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pdfOMB No. 3117‐0016/USITC No. 18‐2‐3929; Expiration Date: 6/30/2020
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U.S. IMPORTERS’ QUESTIONNAIRE
CRYSTALLINE SILICON PHOTOVOLTAIC CELLS AND MODULES FROM CHINA
This questionnaire must be received by the Commission by September 19, 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 review of the antidumping and countervailing duty orders concerning Crystalline Silicon Photovoltaic
(“CSPV”) Cells and Modules from China (Inv. Nos. 701‐TA‐481 and 731‐TA‐1190 (Review)). 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 CSPV cells and/or modules (as defined on the next page) from any country at
any time since January 1, 2012?
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 Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: CSPV1)
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 investigations or reviews
conducted by the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Phone:
Signature
Email address
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 2
PART I.—GENERAL INFORMATION
On December 7, 2012, the Department of Commerce (“Commerce”) issued antidumping and
countervailing duty orders on imports of crystalline silicon photovoltaic (“CSPV”) cells and modules from
China (77 FR 73017–73021). On November 1, 2017, the Commission instituted reviews pursuant to
section 751(c) of the Tariff Act of 1930 (19 U.S.C. § 1675(c)) (the Act) to determine whether revocation
of the orders would be likely to lead to continuation or recurrence of material injury to the domestic
industry within a reasonably foreseeable time. If both the Commission and Commerce make affirmative
determinations, the orders will remain in place. If either the Commission or Commerce makes negative
determinations, Commerce will revoke the orders. Questionnaires and other information pertinent to
this proceeding are available at
https://www.usitc.gov/investigations/701731/2017/crystalline_silicon_photovoltaic_cells_and_modules
/first_review_full.htm
CSPV Cells and Modules covered by these reviews are defined by Commerce as follows:
The merchandise covered by the order are crystalline silicon photovoltaic cells, and modules,
laminates, and panels, consisting of crystalline silicon photovoltaic cells, whether or not partially
or fully assembled into other products, including, but not limited to, modules, laminates, panels
and building integrated materials.
The order covers crystalline silicon photovoltaic cells of thickness equal to or greater than 20
micrometers, having a p/n junction formed by any means, whether or not the cell has undergone
other processing, including, but not limited to, cleaning, etching, coating, and/or addition of
materials (including, but not limited to, metallization and conductor patterns) to collect and
forward the electricity that is generated by the cell.
Merchandise under consideration may be described at the time of importation as parts for final
finished products that are assembled after importation, including, but not limited to, modules,
laminates, panels, building‐integrated modules, building‐integrated panels, or other finished
goods kits. Such parts that otherwise meet the definition of merchandise under consideration are
included in the scope of the orders.
Excluded from the scope of the order are thin film photovoltaic products produced from
amorphous silicon (a‐Si), cadmium telluride (CdTe), or copper indium gallium selenide (CIGS).
Also excluded from the scope of the order are crystalline silicon photovoltaic cells, not exceeding
10,000 mm2 in surface area, that are permanently integrated into a consumer good whose
function is other than power generation and that consumes the electricity generated by the
integrated crystalline silicon photovoltaic cell. Where more than one cell is permanently
integrated into a consumer good, the surface area for purposes of this exclusion shall be the
total combined surface area of all cells that are integrated into the consumer good.
Additionally, excluded from the scope of this order are panels with surface area from 3,450 mm2
to 33,782 mm2 with one black wire and one red wire (each of type 22 AWG or 24 AWG not more
than 206 mm in length when measured from panel extrusion), and not exceeding 2.9 volts, 1.1
amps, and 3.19 watts. For the purposes of this exclusion, no panel shall contain an internal
battery or external computer peripheral ports.
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 3
Modules, laminates, and panels produced in a third‐country from cells produced in China are
covered by the orders; however, modules, laminates, and panels produced in China from cells
produced in a third‐country are not covered by the order.
Merchandise covered by this order is currently classified in the Harmonized Tariff System of the
United States (HTSUS) under subheadings 8501.61.0000, 8507.20.80, 8541.40.6020,
8541.40.6030, and 8501.31.8000. These HTSUS subheadings are provided for convenience and
customs purposes; the written description of the scope of the order is dispositive.
Module.‐‐A joined group of CSPV cells, regardless of the number of cells or the shape of the joined
group, that are capable of generating electricity. The term “module” is frequently used interchangeably
with the term “panel.” A “laminate” is a module that does not have a frame.
Building Integrated Materials.‐‐Materials integrated into the building envelope, such as the façade or
roof, containing CSPV cells. These building integrated materials replace conventional construction
materials, such as glass or roof shingles, taking over the function that conventional materials would
otherwise perform while also producing electricity.
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.
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.
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 4
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.
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
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.
I‐2.
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 CSPV cells and modules,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐3.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
I‐4.
Page 5
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 CSPV cells and modules into the United States or that are
engaged in exporting CSPV cells and modules to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 6
I‐5.
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of CSPV cells or assembly (fully or partially) CSPV cells into other
products?
No
Yes‐‐List the following information.
Extent of ownership Production/processing
Firm name
Address
(percent)/Affiliation activity performed
I‐6.
Importing operations.‐‐Please indicate the nature of your firm’s importing operations on CSPV
cells and modules. More than one answer may be applicable.
Importer of record
Takes title to the
imported product(s)
Consignee of the
imported products(s)
Customs broker or
freight forwarder
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 7
I‐7.
Consignees.‐‐If your firm is an importer of record of CSPV cells and modules but is not the
consignee, please list the consignees below (firm name, address, telephone number, and
individual to contact).
I‐8.
Firm name
Address
Contact person and
phone number
FTZ, TIB, or bonded warehouses.‐‐Please indicate whether your firm enters CSPV cells and
modules into, or withdraws such merchandise from, foreign trade zones or bonded warehouses.
Also indicate whether your firm imports CSPV cells and modules 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 (HTS).
Item
No
Yes
Foreign trade zones
Bonded warehouses
Temporary importation under bond
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 8
I‐9.
Business plan.‐‐In Parts II and III of this questionnaire we request a copy of your company’s
business plan. Does your company or any related firm have a business plan or any internal
documents that describe, discuss, or analyze expected market conditions for CSPV cells and
modules?
No
Yes–Please provide the requested documents. If you are not providing the
requested documents, please explain why not.
I‐10.
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–Please specify.
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 9
PART II.‐‐TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Mary Messer (202‐205‐3193,
mary.messer@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 CSPV cells and modules since January 1, 2012.
Check as many as appropriate.
If checked, please describe; leave blank if not applicable.
Office/warehouse openings
Office/warehouse closings
Relocations
Expansions
Acquisitions
Bankruptcy
Consolidations
Prolonged shutdowns or
importation curtailments
Revised labor agreements
Other (e.g., technology)
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 10
II‐2b Anticipated changes in operations.‐‐Does your firm anticipate any changes in in the character of
its operations or organization relating to the importation of CSPV cells and modules in the
future?
II‐3.
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.
Arranged imports.‐‐Has your firm imported or arranged for the importation of CSPV cells and
modules for delivery after June 30, 2018?
“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–Fill out the table below.
Quantity (in kilowatts)
Period/Source
Jul‐Sep 2018
CSPV cells.‐‐
China
All other sources
CSPV modules. ‐‐
China1
2
All other sources
Oct‐Dec 2018
Jan‐Mar 2019
Apr‐Jun 2019
1
Module data from China should relate to modules made from Chinese‐origin cells regardless of the country of
module assembly or country of exportation. These data should exclude modules assembled with non Chinese‐
origin cells, including those assembled in China.
2
Module data from all other sources should relate to modules made from non‐Chinese‐origin cells regardless
of the country of module assembly or country of exportation. These data should include modules assembled in
China with non‐Chinese‐origin cells.
II‐4.
Reasons for importing if producer.‐‐If your firm also produces CSPV cells or assembles CSPV
cells into other products (e.g., laminates, panels, modules, etc.) 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 ‐ CSPV Cells and Modules (CSPV1 Review)
Page 11
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). For products, such as laminates,
panels, and modules that are partially or fully assembled from CSPV cells, the location where the
CSPV cells were manufactured determines the country of origin.
“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.
“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.
“Module”‐‐A joined group of CSPV cells, regardless of the number of cells or the shape of the
joined group, that are capable of generating electricity. The term “module” is frequently used
interchangeably with the term “panel.” A “laminate” is a module that does not have a frame.
“Building Integrated Materials”‐‐Materials integrated into the building envelope, such as the
façade or roof, containing CSPV cells. These building integrated materials replace conventional
construction materials, such as glass or roof shingles, taking over the function that conventional
materials would otherwise perform while also producing electricity.
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 ‐ CSPV Cells and Modules (CSPV1 Review)
Page 12
II‐5a. Imports from China: CSPV cells.‐‐Report your firm’s imports and your firm’s shipments and
inventories of CSPV cells imported from China during the specified periods.
CHINA‐‐CELLS
Quantity (in kilowatts), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
2
Value (G)
Transfers to related firms:2
Quantity (H)
2
Value (I)
3
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please identify the foreign producers, if known: .
2
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐5a. Imports from China: CSPV cells.‐‐Continued
Page 13
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 year
January‐June
Reconciliation
2012
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2013
0
0
2014
2015
0
0
2016
2017
0
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐5b. Channels of distribution: China—CSPV cells.‐‐Report your firm’s U.S. shipments (i.e., inclusive of
commercial U.S. shipments, internal consumption, and transfers to related firms) of imports of
CSPV cells from China by channel of distribution.
CHINA—CELLS
Calendar year
Item
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Quantity (in kilowatts)
Channels of distribution:
U.S. shipments of CSPV cells:
To module assemblers (M)
To distributors (N)
To residential installers (O)
To commercial installers (P)
To utilities/developers (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through Q) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N + O + P + Q – D – F – H
= zero ("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 14
II‐6a. Imports from China: CSPV modules.‐‐Report your firm’s imports and your firm’s shipments and
inventories of CSPV modules from China (i.e., modules made from Chinese‐origin CPSV cells
regardless the country of module assembly) during the specified periods.
CHINA‐‐MODULES
Note.‐‐These data should relate to modules made from Chinese‐origin cells regardless of the country of module
assembly or country of exportation. These data should exclude modules assembled with non Chinese‐origin cells,
including those assembled in China.
Quantity (in kilowatts), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1 2
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
3
Value (G)
Transfers to related firms:
Quantity (H)
3
Value (I)
2
4
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please identify the foreign producers, if known: .
Please identify the country(‐ies) of module assembly. If your firm reported imports of modules assembled in multiple
countries from Chinese‐origin cells over the period, please list each country of assembly and provide the percent of total
imports in 2017 by country of assembly: .
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.
4
Identify your firm’s principal export markets: .
2
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 15
II‐6a. Imports from China: CSPV modules.–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 year
January‐June
Reconciliation
2012
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2013
0
2014
0
2015
0
2016
0
2017
0
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐6b. Channels of distribution: China—CSPV modules.‐‐Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
imports of CSPV modules from China by channel of distribution.
CHINA‐‐MODULES
Note.‐‐These data should relate to modules made from Chinese‐origin cells regardless of the country of module
assembly or country of exportation. These data should exclude modules assembled with non Chinese‐origin cells,
including those assembled in China.
Item
Calendar year
2012
2013
2014
January‐June
2015
2016
2017
2017
2018
Quantity (in kilowatts)
Channels of distribution:
U.S. shipments:
To module assemblers (M)
To distributors (N)
To residential installers (O)
To commercial installers (P)
To utilities/developers (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through Q) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N + O + P + Q – D – F – H
= zero ("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 16
II‐6c. US shipments by module size: CSPV modules China.‐‐Report your firm’s U.S. shipments (i.e.,
inclusive of commercial U.S. shipments, internal consumption, and transfers to related firms) of
CSPV modules from China by configuration size for the specified periods.
CHINA‐‐MODULES
Note.‐‐These data should relate to modules made from Chinese‐origin cells regardless of the country of
module assembly or country of exportation. These data should exclude modules assembled with non
Chinese‐origin cells, including those assembled in China.
Quantity (in kilowatts) and value (in $1,000)
Calendar years
Item
U.S. shipments of CSPV modules‐‐
60‐cell configuration.‐‐
Quantity (R)
Value (S)
72‐cell configuration.‐‐
Quantity (T)
Value (U)
January‐June
2012
2013
2014
2015
2016
2017
2017
2018
1
Other products. ‐‐
Quantity (V)
Value (W)
1
Please specify these products: .
RECONCILIATION OF US SHIPMENTS.‐‐Please ensure that the quantities and values reported for US
shipments by cell configuration (i.e., lines R through W) in each time period equal the quantity and value
of US shipments (i.e., lines D through I) in each time period in part "a" of this question. 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‐June
Reconciliation
Quantity: R + T + V – D – F –
H = zero ("0"), if not revise.
Value: S + U + W – E – G – I =
zero ("0"), if not revise.
2012
2013
2014
2015
2016
2017
2017
2018
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 17
II‐7a. Imports of CSPV cells from all other sources.‐‐Report your firm’s imports and your firm’s
shipments and inventories of CSPV cells imported from all other sources during the specified
periods.
ALL OTHER SOURCES‐‐CELLS
(list sources:
)
Quantity (in kilowatts), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
Value2 (G)
Transfers to related firms:
Quantity (H)
2
Value (I)
Export shipments:3
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
2
Please identify the foreign producers, if known: .
Internal consumption and transfers to related firms must be valued at fair market value. If your firm uses a different
basis for valuing these transactions in your records, please specify that basis (e.g., cost, cost plus, etc.): . However,
the data provided above in this table should be based on fair market value.
3
Identify your firm’s principal export markets: .
2
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 18
II‐7a. Imports of CSPV cells 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 year
January‐June
Reconciliation
2012
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2013
0
2014
0
2015
0
2016
0
2017
0
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐7b. Channels of distribution: CSPV cells, 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 of CSPV cells from all other sources by channel of distribution.
ALL OTHER SOURCES‐‐CELLS
Calendar year
Item
2012
2013
2014
January‐June
2015
2016
2017
2017
2018
Quantity (in kilowatts)
Channels of distribution:
U.S. shipments:
To module assemblers (M)
To distributors (N)
To residential installers (O)
To commercial installers (P)
To utilities/developers (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through Q) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N + O + P + Q – D – F – H
= zero ("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 19
II‐8a. Imports from all other sources: CSPV modules.‐‐Report your firm’s imports and your firm’s
shipments and inventories of CSPV modules from all other sources (i.e., modules made from any
non‐Chinese‐origin CPSV cells) during the specified periods.
ALL OTHER SOURCES‐‐MODULES
Note.‐‐These data should relate to modules made from non‐Chinese‐origin cells regardless of the country
of module assembly or country of exportation. These data should include modules assembled in China
with non‐Chinese‐origin cells.
(list sources:
)
Quantity (in kilowatts), value (in $1,000)
Calendar year
Item
2012
Beginning‐of‐period
inventories (quantity) (A)
2013
2014
2015
January‐June
2016
2017
2017
2018
Imports:
Quantity (B)
Value (C)
1 2
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
2
Internal consumption:
Quantity (F)
3
Value (G)
Transfers to related firms:
Quantity (H)
Value3 (I)
2
4
Export shipments:
Quantity (J)
Value (K)
End‐of‐period inventories
(quantity) (L)
1
Please identify the foreign producers, if known: .
Please indicate the share (if applicable) of the total imports reported in 2017 above that represent modules assembled
in China: percent.
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.
4
Identify your firm’s principal export markets: .
2
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 20
II‐8a. Imports from all other sources: CSPV modules.–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 year
January‐June
Reconciliation
2012
A + B – D – F – H – J ‐ L=
should equal zero ("0") or
provide an explanation.1
2013
0
2014
0
2015
0
2016
0
2017
0
0
2017
2018
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless accurate:
.
II‐8b. Channels of distribution: CSPV modules—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 of CSPV modules from all other sources by channel of distribution.
ALL OTHER SOURCES‐‐MODULES
Note.‐‐These data should relate to modules made from non‐Chinese‐origin cells regardless of the country
of module assembly or country of exportation. These data should include modules assembled in China
with non‐Chinese‐origin cells.
Calendar year
Item
2012
2013
2014
January‐June
2015
2016
2017
2017
2018
Quantity (in kilowatts)
Channels of distribution:
U.S. shipments:
To module assemblers (M)
To distributors (N)
To residential installers (O)
To commercial installers (P)
To utilities/developers (Q)
RECONCILIATION OF CHANNELS.‐‐Please ensure that the quantities reported for channels of distribution
(i.e., lines M through Q) in each time period equal the quantity reported for U.S. shipments (i.e., line D, F,
and H) in each time period. If the calculated fields below return values other than zero (i.e., “0”), the
data reported must be revised prior to submission to the Commission.
Calendar year
January‐June
Reconciliation
M + N + O + P + Q – D – F – H
= zero ("0"), if not revise.
2012
0
2013
0
2014
0
2015
0
2016
0
2017
0
2017
0
2018
0
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 21
II‐8c. US shipments by module size: CSPV modules—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 CSPV modules from all other sources by configuration size for the specified
periods.
ALL OTHER SOURCES‐‐MODULES
Note.‐‐These data should relate to modules made from non‐Chinese‐origin cells regardless of the country
of module assembly or country of exportation. These data should include modules assembled in China
with non‐Chinese‐origin cells.
Quantity (in kilowatts) and value (in $1,000)
Calendar years
January‐June
Item
U.S. shipments of CSPV
modules‐‐
60‐cell configuration.‐‐
Quantity (R)
Value (S)
72‐cell configuration.‐‐
Quantity (T)
Value (U)
2012
2013
2014
2015
2016
2017
2017
2018
1
Other products. ‐‐
Quantity (V)
Value (W)
1
Please specify these products: .
RECONCILIATION OF US SHIPMENTS.‐‐Please ensure that the quantities and values reported for US
shipments by cell configuration (i.e., lines R through W) in each time period equal the quantity and value
of US shipments (i.e., lines D through I) in each time period in part "a" of this question. 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
2012
2013
2014
2015
January‐June
2016
2017
2017
2018
Quantity: R + T + V – D – F – H =
zero ("0"), if not revise.
0
0
0
0
0
0
0
0
Value: S + U + W – E – G – I =
zero ("0"), if not revise.
0
0
0
0
0
0
0
0
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 22
For questions II‐9 and II‐10, if your firm’s response differs for particular orders, please indicate and
explain the particular effect of imposition and/or revocation of specific orders.
II‐9. Effect of order(s).‐‐Describe the significance of the existing antidumping and countervailing duty
orders covering imports of CSPV cells and modules from China in terms of its effect on your
firm’s imports, U.S. shipments of imports, and inventories. You may wish to compare your firm’s
operations before and after the imposition of the order.
II‐10. Likely impact of revocation. ‐‐Would your firm anticipate any changes in in the character of its
operations or organization, including its imports, U.S. shipments of imports, or inventories of
CSPV cells and modules in the future if the antidumping and countervailing duty orders on CSPV
cells and modules from China were to be revoked?
No
Yes
If yes, supply details as to the time, nature, and significance of
such changes and provide underlying assumptions, along with
relevant portions of business plans or other supporting
documentations that address this issue.
II‐11. Other explanations.‐‐If your firm would like to further explain a response to a question in Part II
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
PART III.‐‐PRICING AND MARKET FACTORS
Page 23
Further information on this part of the questionnaire can be obtained from James Horne (202‐205‐2722,
James.Horne@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 of the following products your firm imported from China:
Product 1.‐‐ 60 cell multicrystalline silicon module, with a the peak power wattage between
240w to 265w, inclusive, p‐max or Wp
Product 2.‐‐ 60 cell multicrystalline silicon module, with a peak power wattage between 266w to
290w, inclusive, P‐max or Wp
Product 3.‐‐ 60 cell monocrystalline silicon module, with a peak power wattage between 250w
to 280w, inclusive, P‐max or Wp
Product 4.‐‐ 60 cell monocrystalline silicon module, with a peak power wattage between 281w
to 310w, inclusive, P‐max or Wp
Product 5.‐‐ 72 cell multicrystalline silicon module, with a peak power wattage between 290w to
315w, inclusive, P‐max or Wp
Product 6.‐‐ 72 cell multicrystalline silicon module, with a peak power wattage between 316w to
340w, inclusive, P‐max or Wp
Product 7.‐‐ 72 cell monocrystalline silicon module, with a peak power wattage between 300w
to 330w, inclusive, P‐max or Wp
Product 8.‐‐ 72 cell monocrystalline silicon module, with a peak power wattage between 331w
to 360w, inclusive, P‐max or Wp
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 24
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).
(a) During January 2012‐June 2018, 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(s) as appropriate.
No.‐‐Skip to question III‐3.
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 25
III‐2(b). Price data (China).‐‐Report below the quarterly price data1 for pricing products2 imported from
China and sold by your firm.
China
Note.‐‐These data should relate to modules made from Chinese‐origin cells regardless of the country of
module assembly or country of exportation. These data should exclude modules assembled with non‐
Chinese‐origin cells, including those assembled in China.
Report data in kilowatts and actual dollars (not 1,000s).
Product 1
Quantity
Value
(Quantity in kilowatts, value in dollars)
Product 2
Product 3
Quantity
Value
Quantity
Value
Product 4
Period of
shipment
Quantity
Value
2012:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2013:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2014:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2015:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 1:
Product 2:
Product 3:
Product 4:
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
III‐2(b). Continued
(Quantity in kilowatts, value in dollars)
Product 6
Product 7
Quantity
Value
Quantity
Value
Page 26
Product 5
Product 8
Period of
Quantity
Value
Quantity
Value
shipment
2012:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2013:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2014:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2015:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2016:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2017:
Jan‐Mar
Apr‐Jun
Jul‐Sep
Oct‐Dec
2018:
Jan‐Mar
Apr‐Jun
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 the product. Also, please explain any anomalies in your firm’s reported pricing data.
Product 5:
Product 6:
Product 7:
Product 8:
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 27
III‐2 (c). Price data checklist.‐‐Please check that the pricing data in question III‐2(b) has been correctly
reported.
Is the price data reported above:
√ if Yes
In actual dollars (not $1,000)?
F.o.b. U.S. point of shipment (i.e., does not include U.S. transport costs)?
Net of all discounts and rebates?
Have returns credited to the quarter in which the sale occurred?
Less than reported commercial shipments in question II‐6a in each year?
III‐2(d). 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‐3.
Price setting.‐‐How does your firm determine the prices that it charges for sales of CSPV cells
and modules (check all that apply)? If your firm issues price lists, please submit sample pages of
a recent list.
Transaction
by
transaction
Contracts
III‐4.
Set
price
lists
Other
If other, describe
Discount policy.‐‐Please indicate and describe your firm’s discount policies for CSPV cells and
modules (check all that apply).
Quantity
discounts
Annual
total
volume
discounts
III‐5.
Pricing terms.‐‐
No
discount
policy
Other
Describe
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 28
(a)
What are your firm’s typical sales terms for CSPV cells and modules imported from
China?
Net 30
days
Net 60
days
(b)
2/10 net
30 days
Other
Other (specify)
On what basis are your firm’s prices of imported CSPV cells and modules from China
usually quoted? (check one)
Delivered
F.o.b.
III‐6.
If f.o.b., specify point
Contract versus spot.‐‐Approximately what share of your firm’s sales of CSPV cells and modules
imported from China in 2017 was on a (1) long‐term contract basis, (2) annual contract basis, (3)
short‐term contract basis, and (4) spot sales basis?
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of your
2017 sales
(CSPV cells)
Share of your
2017 sales
(CSPV
modules)
Type of sale
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
Total
(should
sum to
100.0%)
Spot sales
(for a single
delivery)
%
%
%
%
0.0
%
%
%
%
%
0.0
%
Type of sale
Long‐term
contracts
(multiple
deliveries for
more than 12
months)
Share of your
2017 sales
%
Short‐term
Annual
contracts
contracts
(multiple
(multiple
deliveries for 12 deliveries for less
than 12 months)
months)
%
%
Spot sales
(for a single
delivery)
%
Total
(should
sum to
100.0%)
0.0
%
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 29
III‐7. Contract provisions.‐‐Please fill out the table regarding your firm’s typical sales contracts for
CSPV cells and modules from China (or check “not applicable” if your firm does not sell on a
long‐term, short‐term, and/or contract basis).
Short‐term contracts Annual contracts
Long‐term contracts
(multiple
(multiple deliveries
Typical sales
(multiple deliveries for
Item
deliveries for 12
for less than 12
contract provisions
more than 12 months)
months)
months)
Average contract
duration
No. of
days
Price renegotiation
(during contract
period)
Yes
No
Quantity
Price
Both
Yes
No
Fixed quantity
and/or price
Meet or release
provision
Not applicable
III‐8.
365
Lead times.‐‐What is your firm’s share of sales of CSPV cells and modules imported from China
from inventory and 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 CSPV cells and modules?
Source
Lead time (average
number of days)
From inventory
%
From foreign manufacturers’ inventory
%
Produced to order
%
Total (should sum to 100.0%)
Share of 2017 sales
0.0 %
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 30
III‐9. Shipping information.‐‐
(a)
What is the approximate percentage of the cost of CSPV cells and modules imported
from China that is accounted for by U.S. inland transportation costs? %
(b)
Who generally arranges the transportation to your firm’s customers’ locations?
Your firm Purchaser (check one)
(c)
When your firm sells CSPV cells and modules imported from China, from where is it
shipped?
Point of importation Storage facility (check one)
(d)
Indicate the approximate percentage of your sales of CSPV cells and modules 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‐10. Geographical shipments.‐‐ In which U.S. geographic market area(s) has your firm sold CSPV cells
and modules imported from subject countries since January 1, 2012 (check all that apply)?
Geographic area
China
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA,
and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously
listed, including AK, HI, PR, and VI.
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 31
III‐11. End uses.‐‐
(a) Estimate the percent of your total production cost that is accounted for by CSPV cells and by
other inputs (such as labor, energy, and other raw materials) in modules.
Share of total cost of end use product
accounted for by
Total
(should sum to 100.0%
across)
CSPV Cells
Other inputs
End use product
Module
(b)
%
%
0.0 %
For products you make using CSPV modules, please estimate the percent of your total
production cost that is accounted for by CSPV modules and by other inputs (such as
labor, energy, and other raw materials).
Share of total cost of end‐use product
accounted for by
CSPV Modules
End use product
Other inputs
Total
(should sum to 100.0%
across)
Residential system
%
%
0.0 %
Commercial system
%
%
0.0 %
Utility system
%
%
0.0 %
Off grid portable
consumer goods
%
%
0.0 %
(c)
Have there been any changes in the end uses of CSPV cells and modules since January 1,
2012? Do you anticipate any future changes?
Changes in end
uses
No
Yes
Explain
Changes since
January 1, 2012
Anticipated
changes
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 32
III‐12. Substitutes.‐‐
(a) Are thin film solar products considered substitutes for CSPV cells and modules in the
same end use(s)?
Substitutes
Are these
considered
substitutes in the
End use(s) in which
market?
this substitute is
No
Yes
used
Thin film solar
products
Have changes in the price of this
substitute affected the price for CSPV
cells and modules?
No
Yes
Explanation
(b) Can other products not already listed in part "a" of this question be substituted for CSPV
cells and modules?
No
Yes‐‐Please fill out the table.
End use in which this
substitute is used
Other substitutes
Have changes in the price of this substitute
affected the price for CSPV cells and modules?
No Yes
Explanation
1.
2.
3.
(c) Have there been any changes in the number or types of products that can be substituted for
CSPV cells and modules since January 1, 2012? Do you anticipate any future changes?
Changes in substitutes No Yes
Changes since
January 1, 2012
Anticipated changes
Explain
Business Proprietary
U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐13. Availability of supply.‐‐Has the availability of CSPV cells and modules in the U.S. market changed
since January 1, 2012? Do you anticipate any future changes?
Availability in the U.S.
Please explain, noting the countries and reasons for the
No Yes
market
changes.
Changes since January 1, 2012:
U.S.‐produced product
Imports from China
Imports from all other
countries
U.S.‐produced product
Imports from China
Imports from all other
countries
Anticipated changes:
III‐14. Demand trends.‐‐ Indicate how demand within the United States and outside of the United
States (if known) for CSPV cells and modules has changed since January 1, 2012, and how you
anticipate demand will change in the future. Explain any trends and describe the principal
factors that have affected, and that you anticipate will affect, these changes in demand.
Market
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2012
Within the United States
(Residential)
Within the United States
(Utility)
Outside the United States
Anticipated future demand
Within the United States
(Residential)
Within the United States
(Utility)
Outside the United States
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III‐15. Product changes.‐‐Have there been any significant changes in the product range, product mix,
or marketing of CSPV cells and modules since January 1, 2012? Do you anticipate any future
changes?
Changes in
product range,
product mix, or
marketing
No Yes
Changes since
January 1, 2012
Anticipated
changes
Explain
III‐16. Conditions of competition.‐‐
(a) Is the CSPV cells and modules market subject to business cycles (other than general
economy‐wide conditions) and/or other conditions of competition distinctive to CSPV cells
and modules?
Check all that apply.
Please describe.
No
Skip to question III‐17.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
CSPV cells and modules since January 1, 2012?
No
Yes
If yes, describe.
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐17. Government Incentives.‐‐
(a)
Indicate how the level or availability of government incentives for CSPV cells and
modules has affected demand for CSPV has changed since January 1, 2012, and how you
anticipate demand will change in the future based on the level or availability of
government incentives? In the last column, list or describe the principal incentive
programs (e.g., Section 1603 program, Renewable Portfolio Standards, or California
Solar Initiative) whose change in level or availability might affect demand.
Market
Fluctuate
with no
Overall
No
Overall
increase change decrease clear trend
Explanation and factors
Demand since January 1, 2012
State and
local
government
incentives
Federal
government
incentives
Anticipated future demand
State and
local
government
incentives
Federal
government
incentives
(b) How have changes in the availability of government incentives affected the price of solar
generated electricity since January, 1 2012? Explain any trends and describe the principal
factors that might affect these changes in price.
Explanation and factors
Overall Fluctuate
No
Overall
with no
price
change
price
clear
increase in price decrease
trend
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III‐18. Conventional energy sources.‐‐
(a) How have prices of electricity generated from U.S. conventional energy sources such as
natural gas and coal impacted demand for CSPV cells and modules (whether or not partially
or fully assembled into other products) in each sector below since January 1, 2012? Describe
the principal factors that have affected these changes in demand.
Overall
increase
Market
No
change
Overall
decrease
Fluctuate
with no
clear trend
Factors
Residential
Commercial
Utility
(b) How have changes in the price of electricity generated from U.S. conventional energy
sources affected the price of solar generated electricity since January 1, 2012? Explain any
trends and describe the principal factors that have affected these changes in price.
Overall
No
price
change in
increase
price
Overall
price
decrease
Fluctuate
with no
clear trend
Explanation and factors
III‐19. Supply constraints.‐‐Has your firm refused, declined, or been unable to supply CSPV cells and
modules since January 1, 2012 (examples include placing customers on allocation or “controlled
order entry,” declining to accept new customers or renew existing customers, delivering less
than the quantity promised, being unable to meet timely shipment commitments, etc.)?
No
Yes
If yes, please describe.
III‐20. Raw materials.‐‐Indicate how CSPV cells and modules’ raw material prices have changed since
January 1, 2012, and how you expect they will change in the future.
Raw
materials
prices
Fluctuate
with no Explain, noting how raw material price
clear changes have affected your firm’s selling
Overall
No
Overall
prices for CSPV cells and modules.
increase change decrease trend
Changes since
January 1,
2012
Anticipated
changes
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐21. Price comparisons.‐‐Please compare market prices of CSPV cells and modules in U.S. and non‐
U.S. markets if known. Provide information as to time periods and regions for any price
comparisons.
III‐22. Impact of the section 201 safeguard on firm and market—
(a) Did the announcement on January 22, 2018 and subsequent implementation of remedies in the
section 201 safeguard proceeding have any discernible impact on your firm's CSPV cell and
module operations and/or the market as a whole? Include in this discussion the impact of the
2.5 GW exemption and tariff‐rate quotas for CSPV cells if applicable.
No
Yes‐‐Please specify.
Item
Response
Impact on firm1
Impact on overall market2
1
Please identify the magnitude and timing of any effects, and compare your firm's operations before and
after the announcement of the safeguard measures on January 22, 2018.
2
Please identify the magnitude and timing of any effects, and compare the overall market before and after
the announcement of the safeguard measures on January 22, 2018.
(b) Assessment of specific impacts of the section 201 safeguard. ‐‐Please indicate the impact
that your firm has observed with regards to the announcement on January 22, 2018 and
subsequent implementation of remedies in the section 201 safeguard proceeding.
Item
Overall demand
for CSPV cells and
modules in the
U.S. market
Fluctuate
with no
clear
Overall
No
Overall
trend
Improve change Worsen
Explanation and factors
Prices for CSPV
cells and modules
in the U.S. market
Impact on your
firm's CSPV cell
and module
operations in the
United States
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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(c) Changes to forward looking outlook due to the section 201 safeguard.‐‐What impact did the
announcement on January 22, 2018 and subsequent implementation of remedies in the
section 201 safeguard proceeding have on your firm's forward‐looking outlook?
Strongly Somewhat
Somewhat Strongly
Item
worsened worsened No change improved improved
Firm's forward looking
outlook
Narrative explanation:
III‐23. Market studies.‐‐Please provide as a separate attachment to this request any studies, surveys,
etc. that you are aware of that quantify and/or otherwise discuss CSPV cells and modules supply
(including production capacity and capacity utilization) and demand in (1) the United States, (2)
each of the other major producing/consuming countries, including China, and (3) the world as a
whole. Of particular interest is such data from 2012 to the present and forecasts for the future.
III‐24. Interchangeability.‐‐ Are CSPV cells and modules 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
China
Other countries
For any country‐pair producing CSPV cells and modules that is sometimes or never
interchangeable, identify the country‐pair and explain the factors that limit or preclude
interchangeable use:
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐25. Factors other than price.‐‐Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between CSPV cells and modules
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 CSPV cells and modules, identify the country‐pair and report the
advantages or disadvantages imparted by such factors:
III‐26. Other explanations.‐‐If your firm would like to further explain a response to a question in Part III
that did not provide a narrative response box, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.
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U.S. Importers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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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 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 ‐ CSPV Cells and Modules (CSPV1 Review)
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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/701731/2017/crystalline_silicon_photovoltaic_cells_an
d_modules/first_review_full.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: CSPV1
• E‐mail.—E‐mail the MS Word questionnaire to mary.messer@usitc.gov; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non‐encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not 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 Title | Microsoft Word - US importers--CSPV cells and modules (R1) |
| Author | mary.messer |
| File Modified | 2018-08-06 |
| File Created | 2018-08-06 |