Download:
pdf |
pdfOMB No. 3117‐0016/USITC No. 19‐2‐4038; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)
U.S. IMPORTERS’ QUESTIONNAIRE
STEEL TRAILER WHEELS FROM CHINA
This questionnaire must be received by the Commission by May 23, 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 trailer wheels (“trailer wheels”)
from China (Inv. Nos. 701‐TA‐609 and 731‐TA‐1421 (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 imported trailer wheels (as defined on next page) from any country 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: TRAIL)
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
Signature
Phone
Email address
Business Proprietary
U.S. Importers’ Questionnaire – Steel Trailer wheels (Final)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on August 8, 2018, by
Dexstar Wheel, Elkhart, Indiana. 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_trailer_wheels_china/final.htm.
Trailer wheels covered by these investigations are certain on‐the‐road steel wheels, discs, and rims for
tubeless tires with a nominal wheel diameter of 12 inches to 16.5 inches, regardless of width. Certain
on‐the‐road steel wheels with a nominal wheel diameter of 12 inches to 16.5 inches within the scope
are generally for road and highway trailers and other towable equipment, including, inter alia, utility
trailers, cargo trailers, horse trailers, boat trailers, recreational trailers, and towable mobile homes. The
standard widths of certain on‐the‐road steel wheels are 4 inches, 4.5 inches, 5 inches, 5.5 inches, 6
inches, and 6.5 inches, but all certain on‐the‐road steel wheels, regardless of width, are covered by the
scope.
The scope includes rims and discs for certain on‐the‐road steel wheels, whether imported as an
assembly, unassembled, or separately. The scope includes certain on‐the‐road steel wheels regardless of
steel composition, whether cladded or not cladded, whether finished or not finished, and whether
coated or uncoated. The scope also includes certain on‐the‐road steel wheels with discs in either a “hub‐
piloted” or “stud‐piloted” mounting configuration, though the stud‐piloted configuration is most
common in the size range covered.
All on‐the‐road wheels sold in the United States must meet Standard 110 or 120 of the National
Highway Traffic Safety Administration's (NHTSA) Federal Motor Vehicle Safety Standards, which requires
a rim marking, such as the “DOT” symbol, indicating compliance with applicable motor vehicle
standards. See 49 CFR 571.110 and 571.120. The scope includes certain on‐the‐road steel wheels
imported with or without NHTSA's required markings.
Certain on‐the‐road steel wheels imported as an assembly with a tire mounted on the wheel and/or
with a valve stem or rims imported as an assembly with a tire mounted on the rim and/or with a valve
stem are included in the scope of this investigation. However, if the steel wheels or rims are imported as
an assembly with a tire mounted on the wheel or rim and/or with a valve stem attached, the tire and/or
valve stem is not covered by the scope.
The scope includes rims, discs, and wheels that have been further processed in a third country,
including, but not limited to, the painting of wheels from China and the welding and painting of
rims and discs from China to form a steel wheel, or any other processing that would not
otherwise remove the merchandise from the scope of the investigations if performed in China.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 3
Excluded from this scope are the following:
(1) Steel wheels for use with tube‐type tires; such tires use multi piece rims, which are two‐piece and
three‐piece assemblies and require the use of an inner tube;
(2) aluminum wheels;
(3) certain on‐the‐road steel wheels that are coated entirely with chrome;
(4) steel wheels that do not meet Standard 110 or 120 of the NHTSA's requirements other than the rim
marking requirements found in 49 CFR 571.110S4.4.2 and 571.120S5.2;
(5) steel wheels that meet the following specifications: steel wheels with a nominal wheel
diameter ranging from 15 inches to 16. 5 inches, with a rim width of 8 inches or greater, and a
wheel backspacing ranging from 3. 75 inches to 5.5 inches; and
(6) steel wheels with wire spokes.
Certain on‐the‐road steel wheels subject to this investigation are properly classifiable under the
following category of the Harmonized Tariff Schedule of the United States (HTSUS): 8716.90.5035 which
covers the exact product covered by the scope whether entered as an assembled wheel or in
components. Certain on‐the‐road steel wheels entered with a tire mounted on them may be entered
under HTSUS 8716.90.5059 (Trailers and semi‐trailers; other vehicles, not mechanically propelled, parts,
wheels, other, wheels with other tires) (a category that will be broader than what is covered by the
scope). While the HTSUS subheadings are provided for convenience and customs purposes, the written
description of the subject merchandise is dispositive.
Chrome‐coated steel trailer wheels.‐‐Steel trailer wheels which have been coated in chrome but
otherwise meet the dimensions of in‐scope trailer wheels (see above scope definition).
Non‐galvanized wheels.‐‐Trailer wheels that match the scope definition of trailer wheels, but have not
been galvanized.
Galvanized wheels.‐‐Trailer wheels that match the scope definition of trailer wheels, and which have
been galvanized.
Galvanization is the process of applying a protective zinc coating to the trailer wheel to prevent
corrosion.
Importer.‐‐Any person or firm engaged, either directly or through a parent company or subsidiary, in
importing trailer wheels (as defined above) into the United States from a foreign manufacturer or
through its selling agent.
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.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 4
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.
Valid number error messages.‐‐If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Jordan
Harriman (202‐205‐2610, jordan.harriman@usitc.gov).
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 macro‐
enabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D‐GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D‐GRIDs tool to populate their
data into this questionnaire will need the D‐GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro‐enable MS Excel D‐GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D‐GRIDs tool are
available within the D‐GRIDs tool itself.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
I‐1.
Page 5
OMB statistics.‐‐Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire.
Hours
Dollars
I‐2.
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
40 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.
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”‐‐Each facility of a firm involved in the importation of trailer wheels, including
auxiliary facilities operated in conjunction with (whether or not physically separate from) such
facilities.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
I‐3.
I‐4.
Page 6
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information
Firm name
Address
Extent of
ownership
(percent)
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that are engaged in importing trailer wheels from China into the United States or that
are engaged in exporting trailer wheels from China to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
I‐5.
I‐6.
Page 7
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of trailer wheels?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Importing operations.‐‐Please indicate the nature of your firm’s importing operations on trailer
wheels. More than one answer may be applicable.
Importer of record
I‐7.
Takes title to the
imported product(s)
Consignee of the
imported products(s)
Customs broker or
freight forwarder
Consignee.‐‐If your firm is an importer of record of trailer wheels but is not the consignee,
please list the consignees below (firm name, address, telephone number, and individual to
contact).
Firm name
Address
Contact person
and phone
number
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
I‐8.
Page 8
FTZ, TIB, or bonded warehouses.‐‐Please indicate whether your firm enters trailer wheels into,
or withdraws such merchandise from, foreign trade zones or bonded warehouses. Also indicate
whether your firm imports trailer wheels under the TIB (temporary importation under bond)
program.
“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, as
well as other savings. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign‐Trade Zones Act.
“Bonded warehouse” is a secured facility supervised by U.S. customs, where dutiable landed
imports are stored pending their re‐export, or release after payment of import duties, taxes, and
other charges. A bonded warehouse must be designed as such pursuant to the rules and
procedures set forth in 19 U.S.C. § 1555.
“Temporary Importation under Bond (“TIB”) program” is a procedure whereby imported
merchandise may be entered under certain conditions for a limited time into the United States
free of duty. Under the program, an importer posts a bond for twice the amount of duty, taxes,
etc. that would otherwise be owed on the importation and agrees to export or destroy the
merchandise within a specified time or pay liquidated damages. This program is restricted to
certain categories of merchandise listed in subheadings 9813.00.05 through 9813.00.75 of the
Harmonized Tariff Schedule of the United States (HTS).
Item
I‐9.
No
Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond
Other trade actions.‐‐To your knowledge, have the products subject to this proceeding been the
subject of any other import relief proceedings in the United States or in any other countries?
No
Yes
If yes, Yes–Please specify.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 9
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Jordan Harriman (202‐205‐
2610, Jordan.harriman@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 importation of trailer wheels since January 1, 2016.
(check as many as appropriate)
(If checked, please describe; leave blank if not applicable)
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 10
II‐3a. Arranged imports.‐‐Has your firm imported or arranged for the importation of trailer wheels for
delivery after March 31, 2019?
“Arranged imports” are imports for which your firm has placed an order with a foreign supplier
for subject merchandise, but delivery of those imports is not scheduled to occur until after the
date listed above.
No
Yes
If yes, fill out the table below.
Period
Source
Apr‐Jun 2019
Jul‐Sept 2019
Oct‐Dec 2019
Jan‐Mar 2020
Quantity (in pounds)
China
All other sources
II‐3b. Imports in the 12 month period preceding the petition.‐‐Has your firm imported trailer wheels
from any source between August 1, 2017 and July 31, 2018? (i.e., the last five months in 2017
and first seven months in 2018 combined) Please provide data for non‐galvanized and
galvanized wheels separately.
No
Yes
If yes, report the quantity of such import below by source.
Quantity (in pounds)
Source
U.S. imports: Non‐galvanized trailer wheels.‐‐
China
All other sources
U.S. imports: Galvanized trailer wheels.‐‐
China
All other sources
II‐4.
August 2017 through July 2018
Reasons for importing if producer.‐‐If your firm also produces trailer wheels in the United
States, please indicate the reasons for importing this product. If your firm’s reasons differ by
source, please elaborate.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
II‐5.
Page 11
Out‐of‐scope attachments added domestically.‐‐Does your firm add in the United States out‐of‐
scope wheel components (e.g., tires or valve‐stems) to imported trailer wheels prior to re‐sale
and/or internal consumption?
No
Yes
If yes, please describe the nature and extent of these operations
II‐6.
If your firm indicated "yes" that it processes its imports of trailer wheels domestically in the
United States by adding out‐of‐scope attachments, the nature of those attachments will affect
your responses to questions II‐8a and II‐9a. For attachments of trailer wheels with either tire
and/or valve stems only, your firm should report shipments of those imports as "U.S.
commercial shipments" in rows D and E in questions II‐8a and II‐9a. In reporting the quantity
and value of such shipments, you should exclude the portion of the quantity and value
accounted for by the tire and/or valve stem (i.e., report only the quantity and value of the wheel
itself).
For attachments beyond tire and/or valve stems (e.g., mounting the wheel on an axle or
installation onto a vehicle or trailer), your firm should report shipments of those imports as
"internal consumption" in questions II‐8a and II‐9a. In reporting the quantity and value of such
internal consumption, you should exclude the portion of the quantity and value accounted for
by any out‐of‐scope attachments (i.e., report only the quantity and value of the wheel itself).
Imports with out‐of‐scope attachments at the time of importation.‐‐Does your firm import
trailer wheels with out‐of‐scope attachments (e.g., tires or valve stems) at the time of
importation?
No
Yes
If yes, please describe
If your firm, indicated "yes" that it imports trailer wheels (as defined on page 2) with a tire
already mounted on the wheel and/or with a valve stem attached, information on those imports
should still be reported below in II‐8a and II‐9a; however, in reporting the quantity and value of
such imports, you should exclude the portion of the quantity and value accounted for by the tire
and/or valve stem (i.e., report only the quantity and value of the wheel itself).
If your firm simply re‐sells its imports of trailer wheels with out‐of‐scope attachments (e.g., tires
and/or valve stems), you should report those shipments of imports as "commercial U.S.
shipments" in rows D and E in questions II‐8a and II‐9a. In reporting the quantity and value of
such shipments, you should exclude the portion of the quantity and value accounted for by the
tire and/or valve stem (i.e., report only the quantity and value of the wheel itself). If your firm
incorporates its imports of trailer wheels with out‐of‐scope attachments into further
downstream products (e.g., by mounting the wheel on an axle or installing the wheel on to a
vehicle or trailer), your firm should report shipments of those imports as "internal consumption"
in questions II‐8a and II‐9a.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
II‐7.
Page 12
Assembling in‐scope parts into In‐scope whole trailer wheels.‐‐Does your firm import in‐scope
wheel parts (e.g., rims, center discs, or other parts as identified in the definition of trailer wheel
on page 2) and assemble these parts into whole trailer wheels prior to re‐sale or use?
“In‐scope whole trailer wheels” – A fully assembled trailer wheel consisting of, generally, a rim
and a center disc, but with no further attachments (e.g., a tire and/or valve stem).
“In‐scope wheel parts” – The main components of a whole trailer wheel (generally, a rim and a
center disc or other parts as identified in the definition of trailer wheel on page 2).
No
Yes
If yes—Please describe the nature and extent of the following items in
relation to your firm's processing of in‐scope parts into in‐scope whole trailer
wheels conducted in the United States. Do not include in the discussion
below information relating to out‐of‐scope attachments (e.g., attaching tires
and/or valve stems), or any further downstream manufacturing past
assembly of the trailer wheel itself.
Capital investments
Technical expertise
Value added
Employment
Quantity, type and source
of parts
Costs and activities
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 13
Definitions
“Imports” –Those products identified for Customs purposes as imports for consumption for
which your firm was the importer of record (i.e., was responsible for paying any import duty) or
consignee (i.e., to which the merchandise was first delivered).
“Import quantities” –Quantities reported should be net of returns.
“Import values”—Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all
charges except inland freight in the United States).
“U.S. commercial 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. If your firm is only adding a tire and/or valve stem to a trailer
wheel, do not count such wheels as internally consumed. Please report commercial shipments
of such trailer wheels with a tire and/or valve stem attached in rows D and E below (however,
report only the quantity and value of the wheel itself and exclude the portion of the weight and
value of the attached tire and/or valve stem).
“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.
“Original Equipment Manufacturer (OEM)” – Manufacturer of trailers or mobile homes.
“Assembler” –Firm which further modifies trailer wheels (e.g., by attaching a tire and/or valve
stem) for sale to OEMs.
“Aftermarket” ‐‐Distributors, retailers, and/or online sellers of trailer wheels for repairs,
replacements, or other non‐original equipment uses.
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. Importers’ Questionnaire – Trailer wheels (Final)
Page 14
II‐8a. U.S. imports from China.–Report your firm’s imports and your firm’s shipments and inventories
of trailer wheels imported from China by your firm during the specified periods.
China
Quantity (in pounds), value (in dollars)
Calendar years
Item
2016
2017
January‐March
2018
2018
2019
Beginning‐of‐period
inventories (quantity) (A)
Imports under HTS number
8716.90.50351 2
Quantity (B)
Value (C)
Imports under other HTS
numbers:1 2
Quantity (D)
Value (E)
U.S. shipments:2
Commercial shipments:
Quantity (F)
Value (G)
3
Internal consumption:
Quantity (H)
3
Value (I)
Transfers to related firms:
Quantity (J)
3
Value (K)
3
4
Export shipments:
Quantity (L)
Value (M)
End‐of‐period inventories
(quantity) (N)
1
Please identify the foreign producers, if known: . Identify “other HTS numbers” reported in rows D and E
here: .
2
Report only the weight and value of the trailer wheel itself and exclude the portion of the weight and value
accounted for by any attached tires and/or valve stems.
3
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. If your firm is only adding
a tire and/or valve stem to a trailer wheel, do not count such wheels as internally consumed.
4
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 15
II‐8a. U.S. imports from China.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation
A + B + D – F – H – J – L ‐ N =
should equal zero ("0") or
provide an explanation.1
1
2016
2017
0
January‐March
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 16
II‐8b. Channels of distribution: China.‐‐Report your firm’s U.S. shipments (i.e., inclusive of commercial
U.S. shipments, internal consumption, and transfers to related firms) of imports from China by
channel of distribution
China
Quantity (in pounds) and value (in dollars)
Calendar years
Item
2016
2017
January‐March
2018
2018
2019
Channels of distribution:
Non‐Galvanized Wheels:
U.S. shipments:
To OEMs/assemblers
Quantity (O)
Value (P)
Value (R)
Galvanized Wheels:
U.S. shipments:
To OEMs/assemblers
Quantity (S)
Value (T)
To the aftermarket
Quantity (Q)
To the aftermarket
Quantity (U)
Value (V)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., lines D
through 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
January‐March
Reconciliation item
Quantity: O + Q + S + U ‐ F ‐ H
‐ J = zero ("0"), if not revise.
Value: P + R + T + V ‐ G ‐ I ‐ K
= zero ("0"), if not revise.
2016
2017
2018
2018
2019
0
0
0
0
0
0
0
0
0
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 17
II‐8c. U.S. imports by product type: China.‐‐Report your firm’s imports from China for the product types
described below during the specified periods.
China
Calendar years
Item
2016
2017
January‐March
2018
2018
2019
U.S. imports.‐‐
Rims:
Quantity (W) in units
Weight (X) in pounds
Value (Y) in dollars
Weight (AA) in pounds
Value (AB) in dollars
Whole trailer wheels without
tires/valve stems:
Quantity (AC) in units
Weight (AD) in pounds
Value (AE) in dollars
Whole trailer wheels with
tires/valve stems:1
Quantity (AF) in units
Weight (AJ) in pounds
Value (AK) in dollars
Center discs:
Quantity (Z) in units
Weight (AG) in pounds
2
Value (AH) in dollars
3
Other in‐scope products:
Quantity (AI) in units
Report only the quantity and value of the wheel itself and exclude the portion of the weight and value of the attached tire
and/or valve stem.
2
Please explain the methodology your firm used to calculate the value of the trailer wheels only from the combined value
of the wheels with tires and/or valve stems attached: .
3 Please describe these other in‐scope products: .
1
RECONCILIATION OF IMPORTS BY PRODUCT TYPE.‐‐Please ensure that the quantity in weight and values
reported for product type imports in this question equal the quantity and value reported for U.S. imports (i.e.,
lines B and C) in each time period in question II‐8a. 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
2016
2017
January‐March
2018
2018
2019
Quantity: X + AA + AD + AG + AJ ‐ B
– D = zero ("0"), if not revise.
0
0
0
0
0
Value: Y + AB + AE + AH + AK ‐ C ‐ E
= zero ("0"), if not revise.
0
0
0
0
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 18
II‐8d. Monthly U.S. imports: China.—Report your firm’s monthly U.S. imports of steel wheels from
China during the specified periods:
China
U.S. Imports from China
Quantity
(in pounds)
Month
2018.‐‐
January (AL)
February (AM)
March (AN)
April (AO)
May (AP)
June (AQ)
July (AR)
August (AS)
September (AT)
October (AU)
November (AV)
December (AW)
2019.‐‐
January (AX)
February (AY)
March (AZ)
Month
Aggregation of monthly imports
Calendar year 2018
0
Jan‐Mar 2018
Jan‐Mar 2019
0
0
RECONCILIATION OF IMPORTS.‐‐Please ensure that the total imports reported for full year 2018, and for
the two partial periods (e.g., January to September 2018 and 2019) reported in question II‐8a matches
the monthly data reported here. 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 year 2018
Jan‐Mar 2018
Jan‐Mar 2019
Reconciliation for
Aggregated monthly data minus
U.S. imports from China by
quantity (II‐8a, rows B and D),
revise if not returning zero (“0”)
Aggregated monthly data minus
U.S. imports from China by
value (II‐8a, rows C and E),
revise if not returning zero (“0”)
0
0
0
0
0
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 19
II‐8e. Imports by wheel dimension: China.‐‐ Please provide your firm’s share of imports of trailer
wheels from China by the specified wheel dimensions in 2018.
China
Wheel dimension (wheel diameter x width)
Share of 2018 imports
(percent)
12” x 4.0”
13” x 4.5”
13” x 5.5”
14” x 5.5”
14” x 6.0”
15” x 5.0”
15” x 6.0”
16” x 6.0”
1
Other wheel dimensions
Total (should sum to 100 percent)
1
II‐8f.
0.0
Please describe these other wheel dimensions: .
Imports by additional attributes: China.‐‐ Please indicate the share (by percent in pounds) that
each attribute contributed to the total amount of trailer wheels imported from China by your
firm in each respective category in 2018. (Each of the three categories should separately sum to
100 percent.)
i.
Steel used in production
Attribute
Carbon hot‐rolled steel
High strength low alloy (“HSLA”) hot‐rolled
steel
Other steels (describe: )
Total (should sum to 100 percent)
Share of 2018 U.S. imports
(percent)
0.0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 20
II‐8f. Production by additional attributes: China.‐‐Continued
ii.
Piloting
Attribute
Hub‐piloted
Stud‐piloted with ITR (improved torque
retention) technology
Stud‐piloted without ITR technology
Other (describe: )
Total (should sum to 100 percent)
iii.
0.0
Coatings
Attribute
Share of 2018 U.S. imports (percent)
Cationic electro‐deposited grey primer
base paint coat (“e‐coat”) ONLY (i.e., e‐
coat is the only coat applied with no
further coating)
Polyester powder paint
Hot‐dipped galvanized
Other coatings (describe: )
No coating
Total (should sum to 100 percent)
iv.
Share of 2018 U.S. imports (percent)
0.0
Please use the space provided below to explain any issues your firm had in providing the
data in this question (e.g., returning sums other than 100 percent).
II‐8g.
Shifting of supply from China. Since the petition was filed in August 2018, have any of your
suppliers of trailer wheels in China shifted your supply from a facility in China to one in another
country?
No
Yes
If yes—Please identify all Chinese suppliers that shifted your supply to a
third country, the date the shift occurred, and the country or countries
your supply was moved to:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 21
II‐9a. Imports from all other sources.–Report your firm’s imports and your firm’s shipments and
inventories of trailer wheels imported from all other sources by your firm during the specified
periods. .
All other sources
(list sources:
)
Quantity (in pounds), value (in dollars)
Calendar years
Item
2016
2017
January‐March
2018
2018
2019
Beginning‐of‐period
inventories (quantity) (A)
Imports under HTS number
8716.90.50351 2
Quantity (B)
Value (C)
Imports under other HTS
numbers:1 2
Quantity (D)
Value (E)
U.S. shipments:2
Commercial shipments:
Quantity (F)
Value (G)
3
Internal consumption:
Quantity (H)
3
Value (I)
Transfers to related firms:
Quantity (J)
3
Value (K)
3
4
Export shipments:
Quantity (L)
Value (M)
End‐of‐period inventories
(quantity) (N)
1
Please identify the foreign producers, if known: . Identify “other HTS numbers” reported in rows D and E
here: .
2
Report only the weight and value of the trailer wheel itself and exclude the portion of the weight and value
accounted for by any attached tires and/or valve stems.
3
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. If your firm is only adding
a tire and/or valve stem to a trailer wheel, do not count such wheels as internally consumed.
4
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 22
II‐9a. U.S. imports from all other sources.–Continued
RECONCILIATION OF SHIPMENTS, IMPORTS, AND INVENTORIES.‐‐Generally, the data reported for the
end‐of‐period inventories (i.e., line L) should be equal to the beginning‐of‐period inventories (i.e., line
A), plus imports (i.e., line B), 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 actually reflect your
firm’s records; and also provide any likely explanations for any differences (e.g., theft, loss, damage,
record systems issues, etc.) if they exist.
Calendar years
Reconciliation
A + B + D – F – H – J – L ‐ N =
should equal zero ("0") or
provide an explanation.1
1
2016
2017
0
January‐March
2018
0
2018
0
2019
0
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate: .
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 23
II‐9b. Channels of distribution: All other sources.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports
from all other sources by channel of distribution
All other sources
Quantity (in pounds) and value (in dollars)
Calendar years
Item
2016
2017
January‐March
2018
2018
2019
Channels of distribution:
Non‐Galvanized Wheels:
U.S. shipments:
To OEMs/assemblers
Quantity (O)
Value (P)
Value (R)
Galvanized Wheels:
U.S. shipments:
To OEMs/assemblers
Quantity (S)
Value (T)
To the aftermarket
Quantity (Q)
To the aftermarket
Quantity (U)
Value (V)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M and N) in each time period equal the quantity reported for U.S. shipments (i.e., lines D
through 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
January‐March
Reconciliation item
Quantity: O + Q + S + U ‐ F ‐ H
‐ J = zero ("0"), if not revise.
Value: P + R + T + V ‐ G ‐ I ‐ K
= zero ("0"), if not revise.
2016
2017
2018
2018
2019
0
0
0
0
0
0
0
0
0
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 24
II‐9c. U.S. imports by product type: All other sources.‐‐Report your firm’s imports from all other
sources for the product types described below during the specified periods.
All other sources
Item
Calendar years
2016
2017
January‐March
2018
2018
2019
U.S. imports.‐‐
Rims:
Quantity (W) in units
Weight (X) in pounds
Value (Y) in dollars
Weight (AA) in pounds
Value (AB) in dollars
Whole trailer wheels without
tires/valve stems:
Quantity (AC) in units
Weight (AD) in pounds
Value (AE) in dollars
Whole trailer wheels with
tires/valve stems:1
Quantity (AF) in units
Weight (AG) in pounds
Value (AH) in dollars2
Weight (AJ) in pounds
Value (AK) in dollars
Center discs:
Quantity (Z) in units
3
Other in‐scope products:
Quantity (AI) in units
Report only the quantity and value of the wheel itself and exclude the portion of the weight and value of the attached tire
and/or valve stem.
2
Please explain the methodology your firm used to calculate the value of the trailer wheels only from the combined value
of the wheels with tires and/or valve stems attached: .
3 Please describe these other in‐scope products: .
1
RECONCILIATION OF IMPORTS BY PRODUCT TYPE.‐‐Please ensure that the quantity in weight and values
reported for product type imports in this question equal the quantity and value reported for U.S. imports (i.e.,
lines B and C) in each time period in question II‐8a. 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
2016
2017
January‐March
2018
2018
2019
Quantity: X + AA + AD + AG + AJ ‐ B
– D = zero ("0"), if not revise.
0
0
0
0
0
Value: Y + AB + AE + AH + AK ‐ C ‐ E
= zero ("0"), if not revise.
0
0
0
0
0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 25
II‐9d. Imports by wheel dimension: All other sources.‐‐Please provide your firm’s share of imports of
trailer wheels from all other sources by the specified wheel dimensions in 2018.
All other sources
Share of 2018 imports
(percent)
Wheel dimension (wheel diameter x width)
12” x 4.0”
13” x 4.5”
13” x 5.5”
14” x 5.5”
14” x 6.0”
15” x 5.0”
15” x 6.0”
16” x 6.0”
1
Other wheel dimensions
Total (should sum to 100 percent)
1
0.0
Please describe these other wheel dimensions: .
II‐9e. Imports by additional attributes: All other sources.‐‐Please indicate the share (by percent in
pounds) that each attribute contributed to the total amount of trailer wheels imported from all
other sources by your firm in each respective category in 2018. (Each of the three categories
should separately sum to 100 percent.)
i.
Steel used in production
Attribute
Carbon hot‐rolled steel
High strength low alloy (“HSLA”) hot‐rolled
steel
Other steels (describe: )
Total (should sum to 100 percent)
Share of 2018 U.S. shipments
(percent)
0.0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 26
II‐9e. Production by additional attributes: All other sources.‐‐Continued
ii.
Piloting
Attribute
Hub‐piloted
Stud‐piloted with ITR (improved torque
retention) technology
Stud‐piloted without ITR technology
Other (describe: )
Total (should sum to 100 percent)
iii.
Share of 2018 U.S. shipments
(percent)
0.0
Coatings
Share
(percent)
Attribute
Cationic electro‐deposited grey primer
base paint coat (“e‐coat”) ONLY (i.e., e‐
coat is the only coat applied with no
further coating)
Polyester powder paint
Hot‐dipped galvanized
Other coatings (describe: )
No coating
Total (should sum to 100 percent)
iv.
Please use the space provided below to explain any issues your firm had in providing the
data in this question (e.g., returning sums other than 100 percent).
0.0
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
II‐10
Page 27
Out‐of‐scope imports of chrome‐coated trailer wheels.‐‐Did your firm import chrome‐coated
steel trailer wheels (as defined on page 3) at any point in 2016‐2018?
No
Yes
If yes‐‐ Complete the table below.
Quantity (in pounds) and value (in dollars)
Calendar year
Item
U.S. imports: China.—
Entered in under HTS
statistical reporting
number 8716.90.5035.‐‐
Quantity
Value
Entered in under other
HTS statistical reporting
numbers.1‐‐
Quantity
Value
U.S. imports: All other
sources.—
Entered in under HTS
statistical reporting
number 8716.90.5035.‐‐
Quantity
Value
Entered in under other
HTS statistical reporting
numbers.1‐‐
Quantity
Value
1
2016
2017
2018
2018
2019
Please provide the HTS numbers used: .
January‐March
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 28
II‐11. Comparability of non‐galvanized trailer wheels to galvanized trailer wheels.‐‐For each of the
following, indicate whether non‐galvanized trailer wheels and galvanized trailer wheels are:
fully comparable or the same, i.e., have no differentiation between them; mostly comparable or
similar; somewhat comparable or similar; never or not‐at‐all comparable or similar; or no
familiarity with products.
F: fully comparable or the same, i.e., have no differentiation between them;
M: mostly comparable or similar;
S: somewhat comparable or similar;
N: never or not‐at‐all comparable or similar; or
0: no familiarity with products.
Note.‐‐This product comparison question is being asked in multiple questionnaire types (U.S. producers'
and U.S. importers' questionnaires). If your firm is completing more than one of these questionnaire
types in relation to this proceeding, please respond to the alternative product comparisons question in
only one questionnaire type. In general, your firm should make these comparisons in the questionnaire
type that is most relevant to your firm's role in the market.
(a) Physical Characteristics and End Uses.‐‐The differences and similarities in the physical
characteristics and end uses.
Product‐pair
Non‐galvanized trailer wheels vs
galvanized trailer wheels
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
physical characteristics and uses:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 29
II‐11. Comparability of non‐galvanized trailer wheels to galvanized trailer wheels.‐‐ Continued
(b) Interchangeability.‐‐The ability to substitute the products in the same application.
Product‐pair
Non‐galvanized trailer wheels vs
galvanized trailer wheels
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
interchangeability:
(c) Manufacturing facilities, production processes, and production employees.‐‐Whether
manufactured in the same facilities, from the same inputs, on the same machinery and
equipment, and using the same employees.
Product‐pair
Non‐galvanized trailer wheels vs
galvanized trailer wheels
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
manufacturing facilities, production processes, and
production employees:
(d) Channels of distribution.‐‐Channels of distribution/market situation through which the
products are sold (i.e., sold direct to end users, through wholesaler/distributors, etc.).
Product‐pair
Non‐galvanized trailer wheels vs
galvanized trailer wheels
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
channels of distribution:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 30
II‐11. Comparability of non‐galvanized trailer wheels to galvanized trailer wheels.‐‐ Continued
(e) Customer and producer perceptions.‐‐Perceptions as to the differences and/or
similarities in the market (e.g., sales/marketing practices).
Product‐pair
Non‐galvanized trailer wheels vs
galvanized trailer wheels
Comparison
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
customer and product perceptions:
(f) Price.‐‐Whether prices are comparable or differ between the products.
Product‐pair
Comparison
Non‐galvanized trailer wheels vs
galvanized trailer wheels
Please provide a narrative discussion for the
comparability ratings you provided in terms of their
price:
II‐12. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
for which a narrative response box was not provided, 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. Importers’ Questionnaire – Trailer wheels (Final)
Page 31
PART III.‐‐PRICING AND MARKET FACTORS
Further information on this part of the questionnaire can be obtained from Andrew Knipe (202‐205‐
2390, andrew.knipe@usitc.gov).
III‐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 III.
Name
Title
Email
Telephone
PRICE DATA
III‐2. This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2016 of the following products your firm imported
from China:
Product 1.‐‐12 inches by 4 inches steel wheels, coated with polyester powder paint
Product 2.‐‐13 inches by 4.5 inches steel wheels, coated with polyester powder paint
Product 3.‐‐15 inches by 5 inches steel wheels, coated with polyester powder paint
Product 4.‐‐16 inches by 6 inches steel wheels, coated with polyester powder paint
Product 5.‐‐15 inches by 5 inches steel wheels, galvanized
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.‐inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates). Please report sales of trailer wheels that are unmounted
only. Trailer wheels that are assembled with a tire mounted should not be included.
During January 2016‐March 2019, did your firm import from China 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 III‐3.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 32
III‐2a. Price data: OEM/assemblers.‐‐Report below the quarterly price data1 for pricing products2
imported from China and sold by your firm to unaffiliated OEM/assemblers.
Please report sales of trailer wheels that are unmounted only. Trailer wheels that are
assembled with a tire mounted, including imports that your firm attached a tire and/or a valve
prior to resale, should NOT be included.
China (price data)
To unaffiliated OEM/assemblers
Report data in wheels and actual dollars (not 1,000s).
(Quantity in wheels, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Period of shipment
Quantity
Value
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part III.
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:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 33
III‐2a. Price data: OEM/assemblers.‐‐Continued
China (price data)
To unaffiliated OEM/assemblers
(Quantity in wheels, value in dollars)
Product 4
Quantity
Value
Product 5
Period of shipment
Quantity
Value
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part III.
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 4:
Product 5:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 34
III‐2b. Price data: Aftermarket/distributors.‐‐Report below the quarterly price data1 for pricing
products2 imported from China and sold by your firm to unaffiliated aftermarket/distributors.
Please report sales of trailer wheels that are unmounted only. Trailer wheels that are
assembled with a tire mounted, including imports that your firm attached a tire and/or a valve
prior to resale, should NOT be included.
China (price data)
To unaffiliated aftermarket/distributors
Report data in wheels and actual dollars (not 1,000s).
(Quantity in wheels, value in dollars)
Product 1
Product 2
Quantity
Value
Quantity
Value
Product 3
Period of shipment
Quantity
Value
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part III.
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:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 35
III‐2b. Price data: Aftermarket/distributors.‐‐Continued
China (price data)
To unaffiliated aftermarket/distributors
(Quantity in wheels, value in dollars)
Product 4
Quantity
Value
Product 5
Period of shipment
Quantity
Value
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned goods),
f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part III.
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 4:
Product 5:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 36
III‐2c. Price data checklist.‐‐Please check that the pricing data in questions III‐2(a) and III‐2(b) has
been correctly reported.
Is the price data reported above:
√ if Yes
Value data in actual dollars (not $1,000)?
Quantity data in number of units (not pounds)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in II‐8a in each year?
III‐2d. 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.
III‐3a. Import purchase costs.‐‐Did your firm import any of the above listed products for internal
consumption, assembly, or resale in your firm’s or a related firm’s retail locations since January
1, 2016?
Yes.‐‐Please complete the following table as appropriate.
No.‐‐Skip to question III‐4.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 37
III‐3b. Purchase costs data.‐‐Report below the purchase cost data1 for pricing products2 imported from
China and used by your own firm or sold at retail. These are imports that your firm does NOT
resell in unmounted form, except at your own retail establishments.
Please note that values should be landed, duty‐paid and should not include U.S.‐inland transportation
costs. Values should reflect the final net amount paid by your firm (i.e., should be net of all returns,
discounts, allowances, and rebates).
China (purchase cost data)
Report data in wheels and actual dollars (not 1,000s).
(Quantity in wheels, value in dollars)
Product 1
Product 2
Landed, duty‐
Landed, duty‐
paid (LDP)
paid (LDP)
Quantity
value1
Quantity
value1
Product 3
Landed, duty‐
paid (LDP)
Quantity
value1
Period of importation
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
1
LDP value (i.e., landed duty‐paid values): Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland freight in the
United States). See “Import values” definition in Part II (Trade and Related Information – Definitions).
2
Pricing product definitions are provided on the first page of Part III.
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:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 38
III‐3b. Purchase costs data.‐‐Continued
China (purchase cost data)
(Quantity in wheels, value in dollars)
Product 4
Landed, duty‐paid
Quantity
(LDP) value1
Product 5
Landed, duty‐paid
(LDP) value1
Period of importation
Quantity
2016:
January‐March
April‐June
July‐September
October‐December
2017:
January‐March
April‐June
July‐September
October‐December
2018:
January‐March
April‐June
July‐September
October‐December
2019:
January‐March
1
LDP value (i.e., landed duty‐paid values): Values reported should be landed, duty‐paid values at the U.S. port of entry,
including ocean freight and insurance costs, brokerage charges, and import duties (i.e., all charges except inland freight in the
United States). See “Import values” definition in Part II (Trade and Related Information – Definitions).
2
Pricing product definitions are provided on the first page of Part III.
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 4:
Product 5:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
III‐3c.
Page 39
Inland transportation costs for your firm’s direct imports of trailer wheels for internal use,
assembly, or retail sale.‐‐
If your firm reported import purchases costs above (question III‐3a) what is the approximate
percentage of the total cost of the trailer wheels that you directly imported from China that is
accounted for by U.S. inland transportation costs from the port of importation to your
distribution network, retail store(s), or manufacturing plant(s)? %
III‐3d.
Additional costs for your firm’s direct imports of trailer wheels for your firm’s internal use,
assembly, or retail sale.‐‐
(i)
If your firm reported direct import purchase costs above (question III‐3a), please identify
the factors (other than U.S. inland transportation costs or costs already included in
landed duty paid values) that add to your cost of importing directly since January 1,
2016. Estimate the share of the cost of the landed duty‐paid value, and explain the
specific costs associated with each category.
Estimated share
of landed duty‐
paid value
(percent)
Explanation
Factors
Logistical or supply chain management
costs (not already included in LDP
value)
Warehousing/inventory carrying costs
(not already included in LDP value)
Insurance costs (not already included in
LDP value)
Other, please identify ( )
(ii)
To which source(s) does your firm compare costs in determining your additional
transaction costs to directly import?
U.S. importers
U.S. producers
Both
Neither
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
III‐3d.
Page 40
Additional costs for your firm’s direct imports of trailer wheels for your firm’s internal use,
assembly, or retail sale.‐‐Continued
(iii)
(a) Briefly identify the benefits of directly importing trailer wheels instead of purchasing
trailer wheels from a U.S. importer or from a U.S. producer.
(b) Please provide the estimated margin saved by having directly imported trailer
wheels instead of purchasing from a U.S. importer. percent of landed duty‐paid
value.
(c) Explain any variation in the margin saved since January 1, 2016.
III‐3e. Did your firm purchase trailer wheels from a U.S. producer?
No
Yes‐‐Please complete the U.S. purchaser’s questionnaire.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 41
Please respond to the remainder of part III with respect to trailer wheels, of any type, as defined on
pages 2‐3. If your response varies by type of trailer wheel, such as galvanized vs. non‐galvanized,
please indicate in the narrative section of the question or at question III‐24.
III‐4.
Price setting.‐‐How does your firm determine the prices that it charges for sales of trailer wheels
(check all that apply)? If your firm issues price lists, please submit sample pages of a recent list.
Transaction
by
transaction
Contracts
III‐5.
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
III‐6.
Set
price
lists
No
discount
policy
Other
Describe
Pricing terms.‐‐On what basis are your firm’s prices of imported trailer wheels from China
usually quoted (check one)?
Delivered
F.o.b.
III‐7.
Contract versus spot.‐‐Approximately what share of your firm’s sales of trailer wheels imported
from China in 2018 was on a (1) short‐term contract basis, (2) annual contract basis, (3) long‐
term contract basis, and (4) spot sales basis?
Item
Share of 2018
sales
If f.o.b., specify point
Short‐term
contracts
(multiple
deliveries for
less than 12
months)
%
Type of sale
Long‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
more than 12
months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
III‐8.
Page 42
Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
U.S.‐produced trailer wheels (or check “not applicable” if your firm does not sell on a short‐
term, annual and/or long‐term contract basis).
Short‐term contracts Annual contracts
(multiple
(multiple deliveries
deliveries for 12
for less than 12
months)
months)
Long‐term contracts
(multiple deliveries
for more than 12
months)
Typical sales
contract provisions
Item
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Indexed to raw
material costs1
Not applicable
365
1
Please identify the indexes used:
III‐9.
Lead times.‐‐What is your firm’s share of sales of trailer wheels imported from China 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 trailer wheels?
Lead time
(average number
Source
Share of 2018 sales
of days)
From your firm’s U.S. inventory
%
From foreign manufacturers’ inventory
%
Produced to order
%
Total (should sum to 100.0%)
0.0 %
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 43
III‐10. Shipping information.‐‐
(a)
What is the approximate percentage of the cost of trailer wheels imported from China
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)
When your firm sells trailer wheels imported from China, from where is it shipped?
Point of importation Storage facility (check one)
(d)
Indicate the approximate percentage of your firm’s sales of trailer wheels imported
from China that are delivered the following distances from your firm’s U.S. point of
shipment.
Distance from your firm’s U.S. point of shipment
Share
Within 100 miles
%
101 to 1,000 miles
%
Over 1,000 miles
%
Total (should sum to 100.0%)
0.0 %
III‐11. Geographical shipments.‐‐In which U.S. geographic market area(s) has your firm sold trailer
wheels imported from China since January 1, 2016 (check all that apply)?
Geographic area
√ if applicable
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.
FORMCHECKBOX
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 44
III‐12. End uses.‐‐List the end uses of the trailer wheels that your firm imports. For each end‐use
product, what percentage of the total cost is accounted for by trailer wheels vs. other inputs?
Share of total cost of end‐use product
accounted for by
Total
Trailer wheels
(should sum to
(unmounted)
Other inputs
End‐use product
100.0% across)
%
%
0.0 %
%
%
0.0 %
%
%
0.0 %
III‐13. Substitutes.‐‐Can other products be substituted for trailer wheels?
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 trailer wheels?
No Yes
Explanation
1.
2.
3.
III‐14. Demand trends.‐‐Indicate how demand within the United States and outside of the United
States (if known) for trailer wheels has changed since January 1, 2016. Explain any trends and
describe the principal factors that have affected these changes in demand.
Overall
No
Overall Fluctuate with
increase change decrease no clear trend
Market
Explanation and factors
Within the U.S.
Outside the U.S.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 45
III‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix or
marketing of trailer wheels since January 1, 2016?
No
Yes If yes, please describe.
III‐16. Conditions of competition.‐‐
(a)
Is the market for trailer wheels subject to business cycles (other than general economy‐
wide conditions) and/or other conditions of competition distinctive to trailer wheels?
Check all that apply.
(b)
Please describe.
No
Skip to question III‐16.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
If yes, have there been any changes in the business cycles or conditions of competition
for trailer wheels since January 1, 2016?
No
Yes If yes, describe.
III‐17. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply trailer wheels
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 provide timely product delivery, etc.)?
No
Yes If yes, please describe.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 46
III‐18. Impact of the section 301 investigation.‐‐This question concerns the section 301 investigation
and tariffs that have been proposed and implemented by the United States in response to
Chinese trade practices.
(a)
Did the announcement in March 2018 and subsequent implementation of tariff
remedies in the section 301 investigation impact, or do you anticipate that it will impact,
your firm's trailer wheels business and/or the U.S. trailer wheels market as a whole?
Yes—
Please fill out table below and answer part (b)
No
Don’t know
Item
Description
Impact on your firm1
1
Impact on overall U.S. market
1
Please identify the magnitude and timing of any effects, and compare your firm's operations/overall
market before and after the announcement of the section 301 measures.
(b)
Please indicate the impact of the announcement and subsequent implementation of
remedies in the section 301 investigation and tariff actions regarding trailer wheels.
Item
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Overall demand for
trailer wheels in the
U.S. market
Prices for trailer
wheels in the U.S.
market
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 47
III‐19. Raw materials.‐‐How have trailer wheels’ raw material prices changed since January 1, 2016?
Explain, noting how raw material price changes,
Fluctuate including the section 232 steel tariffs imposed in
March 2018, have affected your firm’s selling
Overall
No
Overall
with no
prices for trailer wheels.
increase change decrease clear trend
III‐20.
Assessment of specific impacts of the section 232 investigation.‐‐Please indicate the impact of
the announcement and subsequent implementation of remedies in the section 232
investigation and tariff tariffs on imported steel products.
Item
Fluctuate
with no
No
clear
Increase change Decrease
trend
Explanation and factors
Cost of raw materials
used to produce
trailer wheels in the
U.S. market
Overall demand for
trailer wheels in the
U.S. market
Prices for trailer
wheels in the U.S.
market
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 48
III‐21. Interchangeability.‐‐Are trailer wheels 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
United States
China
Other countries
China
For any country‐pair producing trailer wheels which is sometimes or never interchangeable, please
identify the country‐pair and explain the factors that limit or preclude interchangeable use:
III‐22. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between trailer wheels
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
United States
China
China
Other countries
For any country‐pair for which factors other than price always or frequently are a significant factor in
your firm’s sales of trailer wheels, identify the country‐pair and report the advantages or disadvantages
imparted by such factors:
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 49
III‐23. Customer identification.‐‐List the names and contact information for your firm’s 10 largest U.S.
customers for trailer wheels since January 1, 2016. Indicate the share of the quantity of your
firm’s total shipments of trailer wheels that each of these customers accounted for in 2018.
Customer’s name
City
State
Share of 2018
sales (%)
1
2
3
4
5
6
7
8
9
10
III‐24. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
for which a narrative response box was not provided, 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. Importers’ Questionnaire – Trailer wheels (Final)
Page 50
Correcting Valid number error messages.‐‐If you are completing a Commission
questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set‐up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)
When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the questionnaire. When you finish reporting the data then you can close the questionnaire and switch
back to Italy settings.
Business Proprietary
U.S. Importers’ Questionnaire – Trailer wheels (Final)
Page 51
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_trailer_wheels_china/final.ht
m.
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: TRAIL
• E‐mail.—E‐mail the MS Word questionnaire to Jordan.harriman@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 import 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 (202‐
205‐1803). 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 Modified | 0000-00-00 |
| File Created | 0000-00-00 |