 100.0% down)
III-5.

%
%
%
0.0 %

Demand for end use products.-(a)

Has the demand for your firm’s final products incorporating steel racks changed since
January 1, 2016?
Increased

(b)

No change

Decreased

Fluctuated

Has this had any effect on your firm’s demand for steel racks?
No

Yes

Explain

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U.S. Purchasers’ Questionnaire – Steel racks (Final)
III-6.

Page 11

Substitutes.--Can other products be substituted for steel racks?
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 steel racks?
No Yes

Explanation

1.
2.
3.
III-7.

Demand trends.--Indicate how demand within the United States and outside of the United
States (if known) for steel racks has changed since January 1, 2016. Explain any trends and
describe the principal factors that have affected these changes in demand.

Overall
increase

Market

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Within the United States
Outside the United States
III-8.

Country preferences.--Do you or your customers ever specifically order steel racks from one
country in particular over other possible sources of supply?
No

Yes

If yes, identify the countries and explain.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

III-9.

Page 12

Importance of purchasing domestic product.--Please fill out the table below, estimating the
percentage of your firm’s total 2018 purchases of steel racks that required steel racks produced
in the United States.

Purchases that did not require domestic product
Purchases that were required by law or regulation to be domestic product
(e.g., government purchases under “Buy American” provisions)
Purchases that were not required by law or regulation, but were required by
your customers to be domestic product
Purchases that were required to be domestic product for other reasons
(explain:
)
Total (should sum to 100.0%)

Estimated percentage of
your firm’s total 2018
purchases of steel racks
%
%
%
%
0.0 %

III-10. Conditions of competition.-(a)

Is the steel racks market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to steel racks?

Check all that apply.

Please describe.

No

Skip to question III-11.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b)

Have there been any changes in the business cycles or conditions of competition for
steel racks since January 1, 2016?
No

Yes

If yes, describe.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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III-11. Decisions based on producer and country-of-origin.--How often does your firm, and if known,
do your customers, make purchasing decisions involving steel racks based on its producer or
country of origin?
Item

Always

Usually

Sometimes

Never

If at least sometimes, explain.

Decision based on producer
Your firm
Your
customers
Decision based on country of origin
Your firm
Your
customers
III-12. Availability of supply.--Has the availability of steel racks in the U.S. market changed since
January 1, 2016?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
U.S.-produced product
Chinese imports
Non-Chinese imports
III-13. Supply constraints.--Has any firm refused, declined, or been unable to supply your firm with
steel racks since January 1, 2016 (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.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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III-14. Availability of specific product types.--Are certain grades/types/sizes of steel racks only
available from certain country sources?
No

Yes

If yes, please identify the countries and the grade/type/size.

III-15. Purchasing frequency.-(a)

How frequently does your firm make purchases of steel racks (check one)?
Daily

(b)

Weekly

Monthly

Quarterly

Annually

Other

If other, specify

Has this purchasing frequency changed since January 1, 2016?
No

Yes

If yes, please describe.

III-16. Number of suppliers contacted.--How many suppliers does your firm generally contact before
making a purchase? Between
and
firms
III-17. Supplier negotiations.--Do your firm’s purchases of steel racks usually involve negotiations
between supplier and purchaser?

No

Yes

If yes, explain the factors your firm generally negotiates and note
whether your firm quotes competing prices during negotiations.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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III-18. Change in suppliers.--Has your firm changed suppliers since January 1, 2016?

No

Yes

If yes, please list the supplier(s), whether the firm was added or
dropped, and the reasons for the change.

III-19. New suppliers.--Are you aware of any new suppliers, either foreign or domestic, that have
entered the market since January 1, 2016?
No

Yes

If yes, please identify the firms.

III-20. Supplier qualification.--Do you require your suppliers to be or to become certified or qualified
to sell steel racks to your firm?
If yes, provide the following information.
 The number of days to qualify a new supplier.
 A general description of the certification or qualification process. Also, a brief
description of the factors that you consider when qualifying a new supplier (e.g., quality
of product, reliability of supplier, etc.).

No

Yes

Number
of days Process and factors

III-21. Failure to certify.--Since January 1, 2016, have any domestic or foreign producers failed in their
attempts to certify or qualify their steel racks with your firm or have any producers lost their
approved status?

No

Yes

If yes, please identify these firms, the countries where they are located,
and the reasons why they failed the certification/qualification.

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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III-22. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase steel racks (examples include availability,
extension of credit, contracts, price, quality, range of supplier’s product line, traditional supplier,
etc.).
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:

.

III-23. Purchasing factors.--Please rate the importance of the following factors in your firm’s
purchasing decisions for steel racks.

Factor
Assembly/installation service
Availability
Corrosion protection
Delivery terms
Delivery time
Discounts offered
Minimum quantity requirements
Packaging
Payment terms
Price
Product consistency
Product range
Quality meets industry standards
Reliability of supply
RMI certification
Technical support/service
U.S. transportation costs
Visual aesthetics

Very
important

Somewhat
important

Not
important

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

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III-24. Quality characteristics.--What characteristics does your firm consider when determining the
quality of steel racks?

III-25. Minimum quality.--How often do steel racks from the following countries meet minimum
quality specifications for your uses or your customers’ uses?

Source

Always

Usually

Sometimes

Rarely or
never

Don’t
know

United States
China
Mexico
Other:
III-26. Frequency of decisions based on price.--How often does your firm purchase the steel racks that
are offered at the lowest price?
Always

Usually

Sometimes

Never

III-27. Price leaders.--A price leader is defined as (1) one or more firms that initiate a price change,
either upward or downward, that is followed by other firms, or (2) one or more firms that have a
significant impact on prices. A price leader is not necessarily the lowest-priced supplier.
Please list the names of any firms you considered price leaders in the steel racks market since
January 1, 2016.
Firm(s)

Describe how the firm(s) exhibited price leadership

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

Page 18

III-28. Purchasing subject imports rather than domestic products.—
(a)

Since January 2016, did your firm purchase imports of steel racks from China instead of
available U.S.-produced steel racks?

Source

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

No
(Please ensure that this answer does
not contradict the response in question
II-1. If “No,” skip parts (b) and (c))

China
(b)

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

Yes

No

China
(c)

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

Source

China

Yes

If Yes, estimate the quantity
of imports purchased instead
of domestic product since
January 2016
(in pounds)

No

If No, please do not
estimate the quantity of
imports, but instead
indicate the reason your
firm purchased imports
instead of domestic product

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U.S. Purchasers’ Questionnaire – Steel racks (Final)

Page 19

III-29. U.S. producers and import competition.—
(a)

Since January 1, 2016, in connection with a sale or offer to sell steel racks to your firm,
did U.S. producers reduce their prices of domestically produced steel racks in order to
compete with lower-priced imports of steel racks from the subject countries?

Source

Yes (also respond to
question part (b))

No (If “No,” skip part (b))

Don’t know

China
(b)

If your firm responded “yes” above, 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
China

Estimated
reduction in U.S.
prices
(percent)
%

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

Business Proprietary
U.S. Purchasers’ Questionnaire – Steel racks (Final)

Page 20

PART IV.—PRODUCT COMPARISONS
IV-1.

Interchangeability.--Are steel racks 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

Mexico

Other countries

United States
China
Mexico
For any country-pair producing steel racks which is sometimes or never interchangeable, please identify
the country-pair and explain the factors that limit or preclude interchangeable use:

IV-2.

Interchangeability of components/parts.--To what extent can steel rack components made by
different manufacturers be used together to form a complete steel rack?

Always

Frequently

Somewhat

Never

Additional
explanation

Business Proprietary
U.S. Purchasers’ Questionnaire – Steel racks (Final)
IV-3.

Page 21

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

China

Mexico

Other countries

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

Business Proprietary
U.S. Purchasers’ Questionnaire – Steel racks (Final)

Factor country comparisons.--For the factors listed below, please rate how steel racks produced
in each country you identified in your response to the first question in Part IV compares with
steel racks produced in each of the other countries you identified.

Inferior

Comparable

Product from
China compared to
product from
Nonsubject sources

Superior

Inferior

Product from
United States
compared to product
from
Nonsubject sources

Comparable

Inferior

Comparable

Factor

Superior

Product from
United States
compared to product
from
China

Superior

IV-4.

Page 22

Assembly/installation service
Availability
Corrosion protection
Delivery terms
Delivery time
Discounts offered
Minimum quantity
requirements
Packaging
Payment terms
Price1
Product consistency
Product range
Quality meets industry
standards
Reliability of supply
RMI certification
Technical support/service
U.S. transportation costs1
Visual aesthetics
1

A rating of superior on price and U.S. transportation costs indicates that the first country generally has lower
prices/U.S. transportation costs than the second country.

Business Proprietary
U.S. Purchasers’ Questionnaire – Steel racks (Final)

Page 23

PART V.—ADDITIONAL INFORMATION
V-1.

Other explanations.--If your firm would like to further explain a response to any question that
did not provide a narrative response box, please note the question number and the explanation
in the space provided below.

V-2.

OMB statistics.--Please report 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
25 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.

Business Proprietary
U.S. Purchasers’ Questionnaire – Steel racks (Final)

Page 24

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/steel_racks_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: RACKS

• E-mail.—E-mail the MS Word questionnaire to Cindy.CohenE@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 purchase 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 your firm submits (see
19 CFR § 207.7). Service of the questionnaire must be made in paper form.