18-4-3823 Foreign producers' questionnaire

OMB No. 3117-0016/USITC No. 18-4-3823; Expiration Date: : 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
CITRIC ACID AND CERTAIN CITRATE SALTS (“CACCS”)
FROM BELGIUM, COLOMBIA, AND THAILAND
This questionnaire must be received by the Commission by March 5, 2018
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its antidumping and countervailing duty investigations concerning CACCS from Belgium,
Colombia, and Thailand (Inv. Nos. 701-TA-581 and 731-TA-1374-1376 (Final)). The information requested in the
questionnaire is requested under the authority of the Tariff Act of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported CACCS (as defined on next page) at any time since January 1, 2015?

NO

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

YES

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

Data reported in this questionnaire relate to (Check one):
BELGIUM

COLOMBIA

THAILAND

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: CBCT)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my knowledge and
belief and understand that the information submitted is subject to audit and verification by the Commission. By means of this
certification I also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this
questionnaire and throughout this proceeding in any other import-injury proceedings conducted by the Commission on the same or
similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this proceeding
or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract personnel (a) for
developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits, reviews, and evaluations
relating to the programs, personnel, and operations of the Commission including under 5 U.S.C. Appendix 3; or (ii) by U.S. government
employees and contract personnel, solely for cybersecurity purposes. I understand that all contract personnel will sign appropriate
nondisclosure agreements
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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Foreign Producers’ Questionnaire – CACCS (Final)

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PART I.--GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on June 2, 2017, by Archer
Daniels Midland Company, Decatur, Illinois; Cargill, Incorporated, Minneapolis, Minnesota; and Tate &
Lyle Ingredients Americas, LLC, Hoffman Estates, Illinois.. Countervailing/antidumping duties may be
assessed on the subject imports as a result of these proceedings if the Commission makes an affirmative
determination of injury, threat, or material retardation, and if the U.S. Department of Commerce
(“Commerce”) makes an affirmative determination of subsidization/dumping. Questionnaires and other
information pertinent to this proceeding are available at
https://usitc.gov/investigations/701731/2018/citric_acid_and_certain_citrate_salts_belgium/final.htm.
CACCS covered by these investigations is all grades and granulation sizes of citric acid, sodium citrate,
and potassium citrate in their unblended forms, whether dry or in solution, and regardless of packaging
type. The scope also includes blends of citric acid, sodium citrate, and potassium citrate; as well as
blends with other ingredients, such as sugar, where the unblended form(s) of citric acid, sodium citrate,
and potassium citrate constitute 40 percent or more, by weight, of the blend.
The scope also includes all forms of crude calcium citrate, including dicalcium citrate monohydrate, and
tricalcium citrate tetrahydrate, which are intermediate products in the production of citric acid, sodium
citrate, and potassium citrate.
The scope includes the hydrous and anhydrous forms of citric acid, the dihydrate and anhydrous forms
of sodium citrate, otherwise known as citric acid sodium salt, and the monohydrate and monopotassium
forms of potassium citrate. Sodium citrate also includes both trisodium citrate and monosodium citrate
which are also known as citric acid trisodium salt and citric acid monosodium salt, respectively.
The scope does not include calcium citrate that satisfies the standards set forth in the United States
Pharmacopeia and has been mixed with a functional excipient, such as dextrose or starch, where the
excipient constitutes at least 2 percent, by weight, of the product.
Citric acid and sodium citrate are classifiable in subheadings 2918.14.00 and 2918.15.10 of the HTSUS,
respectively. Potassium citrate and crude calcium citrate are classifiable in subheading 2918.15.50 and,
if included in a mixture or blend, subheading 3824.99.92 (statistical reporting number 3824.99.9295) of
the HTSUS. Blends that include citric acid, sodium citrate, and potassium citrate are also imported under
statistical reporting number 3824.99.9295 of the HTSUS. Although the HTSUS subheadings are provided
for convenience and customers purposes, the written description of the merchandise is dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
purchaser and/or foreign producer 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.

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Foreign Producers’ Questionnaire – CACCS (Final)

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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 Amelia
Shister (202-205-2047, amelia.shister@usitc.gov).
I-1.

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
20 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.

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Foreign Producers’ Questionnaire – CACCS (Final)
I-2.

Page 4

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 in Belgium, Colombia, or Thailand involved in the
production or export of CACCS, including auxiliary facilities operated in conjunction with
(whether or not physically separate from) such facilities. Firms operating more than one
establishment in Belgium, Colombia, or Thailand should combine the data for all establishments
into a single report.

I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce CACCS in the United States or other countries?
No

I-4.

Yes--Please name the firm(s) and country(ies) below and, if U.S. producer(s),
ensure that they complete the Commission’s producer questionnaire.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
CACCS into the United States?
No

Yes--Please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

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Foreign Producers’ Questionnaire – CACCS (Final)
I-5.

U.S. importers.--Please provide the names, street addresses (not P.O. boxes), contacts,
telephone numbers, and e-mail addresses of the FIVE largest U.S. importers of your firm’s
CACCS in 2017.

Importer’s name
1
2
3
4
5

Page 5

Contact person

Email

Telephone

Share of your
firm’s 2017 U.S.
exports (%)

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Foreign Producers’ Questionnaire – CACCS (Final)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Amelia Shister (202-2052047, amelia.shister@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
Fax

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of CACCS since January 1, 2015.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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Foreign Producers’ Questionnaire – CACCS (Final)
II-3.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of CACCS in the
future?
No

II-4a.

Page 7

Yes--Supply details as to the time, nature, and significance of such changes.

Production using same machinery.--Please report your firm’s production of products made on
the same equipment and machinery used to produce CACCS, and the combined production
capacity on this shared equipment and machinery.
“Overall production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise (i.e., you have reported no data for "other products" in this
question) then the "overall production capacity" numbers reported in this question should be
exactly equal to the "average production capacity" numbers reported in question II-9. If,
however, your firm does produce out-of-scope merchandise using the same machinery and
equipment as scope merchandise (i.e., you have reported data for "other products" in this
question), then the "average production capacity" reported in question II-9 should exclude the
portion of "overall production capacity" that was used to produce this out-of-scope
merchandise (i.e., "average production capacity" in question II-9 should be smaller than "overall
production capacity" in this question).
“Production” – All production in your establishment(s) in Belgium, Colombia, or Thailand,
including production consumed internally within your firm.
Quantity (in 1,000 dry pounds)
Calendar years
Item

2015

2016

2017

Overall production capacity
Production of:
CACCS1

0

0

0

0

0

0

2

Other products
Total
1
2

Data entered for production of CACCS will populate here once reported in question II-10.
Please identify these products:
.

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Foreign Producers’ Questionnaire – CACCS (Final)

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II-4b.

Operating parameters.--The production capacity reported in II-4a is based on operating
per week,
weeks per year.

II-4c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-4a, and explain any changes in reported capacity.

II-4d.

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

II-4e.

Product shifting.-(i).

Is your firm able to switch production (capacity) between CACCS and other products using
the same equipment and/or labor?
No

(ii).

hours

Yes--(i.e., have produced other products or are able to produce other
products). Please identify other actual or potential products:
.

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

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Foreign Producers’ Questionnaire – CACCS (Final)
II-5a.

Production processes.--Please identify the production process your firm utilizes for production
of citric acid?
Deep tank method
Shallow pan method
Other (please specify:

II-5b.

Page 9

)

Raw materials.--Please identify the raw materials your firm utilizes for production of citric acid?
Corn
Sugar beets
Other (please specify:

)

II-5c.

Operation costs.--Based on a.) and b.), please discuss how that affects your operation costs.

II-6.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of CACCS?
percent.

II-7.

Firm's estimated share of production in Belgium, Colombia, or Thailand.--Please estimate the
percentage of total production of CACCS in the country specified on the certification page accounted
for by your firm’s production in 2017.
percent.

II-8.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of CACCS from the country specified on the certification page accounted for by
your firm’s exports in 2017.
percent.

II-9.

Third country trade actions.--Is the CACCS exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings?
No

Yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

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Foreign Producers’ Questionnaire – CACCS (Final)
II-10.

Page 10

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of CACCS in your establishment(s) in Belgium, Colombia, Thailand
during the specified periods. Do not include resales of CACCS that your firm did not produce in
this question; those data to the degree they are exported to the United States should only be
reported in question II-12.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
Do not submit data on multiple countries combined. The establishments reported here should
all be located in the country of the firm’s address reported on the certification page.
Multinational companies with production in multiple subject countries should submit separate
foreign producer questionnaire responses for each subject country.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” – All production in your establishment(s) in Belgium, Colombia, or Thailand,
including production consumed internally within your firm.
“Shipments” – Shipments of products produced in your establishment(s) in Belgium, Colombia,
or Thailand. Quantities reported should be net of returns.
“Home market commercial shipments” – Shipments, other than internal consumption and
transfers to related firms, within Belgium, Colombia, or Thailand.
“Home market internal consumption/transfers to related firms” – Shipments made to
related firms in Belgium, Colombia, or Thailand, including product consumed internally by your
firm.
“Export shipments” – Shipments to destinations outstide of the country indicacted on page 1
(Belgium, Colombia, or Thailand), including shipments to related firms.
“Inventories” – Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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Foreign Producers’ Questionnaire – CACCS (Final)
II-10.

Page 11

Trade data.--Continued.
Quantity (in 1,000 dry pounds)

Item

Actual experience

Projections1

Calendar year

Calendar year

2015

2016

2017

2018

2019

2

Average production capacity (A)
Beginning-of-period inventories (B)
Production (quantity).-Using corn substrates (C)
Using sugar substrates (D)
Using tapioca substrates (E)
Using all other substrates3 (F)
Total production (G)

0

0

0

0

0

Total exports (L)
(should equal J + K)

0

0

0

0

0

Total shipments (M)
(should equal H+I+J+K)

0

0

0

0

0

Home market shipments:
Internal consumption/ transfers
(H)
Commercial shipments (I)
Exports to the United States (J)
Exports to all other markets4 (K)

End-of-period inventories (N)
1

Please explain the basis for your firm’s projections.
.
The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity.
.
3
Identify the other substrates used in CACCS production.
.
4
Identify principal other export markets.
.
2

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Foreign Producers’ Questionnaire – CACCS (Final)
II-10.

Page 12

Trade data.—Continued.
RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported
for the end-of-period inventories (i.e., line N) should be equal to the beginning-of-period
inventories (i.e., line B), plus production (i.e., lines C through F), less total shipments (i.e., lines H,
I, J, and K). 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.

Item

2015

Actual experience

Projections

Calendar year

Calendar year

2016

2017

2018

2019

B+C+D+E+F–H–I–J
–K – N = should equal zero
("0") or provide an
explanation.1
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.
II-11.

Inventory trends.--Based on inventories reported in question II-10, please describe the
evolution and trends of inventories during 2015-17.

0

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Foreign Producers’ Questionnaire – CACCS (Final)
II-12.

Page 13

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of CACCS that was produced in Belgium, Colombia, Thailand but not by your firm
during the specified periods. Note these data should not be included in question II-10.
Quantity (in 1,000 dry pounds)

Item

2015

Actual experience

Projections

Calendar year

Calendar year

2016

2017

2018

2019

Exports of CACCS to the United
States not produced by your firm1
1

List the producer(s).

II-13.

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

.

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Foreign Producers’ Questionnaire – CACCS (Final)

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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 USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://usitc.gov/investigations/701731/2018/citric_acid_and_certain_citrate_salts_bel
gium/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: CBCT

• E-mail.--E-mail your questionnaire to amelia.shister@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 produce or export 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, you are required to serve a copy of
the completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.