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pdfOMB No. 3117‐0016/USITC No. xx‐x‐xxx; Expiration Date: 6/30/2020
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U.S. PURCHASERS’ 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 countervailing duty and antidumping orders concerning Crystalline Silicon Photovoltaic
Cells and Modules (“CSPV cells and modules”) from China (Inv. No. 701‐TA‐481 & 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 possession (19 U.S.C. § 1333(a)). Further information on this questionnaire can be
obtained from James Horne (202‐205‐2722, James.Horne@usitc.gov).
Name of firm
Address
City
State
Zip Code
Website
Has your firm purchased CSPV cells and modules (as defined on the next page) from any source (domestic or
foreign) 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 proceedings 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
Phone:
Signature
Date
Email address
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 2
PART I.—GENERAL INFORMATION
Background.‐‐ 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 mm 2 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. Purchasers’ 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.
Purchaser.‐‐Any firm engaged, either directly or through a parent company or subsidiary, in purchasing
certain crystalline silicon photovoltaic products from another firm that produces, imports, or otherwise
distributes CSPV cells and modules.
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 in connection with this
proceeding (i.e., a producer, importer, and/or purchaser questionnaire), you need not respond to
duplicated questions.
Confidentiality.‐‐The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.‐‐The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all of your 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. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐1.
Page 4
Establishments covered.‐‐Provide the name and address of establishment(s) covered by this
questionnaire, if different from that listed on the cover page. Firms operating more than one
establishment should combine the data for all establishments into a single response.
“Establishment”‐‐Each facility of a firm involved in the purchase of CSPV cells and modules,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
I‐2.
Ownership.‐‐Is your firm owned, in whole or in part, by any other firm?
No
Yes‐‐List the following information.
Extent of ownership
Firm name
Address
(percent)
I‐3.
I‐4.
Related importers/exporters.‐‐Does your firm have any related firms, either domestic or
foreign, that import CSPV cells and modules into the United States or that export CSPV cells and
modules to the United States?
No
Yes‐‐List the following information.
Firm name
Country
Affiliation
Related producers.‐‐Does your firm have any related firms, either domestic or foreign, that
produce certain CSPV cells and modules?
No
Yes‐‐List the following information.
Firm name and country
Country
Affiliation
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
I‐5.
Page 5
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?
If yes, please provide these documents. If you are not providing the
Yes requested documents, please explain why not.
No
PART II.‐‐PURCHASES
Contact information.‐‐Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this questionnaire.
Name
Title
Email
Telephone
II‐1. Purchases.‐‐Please report your firm’s U.S. purchases of CSPV cells and modules in 2017. (Do not
include imports for which your firm was the importer of record; such imports should be
reported in your U.S. importer’s questionnaire.)
Note.—For CSPV modules, report module origin based on cell origin (e.g., purchases of modules
assembled in Malaysia using Chinese‐origin cells should be reported as "China").
Crystalline silicon photovoltaic products
produced in:
Purchases in 2017
CSPV cells
(kilowatts)
CSPV modules
(kilowatts)
United States
China
All other countries
Sources unknown
0.0
0.0
Total purchases
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐2.
Page 6
Purchases before and after order.‐‐
(a)
(b)
Did your firm purchase CSPV cells and modules from China before 2012?
No‐‐skip to (c)
Yes
If yes, has your pattern of purchasing CSPV cells and modules from China changed since
2012?
No, our pattern of purchasing is essentially unchanged.
Yes, we discontinued purchases from China because of the order.
Yes, we reduced purchases from China because of the order.
Yes, but we changed the pattern of purchases from China for reasons other
than the order (please explain below).
(c)
Has your pattern of purchasing CSPV cells and modules from non‐subject foreign
sources (i.e., countries other than China) changed since 2012?
We did not purchase from non‐subject foreign sources before or after the
order.
No, our pattern of purchasing is essentially unchanged.
Yes, we increased purchases from non‐subject foreign sources because of the
order.
Yes, but we changed our pattern of purchases from non‐subject foreign sources
for reasons other than the order (please explain below).
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
II‐3.
Page 7
Changes in purchasing patterns.‐‐Please indicate how the shares of your firm’s purchases of
CSPV cells and modules from different sources have changed since January 1, 2012.
Source of Did not
purchases purchase Decreased Increased Constant Fluctuated
II‐4.
Explanation for trend
United
States
China
All other
countries
Sources
unknown
Country knowledge.‐‐Please indicate the countries of origin with which your firm has
experience or information in the market for CSPV cells and modules.
United
States
II‐5.
China
Other
countries
Other countries (specify)
Supplier identification.‐‐Please list your firm’s FIVE largest suppliers for CSPV cells and modules
since January 1, 2012. Also, provide the share of the quantity of your firm’s total purchases of
CSPV cells and modules that each of these suppliers accounted for in 2017.
No.
Supplier’s name
City and state
Share of quantity of
2017 purchases
1
%
2
%
3
%
4
%
5
%
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 8
PART III.‐‐MARKET CHARACTERISTICS AND PURCHASING PRACTICES
III‐1. Firm type.‐‐Which of the following best describes your firm as a purchaser of CSPV cells and
modules (check all that apply)?
Residential Installer
Commercial Installer
Utility Company/Developer
Distributor of Cells
Distributor of Modules
Module Assembler
Other (Describe: )
If your firm is a distributor of CSPV cells and modules, please answer questions III‐2 and III‐3.
III‐2. Competition for sales.‐‐Do you compete for sales to your customers with the manufacturers or
importers from which you purchase CSPV cells and modules?
No
Yes If yes, please describe.
III‐3.
Types of customers.‐‐What are the major types of consumers to which you sell CSPV cells and
modules?
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 9
If your firm is an end user of CSPV cells and modules, please answer questions III‐4 and III‐5.
III‐4. 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 in each of the product(s) your
Total
firm produces accounted for by
(should
sum to
100.0%
Product(s) your firm
across)
produces
CSPV cells
Other inputs
Module
% +
% =
0.0 %
(b) 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 in each of the product(s) your
firm produces accounted for by
Product(s) your firm
produces
CSPV modules
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 %
Other:
% +
% =
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
Changes since
January 1, 2012
Anticipated changes
Explain
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
III‐5.
Page 10
Demand for end use products.‐‐
(a)
Has the demand for your firm’s final products incorporating CSPV cells and modules
changed since January 1, 2012?
Increased
No change
(b)
III‐6.
Decreased
Fluctuated
Has this had any effect on your firm’s demand for CSPV cells and modules?
No
Yes
Explain
Substitutes.—
(a) Are thin film solar products considered substitutes for CSPV cells and modules in the
same end use(s)?
Substitutes
Thin film solar
products
Are these
considered
substitutes in the
End use(s) in which
market?
this substitute is
No
Yes
used
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.
Other substitutes
End use in which this
substitute is used
Have changes in the price of this substitute
affected the price for CSPV cells and modules?
No Yes
Explanation
1.
2.
3.
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
(c)
Page 11
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
III‐7.
Explain
Changes since
January 1, 2012
Anticipated changes
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
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
III‐8.
III‐9.
Page 12
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 2012to the present and forecasts for the future.
Country preferences.‐‐Do you or your customers ever specifically order CSPV cells and modules
from one country in particular over other possible sources of supply?
No
Yes
If yes, identify the countries and explain.
III‐10. Importance of purchasing domestic product.‐‐Please fill out the table below, estimating the
percentage of your firm’s total 2017 purchases of CSPV cells and modules that required CSPV
cells and modules produced in the United States.
Estimated percentage of
your firm’s total 2017
purchases of CSPV cells
and modules
Purchases that did not require domestic product
%
Purchases that were required by law or regulation to be domestic
product (e.g., government purchases under “Buy American” provisions)
%
Purchases that were not required by law or regulation, but were required
by your customers to be domestic product
%
Purchases that were required to be domestic product for other reasons
(explain: )
%
Total (should sum to 100.0%)
0.0 %
III‐11. Conditions of competition.‐‐
(a) Is the market for CSPV cells and modules 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‐12.
Yes‐Business cycles (e.g.
seasonal business)
Yes‐Other distinctive
conditions of competition
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 13
(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.
III‐12. Decisions based on producer and country‐of‐origin.‐‐ How often does your firm, and if you know,
do your customers, make purchasing decisions involving CSPV cells and modules based on its producer
or country of origin?
Always
Usually
Sometimes
Never
If at least sometimes, explain.
Decision based on producer
Your firm
Your
customers
Decision based on country of origin
Your firm
Your
customers
III‐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:
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 14
III‐14. Availability of specific product types.‐‐Are certain grades/types/sizes of CSPV cells and modules
only available from certain country sources?
No
Yes
If yes, please identify the countries and the grade/type/size.
III‐15. Government Incentives.‐‐
(a)
Indicate how in the level or availability of government incentives for CSPV cells and
modules affect 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.
Fluctuate
Overall
No
Overall
with no
increase change decrease clear trend
Market
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
Fluctuate
with no
Overall
No
Overall
clear
price
change
price
Explanation and factors
trend
in price decrease
increase
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 15
III‐16. 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 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‐17. Supply constraints.‐‐Has any firm refused, declined, or been unable to supply your firm with
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.
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 16
III‐18. Purchasing frequency.‐‐
(a)
How frequently do you make purchases of CSPV cells and modules (check one)?
Daily Weekly
(b)
Monthly
Quarterly Annually
Other If other, specify
Do you expect this purchasing frequency to change in the next two years?
No
Yes If yes, explain.
III‐19. Number of suppliers contacted.‐‐How many suppliers do you generally contact before making a
purchase? Between and firms.
III‐20. Supplier negotiations.‐‐Do your firm’s purchases of CSPV cells and modules usually involve
negotiations between supplier and purchaser?
No
Yes
If yes, explain the factors you generally negotiate and note whether your firm
quotes competing prices during negotiations.
III‐21. Change in suppliers.‐‐ Has your firm changed suppliers since January 1, 2012?
No
Yes
If yes, please list the supplier(s), whether the firm was added or dropped, and
the reasons for the change.
III‐22. New suppliers.‐‐
(a)
Are you aware of any new suppliers, either foreign or domestic, that have entered the
market since January 1, 2012?
No
Yes If yes, please identify the firms.
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
(b)
Page 17
Do you expect new suppliers of CSPV cells and modules to enter the U.S. market?
No
Yes If yes, please explain.
III‐23. Supplier qualification.‐‐Do you require your suppliers to be or to become certified or qualified
to sell CSPV cells and modules to your firm?
If yes, provide the following information.
The number of days to qualify a new supplier.
A general description of the certification or qualification process. Also, a brief
description of the factors that you consider when qualifying a new supplier (e.g., quality
of product, reliability of supplier, etc.).
No
Yes
Number
of days Process and factors
III‐24. Failure to certify.‐‐Since January 1, 2012, have any domestic or foreign producers failed in their
attempts to certify or qualify their CSPV cells and modules with your firm or have any producers
lost their approved status?
No
Yes
If yes, please identify these firms, the countries where they are located, and
the reasons why they failed the certification/qualification.
III‐25. Major purchasing factors.‐‐ Please list, in order of their importance, the three major factors
your firm considers in deciding from whom to purchase CSPV cells and modules (examples may
include availability, extension of credit, contracts, price, quality, range of supplier’s product line,
traditional supplier, etc.).
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 18
III‐26. Purchasing factors.‐‐Please rate the importance of the following factors in your firm’s
purchasing decisions for CSPV cells and modules.
Factor
Very
important
Somewhat
important
Not
important
Availability
Bankability
Cell count (60, 72, 90–cell modules)
Cell efficiency
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Module racking systems
Packaging
Price
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
Warranty
Wattage
U.S. transportation costs
III‐27. Quality characteristics.‐‐What characteristics does your firm consider when determining the
quality of CSPV cells and modules?
Business Proprietary
U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
Page 19
III‐28. Minimum quality.‐‐How often do CSPV cells and modules from the following countries meet
minimum quality specifications for your uses or your customers’ uses?
Rarely or
Don’t
Source
Always
Usually
Sometimes
never
know
United States
China
Other:
III‐29. Frequency of decisions based on price.‐‐How often does your firm purchase the CSPV cells and
modules that is offered at the lowest price?
Always
Usually
Sometimes
Never
III‐30. Price leaders.‐‐A price leader is defined as (1) one or more firms that initiate a price change,
either upward or downward, that are followed by other firms, or (2) one or more firms that have
a significant impact on prices. A price leader is not necessarily the lowest‐priced supplier.
Please list the names of any firms you considered price leaders in the CSPV cells and modules
market since January 1, 2012.
Firm(s)
Describe how the firm(s) exhibited price leadership
III‐31. Changes in U.S. industry.‐‐
(a)
Please identify and discuss any improvements/changes in the U.S. CSPV cells and
modules industry since January 1, 2012 and explain the factors, including the order(s)
under review, which were responsible for each improvement/change.
(b)
Please discuss any improvements/changes that you anticipate in the future in the U.S.
CSPV cells and modules industry. Identify the time period and causes for these
improvements/changes.
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U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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III‐32. Effect of revocation of orders.‐‐ What do you think will be the effects on your firm and on the
U.S. market of any revocation of the countervailing duty order on imports of CSPV cells and
modules from China?
III‐33. 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.
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(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.
Fluctuate
Overall
No
Overall
with no
improve change worsen clear trend
Item
Explanation and factors
Overall
demand for
CSPV cells
and modules
in the U.S.
market
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
(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?
Item
Firm's forward looking
outlook
Narrative explanation:
Strongly
worsened
Somewhat
Somewhat
worsened No change improved
Strongly
improved
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PART IV.‐‐PRODUCT COMPARISIONS
IV‐1. 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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IV‐2. 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 purchases of the
products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country‐pair
Country‐pair
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:
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U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
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Superior
Comparable
Inferior
Superior
Comparable
Inferior
Superior
Comparable
Inferior
IV‐3. Factor country comparisons.‐‐For the factors listed below, please rate how CSPV cells and
modules produced in each country you identified in your response to question II‐4 compares with CSPV
cells and modules produced in each of the other countries you identified.
If you are unfamiliar with the product from a particular country, please leave the boxes for those
country comparisons blank.
Product from
Product from
United States
Product from
United States
China compared to
compared to
compared to
product from
product from
product from
Nonsubject
Nonsubject
China
countries
countries
Availability
Bankability
Cell count (60, 72, 90–cell modules)
Cell efficiency
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Module racking systems
Packaging
Price
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
Warranty
Wattage
U.S. transportation costs
Factor
1
A rating of superior on price and U.S. transportation costs indicates that the first country generally has lower
prices/U.S. transportation costs than the second country.
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U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
IV‐4.
Page 25
Change in price.‐‐
(a)
Since January 1, 2012, has there been a change in the price of CSPV cells and modules?
If so, has the price of U.S.‐produced CSPV cells and modules changed more or less than
the price of imported CSPV cells and modules from China?
No change in price.
Prices have changed by the same amount.
Price of U.S.‐produced CSPV cells and modules has changed relative to the price of
CSPV cells and modules from China.
(b)
If the price of U.S.‐produced CSPV cells and modules has changed relative to the price of
CSPV cells and modules from China, the price of U.S.‐produced CSPV cells and modules
is now relatively
Higher
Lower
than those from China.
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IV‐5. Product Comparisons.‐‐
(a)
Has your firm evaluated both CSPV modules and think film for the same end use or
project?
No
Yes
If yes, describe.
(b) If yes, for what share of your firm’s purchases have you considered both CSPV modules and
thin film for the same end use of project since 2012? Share___%?
(c) For what applications did you consider both?
(d) Has demand for thin film increased since May 17th 2017?
No
Yes
If yes, describe.
PART V.—ADDITIONAL INFORMATION
V‐1. Other explanations.‐‐If your firm would like to further explain a response to any question that
did not provide a narrative response box, please note the question number and the explanation
in the space provided below.
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U.S. Purchasers’ Questionnaire ‐ CSPV Cells and Modules (CSPV1 Review)
V‐2.
Page 27
OMB statistics.‐‐Please report the actual number of hours required and the cost to your firm of
completing this questionnaire.
Hours
Dollars
The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
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.
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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_cell
s_and_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 James.Horne@usitc.gov; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop‐box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non‐encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm does not purchase this product, please fill out page 1, print, sign, and submit a scanned
copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, it is required to serve a copy of the
completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (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 purchasers--CSPV cells and modules (R1) |
Author | mary.messer |
File Modified | 2018-08-06 |
File Created | 2018-08-06 |