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pdfOMB No. 3117‐0016/USITC No. 18‐3‐3934; Expiration Date: 6/30/2020
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LOST SALES AND LOST REVENUE SURVEY
STEEL TRAILER WHEELS FROM CHINA
This survey must be received by the Commission by August 22, 2018
See last page for filing instructions.
The information called for in this survey is for use by the United States International Trade Commission in connection
with its countervailing duty and antidumping investigations concerning steel trailer wheels (“trailer wheels”) from China
(Inv. Nos. 701‐TA‐609 and 731‐TA‐1421 (Preliminary)). The information requested in the survey 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 survey can be obtained from Aimee Larsen (202‐205‐3179, Aimee.Larsen@usitc.gov).
Name of firm
Address
City
State
Zip Code
Website
Has your firm purchased trailer wheels (as defined on next page) at any time since January 1, 2015?
NO
(Sign the certification below and promptly return only this page of the survey to the Commission)
YES
(Complete all parts of the survey, and return the entire survey to the Commission)
Return questionnaire via the U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: TRAIL)
CERTIFICATION
I certify that the information herein supplied in this survey is complete and correct to the best of my knowledge and belief and
understand that the information submitted is subject to audit and verification by the Commission. By submitting this certification I
also grant consent for the Commission, and its employees and contract personnel, to use the information provided in this survey
and throughout this proceeding in any other import‐injury proceedings conducted by the Commission on the same or similar
merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
investigation or other proceeding may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official Title of Authorized Official
Date
Signature
Phone
Email address
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 2
GENERAL INFORMATION
Background.‐‐This proceeding was instituted in response to a petition filed on August 8, 2018, by
Dexstar Wheel, Elkhart, Indiana. Countervailing and/or antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2018/steel_trailer_wheels_china/preliminary.htm.
Trailer wheels covered by these investigations are certain on‐the‐road steel wheels, and components
thereof, for tubeless tires with a nominal wheel diameter of 12 inches to 16.5 inches, regardless of
width. Certain on‐the‐road steel wheels with a wheel diameter of 12 inches to 16.5 inches within the
scope are generally for road and highway trailers and other towable equipment, including, inter alia,
utility trailers, cargo trailers, horse trailers, boat trailers and recreational trailers. Rims may be entered
separately and sold to towable mobile home customers where the rim will be mounted to the wheel
hub without a disc. The standard widths of certain on‐the‐road steel wheels are 4 inches, 4.5 inches, 5
inches, 5.5 inches, 6 inches, and 6.5 inches, but all certain on‐the‐road steel wheels, regardless of width,
are covered by the scope.
The scope includes rims and discs for certain on‐the‐road steel wheels, whether imported as an
assembly, unassembled, or separately. The scope includes certain on‐the‐road steel wheels regardless of
steel composition, whether cladded or not cladded, whether finished or not finished, and whether
coated or uncoated. The scope also includes certain on‐the‐road steel wheels with discs in either a “hub‐
piloted” or “stud‐piloted” mounting configuration, though the stud‐piloted configuration is most
common in the size range covered.
All on‐the‐road wheels sold in the United States must meet Standard 110 or 120 of the National
Highway Traffic Safety Administration’s (NHTSA) Federal Motor Vehicle Safety Standards, which requires
a rim marking, such as the “DOT” symbol, indicating compliance with applicable motor vehicle
standards. See 49 C.F.R. § 571.110 and § 571.120. The scope includes certain on‐the‐road steel wheels
imported with or without NHTSA’s required markings.
Certain on‐the‐road steel wheels imported as an assembly with a tire mounted on the wheel and/or
with a valve stem or rims imported as an assembly with a tire mounted on the rim and/or with a valve
stem are included in the scope of this investigation. However, if the steel wheels or rims are imported as
an assembly with a tire mounted on the wheel or rim and/or with a valve stem attached, the tire and/or
valve stem is not covered by the scope.
Excluded from this scope are the following: steel wheels for tube‐type tires; such tires use multi‐piece
rims, which are two‐piece and three‐piece assemblies and require the use of an inner tube. Also
excluded from this scope are aluminum wheels and certain on‐the‐road steel wheels that are coated
with chrome. Steel wheels that do not meet Standard 110 or 120 of the NHTSA’s requirements are
excluded from the scope.
Certain on‐the‐road steel wheels subject to this investigation are properly classifiable under the
following category of the Harmonized Tariff Schedule of the United States (“HTSUS”): 8716.90.5035
which covers the exact product covered by the scope whether entered as an assembled wheel or in
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 3
components. Wheels entered with a tire mounted on them are believed entered under HTS
8716.90.5059 (Trailers and semi‐trailers; other vehicles, not mechanically propelled, parts, wheels,
other, wheels with other tires) (a category that will be broader than what is covered by the scope).
While the HTSUS subheading is provided for convenience and customs purposes, the written description
of the subject merchandise is dispositive.
Chrome‐coated steel trailer wheels.‐‐Steel trailer wheels which have been coated in chrome but
otherwise meet the dimensions of in‐scope trailer wheels (see above scope definition).
Reporting of information.‐‐ If information is not readily available from your records, provide carefully
prepared estimates.
Confidentiality.‐‐The data furnished in response to this survey 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.
Release of information.‐‐The information provided by your firm in response to this survey, 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. Please also retain a copy of the final document that you submit.
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 4
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 survey. This
may or may not be the person whose signature is at the bottom of page 1.
Name
Title
Email
Telephone
Firms operating more than one establishment should combine the data for all establishments into a
single response.
PURCHASE INFORMATION
1. Purchases and imports.‐‐Report separately your firm’s domestic purchases and imports of trailer
wheels, including components such as rims and center discs. If your firm purchased and/or
imported trailer wheels with out‐of‐scope attachments (e.g., tires and/or value stems) report only
the value of the trailer wheel itself.
“Purchase” – Purchase from a U.S. entity such as a U.S. producer, a U.S. importer, or other U.S. firm.
“Import” – Purchase directly from a foreign supplier and your firm is the importer of record.
2015
2016
2017
Item
Purchases of trailer wheels produced in—
United States
Value (in dollars)
China
All other countries1
Sources unknown
0
0
0
0
0
0
Total purchases
Imports of trailer wheels from—
China
1
All other countries
Total imports
1
Please identify these countries:
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 5
2. Changes in purchasing patterns.‐‐Please indicate how the shares of your firm’s purchases of trailer
wheels from different sources have changed since January 1, 2015.
Source of
purchases
Did not
purchase Decreased Increased
Constant Fluctuated
Explanation for trend
United States
China
All other
countries
Sources
unknown
3. Major purchasing factors.‐‐Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase trailer wheels.
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
4. Assembly.—Does your firm purchase rims and center discs for internal use to manufacture in‐scope
whole trailer wheels?
No
Yes
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 6
Note.‐‐As a reminder, as per the definition on page 2, “trailer wheels” includes rims and discs for
certain on‐the‐road steel wheels, whether assembled or purchased separately.
5. Purchasing subject imports rather than domestic products.—
(a)
Since January 2015, did your firm purchase imports of trailer wheels from China instead
of U.S.‐produced trailer wheels?
Yes
No
Source
(also respond to parts (b) and (c))
(If “No”, skip to next question)
China
(b)
If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Source
Yes
No
China
(c)
If you responded “Yes” to part (a), was price a primary reason for purchasing subject
imports rather than domestic product?
Source
Yes
If Yes, estimate the value of
imports purchased instead of
domestic product since
January 2015
(in actual dollars)
China
No
If No, please indicate the
reason your firm purchased
imports instead of domestic
product
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 7
6.
U.S. producers and import competition.—
(a)
Since January 1, 2015, in connection with a sale or offer to sell trailer wheels to your
firm, did U.S. producers reduce their prices of domestically produced trailer wheels in
order to compete with lower‐priced imports of trailer wheels from China?
Yes (also respond to
No (If “No”, skip to next
Source
question part (b))
question)
Don’t know
China
(b)
If your firm responded “yes”, please provide an estimate of the reduction in U.S.
producers’ prices, and any additional explanations, such as timing (e.g., months/years),
frequency of price reductions, or other market/competitive factors.
Source
China
Estimated
reduction in U.S.
prices
(percent)
%
Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors
7. Method of purchase‐‐Please provide a general description of your firm’s method(s) of purchase
(e.g., individual purchase, contract, bids, etc.) for trailer wheels.
8. Other explanations‐‐Please provide any additional comments in this box.
Business Proprietary
Lost Sales and Lost Revenue Survey‐ Trailer wheels
Page 8
OMB INFORMATION
8. OMB statistics.‐‐Please report the actual number of hours required and the cost to your firm of
completing this survey.
Hours
Dollars
The questions in this survey 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 survey is estimated to average 4 hours per response,
including the time for reviewing instructions, gathering data, and completing and reviewing the
survey.
We welcome comments regarding the accuracy of this burden estimate, suggestions for reducing
the burden, and any suggestions for improving this survey. Please attach such comments to your
response or send to the Office of Investigations, USITC, 500 E St. SW, Washington, DC 20436.
HOW TO FILE YOUR SURVEY RESPONSE
Please do not attempt to modify the format or permissions of the survey document.
Please submit the completed survey using one of the methods noted below. If your firm
is unable to complete the MS Word survey 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 survey along with a scanned copy of the signed
certification page (page 1) through the Commission’s secure upload facility:
o
o
o
Web address: https://dropbox.usitc.gov/oinv/
Enter Investigation: Select “Steel Trailer Wheels from China” in the drop down menu
Pin: TRAIL
• E‐mail.—E‐mail the MS Word survey to Aimee.Larsen@usitc.gov; include a scanned copy of the signed
certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents that are
electronically transmitted to the Commission to protect your sensitive information from unauthorized
disclosure. The USITC secure drop‐box system and the Electronic Document Information System (EDIS)
use Federal Information Processing Standards (FIPS) 140‐2 cryptographic algorithms to encrypt data in
transit. Submitting your nonpublic documents by a means that does not use these encryption algorithms
(such as by email) may subject your firm’s nonpublic information to unauthorized disclosure during
transmission. If you choose a non‐encrypted method of electronic transmission, the Commission warns
you that the risk of such possible unauthorized disclosure is assumed by you and not by the Commission.
If your firm did not purchase this product, please fill out page 1, print, sign, and submit a scanned copy
to the Commission.
File Type | application/pdf |
File Title | Microsoft Word - LSLR Questionnaire--Trailer Wheels (P) |
Author | jordan.harriman |
File Modified | 2018-08-10 |
File Created | 2018-08-10 |