19-4-4020 Foreign producers' questionnaire

OMB No. 3117-0016/USITC No. 19-4-4020; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
WOODEN CABINETS AND VANITIES
This questionnaire must be received by the Commission by March 20, 2019
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping investigations concerning wooden cabinets and
vanities from China (Inv. Nos. 701-TA-620 and 731-TA-1445 (Preliminary)). The information requested in the
questionnaire is requested under the authority of the Tariff Act of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported wooden cabinets and vanities from China (as defined on next page) at any
time since January 1, 2016?

NO

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

YES

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

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

Title of Authorized Official

Date

Signature

Phone

Email address

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

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PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 6, 2019, by the
American Kitchen Cabinet Alliance. 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/701731/2019/wooden_cabinets_and_vanities_china/preliminary.
htm.
Wooden cabinets and vanities covered by these investigations are wooden cabinets and vanities that
are designed for permanent installation (including floor mounted, wall mounted, ceiling hung or by
attachment of plumbing), and wooden components thereof. Wooden cabinets and vanities and wooden
components are made substantially of wood products, including solid wood and engineered wood
products (including those made from wood particles, fibers, or other wooden materials such as
plywood, strand board, block board, particle board, or fiberboard), or bamboo. Wooden cabinets and
vanities consist of a cabinet box (which typically includes a top, bottom, sides, back, base blockers,
ends/end panels, stretcher rails, toe kicks, and/or shelves) and may or may not include a frame, door,
drawers and/or shelves. Subject merchandise includes wooden cabinets and vanities with or without
wood veneers, wood, paper or other overlays, or laminates, with or without non-wood components or
trim such as metal, marble, glass, plastic, or other resins, whether or not surface finished or unfinished,
and whether or not assembled or completed.
Wooden cabinets and vanities are covered by the investigation whether or not they are imported
attached to, or in conjunction with, faucets, metal plumbing, sinks and/or sink bowls, or countertops. If
wooden cabinets or vanities are imported attached to, or in conjunction with, such merchandise, only
the wooden cabinet or vanity is covered by the scope.
Subject merchandise includes the following wooden component parts of cabinets and vanities: (1)
wooden cabinet and vanity frames (2) wooden cabinet and vanity boxes (which typically include a top,
bottom, sides, back, base blockers, ends/end panels, stretcher rails, toe kicks, and/or shelves), (3)
wooden cabinet or vanity doors, (4) wooden cabinet or vanity drawers and drawer components (which
typically include sides, backs, bottoms, and faces), (5) back panels and end panels, ( 6) and desks,
shelves, and tables that are attached to or incorporated in the subject merchandise.
Subject merchandise includes all unassembled, assembled and/or "ready to assemble" (RTA) wooden
cabinets and vanities, also commonly known as "flat packs," except to the extent such merchandise is
already covered by the scope of antidumping and countervailing duty orders on Hardwood Plywood
from the People's Republic of China. See Certain Hardwood Plywood Products from the People's Republic
of China, 83 Fed. Reg. 504 (Dep't Commerce Jan. 4, 2018) (amended final deter. of sales at less than fair
value, & antidumping duty order); Certain Hardwood Plywood Products from the People's Republic of
China, 83 Fed. Reg. 513 (Dep't Commerce Jan. 4, 2018) (countervailing duty order). RTA wooden
cabinets and vanities are defined as cabinets or vanities packaged so that at the time of importation
they may include: (1) wooden components required to assemble a cabinet or vanity (including drawer
faces and doors); and (2) parts (e.g., screws, washers, dowels, nails, handles, knobs, adhesive glues)
required to assemble a cabinet or vanity. RTAs may enter the United States in one or in multiple
packages.

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Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

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Subject merchandise also includes wooden cabinets and vanities and in-scope components that have
been further processed in a third country, including but not limited to one or more of the following:
trimming, cutting, notching, punching, drilling, painting, staining, finishing, assembly, or any other
processing that would not otherwise remove the merchandise from the scope of the investigation if
performed in the country of manufacture of the in-scope product.
Excluded from the scope of these investigations, if entered separate from a wooden cabinet or vanity
are:
(1) Aftermarket accessory items which may be added to or installed into an interior of a cabinet and
which are not considered a structural or core component of a wooden cabinet or vanity.
Aftermarket accessory items may be made of wood, metal, plastic, composite material, or a
combination thereof that can be inserted into a cabinet and which are utilized in the function of
organization/accessibility on the interior of a cabinet; and include:
• Inserts or dividers which are placed into drawer boxes with the purpose of organizing or
dividing the internal portion of the drawer into multiple areas for the purpose of
containing smaller items such as cutlery, utensils, bathroom essentials, etc.
• Round or oblong inserts that rotate internally in a cabinet for the purpose of
accessibility to foodstuffs, dishware, general supplies, etc.
(2) Carved wooden accessories including corbels and rosettes, which serve the primary purpose of
decoration and personalization.
(3) Non-wooden cabinet hardware components including metal hinges, brackets, catches, locks,
drawer slides, fasteners (nails, screws, tacks, staples), handles, and knobs.
Also excluded from the scope of these investigations are:
(1) All products covered by the scope of the antidumping duty order on Wooden Bedroom Furniture
from the People’s Republic of China (Inv. No. A-570-890). See Wooden Bedroom Furniture From
the People’s Republic of China, 70 Fed. Reg. 329 (Dep’t Commerce Jan 4, 2005) (notice of
amended final deter. of sales at less than fair value & antidumping duty order).
(2) All products covered by the scope of the antidumping and countervailing duty orders on
Hardwood Plywood from the People’s Republic of China (Inv. No. A-570-051 and Inv. No. C-570052 See Certain Hardwood Plywood Products from the People's Republic of China, 83 Fed. Reg.
504 (Dep't Commerce Jan. 4, 2018) (amended final deter. of sales at less than fair value, &
antidumping duty order) (Certain Hardwood Plywood Products from the People's Republic of
China, 83 Fed. Reg. 513 (Dep't Commerce Jan. 4, 2018) (countervailing duty order).
Wooden cabinets and vanities are currently imported under statistical reporting numbers 9403.40.9060
and 9403.60.8081 of the Harmonized Tariff Schedule of the United States (HTSUS). They may also be
imported under HTSUS statistical reporting number 9403.90.7080. The HTSUS provisions are for
convenience and customs purposes; the written description of the scope of these investigations is
dispositive.
Full units are (1) fully assembled wooden cabinets and vanities and/or (2) RTA "flat packs" of wooden
cabinets and vanities containing all the necessary components for fully assembled wooden cabinets or
vanities.
Components are specifically the parts of cabinets and vanities such as: wooden cabinet and vanity
frames; the cabinet box; wooden cabinet or vanity doors; and wooden cabinet or vanity drawer and
drawer components.

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

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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.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from Celia
Feldpausch (202-205-2387, celia.feldpausch@usitc.gov).

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
I-1.

Page 5

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

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
20 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
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 in China involved in the production or export of wooden
cabinets and vanities, including auxiliary facilities operated in conjunction with (whether or not
physically separate from) such facilities. Firms operating more than one establishment in China
should combine the data for all establishments into a single report.

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce wooden cabinets and vanities in the United States or other
countries?

No

I-4.

Yes

Yes

2
3
4
5

If yes, please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

U.S. importers.--Please provide the names, contacts, telephone numbers, and e-mail addresses
of the FIVE largest U.S. importers of your firm’s wooden cabinet and vanities in 2018.

Importer’s name
1

If yes, please name the firm(s) and country(ies) below and, if U.S.
producer(s), ensure that they complete the Commission’s producer
questionnaire.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
wooden cabinets and vanities into the United States?

No

I-5.

Page 6

Contact person

Email

Telephone

Share of your
firm’s 2018 U.S.
exports (%)

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Celia Feldpausch (202-2052387, celia.feldpausch@usitc.gov). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone
Fax

II-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of wooden cabinets and vanities since January 1, 2016.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

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

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
II-2b.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of wooden cabinets
and vanities in the future?

No

II-3.

Page 8

Yes

If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions.

Product shifting.—
(a).

Is your firm able to switch production (capacity) between wooden cabinets and vanities and
other products using the same equipment and/or labor?

No

(b).

Yes

If yes—(i.e., have produced other products or are able to produce other
products) Please identify other actual or potential products.

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

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Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

Page 9

II-4.

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

II-5.

Firm's estimated share of production in China.--Please estimate the percentage of total production
of wooden cabinets and vanities in the country specified on the certification page accounted for by
your firm’s production in 2018.
percent.

II-6.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of wooden cabinets and vanities from the country specified on the
certification page accounted for by your firm’s exports in 2018.
percent.

II-7.

Third country trade actions.--Is the wooden cabinets and vanities exported by your firm subject
to antidumping/countervailing duty/safeguard findings, remedies, or proceedings?

No

Yes

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

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
II-8.

Page 10

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of wooden cabinets and vanities in your establishment(s) in China
during the specified periods. Do not include resales of wooden cabinets and vanities that your
firm did not produce in this question; those data to the degree they are exported to the United
States should only be reported in question II-9.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” --All production in your establishment(s) in China, including production consumed
internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”--Shipments to destinations outstide of the country indicacted on page 1
(China), including shipments to related firms.
“Inventories”--Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
II-8.

Page 11

Trade data.--Continued.

Full Units
Quantity (number of cabinets); Value (in $1,000)

Item

Actual experience

Projections1

Calendar year

Calendar year

2016

2017

2018

2019

2020

Average production capacity2 (A)
Beginning-of-period inventories (B)
Production (C)
Home market shipments:
Internal consumption/ transfers
Quantity (D)
Value (E)
Commercial shipments
Quantity (F)
Value (G)
Exports to the United States
Quantity (H)
Value (I)
Exports to other markets3
Quantity (J)
Value (K)
Total shipments
Quantity (L)

0

0

0

0

0

Value (M)

0

0

0

0

0

End-of-period inventories (N)
Please explain the basis for your firm’s projections.
.
The production capacity reported is based on operating
hours per week,
weeks per year. Please
describe the methodology used to calculate production capacity, and explain any changes in reported capacity.
3
Identify principal other export markets.
.
1
2

.

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
II-8.

Page 12

Trade data.--Continued.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line N) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), 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.

Item

2016

Actual experience

Projections

Calendar year

Calendar year

2017

2018

2019

2020

B + C – D – F – H –J – N = should equal
zero ("0") or provide an explanation.1
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:
II-9.

0

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of wooden cabinets and vanities that was produced in China but not by your firm
during the specified periods. Note these data should not be included in question II-8.

Full Units
Quantity (number of cabinets)

Item

2016

Actual experience

Projections

Calendar year

Calendar year

2017

2018

2019

2020

Exports of wooden cabinets and
vanities to the United States not
produced by your firm1
1

List the producer(s).

.

Business Proprietary
Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)
II-10.

Page 13

Exports of components.--Report your firm’s exports to the United States in the specified periods
of components produced by your firm but not combined and sold as part of a whole cabinet or
vanity.

Components
Value (in $1,000)
Calendar years
Item

2016

2017

2018

Exports to the United States.—
Component: Frames
Component: Boxes
Component: Doors
Component: Drawers
Component: Back and end panels
Component: Other
II-11.

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

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Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

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Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):
•
•
•
•
•

START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

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Foreign Producers’ Questionnaire – Wooden Cabinets and Vanities (Preliminary)

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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://www.usitc.gov/investigations/701731/2019/wooden_cabinets_and_vanities_chi
na/preliminary.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: CABN

• E-mail.—E-mail your questionnaire to celia.feldpausch@usitc.gov; include a scanned copy of the
signed certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents
that are electronically transmitted to the Commission to protect your sensitive information from
unauthorized disclosure. The USITC secure drop-box system and the Electronic Document Information
System (EDIS) use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to
encrypt data in transit. Submitting your nonpublic documents by a means that does not use these
encryption algorithms (such as by email) may subject your firm’s nonpublic information to unauthorized
disclosure during transmission. If you choose a non-encrypted method of electronic transmission, the
Commission warns you that the risk of such possible unauthorized disclosure is assumed by you and not
by the Commission.
If your firm did not produce or export this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, you are required to serve a copy of
the completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.